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In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. | In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. | ||
The requirements for containment during MODE 6 are addressed in LCO 3.9.3, "Containment Penetrations." ACTIONS A.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour. The 1 hour Completion Time provides a OPERABLE period of time to correct the problem commensurate with the importance of maintaining containment during MODES 1, 2, 3, and 4. This time period also ensures the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal.B.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.0 BWOG STS B 3.6.1-3 Rev. 3.1, 12/01105 Attachment 1, Volume 11, Rev. 0, Page 18 of 189 Attachment 1, Volume 11, Rev. 0, Page 19 of 189 Containment B 3.6.1 BASES SURVEILLANCE SR 316.1.1 REQUIREMENTS Maintaining the containmentOPERABLE requires compliance with the shield f ~building visual examinations and leakage rate test requirements of the exterio Containment Leakage Rate Testing Program. The nain nt concrete visual examinations may be performed during either power operatio e.g., performe ncurrently with other contaipfnent inspection-.relate (d)Activ t es suh as tendon testingor during a maintenance or refueling shield building interior outage. The visual examinations of thelsteel liner ,.te inside containment (1)and the = 1are performed during maintenance or refueling outages Li--LJ steel containmentves-sel since this is the only time thenea is fully accessible. | The requirements for containment during MODE 6 are addressed in LCO 3.9.3, "Containment Penetrations." ACTIONS A.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour. The 1 hour Completion Time provides a OPERABLE period of time to correct the problem commensurate with the importance of maintaining containment during MODES 1, 2, 3, and 4. This time period also ensures the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal.B.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.0 BWOG STS B 3.6.1-3 Rev. 3.1, 12/01105 Attachment 1, Volume 11, Rev. 0, Page 18 of 189 Attachment 1, Volume 11, Rev. 0, Page 19 of 189 Containment B 3.6.1 BASES SURVEILLANCE SR 316.1.1 REQUIREMENTS Maintaining the containmentOPERABLE requires compliance with the shield f ~building visual examinations and leakage rate test requirements of the exterio Containment Leakage Rate Testing Program. The nain nt concrete visual examinations may be performed during either power operatio e.g., performe ncurrently with other contaipfnent inspection-.relate (d)Activ t es suh as tendon testingor during a maintenance or refueling shield building interior outage. The visual examinations of thelsteel liner ,.te inside containment (1)and the = 1are performed during maintenance or refueling outages Li--LJ steel containmentves-sel since this is the only time thenea is fully accessible. | ||
s, and secondary containment bypass leakage paths andrto meet airurg alve with resilient sealleaka g limits cinment specified in LCO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test is required to be < 0.6 La for combined Type B and C leakage, and j< U. /,or Option A]IIJ 0.75 La for Option Bf]for overall Type A leakage. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A D leakage limit o 1 .0 La. .A 1.0 L. the offsite dose consequences are bounded by the assumptions of the safety analysis. | s, and secondary containment bypass leakage paths andrto meet airurg alve with resilient sealleaka g limits cinment specified in LCO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test is required to be < 0.6 La for combined Type B and C leakage, and j< U. /,or Option A]IIJ 0.75 La for Option Bf]for overall Type A leakage. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A D leakage limit o 1 .0 La. .A 1.0 L. the offsite dose consequences are bounded by the assumptions of the safety analysis. | ||
[SR Frec;Uencies are as required by the ontainment Leakag ate Testing Pro am. These periodic testing r quirements verify thtthe containment Ikage rate 0 does not exce the leakage rate as med in the safety Fnalysis.SR Frequencies are as required by the Containment Leakage Rate Testing Program. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.7-------- | [SR Frec;Uencies are as required by the ontainment Leakag ate Testing Pro am. These periodic testing r quirements verify thtthe containment Ikage rate 0 does not exce the leakage rate as med in the safety Fnalysis.SR Frequencies are as required by the Containment Leakage Rate Testing Program. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.7-------- | ||
.-.--REVIEW"E 'S NOTE-- -Regulatory Gui e 1.163 and NEI 94- 1 include acceptan-e criteria for as-left and as-fou d Type A leakage s and combined T ye B and C leakage rates which may be reflect.d in the Bases.LSR 3.6.1.2 For ungrouted post tensioned tend s, this SR ensures that the structural inte rity of the containme t will be maintained in accordance with the provi ions of the Contain nt Tendon Surveill nce Program.Testing and requency are in acco dance with the AS E Code, Section Xl, bsection IWL (Ref. , and applicable ad enda as required by 10 CFR 0.55a. ]BWOG STS B 3.6.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 19 of 189 Attachment 1, Volume 11, Rev. 0, Page 20 of 189 Containment B 3.6.1 BASES REFERENCE ES 1. 10 CFR 50, Appendix J, Option M- BM 2. FSAR, Section ona]3. FSAR, Section 14. ASME8 Code. Section XI. | .-.--REVIEW"E 'S NOTE-- -Regulatory Gui e 1.163 and NEI 94- 1 include acceptan-e criteria for as-left and as-fou d Type A leakage s and combined T ye B and C leakage rates which may be reflect.d in the Bases.LSR 3.6.1.2 For ungrouted post tensioned tend s, this SR ensures that the structural inte rity of the containme t will be maintained in accordance with the provi ions of the Contain nt Tendon Surveill nce Program.Testing and requency are in acco dance with the AS E Code, Section Xl, bsection IWL (Ref. , and applicable ad enda as required by 10 CFR 0.55a. ]BWOG STS B 3.6.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 19 of 189 Attachment 1, Volume 11, Rev. 0, Page 20 of 189 Containment B 3.6.1 BASES REFERENCE ES 1. 10 CFR 50, Appendix J, Option M- BM 2. FSAR, Section ona]3. FSAR, Section 14. ASME8 Code. Section XI. | ||
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Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 23 of 189 Attachment 1, Volume 11, Rev. 0, Page 24 of 189 ATTACHMENT 2 ITS 3.6.2, CONTAINMENT AIR LOCKS Attachment 1, Volume 11, Rev. 0, Page 24 of 189 Attachment 1, Volume 11, Rev. 0, Page 25 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 25 of 189 Attachment 1, Volume 11, Rev. 0, Page 26 of 189 ITS 3.6.2 ITS CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS LIM1TTNG CONDETMN FOR OPERATION 3.6.2 3.6.1.3 Each containment air lock shall be OPERABLE [T a. Both doors closl except when the air lockis being used for entry a d one air lock do r shall be closed, and b. An overall ai lock leakage rate in accor/ance with the Containm nt lU Testing Pro am.APPLICABILITY: | Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 23 of 189 Attachment 1, Volume 11, Rev. 0, Page 24 of 189 ATTACHMENT 2 ITS 3.6.2, CONTAINMENT AIR LOCKS Attachment 1, Volume 11, Rev. 0, Page 24 of 189 Attachment 1, Volume 11, Rev. 0, Page 25 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 25 of 189 Attachment 1, Volume 11, Rev. 0, Page 26 of 189 ITS 3.6.2 ITS CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS LIM1TTNG CONDETMN FOR OPERATION 3.6.2 3.6.1.3 Each containment air lock shall be OPERABLE [T a. Both doors closl except when the air lockis being used for entry a d one air lock do r shall be closed, and b. An overall ai lock leakage rate in accor/ance with the Containm nt lU Testing Pro am.APPLICABILITY: | ||
MODES 1,2, 3 and 4.Add proposed ACTIONS Note 2 A02 AC I N A TIN* __Add proposed ACTIONSi~ii Note 3 ACTION A *a. _With one air lock door inoperable in one or more containment air locks, or with the ACTION B containment air lock interlock mechamsm inoperable in one or more containment air locks: Add proposed ACTIONS A and B Note 1'Add proposed ACTION A Note 2 and ACTIONB Note 2 L01 I. Verify an OPERABLE door in each affected air lock is closed within one hour, and ACTIONS A 2. Lock an OPERABLE door closed in each affected air lock within 24 hours, and and B Add proposed Required Actions A.3 and B.3 Note L 3. Operation may then continue provided that an OPERABLE door in each affected air lock is maintained closed and is verified to be locked closed at least once per 31 days_,and provided that He containment air lock passes each s heduled performance A05 of the overall air lock 1akage rate test. I ACTION D 4. Otherwise, be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.*b. With one or more containment air locks inoperable except as a result of an inoperable air ACTION C lock door or air lock interlock mechanism: | MODES 1,2, 3 and 4.Add proposed ACTIONS Note 2 A02 AC I N A TIN* __Add proposed ACTIONSi~ii Note 3 ACTION A *a. _With one air lock door inoperable in one or more containment air locks, or with the ACTION B containment air lock interlock mechamsm inoperable in one or more containment air locks: Add proposed ACTIONS A and B Note 1'Add proposed ACTION A Note 2 and ACTIONB Note 2 L01 I. Verify an OPERABLE door in each affected air lock is closed within one hour, and ACTIONS A 2. Lock an OPERABLE door closed in each affected air lock within 24 hours, and and B Add proposed Required Actions A.3 and B.3 Note L 3. Operation may then continue provided that an OPERABLE door in each affected air lock is maintained closed and is verified to be locked closed at least once per 31 days_,and provided that He containment air lock passes each s heduled performance A05 of the overall air lock 1akage rate test. I ACTION D 4. Otherwise, be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.*b. With one or more containment air locks inoperable except as a result of an inoperable air ACTION C lock door or air lock interlock mechanism: | ||
: 1. Verify at least one door in each affected air lock is closed within one hour, and 2. Restore air lock(s) to OPERABLE status within 24 hours.ACTION D 3. Otherwise, be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.ACTIONS *Entry and exit through the OPERABLE door is permissible if necessary to perform repairs of Note 1 the affected air lock components. | : 1. Verify at least one door in each affected air lock is closed within one hour, and 2. Restore air lock(s) to OPERABLE status within 24 hours.ACTION D 3. Otherwise, be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.ACTIONS *Entry and exit through the OPERABLE door is permissible if necessary to perform repairs of Note 1 the affected air lock components. | ||
[After each e jir3and exit, the OPERABdoor must be L Iclosed wi out delay.DAVIS-BESSE, UNIT 1 3/4 6-6 Amendment No. 194, 223, 240 Page 1 of 3 Attachment 1, Volume 11, Rev. 0, Page 26 of 189 Attachment 1, Volume 11, Rev. 0, Page 27 of 189 0 ITS 3.6.2 ITS CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS SR 3.6.2.1 SR 3.6.2.2 SR 3.6.2.1 Note 1 SURVEILLANCE REQUIREMENTS 4.6.1.3 Each-containment air lock shall be demonstrated OPERABLE: Add proposed SR 3.6.2.1 Note 2 a. By performing required air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program.*b. Deleted.c. At least once per REFUELING INTERVAL by verifying that only one door in each air lock can be opened at a time.*One inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.S0 DAVIS-BESSE, UNIT 1 3/4 6-6a Amendment No. 194, 223, 240 Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 27 of 189 Attachment 1, Volume 11, Rev. 0, Page 28 of 189 GD ITS 3.6.2 ITS DEFINITIONS 1.7 Deleted.CONTAINMENT INTEGRITY L 1.8 CONTAINMENT INTEGRITY shall exist when: a. All penetrations required to be closed during accident conditions are either: 1. Capable of being closed by the Safety Features Actuation System, or 2. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions. | [After each e jir3and exit, the OPERABdoor must be L Iclosed wi out delay.DAVIS-BESSE, UNIT 1 3/4 6-6 Amendment No. 194, 223, 240 Page 1 of 3 Attachment 1, Volume 11, Rev. 0, Page 26 of 189 Attachment 1, Volume 11, Rev. 0, Page 27 of 189 0 ITS 3.6.2 ITS CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS SR 3.6.2.1 SR 3.6.2.2 SR 3.6.2.1 Note 1 SURVEILLANCE REQUIREMENTS 4.6.1.3 Each-containment air lock shall be demonstrated OPERABLE: Add proposed SR 3.6.2.1 Note 2 a. By performing required air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program.*b. Deleted.c. At least once per REFUELING INTERVAL by verifying that only one door in each air lock can be opened at a time.*One inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.S0 DAVIS-BESSE, UNIT 1 3/4 6-6a Amendment No. 194, 223, 240 Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 27 of 189 Attachment 1, Volume 11, Rev. 0, Page 28 of 189 GD ITS 3.6.2 ITS DEFINITIONS 1.7 Deleted.CONTAINMENT INTEGRITY L 1.8 CONTAINMENT INTEGRITY shall exist when: a. All penetrations required to be closed during accident conditions are either: 1. Capable of being closed by the Safety Features Actuation System, or 2. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions. | ||
except those approved to be open under administrative controls, b. The equipment hatch is closed, c. Each air lock is in compliance with the requirements of Specification 3.6.1.3, d. The containment leakage rates are within the limits specified in the Containment Leakage Rate Testing Program, and e. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) is OPERABLE.LCO 3.6.2 See ITS Chapter 1.09 See ITS 3.6.1 See ITS 3.6.1 See ITS Chapter 1.0, CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessry, of the channel output such that it responds with necessary range and accuracy to known values of the parameter which the channel monitors. | except those approved to be open under administrative controls, b. The equipment hatch is closed, c. Each air lock is in compliance with the requirements of Specification 3.6.1.3, d. The containment leakage rates are within the limits specified in the Containment Leakage Rate Testing Program, and e. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) is OPERABLE.LCO 3.6.2 See ITS Chapter 1.09 See ITS 3.6.1 See ITS 3.6.1 See ITS Chapter 1.0, CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessry, of the channel output such that it responds with necessary range and accuracy to known values of the parameter which the channel monitors. | ||
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Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. | Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. | ||
Periodic testing of this interlock demonstrates BWOG STS B 3.6.2-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 46 of 189 Attachment 1, Volume 11, Rev. 0, Page 47 of 189 Containment Air Locks B 3.6.2 BASES SURVEILLANCE REQUIREMENTS (continued) that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when the containment air lock door is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed every 24 months. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, and the potential for loss of containment OPERABILITY if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency. | Periodic testing of this interlock demonstrates BWOG STS B 3.6.2-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 46 of 189 Attachment 1, Volume 11, Rev. 0, Page 47 of 189 Containment Air Locks B 3.6.2 BASES SURVEILLANCE REQUIREMENTS (continued) that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when the containment air lock door is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed every 24 months. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, and the potential for loss of containment OPERABILITY if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency. | ||
The 24 month Frequency is based on engineering judgment and is considered adequate given that the interlock is not challenged during the use of the aro REFERENCES | The 24 month Frequency is based on engineering judgment and is considered adequate given that the interlock is not challenged during the use of the aro REFERENCES | ||
: 1. 10 CFR 50, Appendix J, Option M[] " ir- loc 2.. FSAR, Sectiong[1nd -Vj5.3. FSAR, Section -0 0 00 00 B\AAOG STS B 3.6.2-7 Rev. 3.0, 03/31104 Attachment 1, Volume 11, Rev. 0, Page 47 of 189 Attachment 1, Volume 11, Rev. 0, Page 48 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.2 BASES, CONTAINMENT AIR LOCKS 1, Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description. | : 1. 10 CFR 50, Appendix J, Option M[] " ir- loc 2.. FSAR, Sectiong[1nd -Vj5.3. FSAR, Section -0 0 00 00 B\AAOG STS B 3.6.2-7 Rev. 3.0, 03/31104 Attachment 1, Volume 11, Rev. 0, Page 47 of 189 Attachment 1, Volume 11, Rev. 0, Page 48 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.2 BASES, CONTAINMENT AIR LOCKS 1, Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description. | ||
