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The inspectors identified an unresolved it … The inspectors identified an unresolved item (URI) involving the licensees implementation of a commitment concerning closure of the containment equipment hatch in the case of a fuel handling accident in the containment building. This issue is unresolved pending further NRC inspection and review of additional information to be provided by the licensee. On April 1, 2009, during a refueling outage of Unit 1, the inspectors performed a routine inspection of the licensees ability to close the containment equipment hatch should residual heat removal (RHR) cooling be lost while the reactor coolant system (RCS) is open to the containment atmosphere. The inspectors noted that the licensee had performed an analysis of containment environmental conditions, following the loss of RHR, to determine how much time was available to close the hatch prior to conditions within the containment becoming so harsh as to potentially prohibit hatch closure. The licensee conducted a drill to ensure that personnel could be mobilized and the hatch could be closed within analyzed time limits. Upon review of the analysis, the inspectors noted that it covered only the condition of loss of RHR. Further inspection revealed that the licensee also intended to leave the equipment hatch open during fuel movement in the containment building, and that the plant Technical Specification (TS) Bases specified that a method to promptly close the containment equipment hatch during movement of irradiated fuel assemblies will be in place. This commitment was introduced into the plants licensing basis as part of a license amendment issued on October 28, 2003, which was TS change 02-08, Partial Scope Implementation of the Alternate Source Term and Revision of Requirements for Closure of the Containment Building Equipment Door During Movement of Irradiated Fuel. This TS change revised LCO 3.9.4 to remove the requirement for the containment equipment hatch to be closed during movement of fuel within the containment, unless the fuel had been irradiated (i.e. part of a critical core) within the previous 100-hour period. The change included a commitment to establish the capability to close the equipment hatch in the event of a fuel handling accident. This commitment was reflected in the revision to the TS Bases, as noted above, and was implemented through a revision to the licensees procedure AOP-M.04, Refueling Malfunctions, revision 6, on October 25, 2004. The inspectors requested that the licensee provide a copy of the analysis which determined that the environmental conditions which would be present within the containment following the design basis fuel handling accident would not prohibit plant personnel from closing the hatch in accordance with the commitment reflected in the TS Bases. The licensee was unable to provide such an analysis. The inspectors noted that licensee design basis document SQN-DC-V-21.0, Sequoyah Nuclear Plant Environmental Design, revision 20, identified that a fuel handling accident is among those design basis accidents that could result in plant personnel approaching GDC-19 dose limits, and requires that a post accident mission dose analysis shall be performed where plant personnel are required to enter vital areas of the plant via a preplanned procedure to maintain the plant design basis following a fuel handling accident. The inspectors also noted that plant procedure EPM-7-1, EOI Administrative Controls, revision 8, required that the mission dose estimate be evaluated, prior to implementing new manual operator actions in EOPs or AOPs, for all activities required to be performed outside the control room in the event of a design basis accident as identified by SQNDC- V-21.0. The inspectors requested the mission dose calculation for hatch closure following a design basis fuel handling accident. The licensee was unable to provide such a calculation. It was identified that this evaluation had not been performed in conjunction with revision 6 to AOP-M.04. These issues were entered into the licensees corrective action program as PERs 167420 and 167428. Pending additional information from the licensees evaluation of their ability to close the equipment hatch following a fuel handling accident, this item is identified as URI 050000327,328/2009003-01, Containment Equipment Hatch Closure Capability During Fuel Handling Accidente Capability During Fuel Handling Accident
23:59:59, 30 June 2009 +
23:59:59, 30 June 2009 +
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00:37:20, 21 February 2018 +
23:59:59, 30 June 2009 +