: 2. The brackets have been removed and the proper plant specific information/value has been provided.3. Typographical error corrected. | : 2. The brackets have been removed and the proper plant specific information/value has been provided.3. Typographical error corrected. | ||
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This ensures that potential paths to the environment through containment isolation valves (including containment purge[ andexhaust valves) are minimized. | This ensures that potential paths to the environment through containment isolation valves (including containment purge[ andexhaust valves) are minimized. | ||
The safety analysis assumes that the M48M inch purge valves are closed at event initiation. | The safety analysis assumes that the M48M inch purge valves are closed at event initiation. | ||
The DBA analysis assumes that, within 60 seconds after the accident, isolation of the containment is complete and leakage terminated except for the design leakage rate, La. The containment isolation total response time of 60 seconds includes signal delay, iesel generator startup (for emergency loss of offsite power), and containment isolation valve stroke times.The single-failure criterion required to be imposed in the conduct of unit aea safety analyses was considered in the original design of the containment | The DBA analysis assumes that, within 60 seconds after the accident, isolation of the containment is complete and leakage terminated except for the design leakage rate, La. The containment isolation total response time of 60 seconds includes signal delay, iesel generator startup (for emergency loss of offsite power), and containment isolation valve stroke times.The single-failure criterion required to be imposed in the conduct of unit aea safety analyses was considered in the original design of the containment | ||
{ and exhaust purge-valves. | { and exhaust purge-valves. | ||
Two valves in a series on eachipurgehline provide assurance that both the supply and exhaust lines could be isolated even if tnment a single failure occurred. | Two valves in a series on eachipurgehline provide assurance that both the supply and exhaust lines could be isolated even if tnment a single failure occurred. | ||
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rradiated fuel asse blies), pressurizationiconcerns are not pre ent, thus the purge .alves can be fully open. Tle [18] month Frequenly is appropriate be ause the blocking devi ýes are typically remo ed only during a ref eling outage.INSRTL 0 BWOG STS B 3.6.3-13 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 102 of 189 Attachment 1, Volume 11, Rev. 0, Page 103 of 189 B 3.6.3 O INSERT 7 SR 3.6.3.7 This SR ensures that the combined leakage rate of all secondary containment bypass leakage paths is less than or equal to the specified leakage rate. This provides assurance that the assumptions in the safety analysis are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. The Frequency is required by the Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria. | rradiated fuel asse blies), pressurizationiconcerns are not pre ent, thus the purge .alves can be fully open. Tle [18] month Frequenly is appropriate be ause the blocking devi ýes are typically remo ed only during a ref eling outage.INSRTL 0 BWOG STS B 3.6.3-13 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 102 of 189 Attachment 1, Volume 11, Rev. 0, Page 103 of 189 B 3.6.3 O INSERT 7 SR 3.6.3.7 This SR ensures that the combined leakage rate of all secondary containment bypass leakage paths is less than or equal to the specified leakage rate. This provides assurance that the assumptions in the safety analysis are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. The Frequency is required by the Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria. | ||
Bypass leakage is considered part of La.Insert Page B 3.6.3-13 Attachment 1, Volume 11, Rev. 0, Page 103 of 189 Attachment 1, Volume 11, Rev. 0, Page 104 of 189 B 3.6.3 0 Containment Isolation Valves B 3.6.3 BASES REFERENCES | Bypass leakage is considered part of La.Insert Page B 3.6.3-13 Attachment 1, Volume 11, Rev. 0, Page 103 of 189 Attachment 1, Volume 11, Rev. 0, Page 104 of 189 B 3.6.3 0 Containment Isolation Valves B 3.6.3 BASES REFERENCES | ||
: 1. 10 CFR 20.2 *SAR, Section D3FSAR, Sectionls | : 1. 10 CFR 20.2 *SAR, Section D3FSAR, Sectionls | ||
[14.yand 14.-2]iýil | [14.yand 14.-2]iýil | ||
: 4. FSAR, [5.3] Ta62 00 5. F R, Secti n [5.3].6. St ndard R view Pla, 6.2.4.7. G neric Iss e B-24.0 I I I ..BWOG STS B 3.6.3-14 Rev. 3.0, 03/31/04 Insert Page B 3.6.3-13 Attachment 1, Volume 11, Rev. 0, Page 104 of 189 Attachment 1, Volume 11, Rev. 0, Page 105 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.3 BASES, CONTAINMENT ISOLATION VALVES 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description. | : 4. FSAR, [5.3] Ta62 00 5. F R, Secti n [5.3].6. St ndard R view Pla, 6.2.4.7. G neric Iss e B-24.0 I I I ..BWOG STS B 3.6.3-14 Rev. 3.0, 03/31/04 Insert Page B 3.6.3-13 Attachment 1, Volume 11, Rev. 0, Page 104 of 189 Attachment 1, Volume 11, Rev. 0, Page 105 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.3 BASES, CONTAINMENT ISOLATION VALVES 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description. | ||
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This changes the CTS by moving the detail that the containment pressure limits are relative to the shield building to the Bases.The removal of this detail, which is related to system design, from the CTS is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.6.4 still retains a requirement to maintain containment pressure within limits. Also, this change is acceptable because these type of details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. | This changes the CTS by moving the detail that the containment pressure limits are relative to the shield building to the Bases.The removal of this detail, which is related to system design, from the CTS is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.6.4 still retains a requirement to maintain containment pressure within limits. Also, this change is acceptable because these type of details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. | ||
This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the CTS.LESS RESTRICTIVE CHANGES None Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 111 of 189 Attachment 1, Volume 11, Rev. 0, Page 112 of 189 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 112 of 189 Attachment 1, Volume 11, Rev. 0, Page 113 of 189 CTS Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure I-14 inches water g j+25 inches water gauge LCO 3.6.4 Containment pressure shall be _ [-2. psig and i 5 0i~i.3.6.1.4 0 APPLICABILITY: | This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the CTS.LESS RESTRICTIVE CHANGES None Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 111 of 189 Attachment 1, Volume 11, Rev. 0, Page 112 of 189 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 112 of 189 Attachment 1, Volume 11, Rev. 0, Page 113 of 189 CTS Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure I-14 inches water g j+25 inches water gauge LCO 3.6.4 Containment pressure shall be _ [-2. psig and i 5 0i~i.3.6.1.4 0 APPLICABILITY: | ||
ACTIONS MODES 1, 2, 3, and 4.Action Action 4.6.1.4 CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure A.1 Restore containment 1 hour not within limits, pressure to within limits.B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met- AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits. 12 hours BWOG STS 3.6.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 113 of 189 Attachment 1, Volume 11, Rev. 0, Page 114 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.4, CONTAINMENT PRESSURE 1. The brackets have been removed and the proper plant specific information/value has been provided.Davis-Besse Page 1 of I Attachment 1, Volume 11, Rev. 0, Page 114 of 189 Attachment 1, Volume 11, Rev. 0, Page 115 of 189 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 115 of 189 Attachment 1, Volume 11, Rev. 0, Page 116 of 189 I All changes are unless otherwise noted 9 Containment | ACTIONS MODES 1, 2, 3, and 4.Action Action 4.6.1.4 CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure A.1 Restore containment 1 hour not within limits, pressure to within limits.B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met- AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits. 12 hours BWOG STS 3.6.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 113 of 189 Attachment 1, Volume 11, Rev. 0, Page 114 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.4, CONTAINMENT PRESSURE 1. The brackets have been removed and the proper plant specific information/value has been provided.Davis-Besse Page 1 of I Attachment 1, Volume 11, Rev. 0, Page 114 of 189 Attachment 1, Volume 11, Rev. 0, Page 115 of 189 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 115 of 189 Attachment 1, Volume 11, Rev. 0, Page 116 of 189 I All changes are unless otherwise noted 9 Containment | ||
:Pressure B 3.6.4 B3.6 CONTAINMENT SYSTEMS B 3.6.4 Containment Pressure BASES BACKGROUND The containment pressure is limited during normal operation to preserve the initial conditions assumed in the accident analyses for a loss of M Ecoolant accident (LOCA) orsteam line break SLB). These limits also prevent the containment pressure from exceeding the containment design negative pressure differential with respect to the outside atmosphere in the event of inadvertent actuation of the Containment Spray System.Containment pressure is a process variable that is monitored and controlled. | :Pressure B 3.6.4 B3.6 CONTAINMENT SYSTEMS B 3.6.4 Containment Pressure BASES BACKGROUND The containment pressure is limited during normal operation to preserve the initial conditions assumed in the accident analyses for a loss of M Ecoolant accident (LOCA) orsteam line break SLB). These limits also prevent the containment pressure from exceeding the containment design negative pressure differential with respect to the outside atmosphere in the event of inadvertent actuation of the Containment Spray System.Containment pressure is a process variable that is monitored and controlled. | ||
The containment pressure limits are derived from the input conditions used in the containment functional analyses and the containment structure external pressure analysis. | The containment pressure limits are derived from the input conditions used in the containment functional analyses and the containment structure external pressure analysis. | ||
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Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 121 of 189 Attachment 1, Volume 11, Rev. 0, Page 122 of 189 ATTACHMENT 5 ITS 3.6.5, CONTAINMENT AIR TEMPERATURE Attachment 1, Volume 11, Rev. 0, Page 122 of 189 Attachment 1, Volume 11, Rev. 0, Page 123 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 123 of 189 Attachment 1, Volume 11, Rev. 0, Page 124 of 189 ITS 3.6.5 ITS jCONTAINMENT SYSTEMS AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.6,5 3.6.1.5 Primary containment-average 1200i.air Abt exceed ACTION A---ACTION B--APPLICABILITY: | Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 121 of 189 Attachment 1, Volume 11, Rev. 0, Page 122 of 189 ATTACHMENT 5 ITS 3.6.5, CONTAINMENT AIR TEMPERATURE Attachment 1, Volume 11, Rev. 0, Page 122 of 189 Attachment 1, Volume 11, Rev. 0, Page 123 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 123 of 189 Attachment 1, Volume 11, Rev. 0, Page 124 of 189 ITS 3.6.5 ITS jCONTAINMENT SYSTEMS AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.6,5 3.6.1.5 Primary containment-average 1200i.air Abt exceed ACTION A---ACTION B--APPLICABILITY: | ||
MODES 1, 2, 3 and 4.ACTION: With the containment average air temperature | MODES 1, 2, 3 and 4.ACTION: With the containment average air temperature | ||
> 120*F, reduce the average air temperature to within the limit within 8 hours,\or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.SURVEILLANCE REQUIREMENTS 4.6.1.5 The primary containment average air temperature shall be the L arithmetical avefage of the inlet temper ture(s to the opera in containment air/cooler(s) | > 120*F, reduce the average air temperature to within the limit within 8 hours,\or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.SURVEILLANCE REQUIREMENTS 4.6.1.5 The primary containment average air temperature shall be the L arithmetical avefage of the inlet temper ture(s to the opera in containment air/cooler(s) | ||
(1-1, 1-2, a 1-3) andisball be determined at least once per 24 hours.3.6.5.1 DAVIS-BESSE, UNIT 1 3/4 6-8 Amendment No. So Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 124 of 189 Attachment 1, Volume 11, Rev. 0, Page 125 of 189 DISCUSSION OF CHANGES ITS 3.6.5, CONTAINMENT AIR TEMPERATURE ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 -Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) | (1-1, 1-2, a 1-3) andisball be determined at least once per 24 hours.3.6.5.1 DAVIS-BESSE, UNIT 1 3/4 6-8 Amendment No. So Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 124 of 189 Attachment 1, Volume 11, Rev. 0, Page 125 of 189 DISCUSSION OF CHANGES ITS 3.6.5, CONTAINMENT AIR TEMPERATURE ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 -Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) | ||
CTS 4.6.1.5 requires verifying that the primary containment average air temperature "shall be the arithmetical average of the inlet temperature(s) to the operating containment air coolers(s) | CTS 4.6.1.5 requires verifying that the primary containment average air temperature "shall be the arithmetical average of the inlet temperature(s) to the operating containment air coolers(s) | ||
(1-1, 1-2, and 1-3)." ITS SR 3.6.5.1 requires a similar verification, but does not state the specific method for attaining the average air temperature (i.e., the arithmetical average of specific air cooler inlet temperatures location). | (1-1, 1-2, and 1-3)." ITS SR 3.6.5.1 requires a similar verification, but does not state the specific method for attaining the average air temperature (i.e., the arithmetical average of specific air cooler inlet temperatures location). | ||
This changes the CTS by moving the method of calculating the average air temperature to the Bases.The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify the containment air temperature is within limit. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. | This changes the CTS by moving the method of calculating the average air temperature to the Bases.The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify the containment air temperature is within limit. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. | ||
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C. Deleted d. At least once pr 0 ears by performing an aik or smoke flow :13I test through e ch spray header and verifying each spray nozzle is unobstructed. | C. Deleted d. At least once pr 0 ears by performing an aik or smoke flow :13I test through e ch spray header and verifying each spray nozzle is unobstructed. | ||
SR 3.6.6.8 Add proposed SR 3..6.31 M0 1 DAVIS-BESSE, UNIT 1 3/4 6-12 Amendment No. %0%,196 Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 139 of 189 Attachment 1, Volume 11, Rev. 0, Page 140 of 189 IITS 3.6.6 IT__SS CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM LIMITING CONDITION FOR OPERATION/ / .(LA01)LCO3.6.6 3.5.2.2 At east tqo inde endent containment cooling units shall be OPERABLE.APPLICABILITY: | SR 3.6.6.8 Add proposed SR 3..6.31 M0 1 DAVIS-BESSE, UNIT 1 3/4 6-12 Amendment No. %0%,196 Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 139 of 189 Attachment 1, Volume 11, Rev. 0, Page 140 of 189 IITS 3.6.6 IT__SS CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM LIMITING CONDITION FOR OPERATION/ / .(LA01)LCO3.6.6 3.5.2.2 At east tqo inde endent containment cooling units shall be OPERABLE.APPLICABILITY: | ||
MODES 1, 2 F 3/. @ACTION: I day L03 ACTION C W~th one of the above required containment cooling unif erable, rtore at least two units- to QPE-RABLE status within f2/ our [r be ii M02)ACTION F %H1T1nnwN within the next 11 hours.i 1 ACTIO FrpsdATO 0 Add proposed ACTION E L03* I ~1Add proposed ACTION" SURVEILLANCE REQUIREMENTSA0 4.6.2.2 At least the above required containment cooling units shall be demonstrated OPERABLE: a. At least once per 31 days on a STAGGERED TEST BASIS by: I. Starti g (unless alreadyiperating) each k.it from the- LA04 contr I room, and)SR3.6.6.2 | MODES 1, 2 F 3/. @ACTION: I day L03 ACTION C W~th one of the above required containment cooling unif erable, rtore at least two units- to QPE-RABLE status within f2/ our [r be ii M02)ACTION F %H1T1nnwN within the next 11 hours.i 1 ACTIO FrpsdATO 0 Add proposed ACTION E L03* I ~1Add proposed ACTION" SURVEILLANCE REQUIREMENTSA0 4.6.2.2 At least the above required containment cooling units shall be demonstrated OPERABLE: a. At least once per 31 days on a STAGGERED TEST BASIS by: I. Starti g (unless alreadyiperating) each k.it from the- LA04 contr I room, and)SR3.6.6.2 | ||
: 2. Verifying that each unit operates for at least 15 minutes.SR3.6.6.4 | : 2. Verifying that each unit operates for at least 15 minutes.SR3.6.6.4 | ||
: b. At least once per 18 months by verifying that each unit starts automatically Ion 10 speed] upon receipt of a S AS test signal.actual or L02 actuation LA02 LA04 4 Add proposed SRý 3.6.6.5 M0 DAVIS-BESSE, UNIT 1 3/4 6-13 Page 3 of 3 Attachment 1, Volume 11, Rev. 0, Page 140 of 189 Attachment 1, Volume 11, Rev. 0, Page 141 of 189 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.A02 The CTS 3.6.2.1 Action provides the actions when one containment spray train is inoperable and the CTS 3.6.2.2 Action provides the actions when one containment cooling train is inoperable. | : b. At least once per 18 months by verifying that each unit starts automatically Ion 10 speed] upon receipt of a S AS test signal.actual or L02 actuation LA02 LA04 4 Add proposed SRý 3.6.6.5 M0 DAVIS-BESSE, UNIT 1 3/4 6-13 Page 3 of 3 Attachment 1, Volume 11, Rev. 0, Page 140 of 189 Attachment 1, Volume 11, Rev. 0, Page 141 of 189 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.A02 The CTS 3.6.2.1 Action provides the actions when one containment spray train is inoperable and the CTS 3.6.2.2 Action provides the actions when one containment cooling train is inoperable. | ||
However, no specific actions are provided when both a containment spray train and a containment cooling train are inoperable. | However, no specific actions are provided when both a containment spray train and a containment cooling train are inoperable. | ||
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OR Any combination of three or more trains d inoperable. | OR Any combination of three or more trains d inoperable. | ||
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power 31 days operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.SR 3.6.6.2 Operate each [equired~containmenting train 31 days>215 minutes.0 0 (O0 00 BWOG STS 3.6.6-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 149 of 189 Attachment 1, Volume 11, Rev. 0, Page 150 of 189 CTS Containment Spray and Cooling Systems 3.6.6 0 SURVEILLANCE REQUIREMENTS (continued) | SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power 31 days operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.SR 3.6.6.2 Operate each [equired~containmenting train 31 days>215 minutes.0 0 (O0 00 BWOG STS 3.6.6-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 149 of 189 Attachment 1, Volume 11, Rev. 0, Page 150 of 189 CTS Containment Spray and Cooling Systems 3.6.6 0 SURVEILLANCE REQUIREMENTS (continued) | ||
SURVEILLANCE FREQUENCY DOC M01 SR Verify each requiredJ containment*'lng train cooling water flow rate is _O g 00O 24 months 0 IL DOC M01 4.6.2.1.b.1 4.6.2.1.b.2 4.6.2.2.b 4.6.2.1.d SR 3.6.6.J] Verify each containment spray pump's developed In accordance head at the flow test point is greater than or equal to with the Inservice the required developed head. Testing Program 0 SR 3.6.6.t] Verify each automatic containment spray valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.months SR 3.6.6. Verify each containment spray pump starts T-E] automatically on an actual or simulated actuation signal.months 00 00 000 SR 3.6.6.T Verify each containment4,ooling train starts automatically on an actual or simulated actuation signal.j1 80 months L SR 3.6.6.8 Verify each spray nozzle is unobstructed. | SURVEILLANCE FREQUENCY DOC M01 SR Verify each requiredJ containment*'lng train cooling water flow rate is _O g 00O 24 months 0 IL DOC M01 4.6.2.1.b.1 4.6.2.1.b.2 4.6.2.2.b 4.6.2.1.d SR 3.6.6.J] Verify each containment spray pump's developed In accordance head at the flow test point is greater than or equal to with the Inservice the required developed head. Testing Program 0 SR 3.6.6.t] Verify each automatic containment spray valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.months SR 3.6.6. Verify each containment spray pump starts T-E] automatically on an actual or simulated actuation signal.months 00 00 000 SR 3.6.6.T Verify each containment4,ooling train starts automatically on an actual or simulated actuation signal.j1 80 months L SR 3.6.6.8 Verify each spray nozzle is unobstructed. | ||
[At first ref eling]ANDD st 10 years 0 BVVOG STS 3.6.6-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 150 of 189 Attachment 1, Volume 11, Rev. 0, Page 151 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS 1. The brackets have been removed and the proper plant specific information/value has been provided.2. Typographical error corrected. | [At first ref eling]ANDD st 10 years 0 BVVOG STS 3.6.6-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 150 of 189 Attachment 1, Volume 11, Rev. 0, Page 151 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS 1. The brackets have been removed and the proper plant specific information/value has been provided.2. Typographical error corrected. | ||
: 3. The Surveillances have been put in the correct order based on their frequency. | : 3. The Surveillances have been put in the correct order based on their frequency. | ||
| Line 523: | Line 523: | ||
ditional discussion is provided in the/Bases for LCO 3.6.4.The modeled Containment Spray System actuation from the containment analyses is based on a response time associated with exceeding the containment pressure High-High setpoint coincident with a high pressure injection signal to achieve full flow through the containment spray nozzles. The Containment Spray System total response time of gen c ( | ditional discussion is provided in the/Bases for LCO 3.6.4.The modeled Containment Spray System actuation from the containment analyses is based on a response time associated with exceeding the containment pressure High-High setpoint coincident with a high pressure injection signal to achieve full flow through the containment spray nozzles. The Containment Spray System total response time of gen c ( | ||
includes+diesel generator | includes+diesel generator | ||
ý?G) startup (for loss of offsite -(power), block loading of equipment, containment spray pump startup, and CE spray line filling (Ref. 2).ContainrL in'niooling train performance for post accident conditions is containment air 5 given in Reference | ý?G) startup (for loss of offsite -(power), block loading of equipment, containment spray pump startup, and CE spray line filling (Ref. 2).ContainrL in'niooling train performance for post accident conditions is containment air 5 given in Reference | ||
: 3. The result of the analysis is that eachtrain can cooling provide,__/o of the required peak cooling capacity during the post accident condition. | : 3. The result of the analysis is that eachtrain can cooling provide,__/o of the required peak cooling capacity during the post accident condition. | ||
The train post accident cooling capacity under varying containment ambient conditions, required to perform the accident analyses, is also shown in Reference 4.BWOG STS B 3.6.6-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 156 of 189 Attachment 1, Volume 11, Rev. 0, Page 157 of 189 B 3.6.6 (0 INSERT 4 An analysis of the containment vessel negative pressure transient due to inadvertent operation of one train of the Containment Spray System has been performed for various spray water temperatures. | The train post accident cooling capacity under varying containment ambient conditions, required to perform the accident analyses, is also shown in Reference 4.BWOG STS B 3.6.6-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 156 of 189 Attachment 1, Volume 11, Rev. 0, Page 157 of 189 B 3.6.6 (0 INSERT 4 An analysis of the containment vessel negative pressure transient due to inadvertent operation of one train of the Containment Spray System has been performed for various spray water temperatures. | ||
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Therefore, in the event of an accident, the minimum requirements are met, assuming the worst-case single active failure occurs.Each dontainment Opray typically includes a spray pump, spray headers, nozzles, valves, piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the BWST upon an JEna e Safety Features Actuation System signal and manually (D transferring suction to the containmen sump. aci i[ emegenc air cooling train emnergency Each ,ontainment Cooling typicaly includes ersters cooling coils, dampers, an axial flow fan driven by a two speed e coo e electrical motor, instruments, and controls to ensure an OPERABLE flow path.APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature, requiring the operation of the containment spray trains and containment ooling trains.In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these "------- D MODES. Thus, the Containment Spray System and the Containment (3 Cooling System are not required to be OPERABLE in MODES 5 and 6.BWOG STS B 3.6.6-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 158 of 189 Attachment 1, Volume 11, Rev. 0, Page 159 of 189 Containment Spray andCoElng Systems (0 B 3.6.6 BASES ACTIONS A.1 With one containment spray train inoperable, action must be taken to restore it to OPERABLE status In this condition, the remaining OPERABLE containment spray train is adequate to perform the heat removal function. | Therefore, in the event of an accident, the minimum requirements are met, assuming the worst-case single active failure occurs.Each dontainment Opray typically includes a spray pump, spray headers, nozzles, valves, piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the BWST upon an JEna e Safety Features Actuation System signal and manually (D transferring suction to the containmen sump. aci i[ emegenc air cooling train emnergency Each ,ontainment Cooling typicaly includes ersters cooling coils, dampers, an axial flow fan driven by a two speed e coo e electrical motor, instruments, and controls to ensure an OPERABLE flow path.APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature, requiring the operation of the containment spray trains and containment ooling trains.In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these "------- D MODES. Thus, the Containment Spray System and the Containment (3 Cooling System are not required to be OPERABLE in MODES 5 and 6.BWOG STS B 3.6.6-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 158 of 189 Attachment 1, Volume 11, Rev. 0, Page 159 of 189 Containment Spray andCoElng Systems (0 B 3.6.6 BASES ACTIONS A.1 With one containment spray train inoperable, action must be taken to restore it to OPERABLE status In this condition, the remaining OPERABLE containment spray train is adequate to perform the heat removal function. | ||
However, the overall reliability is reduced because a single failure to the remaining containment spray train could result in loss of spray function. | However, the overall reliability is reduced because a single failure to the remaining containment spray train could result in loss of spray function. | ||
Ther7lJday Completion Time is reasonable to ()perform corrective maintenance on the inoperable containment spray train. TheRj7Eday Completion Time is based on the findings of the D deterministic and probabilistic analysis in Reference | Ther7lJday Completion Time is reasonable to ()perform corrective maintenance on the inoperable containment spray train. TheRj7Eday Completion Time is based on the findings of the D deterministic and probabilistic analysis in Reference | ||
: 5. Reference 5 concluded that extendin the Completion Time toR7M days for an 0 inoperable containment spray trai pro es plant operational flexibility (while simultaneously reducing overall plant risk. This is because the risks incurred by having the containment spray train unavailable for a longer time at power will be substantially offset by the benefits associated with avoiding unnecessary plant transitions and by reducing risk during plant shutdown operations. | : 5. Reference 5 concluded that extendin the Completion Time toR7M days for an 0 inoperable containment spray trai pro es plant operational flexibility (while simultaneously reducing overall plant risk. This is because the risks incurred by having the containment spray train unavailable for a longer time at power will be substantially offset by the benefits associated with avoiding unnecessary plant transitions and by reducing risk during plant shutdown operations. | ||
B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 84 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time to attempt restoration of the containment spray train and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.C. 1 remaining OPERABLE1 With one of the required containment olintins inoperable, the containment spray and inoperable containmentlcooling train must be restored to OPERABLE---, air cooling trains status within 7 days. Th comp mentslin this degraded condition provide (D)iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. | B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 84 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time to attempt restoration of the containment spray train and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.C. 1 remaining OPERABLE1 With one of the required containment olintins inoperable, the containment spray and inoperable containmentlcooling train must be restored to OPERABLE---, air cooling trains status within 7 days. Th comp mentslin this degraded condition provide (D)iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. | ||
| Line 563: | Line 563: | ||
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 164 of 189 Attachment 1, Volume 11, Rev. 0, Page 165 of 189 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 11, Rev. 0, Page 165 of 189 Attachment 1, Volume 11, Rev. 0, Page 166 of 189 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS There are no specific NSHC discussions for this Specification. | Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 164 of 189 Attachment 1, Volume 11, Rev. 0, Page 165 of 189 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 11, Rev. 0, Page 165 of 189 Attachment 1, Volume 11, Rev. 0, Page 166 of 189 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS There are no specific NSHC discussions for this Specification. | ||
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 166 of 189 Attachment 1, Volume 11, Rev. 0, Page 167 of 189 ATTACHMENT 7 ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP)STORAGE Attachment 1, Volume 11, Rev. 0, Page 167 of 189 Attachment 1, Volume 11, Rev. 0, Page 168 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 168 of 189 Attachment 1, Volume 11, Rev. 0, Page 169 of 189 ITS 3.6.7 ITS EAMRGENCY CORE COOLING SYSTFOR S EmO SBS-YSTEMS | Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 166 of 189 Attachment 1, Volume 11, Rev. 0, Page 167 of 189 ATTACHMENT 7 ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP)STORAGE Attachment 1, Volume 11, Rev. 0, Page 167 of 189 Attachment 1, Volume 11, Rev. 0, Page 168 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 168 of 189 Attachment 1, Volume 11, Rev. 0, Page 169 of 189 ITS 3.6.7 ITS EAMRGENCY CORE COOLING SYSTFOR S EmO SBS-YSTEMS | ||
-T-v;ý28E LCO 3.6.7 LNMITIG CONDMTON FOR OPERATION 3.5.2 Two independent EdCS subsystems shall be OPERABLE with each subsystem comprised of: a. One OPERABLE high pressure injection (HPI) pump, *b. One OPERABLE low pressure injection (LPl) pump, c. One OPERABLE decay heat cooler, and d. An OPERABLE flow path capable of taking suction from the borated water storage tank (BWS7)on a safety injection signal and manually transfring suction to the containment sump during the recircultion phase of operatin I A BLITY: MODES 1, 2 and 3[-See ITS ]3.5.2]See ITS 3.5.2 L.5.ION: / [Add proposed ACTIONS A and B a. With oe HPI train inoperable, restore the inoperable HPI train to OPERABLE status within 72 hom or be in HOT SH[7IDOWN within the next 12 hours.L With one LPI train or its associated decay heat cooler inoperable, restore the inoperable equipment to OPERABLE status within 7 days or be in HOT SHUTDOWN within the next 12 hours.c. In dhe event the EOCC is actuated and ibjects water into the Reator Coolant System, a Special Reqpot ,hall be prepared and submitted to the Commission pursuant to Specification | -T-v;ý28E LCO 3.6.7 LNMITIG CONDMTON FOR OPERATION 3.5.2 Two independent EdCS subsystems shall be OPERABLE with each subsystem comprised of: a. One OPERABLE high pressure injection (HPI) pump, *b. One OPERABLE low pressure injection (LPl) pump, c. One OPERABLE decay heat cooler, and d. An OPERABLE flow path capable of taking suction from the borated water storage tank (BWS7)on a safety injection signal and manually transfring suction to the containment sump during the recircultion phase of operatin I A BLITY: MODES 1, 2 and 3[-See ITS ]3.5.2]See ITS 3.5.2 L.5.ION: / [Add proposed ACTIONS A and B a. With oe HPI train inoperable, restore the inoperable HPI train to OPERABLE status within 72 hom or be in HOT SH[7IDOWN within the next 12 hours.L With one LPI train or its associated decay heat cooler inoperable, restore the inoperable equipment to OPERABLE status within 7 days or be in HOT SHUTDOWN within the next 12 hours.c. In dhe event the EOCC is actuated and ibjects water into the Reator Coolant System, a Special Reqpot ,hall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the c of the actuation and the total accumulated actuation cycles to date.SURVEILLANCE REQUIREMENTS 4-5.2 Each ECC subsystem shall be demonstrated OPERABLE: a. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed or otherwise secured in position, is in its correct position.An exeption applies to the IHPI pumps for the purpose of conducting Restart Test Plan inspection afivles. Ths exception is valid during the ongoing Thirteenth Refueling Outage for entries into MODE 3 from MODE 4. Under this erception, neither HPI train is required to be capable of taking suction from the LPI trains when aligned for containment sump recirculation. | ||
90 days describing the c of the actuation and the total accumulated actuation cycles to date.SURVEILLANCE REQUIREMENTS 4-5.2 Each ECC subsystem shall be demonstrated OPERABLE: a. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed or otherwise secured in position, is in its correct position.An exeption applies to the IHPI pumps for the purpose of conducting Restart Test Plan inspection afivles. Ths exception is valid during the ongoing Thirteenth Refueling Outage for entries into MODE 3 from MODE 4. Under this erception, neither HPI train is required to be capable of taking suction from the LPI trains when aligned for containment sump recirculation. | |||
The HPI trains will otherwise be OPERABLE. | The HPI trains will otherwise be OPERABLE. | ||
Operation in MODE ) orMODE 2 while relying upon the provisions of this exception is prohibited DAVIS-BESSE, UNIT I 3/4 5-3 Amendment No. 36,182, 253, 257 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 169 of 189 Attachment 1, Volume 11, Rev. 0, Page 170 of 189 ITS 0 ITS 3.6.7 Revised by HK Letter Dated June 6, 1995 StiRVEILLANCE REQUIREPNRTS (ContinuedQ | Operation in MODE ) orMODE 2 while relying upon the provisions of this exception is prohibited DAVIS-BESSE, UNIT I 3/4 5-3 Amendment No. 36,182, 253, 257 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 169 of 189 Attachment 1, Volume 11, Rev. 0, Page 170 of 189 ITS 0 ITS 3.6.7 Revised by HK Letter Dated June 6, 1995 StiRVEILLANCE REQUIREPNRTS (ContinuedQ | ||
| Line 580: | Line 577: | ||
-TF LIMITING CON'OITION FOR OPERATION 3.5.3 As a minimum, one ECCS subsystem cprised of the following shall be OPERABLE: a. One OPERABLE decay heat (DH) puap, b. One OPERABLE DH cooler, and c. An OPERABLE flow path capable of taking suction from the borated water storage tank (BWST) and manually transferring suction to the containment emergency swip during the recirculatlon phase of operation. | -TF LIMITING CON'OITION FOR OPERATION 3.5.3 As a minimum, one ECCS subsystem cprised of the following shall be OPERABLE: a. One OPERABLE decay heat (DH) puap, b. One OPERABLE DH cooler, and c. An OPERABLE flow path capable of taking suction from the borated water storage tank (BWST) and manually transferring suction to the containment emergency swip during the recirculatlon phase of operation. | ||
See ITS ]3.5.3 APPLICABILITY: | See ITS ]3.5.3 APPLICABILITY: | ||
MODE 4.ACTION: a. With no ECCS subsystem OPERABLE because of the inoperability of the OH pump, the DH cooler or the flow path from the BWST, restore at least one ECCS subsystem to OPERABLE status within one hour or Laintain the Reactor Coolant System Tavg less than 280°F by use of alternate heat removal methods.b. In the event the ECCS is actuated and injects water into the reactor coolant system, a Special Report shall be prepared and submitted to the Commission pursuant to Specification | MODE 4.ACTION: a. With no ECCS subsystem OPERABLE because of the inoperability of the OH pump, the DH cooler or the flow path from the BWST, restore at least one ECCS subsystem to OPERABLE status within one hour or Laintain the Reactor Coolant System Tavg less than 280°F by use of alternate heat removal methods.b. In the event the ECCS is actuated and injects water into the reactor coolant system, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the-total accumulated actuation cycles to date.See ITS 3..5.I LO (Add proposed ACTIONS A and B Y eir""I I plier SR 3.6.7.1, LCO 3.6.7 4.5.3 The ECCS subsystems shall be de-nstrzted applicable Surveillance Requirecnts of 4.5.2.OPERABLE per .the Amendment No. ae; 57 DAVIS-BESSE. | ||
90 days describing the circumstances of the actuation and the-total accumulated actuation cycles to date.See ITS 3..5.I LO (Add proposed ACTIONS A and B Y eir""I I plier SR 3.6.7.1, LCO 3.6.7 4.5.3 The ECCS subsystems shall be de-nstrzted applicable Surveillance Requirecnts of 4.5.2.OPERABLE per .the Amendment No. ae; 57 DAVIS-BESSE. | |||
UmIT 1 3/4 5-6 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 172 of 189 Attachment 1, Volume 11, Rev. 0, Page 173 of 189 DISCUSSION OF CHANGES ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP) STORAGE ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 3 -Relaxation of Completion Time) CTS 3.5.2 provides requirements for the ECCS when in MODES 1, 2, and 3. CTS 4.5.2.d.4 requires the TSP storage baskets contain > 290 ft 3 of TSP. If this Surveillance is not met, CTS 3.5.2 does not provide any Actions. Thus, CTS LCO 3.0.3 would be required to be entered. CTS LCO 3.0.3 provides 1 hour to initiate action and requires the unit to be placed in HOT STANDBY (MODE 3) within the next 6 hours and HOT SHUTDOWN (MODE 4) within the following 6 hours.CTS 3.5.3 provides requirements for the ECCS when in MODE 4. CTS 4.5.3 requires the ECCS subsystems to be demonstrated OPERABLE per the applicable Surveillance Requirements of CTS 4.5.2. Thus, for the required ECCS subsystems to be OPERABLE in MODE 4, CTS 4.5.2.d.4 must be met.Since there are no Actions provided in CTS 3.5.3 when the TSP baskets are not within the limit of CTS 4.5.2.d.4, CTS LCO 3.0.3 must also be entered. CTS LCO 3.0.3 requires the unit to be placed in COLD SHUTDOWN (MODE 5) within the subsequent 24 hours. ITS 3.6.7 provides the requirements for the TSP baskets. In the ITS, when the TSP storage baskets contain < 290 ft 3 of TSP, ITS 3.6.7 Condition A is entered. ITS 3.6.7 Required Action A.1 provides 72 hours to restore the TSP baskets to > 290 ft 3 of TSP. If the required TSP volume is not restored, ITS 3.6.7 ACTION B requires the unit to be shut down to MODE 3 within 6 hours and MODE 5 within 84 hours. This changes the CTS by allowing 72 hours to restore the TSP baskets to within the limits and, if not restored, allows 84 hours for the unit to be placed in MODE 5.Davis-Besse Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 173 of 189 Attachment 1, Volume 11, Rev. 0, Page 174 of 189 DISCUSSION OF CHANGES ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP) STORAGE The purpose of CTS 4.5.2.d.4 is to ensure adequate TSP is in the TSP baskets to assist in reducing the iodine fission product inventory in the containment atmosphere resulting from a design basis loss of coolant accident (LOCA). This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. | UmIT 1 3/4 5-6 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 172 of 189 Attachment 1, Volume 11, Rev. 0, Page 173 of 189 DISCUSSION OF CHANGES ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP) STORAGE ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 3 -Relaxation of Completion Time) CTS 3.5.2 provides requirements for the ECCS when in MODES 1, 2, and 3. CTS 4.5.2.d.4 requires the TSP storage baskets contain > 290 ft 3 of TSP. If this Surveillance is not met, CTS 3.5.2 does not provide any Actions. Thus, CTS LCO 3.0.3 would be required to be entered. CTS LCO 3.0.3 provides 1 hour to initiate action and requires the unit to be placed in HOT STANDBY (MODE 3) within the next 6 hours and HOT SHUTDOWN (MODE 4) within the following 6 hours.CTS 3.5.3 provides requirements for the ECCS when in MODE 4. CTS 4.5.3 requires the ECCS subsystems to be demonstrated OPERABLE per the applicable Surveillance Requirements of CTS 4.5.2. Thus, for the required ECCS subsystems to be OPERABLE in MODE 4, CTS 4.5.2.d.4 must be met.Since there are no Actions provided in CTS 3.5.3 when the TSP baskets are not within the limit of CTS 4.5.2.d.4, CTS LCO 3.0.3 must also be entered. CTS LCO 3.0.3 requires the unit to be placed in COLD SHUTDOWN (MODE 5) within the subsequent 24 hours. ITS 3.6.7 provides the requirements for the TSP baskets. In the ITS, when the TSP storage baskets contain < 290 ft 3 of TSP, ITS 3.6.7 Condition A is entered. ITS 3.6.7 Required Action A.1 provides 72 hours to restore the TSP baskets to > 290 ft 3 of TSP. If the required TSP volume is not restored, ITS 3.6.7 ACTION B requires the unit to be shut down to MODE 3 within 6 hours and MODE 5 within 84 hours. This changes the CTS by allowing 72 hours to restore the TSP baskets to within the limits and, if not restored, allows 84 hours for the unit to be placed in MODE 5.Davis-Besse Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 173 of 189 Attachment 1, Volume 11, Rev. 0, Page 174 of 189 DISCUSSION OF CHANGES ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP) STORAGE The purpose of CTS 4.5.2.d.4 is to ensure adequate TSP is in the TSP baskets to assist in reducing the iodine fission product inventory in the containment atmosphere resulting from a design basis loss of coolant accident (LOCA). This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. | ||
The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. During this period of time, at least one train of the Containment Spray System would still be available as specified in LCO 3.6.6 and would remove some iodine from the containment atmosphere in the event of a LOCA. Furthermore, it would be extremely unlikely for no TSP to be in the baskets; thus the pH in the containment emergency sump would still be close to the required limits necessary to retain the removed iodine in solution. | The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. During this period of time, at least one train of the Containment Spray System would still be available as specified in LCO 3.6.6 and would remove some iodine from the containment atmosphere in the event of a LOCA. Furthermore, it would be extremely unlikely for no TSP to be in the baskets; thus the pH in the containment emergency sump would still be close to the required limits necessary to retain the removed iodine in solution. | ||
| Line 598: | Line 592: | ||
The borated water storage tank (BWST) borated water has a nominal pH of approximately 5.0. A pH of 7.0 is assumed for the containment emergency sump for iodine retention and removal post-LOCA by the containment spray system.Insert Page B 3.6.7-1 Attachment 1, Volume 11, Rev. 0, Page 181 of 189 Attachment 1, Volume 11, Rev. 0, Page 182 of 189 I All changes are 1 unless otherwise noted 9 TSP Storage Spr y Addiive S stem B 3.6.7 0 BASES APPLICABLE SAFETY ANALYSES (continued) | The borated water storage tank (BWST) borated water has a nominal pH of approximately 5.0. A pH of 7.0 is assumed for the containment emergency sump for iodine retention and removal post-LOCA by the containment spray system.Insert Page B 3.6.7-1 Attachment 1, Volume 11, Rev. 0, Page 181 of 189 Attachment 1, Volume 11, Rev. 0, Page 182 of 189 I All changes are 1 unless otherwise noted 9 TSP Storage Spr y Addiive S stem B 3.6.7 0 BASES APPLICABLE SAFETY ANALYSES (continued) | ||
The DBA respo se time assumed fo the Spray Additiv System is the same as for th Containment Spray ystem and is dis ussed in the Bases for LC0 3.6.6, "Containment Spray and Cooliný Systems.'The DBA ana es assume that on train of the ContEinment Spray SysterrlSpra Additive System is i operable and that the entire spray additive tank olume is added to t e remaining Cont inment Spray System flow ath.In the evaluation of the worst-case LOCA, the safety analysis assumed that an alkaline containment spray effectively reduced the airborne iodine.Each Contain mnt Spray System su ion line is equippeq with its own gravity feed fro the spray additive nk. Therefore, in t e event of a single failure the Spray Additive System (i.e., su on valve failure), NaOH will stillbe mixed with the bo ated water, establi hing the alkalinity essential to effective iodine removal. 1 TSP Storage The pr' Aive semisatisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). | The DBA respo se time assumed fo the Spray Additiv System is the same as for th Containment Spray ystem and is dis ussed in the Bases for LC0 3.6.6, "Containment Spray and Cooliný Systems.'The DBA ana es assume that on train of the ContEinment Spray SysterrlSpra Additive System is i operable and that the entire spray additive tank olume is added to t e remaining Cont inment Spray System flow ath.In the evaluation of the worst-case LOCA, the safety analysis assumed that an alkaline containment spray effectively reduced the airborne iodine.Each Contain mnt Spray System su ion line is equippeq with its own gravity feed fro the spray additive nk. Therefore, in t e event of a single failure the Spray Additive System (i.e., su on valve failure), NaOH will stillbe mixed with the bo ated water, establi hing the alkalinity essential to effective iodine removal. 1 TSP Storage The pr' Aive semisatisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). | ||
LCO TSPstoraoge Thepra ite emi necessary to reduce the release of baskets are radioactive material to the environment in the event of a DBA. Iýýe contained in the TSP storage considerLýhe volume land c~ncentrat n ot thee spray baskets (_290 ft') is a Eive solytion n')6st e: sufficient Ito/provide NaUH injectioninto te--spayfow until he Containment Spr.py System suction path/is switchc ol tihe BpS to the containment/sump and to raise the average spray ime argincludesj solution pH to a level conducive to iodine average spray.solution pH i~lbetv/een | LCO TSPstoraoge Thepra ite emi necessary to reduce the release of baskets are radioactive material to the environment in the event of a DBA. Iýýe contained in the TSP storage considerLýhe volume land c~ncentrat n ot thee spray baskets (_290 ft') is a Eive solytion n')6st e: sufficient Ito/provide NaUH injectioninto te--spayfow until he Containment Spr.py System suction path/is switchc ol tihe BpS to the containment/sump and to raise the average spray ime argincludesj solution pH to a level conducive to iodine average spray.solution pH i~lbetv/een | ||
[7/2 and/11.nil This pH range maximizes the (D effectiveness of the iodine removal mechanism without introducing conditions that may induce caustic stress corrosion cracking of mechanical system components. | [7/2 and/11.nil This pH range maximizes the (D effectiveness of the iodine removal mechanism without introducing conditions that may induce caustic stress corrosion cracking of mechanical system components. | ||
In ddition, it is essentia t at va ves in the Spray Addiyve ,ystem flow pat s are properly positione and that automatic vales are capable of a ivating to their correct pysitions. | In ddition, it is essentia t at va ves in the Spray Addiyve ,ystem flow pat s are properly positione and that automatic vales are capable of a ivating to their correct pysitions. | ||
Revision as of 22:00, 12 July 2019
| ML072200475 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/03/2007 |
| From: | FirstEnergy Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML072200475 (189) | |
Text
Attachment 1, Volume 11, Rev. 0, Page 1 of 189 ATTACHMENT 1 VOLUME 11 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.6 CONTAINMENT SYSTEMS Revision 0 Attachment 1, Volume 11, Rev. 0, Page 1 of 189 Attachment 1, Volume 11, Rev. 0, Page 2 of 189 LIST OF ATTACHMENTS
- 1. ITS 3.6.1 2. ITS 3.6.2 3. ITS 3.6.3 4. ITS 3.6.4 5. ITS 3.6.5 6. ITS 3.6.6 7. ITS 3.6.7 Attachment 1, Volume 11, Rev. 0, Page 2 of 189 Attachment 1, Volume 11, Rev. 0, Page 3 of 189 ATTACHMENT 1 ITS 3.6.1, CONTAINMENT Attachment 1, Volume 11, Rev. 0, Page 3 of 189 Attachment 1, Volume 11, Rev. 0, Page 4 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 4 of 189 Attachment 1, Volume 11, Rev. 0, Page 5 of 189 Q ITS 3.6.1 ITS 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMTRY CONTAINMENT COTANENT BI LIY LIMITING CONDITION FOR OPERATION 3.6.1 3.6.1.1 Primary be maintained.
APPLICABILITY:
MODES 1, 2, 3 and 4.ACTION: ACTION A__-ithout primaryrEONTAi lv restore ONTAaqfv "N, T within Lone hou or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN ACTION B ithin the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.,RT TR VEI."l .IANC RF.TlIrTRFMPFNT" L0 1 See ITS 1 3.6.3 4.6.1.1 Prinary ONTATLiTF GITY!-shall be demonstrated:
Ia. At let once per 3Ydays by verifFyinR that: [1.All penetrations*
not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except those valves that may be opened under administrative SR 3.6.1.1 I controls per Specificauon 3.6.3.1, and 12. Tfie. equ ipr)ýnt hatch jý closed.-b. By verifying theach containment air lock is with th~e]0 requireme of Specification 3.6.1.3 c. By performing required visual examinations of the containment vessel and shield building in accordance with the Containment Leakage Rate Testing Program.*Except valves, blind flanges, and deactivated automatic valves which are located inside the See ITS Shield Building (including the annulus and containment) and are locked, sealed, or otherwise 3.6.31T secured in the closed position.
These penetrations shall be verified closed during each COLD SHUTDOWN except that verification of these penetrations being closed need not be performed more often than once per 92 days.DAVIS-BESSE, UNIT 1 3/4 6-1 Amendment No. 147, 194, 205, 240 Page 1 of 3 Attachment 1, Volume 11, Rev. 0, Page 5 of 189 Attachment 1, Volume 11, Rev. 0, Page 6 of 189 ITS 3.6.1 ITS DEFINITIONS 1.7 Deleted.I CONTAINMENT INTEGRITY 11.8{ See ITS Chapter 1.0 J CONTAINMENT INTEGRITY shall exist when: a. All penetrati ns required to be closed during accident conditi ns are either: 1. Ca able of being closed by t e Safety Features Act ation System, or 2. Cl sed by manual valves, bi nd flanges, or deactiva ed automatic valves s-red in their closed posi ons. except those app oved to be open u der administrative contro s, b. The equ pment hatch is closed, LAOG1 SSee ITS c. Each air lock is in compliance with the requirements of Specification 3.6.13, -- 3 6.2 d. The contairinent leakage rates are wi in the limits specified i the Containment Leakage te Testing Program, and /e. The seali g mechanism associated ith each penetration ( .g., welds, bellows or O-rings)/s OPERABLE.CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessry.
of the channel output such that it responds with necessary range and accuracy to known values of the parameter which the channel monitors.
The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated.
CHANNEL CHECK 1.10 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation.
This determination shall Include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
See ITS -]Chapter 1.09 DAVIS-BESSE, UNIT I 1-2 Amendment No. 93, 15.. 14.7. 94, 24', 248 Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 6 of 189 Attachment 1, Volume 11, Rev. 0, Page 7 of 189 ITS 3.6.1 ITS CONTAINMENT SYSTEMS CONTAINMENT LEAKAGE LIMITING CONDITION FOR OPERATION 3.6.1.2 Containment leakage rates shall be in accordance with the Containment Leakage Rate Testing Program.SR 3.6.1.1 APPLICABILITY:
MODES 1, 2, 3 and 4.ACTION: ACTIO _ ffi containment leakage rate(s) not within limit(s), restore containment leakage rate(s) within Ai itiýt(s) within one hour o-re in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD ACTION B ----TSHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SR 3.6.1.1 SURVEILLANCE REQUIREMENTS 4.6.1.2.1 The containment leakage rates shall be determined in accordance with the Containment Leakage Rate Testing Program.4.6.1.2.2 A special test shall be performed to verify that the containment purge and exhaust isolation valves leakage rate is within the limits specified in the Containment Leakage Rate Testing Program, by pressurizing the piping section including one valve inside and one valve outside the containment to a pressure greater than or equal to 20 psig: a. Each time the containment purge and exhaust isolation valves are opened, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after valve closure, or prior to entering MODE 4 from MODE 5, whichever is later.b. Each time the plant has been in any combination of MODES 3, 4, 5 or 6 for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, if not performed in the previous 6 months.See ITS 1 3.6.3 ]DAVIS-BESSE, UNIT 1 3/4 6-2 Amendment No. 90, 146, 160, 198, 205,240 Page 3 of 3 Attachment 1, Volume 11, Rev. 0, Page 7 of 189 Attachment 1, Volume 11, Rev. 0, Page 8 of 189 DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.A02 CTS 3.6.1.1 states "Primary CONTAINMENT INTEGRITY shall be maintained." CTS 3.6.1.2 requires containment leakage rates be in accordance with the Containment Leakage Rate Testing Program. ITS 3.6.1 states "Containment shall be OPERABLE." This changes the CTS by deleting all references to the CONTAINMENT INTEGRITY definition, as well as combining the containment requirements of CTS 3.6.1.1 and CTS 3.6.1.2 into one LCO statement.
The purpose of CTS 3.6.1.1 and CTS 3.6.1.2 is to provide requirements pertaining to containment OPERABILITY.
This portion of the change (combining the LCOs) is acceptable because moving these requirements to one LCO, ITS 3.6.1, centralizes the requirements.
The purpose of CTS 1.8 is to clearly describe all aspects of CONTAINMENT INTEGRITY.
The CTS 3/4.6.1 references to CONTAINMENT INTEGRITY have been deleted since the CTS definition of CONTAINMENT INTEGRITY in CTS 1.8 is incorporated into ITS 3.6.1, 3.6.2 and 3.6.3 and is no longer maintained as a separate definition in the ITS. ITS 3.6.1 requires that the containment shall be OPERABLE.
The definition of OPERABLE and the subsequent ITS 3.6.1 LCO, ACTIONS, and Surveillance Requirements are sufficient to encompass the applicable requirements of the CTS definition.
This change removes any confusion that may exist between the definition and the specific requirements of the LCO and is a presentation preference consistent with NUREG-1430, Rev. 3.1. Since all aspects of the CONTAINMENT INTEGRITY definition requirements, along with the remainder of the LCOs in the Containment Systems Primary Containment section (i.e., air locks and containment isolation valves), are maintained in subsequent Specifications of ITS, this change is considered acceptable.
This change is designated as administrative because it does not result in technical changes to the CTS.A03 CTS 4.6.1.1 .b requires that Primary CONTAINMENT INTEGRITY shall be demonstrated by verifying that each containment air lock is in compliance with the requirements of Specification 3.6.1.3. The ITS does not include the reference to CTS 3.6.1.3 (which has changed to ITS 3.6.2). This changes the CTS by not including a reference to another LCO that is required in the same MODES.The purpose of the CTS 4.6.1.1.b is to provide assurance that each containment air lock is performing its function in support of CONTAINMENT INTEGRITY.
This cross reference to another Specification is not necessary and this change is acceptable because ITS 3.6.2 provides assurance that containment air locks are Davis-Besse Page 1 of 3 Attachment 1, Volume 11, Rev. 0, Page 8 of 189 Attachment 1, Volume 11, Rev. 0, Page 9 of 189 DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT OPERABLE without the reference in ITS 3.6.1. This change is designated as administrative because it does not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 2 -Removing Descriptions of System Operation)
CTS 1.8 states, in part,"CONTAINMENT INTEGRITY shall exist when: 1.8.a All penetrations required to be closed during accident conditions are either: 1. Capable of being closed by the Safety Features Actuation System, or 2. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for those approved to be open under administrative controls; 1.8.b The equipment hatch is closed; 1.8.d The containment leakage rates are within the limits specified in the Containment Leakage Rate Testing Program; and 1.8.e The sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) is OPERABLE." ITS 3.6.1 states "Containment shall be OPERABLE." This changes the CTS by moving the reference to penetration and equipment hatch requirements to the Bases.The removal of these details, which are related to system operation, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the containment to be OPERABLE and the relocated material describes aspects of OPERABILITY.
The ITS also still retains the requirement to perform required visual inspections and leakage rate testing in accordance with the Containment Leakage Rate Testing Program, which would provide verification that the equipment hatch is closed, the containment leakage rates are within limits, and the sealing mechanisms are OPERABLE.
Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because information relating to system operation is being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES L01 (Category 5 -Deletion of Surveillance Requirement)
CTS 4.6.1.1 .a.2 requires the primary containment equipment hatches to be verified closed every 31 days.Davis-Besse Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 9 of 189 Attachment 1, Volume 11, Rev. 0, Page 10 of 189 DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT The ITS does not include this requirement.
This changes the CTS by deleting the specific Surveillance Requirement to verify primary containment equipment hatches are closed.The purpose of CTS 4.6.1.1 .a.2 is to help ensure primary CONTAINMENT INTEGRITY is maintained.
However, the ITS still maintains the requirement for the Containment to be OPERABLE, and maintaining the hatches closed is part of this requirement (as described in the Bases). The ITS also continues to require the leakage rate testing in accordance with the Containment Leakage Rate Testing Program. This leakage testing would confirm that the equipment hatch is closed, since if it was not closed, then the measured leakage rate would be affected.
In addition, opening of the equipment hatch is not a routine evolution, and it is strictly controlled by plant procedures.
The appropriate procedure requires proper verification that the opened equipment hatch is reclosed when work is complete.
Therefore, this specific Surveillance Requirement is not necessary to be included in the ITS. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.Davis-Besse Page 3 of 3 Attachment 1, Volume 11, Rev. 0, Page 10 of 189 Attachment 1, Volume 11, Rev. 0, Page 11 of 189 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 11 of 189 Attachment 1, Volume 11, Rev. 0, Page 12 of 189 CTS Containment 3.6.1 3.6 CONTAINMENT SYSTEMS 3.6.1 Containment LCO 3.6.1 Containment shall be OPERABLE.3.6.1.1, 3.6.1.2 APPLICABILITY:
MODES 1,2, 3., and 4.3.6.1.1 Action 3.6.1.2 Action 3.6.1.1 Action 3.6.1.2 Action 4.6.1.1.1.c.
4.6.1.2.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment inoperable.
A.1 Restore containment to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OPERABLE status.B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1 Perform required visual examinations and leakage In accordance rate testing except for containment air lock testing, with the in accordance with the Containment Leakage Rate Containment Testing Program. Leakage Rate Testing Program SR 3.6.1.2 Verify containment struct al integrity in In accordance ccordance with the Con nment Tendon with the Surveillance Program. Containment Tendon Surveillance Program]0 BVWJOG STS 3.6.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 12 of 189 Attachment 1, Volume 11, Rev. 0, Page 13 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.1, CONTAINMENT
- 1. This bracketed requirement regarding Containment Tendon Surveillance Program is deleted because it is not applicable to Davis-Besse.
The Davis-Besse containment does not utilize pre-stressed concrete containment tendons.Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 13 of 189 Attachment 1, Volume 11, Rev. 0, Page 14 of 189 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 14 of 189 Attachment 1, Volume 11, Rev. 0, Page 15 of 189 Containment B 3.6.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment BASES BACKGROUND The containment con ists of the concrete reactor buildino (RB), its steel liner, and the penetr ions through this structure.
The ructure is designed to contain dioactive material that may be re' ased from the reactor core followin a design basis loss of coolant acident (LOCA).Additionally, this str cture provides shielding from the ssion products that may be presený in the containment atmosphere fo lowing accident The containment i a reinforced concrete structure wih a cylindrical wall, a flat foundation at, and a shallow dome roof. For ontainments with ungrouted tendo s, the cylinder wall is prestressed ith a post tensioning system in the ve ical and horizontal directions, and he dome roof is prestressed usi a three way post tensioning syst m. The inside surface of the ntainment is lined with a carbon s el liner to ensure a high degree of I ak tightness during operating and accident conditions.
The concrete B is required for structural integri of the containment under Design sis Accident (DBA) conditions.
he steel liner and its penetrations stablish the leakage limiting boun ry of the containment.
9~T11 0 Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environment.
SR 3.6.1.1 leakage rate requirements comply with 10 CFR 50, Appendix J, Option[F[? ](Ref. 1), as modified by approved exemptions.
The isolation devices for the penetrations in the containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barrier: a. All penetrations required to be closed during accident conditions are either: 1. Capable of being closed by an OPERABLE automatic containment isolation systerrr 2. Closed by manual valves, blind flanges, or de-activated automatic valves secured in their closed positions, except as provided in LCO 3.6.3, "Containment Isolation Valves"Lo b. Each air lock is OPERABLE, except as provided in LCO 3.6.2,"Containment Air Locks_" 0 0 BWOG STS B 3.6.1-1 Rev. 3.1, 12101/05 Attachment 1, Volume 11, Rev. 0, Page 15 of 189 Attachment 1, Volume 11, Rev. 0, Page 16 of 189 B 3.6.1 O INSERT 1 The containment vessel, including all its penetrations, is a low leakage steel structure designed to withstand a postulated loss-of-coolant accident and to confine a postulated release of radioactive material.
The containment vessel is a cylindrical steel pressure vessel with hemispherical dome and ellipsoidal bottom. It is completely enclosed by a reinforced concrete shield building having a cylindrical shape with a shallow dome roof.An annular space is provided between the wall of the containment vessel and the shield building, and clearance is also provided between the containment vessel and the dome of the shield building.The shield building is a concrete structure surrounding the containment vessel. It is designed to provide biological shielding during normal operation and from hypothetical accident conditions.
The building provides a means for collection and filtration of fission product leakage from the containment vessel following a hypothetical accident through the Station Emergency Ventilation System, an engineered safety feature designed for that purpose.Insert Page B 3.6.1-1 Attachment 1, Volume 11, Rev. 0, Page 16 of 189 Attachment 1, Volume 11, Rev. 0, Page 17 of 189 I All changes are 1 unless otherwise noted 9 Containment B 3i6.1 BASES BACKGROUND (continued) eqipen htc. closed and (eg. welds.en hacsmC E be.l..weds, , od. The sealing mechanism associated with each bellows, or O-rings))
penetration xce t as rovi in LCO 3.6. , is OPERABLE.APPLICABLE The E design basis for the containment is that the containment must SAFETY withstand the pressures and temperatures of the limiting DBA without ANALYSES exceeding the design leakage rate.0O 0 0 The DBAs that result in a challenge to containment OPERABILITY from S rod high pressures and temperatures are a LOCA, a steam line break, and a assembly (CRA) ejection accident A) (Ref. 2). In addition, release of significant fission product radioactivity within containment can occur from a LOCA or cPA on [R In the DBA analyses, it is assumed that the containment is accident OPERABLE such that, for the DBAs involving release of fission product radioactivity, release to the environment is controlled by the rate of containment leakage The containment was designed with an allowable 0.50 leakage rate ot of containment air weight per day (Ref. 3). This (leakage rate, used in the evaluation of offsite doses resulting from accidents, is defined in 10 CFR 50, Appendix J, OptionrEJJ (Ref. 1), as (La: the maximum allowable leakage rate at the calculated maximum peak containment pressure (Pa) resulting from the limiting design basis LOCA.The allowable leakage rate represented by La forms the basis for the acceptance criteria imposed on all containment leakage rate te.st .L is 0 assumed to be [0 1 25]I% per day in the safety analysis at Pa = [ sig ((Ref. 3).Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY.
The containment satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).
D D LCO Containment OPERABILITY is maintained by limiting leakage to _ 1.0 La, except prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test. At this time the applicable leakage limits must be met.EtL Compliance with this LCO will ensure a containment configuration, including equipment hatch., that is structurally sound and that will limit leakage to those leakage rates assumed in the safety analysis.BWOG STS B 3.6.1-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 17 of 189 Attachment 1, Volume 11, Rev. 0, Page 18 of 189 Containment B 3.6.1 BASES LCO (continued) and secondary containment bypass leakage paths d exhaust Individual leakage rates specified for the containment air lock (LCO 3.6.2)containmex t @.ndurge valves with resilient seals*(LCO 3.6.3)o are not specifically part of the acceptance criteria of 10 CFR 50, Appendix J. Therefore, leakage rates exceeding these individual limits only result.in the containment being inoperable when the leakage results in exceeding the overall acceptance criteria of 1.0L,.APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment.
In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment.
The requirements for containment during MODE 6 are addressed in LCO 3.9.3, "Containment Penetrations." ACTIONS A.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time provides a OPERABLE period of time to correct the problem commensurate with the importance of maintaining containment during MODES 1, 2, 3, and 4. This time period also ensures the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal.B.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.0 BWOG STS B 3.6.1-3 Rev. 3.1, 12/01105 Attachment 1, Volume 11, Rev. 0, Page 18 of 189 Attachment 1, Volume 11, Rev. 0, Page 19 of 189 Containment B 3.6.1 BASES SURVEILLANCE SR 316.1.1 REQUIREMENTS Maintaining the containmentOPERABLE requires compliance with the shield f ~building visual examinations and leakage rate test requirements of the exterio Containment Leakage Rate Testing Program. The nain nt concrete visual examinations may be performed during either power operatio e.g., performe ncurrently with other contaipfnent inspection-.relate (d)Activ t es suh as tendon testingor during a maintenance or refueling shield building interior outage. The visual examinations of thelsteel liner ,.te inside containment (1)and the = 1are performed during maintenance or refueling outages Li--LJ steel containmentves-sel since this is the only time thenea is fully accessible.
s, and secondary containment bypass leakage paths andrto meet airurg alve with resilient sealleaka g limits cinment specified in LCO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test is required to be < 0.6 La for combined Type B and C leakage, and j< U. /,or Option A]IIJ 0.75 La for Option Bf]for overall Type A leakage. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A D leakage limit o 1 .0 La. .A 1.0 L. the offsite dose consequences are bounded by the assumptions of the safety analysis.
[SR Frec;Uencies are as required by the ontainment Leakag ate Testing Pro am. These periodic testing r quirements verify thtthe containment Ikage rate 0 does not exce the leakage rate as med in the safety Fnalysis.SR Frequencies are as required by the Containment Leakage Rate Testing Program. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.7--------
.-.--REVIEW"E 'S NOTE-- -Regulatory Gui e 1.163 and NEI 94- 1 include acceptan-e criteria for as-left and as-fou d Type A leakage s and combined T ye B and C leakage rates which may be reflect.d in the Bases.LSR 3.6.1.2 For ungrouted post tensioned tend s, this SR ensures that the structural inte rity of the containme t will be maintained in accordance with the provi ions of the Contain nt Tendon Surveill nce Program.Testing and requency are in acco dance with the AS E Code, Section Xl, bsection IWL (Ref. , and applicable ad enda as required by 10 CFR 0.55a. ]BWOG STS B 3.6.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 19 of 189 Attachment 1, Volume 11, Rev. 0, Page 20 of 189 Containment B 3.6.1 BASES REFERENCE ES 1. 10 CFR 50, Appendix J, Option M- BM 2. FSAR, Section ona]3. FSAR, Section 14. ASME8 Code.Section XI.
IWL.I 0 00 00 0 BWOG STS B 3.6.1-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 20 of 189 Attachment 1, Volume 11, Rev. 0, Page 21 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.1 BASES, CONTAINMENT
- 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. The brackets have been removed and the proper plant specific information/value has been provided.3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.4. This Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement.
This is not meant to be retained in the final version of the plant specific submittal.
- 5. Changes are made to reflect changes made to the Specification.
- 6. Editorial change.Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 21 of 189 Attachment 1, Volume 11, Rev. 0, Page 22 of 189 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 11, Rev. 0, Page 22 of 189 Attachment 1, Volume 11, Rev. 0, Page 23 of 189 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.1, CONTAINMENT There are no specific NSHC discussions for this Specification.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 23 of 189 Attachment 1, Volume 11, Rev. 0, Page 24 of 189 ATTACHMENT 2 ITS 3.6.2, CONTAINMENT AIR LOCKS Attachment 1, Volume 11, Rev. 0, Page 24 of 189 Attachment 1, Volume 11, Rev. 0, Page 25 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 25 of 189 Attachment 1, Volume 11, Rev. 0, Page 26 of 189 ITS 3.6.2 ITS CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS LIM1TTNG CONDETMN FOR OPERATION 3.6.2 3.6.1.3 Each containment air lock shall be OPERABLE [T a. Both doors closl except when the air lockis being used for entry a d one air lock do r shall be closed, and b. An overall ai lock leakage rate in accor/ance with the Containm nt lU Testing Pro am.APPLICABILITY:
MODES 1,2, 3 and 4.Add proposed ACTIONS Note 2 A02 AC I N A TIN* __Add proposed ACTIONSi~ii Note 3 ACTION A *a. _With one air lock door inoperable in one or more containment air locks, or with the ACTION B containment air lock interlock mechamsm inoperable in one or more containment air locks: Add proposed ACTIONS A and B Note 1'Add proposed ACTION A Note 2 and ACTIONB Note 2 L01 I. Verify an OPERABLE door in each affected air lock is closed within one hour, and ACTIONS A 2. Lock an OPERABLE door closed in each affected air lock within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and and B Add proposed Required Actions A.3 and B.3 Note L 3. Operation may then continue provided that an OPERABLE door in each affected air lock is maintained closed and is verified to be locked closed at least once per 31 days_,and provided that He containment air lock passes each s heduled performance A05 of the overall air lock 1akage rate test. I ACTION D 4. Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.*b. With one or more containment air locks inoperable except as a result of an inoperable air ACTION C lock door or air lock interlock mechanism:
- 1. Verify at least one door in each affected air lock is closed within one hour, and 2. Restore air lock(s) to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.ACTION D 3. Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.ACTIONS *Entry and exit through the OPERABLE door is permissible if necessary to perform repairs of Note 1 the affected air lock components.
[After each e jir3and exit, the OPERABdoor must be L Iclosed wi out delay.DAVIS-BESSE, UNIT 1 3/4 6-6 Amendment No. 194, 223, 240 Page 1 of 3 Attachment 1, Volume 11, Rev. 0, Page 26 of 189 Attachment 1, Volume 11, Rev. 0, Page 27 of 189 0 ITS 3.6.2 ITS CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS SR 3.6.2.1 SR 3.6.2.2 SR 3.6.2.1 Note 1 SURVEILLANCE REQUIREMENTS 4.6.1.3 Each-containment air lock shall be demonstrated OPERABLE: Add proposed SR 3.6.2.1 Note 2 a. By performing required air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program.*b. Deleted.c. At least once per REFUELING INTERVAL by verifying that only one door in each air lock can be opened at a time.*One inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.S0 DAVIS-BESSE, UNIT 1 3/4 6-6a Amendment No. 194, 223, 240 Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 27 of 189 Attachment 1, Volume 11, Rev. 0, Page 28 of 189 GD ITS 3.6.2 ITS DEFINITIONS 1.7 Deleted.CONTAINMENT INTEGRITY L 1.8 CONTAINMENT INTEGRITY shall exist when: a. All penetrations required to be closed during accident conditions are either: 1. Capable of being closed by the Safety Features Actuation System, or 2. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions.
except those approved to be open under administrative controls, b. The equipment hatch is closed, c. Each air lock is in compliance with the requirements of Specification 3.6.1.3, d. The containment leakage rates are within the limits specified in the Containment Leakage Rate Testing Program, and e. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) is OPERABLE.LCO 3.6.2 See ITS Chapter 1.09 See ITS 3.6.1 See ITS 3.6.1 See ITS Chapter 1.0, CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessry, of the channel output such that it responds with necessary range and accuracy to known values of the parameter which the channel monitors.
The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated.
CHANNEL CHECK 1.10 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation.
This determination shall Include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
DAVIS-BESSE, UNIT 1 1-2 Amendment No. "3, 123. 147, 194, 240, 2448 Page 3 of 3 Attachment 1, Volume 11, Rev. 0, Page 28 of 189 Attachment 1, Volume 11, Rev. 0, Page 29 of 189 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.A02 CTS 3.6.1.3 states "Each containment air lock shall be OPERABLE..." CTS 3.6.1.3 Action a states "With an air lock inoperable" and specifies Actions to be taken. ITS 3.6.2 ACTIONS Note 2 states "Separate Condition entry is allowed for each air lock." ITS 3.6.2 Condition C states "One or more containment air locks inoperable for reasons other than Condition A or B." This changes the CTS by clarifying the current intent of applying the CTS Actions to each air lock separately.
The purpose of CTS 3.6.1.3 is to ensure containment air locks meet their requirements for CONTAINMENT INTEGRITY (changed to containment OPERABILITY in the ITS). One OPERABLE air lock door in each containment air lock provides a pressure boundary, and applying the CTS Actions for an inoperable air lock to each of the air locks separately is appropriate.
ITS 3.6.2 ACTIONS Note 2 clearly states this. The Required Actions for each Condition provide appropriate compensatory action for each inoperable air lock. This change is acceptable because it clarifies existing requirements and better describes how the requirements are currently used. This change is designated as administrative because it does not result in technical changes to the CTS.A03 CTS 3.6.1.3 does not include a reference to entering applicable Conditions and Required Actions of the CONTAINMENT INTEGRITY LCO (CTS 3.6.1.1)(changed to containment OPERABILITY in the ITS). ITS 3.6.2 ACTIONS Note 3 states "Enter applicable Conditions and Required Actions of LCO 3.6.1,"Containment," when air lock leakage results in exceeding the overall containment leakage rate." This changes the CTS by explicitly requiring the Containment Specification Actions be entered when the Containment LCO is not met as a result of air lock leakage exceeding limits.This change is acceptable because it reinforces the requirement in ITS 3.6.1 to meet overall containment leakage limits. This change is designated as administrative because it does not result in technical changes to the CTS.A04 CTS 3.6.1.3 Action a addresses one inoperable containment air lock door or an inoperable interlock mechanism.
CTS 3.6.1.3 Action b addresses an inoperable containment air lock for reasons other than an inoperable air lock door or interlock mechanism, which includes both air lock doors in one air lock being inoperable.
Note 1 to both ITS 3.6.2 ACTIONS A and B states that none of the Required Actions of ACTIONS A and B are to be taken if both doors in the same air lock are inoperable and Condition is entered. This changes CTS by adding a Davis-Besse Page 1 of 5 Attachment 1, Volume 11, Rev. 0, Page 29 of 189 Attachment 1, Volume 11, Rev. 0, Page 30 of 189 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS Note to clarify that when both doors in an air lock are inoperable, the Actions for one inoperable door are not to be taken.This change is acceptable because the intent of the CTS 3.6.1.3 Actions is to enter Action a for one inoperable door or an inoperable interlock mechanism in an air lock, and enter Action b for two inoperable doors in an air lock. This change is designated as administrative because it does not result in technical changes to the CTS.A05 CTS 3.6.1.3 Action a.3 includes a requirement that states operation with an inoperable air lock door or interlock mechanism can continue "provided that the containment air lock passes each scheduled performance of the overall air lock leakage rate test." ITS 3.6.2 does not include this specific statement.
This changes the CTS by deleting a provision when a door or interlock mechanism is inoperable.
This change is acceptable because the requirement is not needed to be stated.CTS 4.0.1 and ITS SR 3.0.1 require Surveillances to be met. If the air lock leakage test fails during the next scheduled performance, then the air lock would be inoperable due to a reason other than an individual door. This would require entry into ITS 3.6.2 ACTION C and the appropriate actions would be taken. This change is designated as administrative because it does not result in a technical change to the CTS.A06 CTS 4.6.1.3.a requires air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program. ITS SR 3.6.2.1 requires a similar test, but is modified by Note 2, which states that results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1. This changes the CTS by adding a Note as a reminder that the air lock leakage must be accounted for in determining the combined Type B and C containment leakage rate.The purpose of CTS 4.6.1.3.a is to ensure that the structural integrity of the containment air locks will be maintained comparable to the original design standards for the life of the facility.
This change is acceptable because it provides clarification that the containment air lock leakage is properly accounted for in determining the combined Type B and C containment leakage rate, consistent with current requirements and practices.
This change is designated as administrative because it does not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None Davis-Besse Page 2 of 5 Attachment 1, Volume 11, Rev. 0, Page 30 of 189 Attachment 1, Volume 11, Rev. 0, Page 31 of 189 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS REMOVED DETAIL CHANGES LA01 (Type I -Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.6.1.3.a and 3.6.1.3.b state what constitutes an OPERABLE containment air lock. ITS LCO 3.6.2 does not include this level of detail. This changes the CTS by moving details concerning what constitutes an OPERABLE containment air lock to the Bases.The removal of these details, which are related to system design, from the CTS is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to have two OPERABLE containment air locks. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the CTS.LA02 (Type 3 -Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)
CTS 3.6.1.3 Actions a and b footnote
- allows entry and exit through the OPERABLE door if necessary to perform repairs of the affected air lock components.
Furthermore, the footnote requires that after each entry and exit, the OPERABLE door must be closed without delay. ITS 3.6.2 ACTIONS Note 1 provides a similar allowance, except the requirement to close the OPERABLE door without delay (after entry or exit), is not included.
This changes the CTS by moving this detail to the Bases.The removal of these details for meeting a Technical Specification requirement is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that entry and exit through the OPERABLE door is permissible.
This allowance implies that if entry and exit is not being made, the door must remain locked closed. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES L01 (Category 4 -Relaxation of Required Action) CTS 3.6.1.3 Action a, which applies when one air lock door or the interlock mechanism is inoperable in one air lock, does not provide an allowance for entry or exit through an air lock except for repair of the affected air lock components (footnote
- ). Note 2 to ITS 3.6.2 ACTION A, which applies when one air lock door is inoperable in an air lock, Davis-Besse Page 3 of 5 Attachment 1, Volume 11, Rev. 0, Page 31 of 189 Attachment 1, Volume 11, Rev. 0, Page 32 of 189 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS states that entry and exit is permissible for 7 days under administrative controls if both air locks are inoperable.
Note 2 to ITS 3.6.2 ACTION B, which applies when the interlock mechanism is inoperable in an air lock, states that entry and exit of containment is permissible under the control of a dedicated individual.
This changes CTS by allowing entry and exit of containment under specified criteria for any reason when an air lock door or an interlock mechanism is inoperable.
The purpose of Note 2 to ITS 3.6.2 ACTIONS A and B is provide reasonable access to containment when air lock doors are inoperable or an interlock mechanism is inoperable.
This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features.
The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. Actions for safe operation of the air lock must still be taken, and controls are placed on the use of the air lock commensurate with the importance of the air lock being able to perform its safety function.
For ITS 3.6.2 ACTION A Note 2, the allowance is only applicable for 7 days if both air locks are inoperable.
For ITS 3.6.2 ACTION B Note 2, the allowance is only applicable if a dedicated individual is present to perform the function of the interlock mechanism.
This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.L02 (Category 4 -Relaxation of Required Action) CTS 3.6.1.3 Action a does not address how to verify locked closed air lock doors in high radiation areas.ITS 3.6.2 Required Actions A.3 and B.3 contain a Note that provides an allowance for air lock doors in high radiation areas to be verified locked closed by administrative means when a containment air lock door or containment air lock interlock mechanism is inoperable.
This changes CTS by allowing an air lock door in a high radiation area to be verified closed by administrative means.The purpose of the Notes to ITS 3.6.2 Required Actions A.3 and B.3 is to provide reasonable assurance in a safe manner that air lock doors in high radiation areas are locked closed. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features.
The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. The air lock doors are still required to be verified locked closed. Considering the doors are initially locked as required by ITS 3.6.2 Required Actions A.2 and B.2, and that they are located in high radiation areas, whose entry into is closely controlled and restricted, verifying the doors closed administratively is reasonable.
This avoids the risks and potential exposure associated with additional entries into high radiation areas. Furthermore, the Davis-Besse Page 4 of 5 Attachment 1, Volume 11, Rev. 0, Page 32 of 189 Attachment 1, Volume 11, Rev. 0, Page 33 of 189 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS probability of misalignment of the locked door, once it has been initially verified to be locked closed, is small. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.Davis-Besse Page 5 of 5 Attachment 1, Volume 11, Rev. 0, Page 33 of 189 Attachment 1, Volume 11, Rev. 0, Page 34 of 189 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 34 of 189 Attachment 1, Volume 11, Rev. 0, Page 35 of 189 CTS Containment Air Locks 3.6.2 3.6 CONTAINMENT SYSTEMS 3.6.2 Containment Air Locks 3.6.1.3 LCO 3.6.2 air loclso]shall be OPERABLE.0 APPLICABILITY:
MODES 1, 2, 3, and 4.ACTIONS-. .----- ......---- N OTES-Actions a and b.footnote *DOC A02 DOC A03 1. Entry and exit is permissible to perform repairs on the affected air lock components.
- 2. Separate Condition entry is allowed for each air lock.3. Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when air lock leakage results in exceeding the overall containment leakage rate acceptance criteria.CONDITION REQUIRED ACTION COMPLETION TIME Actions a.l, a.2, A.and a.3 One or more containment air locks with one containment air lock door inoperable.
-...------------
NOTES ---------1. Required Actions A.1, A.2, and A.3 are not applicable if both doors in the same air lock are inoperable and Condition C is entered.2. Entry and exit is permissible for 7 days under administrative controls Df both air locks are inoperableR 0 A.1 Verify the OPERABLE door is closed in the affected air lock.AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> BVWOG STS 3.6.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 35 of 189 Attachment 1, Volume 11, Rev. 0, Page 36 of 189 CTS Containment Air Locks 3.6.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.2 Lock the OPERABLE door 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> closed in the affected air lock.AND A.3 ............
NOTE Air lock doors in high radiation areas may be verified locked closed by administrative means.Verify the OPERABLE door Once per 31 days is locked closed in the affected air lock.Actions a. 1, a.2, B.and a.3 One or more containment air locks with containment air lock interlock mechanism inoperable.
--.- .-.- ..--- .---- N O T ES -...... ......1. Required Actions B.1, B.2, and B.3 are not applicable if both doors in the same air lock are inoperable and Condition C is entered.2. Entry and exit of containment is permissible under the control of a dedicated individual.
B.1 Verify an OPERABLE door is closed in the affected air lock.AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> BWOG STS 3.6.2-2 Rev. 3.0, 03/31104 Attachment 1, Volume 11, Rev. 0, Page 36 of 189 Attachment 1, Volume 11, Rev. 0, Page 37 of 189 CTS Containment Air Locks 3.6.2 ACTIONS (continued)
CONDITION REQUIRED ACTION 1 COMPLETION TIME B.2 Lock an OPERABLE door 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> closed in the affected air lock.AND B.3 .NOTE-Air lock doors in high radiation areas may be verified locked closed by administrative means.Verify an OPERABLE door Once per 31 days is locked closed in the affected air lock.Actions b.1 and C. One or more b.2 containment air locks inoperable for reasons other than Condition A or B.Actions a.4 and D. Required Action and b.3 associated Completion Time not met.C.1 Initiate action to evaluate overall containment leakage rate per LCO 3.6.1.AND C.2 Verify a door is closed in the affected air lock.AND C.3 Restore air lock to OPERABLE status.Immediately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 24 hours D.1 Be in MODE 3.AND D.2 Be in MODE 5.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours BWOG STS 3.6.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 37 of 189 Attachment 1, Volume 11, Rev. 0, Page 38 of 189 CTS Containment Air Locks 3.6.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.6.1.3.a SR 3.6.2.1 1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.................................................................
Perform required air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program.In accordance with the Containment Leakage Rate Testing Program 4.6.1.3.c SR 3.6.2.2 Verify only one door in the air lock can be opened at 24 months a time.BWOG STS 3.6.2-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 38 of 189 Attachment 1, Volume 11, Rev. 0, Page 39 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.2, CONTAINMENT AIR LOCKS 1. The brackets have been removed and the proper plant specific information/value has been provided.Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 39 of 189 Attachment 1, Volume 11, Rev. 0, Page 40 of 189 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 40 of 189 Attachment 1, Volume 11, Rev. 0, Page 41 of 189 All changes are unless otherwise noted 9 Containment Air Locks B 3.6.2 B 3.6 CONTAINMENT SYSTEMS B 136.2 Containment Air Locks BASES BACKGROUND Containment air locks form part of the containment pressure boundary and provide a means for personnel access during all MODES of operation.
approximately Each air lock is nominally a right circular cylinder, Oft in diametewiha door at each end. The doors are interlocked to prevent simultaneous for the personnel opening. During periods when containment is not required to be air lock and OPERABLE, the door interlock mechanism may be disabled, allowing approximately 6 ft in diameter for the]both doors of an air lock to remain open for extended periods when :emergency airlock frequent containment entry is necessary.
Each air lock door has been designed and is tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design Basis Accident (DBA) in containment.
As such, closure of a single door supports containment OPERABILITY.
Each of the doors contains double gasketed seals and local leakage rate testing capability to ensure pressure integrity.
To effect a leak tight seal, the air lock design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on each door).Each personnel air lock door is provided with limit switches that provideconlI r~oon indication of door position.
Additionally, cntrol room\The containment air locks form part of the containment pressure boundary.
As such, air lock integrity and leak tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA. Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the unit safety analysis.APPLICABLE The DBAs that result in a release of radioactive material within SAFETY containment are a loss of coolant accident (LOCA), aoteam line break, ANALYSES and aFr~d~ejection accident (Ref. 2). In the analysis of each of these control rod assembly-/
accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable 0.50 leakage rate of 0 5] Yo of containment air weight per day (Ref. 3). This leakage rate is defined in 10 CFR 50, Appendix J, Option 6 (Ref. 1), as L 5: the maximum allowable containment leakage rate at the calculated maximum peak containment pressure (Pa) following a design basis D BVVOG STS B 3.6.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 41 of 189 Attachment 1, Volume 11, Rev. 0, Page 42 of 189 Containment Air Locks B 3.6.2 BASES APPLICABLE SAFETY ANALYSES (continued)
LOCA. This allowable leakage rate forms the basis for the acceptance
-0.50 criteria imposed on the SRs associated with the air lock. La is -per 5 r day and Pa is resulting from the limiting design basis LOCA. f K)The containment air locks satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO Each containment air lock forms part of the containment pressure boundary.
As a part of the containment pressure boundary, the air lock safety function is related to control of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.((personnel and emergency)I Each air lock'is required to be OPERABLE.
For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE.
The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE.
Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into or exit from containment.
APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment.
In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material from containment.
The requirements for the containment air locks during MODE 6 are addressed in LCO 3.9.3, "Containment Penetrations." ACTIONS The ACTIONS are modified by a Note that allows entry and exit to perform repairs on the affected air lock component.
If the outer door is If the inner inoperable, then it may be easily accessed for most repairs. /t is door is inoperable, preferred that the air lock be accessed from inside primary containment then by entering through the other OPERABLE air lock. However, if this not practicable, or if repairs on either door must be performed from the barrel side of the door then it is permissible to enter the air lock through the OPERABLE door, which means there is a short time during which the containment boundary is not intact (during access through the BWOG STS B 3.6.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 42 of 189 Attachment 1, Volume 11, Rev. 0, Page 43 of 189 Containment Air Locks B 3.6.2 BASES ACTIONS (continued)-OPERABLE door). The ability to open the OPERABLE door, even if it means the containment boundary is temporarily not intact, is acceptable due to the low probability of an event that could pressurize the containment during the short time in which the OPERABLE door is expected to be open. After each entry and exit the OPERABLE door must be immediately closed. If ALARA conditions permit, entry and exit should be via an OPERABLE air lock.A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each air lock. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable air lock. Complying with the Required Actions may allow for continued operation, and a subsequent inoperable air lock is governed by subsequent Condition entry and application of associated Required Actions.In the event the air lock leakage results in exceeding the overall containment leakage rate, Note 3 directs entry into the applicable Conditions and Required Actions of LCO 3.6.1, "Containment." A.1, A.2, and A.3 With one air lock door inoperable in one or more containment air locks, the OPERABLE door must be verified closed (Required Action A.1) in each affected containment air lock.This ensures that a leak tight containment barrier is maintained by the use of an OPERABLE air lock door. This action must be completed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This specified time period is consistent with the ACTIONS of LCO 3.6.1, which requires containment be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.In addition, the affected air lock penetration must be isolated by locking closed the remaining OPERABLE air lock door within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is considered reasonable for locking the OPERABLE air lock door, considering the OPERABLE door of the affected air lock is being maintained closed.BWOG STS B 3.6.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 43 of 189 Attachment 1, Volume 11, Rev. 0, Page 44 of 189 Containment Air Locks B 3.6.2 BASES ACTIONS (continued)
Required Action A.3 verifies that an air lock with an inoperable door has been isolated by the use of a locked and closed OPERABLE air lock door. This ensures that an acceptable containment leakage boundary is maintained.
The Completion Time of once per 31 days is based on engineering judgment and is considered adequate .in view of the low likelihood of a locked door being mispositioned and other administrative controls.
Required Action A.3 is modified by a Note that applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted.
Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small.The Required Actions have been modified by two Notes. Note 1 clarifies that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable.
With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. The exception of Note 1 does not affect tracking the Completion Time from the initial entry into Condition A; only the requirement to comply with the Required Actions. Note 2 allows use of the air lock for entry and exit for 7 days under administrative controls if both air locks have an inoperable door. This 7 day restriction begins when the second air lock is discovered inoperable.
Containment entry may be required to perform Technical Specifications (TS) Surveillances and Required Actions, as well as other activities on equipment inside containment that are required by TS or activities on equipment that support TS-required equipment.
This Note is not intended to preclude performing other activities (i.e., non-TS-required activities) if the containment was entered, using the inoperable air lock, to perform an allowed activity listed above. This allowance is acceptable due to the low probability of an event that could pressurize the containment during the short time that the OPERABLE door is expected to be open.B.1, B.2, and B.3 With an air lock interlock mechanism inoperable in one or more air locks, the Required Actions and associated Completion Times are consistent with those specified in Condition A.BWVOG STS B 3.6.2-4 Rev. 3.0, 03131/04 Attachment 1, Volume 11, Rev. 0, Page 44 of 189 Attachment 1, Volume 11, Rev. 0, Page 45 of 189 Containment Air Locks B 3.6.2 BASES ACTIONS (continued)
The Required Actions have been modified by two Notes. Note 1 clarifies that only the Required Actions and associated Completion Times of Condition C are required if both doorsin the same air lock are inoperable.
With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and exit from the containment under the control of a dedicated individual stationed at the air lock to ensure that only one door is opened at a time (i.e., the individual performs the function of the interlock).
Required Action B.3 is modified by a Note that applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted.
Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small.C.1, C.2, and C.3 With one or more air locks inoperable for reasons other than those described in Condition A or B, Required Action C.1 requires action to be immediately initiated to evaluate previous combined leakage rates using current air lock test results. An evaluation is acceptable since it is overly conservative to immediately declare the containment inoperable if both doors in an air lock have failed a seal test or if the overall air lock leakage is not within limits. In many instances (e.g., only one seal per door has failed), containment remains OPERABLE, yet only 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (per LCO 3.6.1)would be provided to restore the air lock door to OPERABLE status prior to requiring a plant shutdown.
In addition, even with both doors failing the seal test, the overall containment leakage rate can still be within limits.Required Action C.2 requires that one door in the affected containment air lock must be verified to be closed. This action must be completed within the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time. This specified time period is consistent with the ACTIONS of LCO 3.6.1, which requires that containment be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.Additionally, the affected air lock(s) must be restored to OPERABLE status within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time. The specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status assuming that at least one door is maintained closed in each affected air lock-BWOG STS B 3.6.2-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 45 of 189 Attachment 1, Volume 11, Rev. 0, Page 46 of 189 Containment Air Locks B 3.6.2 BASES ACTIONS (continued)
D.1 and D.2 If the inoperable containment air lock cannot be ,restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.SURVEILLANCE REQUIREMENTS SR 3.6.2.1 Maintaining containment air locks OPERABLE requires compliance with the leakage rate test requirements of the Containment Leakage Rate Testing Program. This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The acceptance criteria were established during initial air lock and containment OPERABILITY testing. The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall containment leakage rate. The Frequency is required by the Containment Leakage Rate Testing Program.The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. This is considered reasonable, since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria which is applicable to SR 3.6.1.1. This ensures that air lock leakage is properly accounted for in determining the combined Type B and C containment leakage rate.SR 3.6.2.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY.
Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment.
Periodic testing of this interlock demonstrates BWOG STS B 3.6.2-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 46 of 189 Attachment 1, Volume 11, Rev. 0, Page 47 of 189 Containment Air Locks B 3.6.2 BASES SURVEILLANCE REQUIREMENTS (continued) that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when the containment air lock door is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed every 24 months. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, and the potential for loss of containment OPERABILITY if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
The 24 month Frequency is based on engineering judgment and is considered adequate given that the interlock is not challenged during the use of the aro REFERENCES
- 1. 10 CFR 50, Appendix J, Option M[] " ir- loc 2.. FSAR, Sectiong[1nd -Vj5.3. FSAR, Section -0 0 00 00 B\AAOG STS B 3.6.2-7 Rev. 3.0, 03/31104 Attachment 1, Volume 11, Rev. 0, Page 47 of 189 Attachment 1, Volume 11, Rev. 0, Page 48 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.2 BASES, CONTAINMENT AIR LOCKS 1, Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. The brackets have been removed and the proper plant specific information/value has been provided.3. Typographical error corrected.
- 4. Editorial change for clarity.Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 48 of 189 Attachment 1, Volume 11, Rev. 0, Page 49 of 189 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 11, Rev. 0, Page 49 of 189 Attachment 1, Volume 11, Rev. 0, Page 50 of 189 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.2, CONTAINMENT AIR LOCKS There are no specific NSHC discussions for this Specification.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 50 of 189 Attachment 1, Volume 11, Rev. 0, Page 51 of 189 ATTACHMENT 3 ITS 3.6.3, CONTAINMENT ISOLATION VALVES Attachment 1, Volume 11, Rev. 0, Page 51 of 189 Attachment 1, Volume 11, Rev. 0, Page 52 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 52 of 189 Attachment 1, Volume 11, Rev. 0, Page 53 of 189 ITS 3.6.3 ITS CONTAINMENT SYSTEIMS 3/4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION LCO 3.6.3 SR 3.6.3.4 ACTION A, ACTION B, -<and ACTION C ACTION F 3.6.3.1 All containment isolation valves shall be OPERABLE with isolation times less tnan or equal to required isolation times., I Add proposed ACTIONS Note 2 APPLICABILITY:
MODES 1, 2, 3 and 4.A0 ACTION:Add proposed ACT SNote4 W-ith one or more of the isolation valve(s) inoperable, either: a. Resto/ the inoperable vilye(s) to OPERABLE s Mtus within SI h1ohourof/
- b. Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of ACTuON M01 at least one deactivated automatic valve secured in the isolation
-position, or posiion or72 hours for L01..C. Isolate each affected penetration within ghours by ýuse of at ACTION C least one closed manual valve or blind flange-- or or-chche w secured L02 d. Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE REQUIREMENTS 4.6.3.1.1
/The isolation valves sha/ 1 be demonstrated OPERABLE pr or to returnin the valve to service after maintenonce, repair or replacement wo k that could affect t ie valve's performance is performed on the valve or its associated actuator, control or power circui by performance of a cyclino test and L verifi rtdion of isolation time./... ... i ... .... ...... I Surveillance te.ting of valves MS100, 1S01 , ICS1lA and ICS lB is not required L may be opened on an intermittent basis under administrative controls.ACTIONS Note 1 DAVIS-BESSE, UNIT 1 3/4 6-14 Amendment No. 147 Page 1 of 6 Attachment 1, Volume 11, Rev. 0, Page 53 of 189 Attachment 1, Volume 11, Rev. 0, Page 54 of 189 ITS 3.6.3 ITS CONTAINMENT SYSTEMS SR 3.6.3.6 SR 3.6.3.4 SURVEILLANCE REQUIREMENTS (Continued) 4.6.3.1.2 Each isolation valve shall be demonstrated OPERABLE at least once each REFUELING INTERVAL, by: aclL a. Verifying that on a [contain t isoýtionest signal, eachL05 automatic isolation valve actuates to its isolation position.r -not locked, sealed, or .b. DELETED -othe ise secured in position 4.6.3.1.3 The isolation time of each power operated r automatic valve L04 shall be determined to be within its limit when tested pursuant to pecilication Inservice Testing Program A08 DAVIS-BESSE, UNIT 1 3/4 6-15 Amendment No. 147,213, 2 2 1 Page 2 of 6 Attachment 1, Volume 11, Rev. 0, Page 54 of 189 Attachment 1, Volume 11, Rev. 0, Page 55 of 189 ITS 3.6.3 ITS 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRITARY CONTAINMENT CONTAINMENT INTEGRITY LZInvING CONDITON FOR OPERATION 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained.
APPLICABILITY:
MODES 1, 2, 3 and 4.See ITS 3.6.1 ACTION: Add proposed ACTIONS Notes 2, 3 and 4. and]Witho t primary CONTAINMENT INTEGRITY, restore CONTNT INTEGRITY within one rgbe in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN ACTION F -_tn .the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.See ITS SURVEILLANCE REOUIREMENTS 3.6.1 I R 4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:
LOB a. At least once per 31 days by verifying that: Add proposed Required Actions A.2 and C.22 Required Actions A.2 Notes 1 and 2 and SRs 3.6.3.3 and 3.6.3.4 Note not lock saaled, and C.2, or ot.s.SR 3.6.3.2, 1. OAll penetrations*
not capable of being closed by OPERABLE containment secured in position SR 3.6.3.3 automatic isolation valvesOEnd required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in L09 ACTIONS NOTE 1, their positions, e[x-cept those valves that may be opened under administrative",0 SR 3.6.3.2. con o s per pecification 3.6.3.1, and or check valve with flow secured" SR 3.6.3.3 2. The equipment hatch is closed.b. By verifying that each containment air lock is in compliance with the requirements of Specification 3.6.1.3 c. By performing required visual examinations of the containment vessel and shield building in accordance with the Containment Leakage Rate Testing Program.See ITS 1 3.6.1 SR 3.6.3.3*Except valves, blind flanges, and deactivated automatic valves which are located inside the not L09 Shield Building (including the annulus and containment) and arlocked, sealed, or otherwise secured in the closed position.
These penetrations shall be verified closed during each COLD SHUTDOWN except that verification of these penetrations being closed need not be performed more often than once per 92 days.DAVIS-BESSE, UNIT 1 3/4 6-1 Amendment No. 147, 194, 205, 240 Page 3 of 6 Attachment 1, Volume 11, Rev. 0, Page 55 of 189 Attachment 1, Volume 11, Rev. 0, Page 56 of 189 GD ITS 3.6.3 ITS CONTAINMENT SYSTEMS CONTAINMENT LEAKAGE LIMITING CONDITION FOR OPERATION 3.6.1.2 Containment leakage rates shall be in accordance with the Containment Leakage Rate Testing Program.APPLICABILITY:
MODES 1, 2, 3 and 4.See ITS 3.6.1 ACTION F ACTION: Add proposed ACTION D L10 proposed ACTION E leakage rate(s) not within I ý__Ws store containment le9kage rate(s) withiný 12 i one hourVmbe in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD-0fffff5bWK:A:::ý,in e following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE REQUIREMENTS 3.6.4.6.1.2.1 The containment leakage rates shall be determined in accordance with the Containment Leakage Rate Testing Program.SR 3.6.3.5 4.6.1.2.2 A special test shall be performed to verify that the containment purge and exhaust isolation valves leakage rate is within the limits Ispecif ied in i ontainment ge IRate Te ng Program, "p surizing Ue/piping section including one valve insie and one valve/outside the containment to/a pressure greater than r equal to 20 psig:-LAO2 LAO3 a. Each time the containment purge and exhaust isolation valves are opened, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after valve closure, or prior to entering MODE 4 from MODE 5, whichever is later.b. Each time the plant has been in any combination of MODES 3, 4, 5 or 6 for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, if not performed in the previous 6 months.DAVIS-BESSE, UNIT 1 3/4 6-2 Amendment No. 90,146, 160, 198, 205, 240 Page 4 of 6 Attachment 1, Volume 11, Rev. 0, Page 56 of 189 Attachment 1, Volume 11, Rev. 0, Page 57 of 189 ITS 3.6.3 ITS CONTAINMENT SYSTEMS CONTAINMENT VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.6.1.7 FThe containment purge supply and exhaust isolation valves shall be[closed with control power removed.3.6.3, SR 3.6.3.1 APPLICABILITY:
MODES 1, 2, 3 and 4.ACTION: _ d rpsdATOSNt W3ith one isolation valve open in a containment purge supply and/or exhaust C N penetration, or with i.ts control power not removed, ,verify that the remaining ACTION A jr-ontainment purge supply and exhaust isolation valves are closed with controll G0 ACTION F SURVEILLANCE REQUIREMENTS 4.6.1.7 At least once per 31 days verify that each containment purge supply and exhaust isolation valve is closed with control power removed.SR 3.6.3.1 DAVIS-BESSE, UNIT I 3/4 6-10 Amendment No. .4-,-3221 Page 5 of 6 Attachment 1, Volume 11, Rev. 0, Page 57 of 189 Attachment 1, Volume 11, Rev. 0, Page 58 of 189 ITS 3.6.3 ITS 6.0 ADMINISTRATIVE CONTROLS 6.16 CONTAINMENT LEAKAGE RATE TESTING PROGRAM a. A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions.
This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, as modified by the following exceptions:
- 1) A reduced duration Type A test may be performed using the criteria and Total Time method specified in Bechtel Topical Report BN-TOP-l, Revision I.2) The fuel transfer tube blind flanges (containment penetrations 23 and 24) will not be eligible for extended test frequencies.
Their Type B test frequency will-remain at 30 months. However, As-found testing will not be required.b. The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 38 psig.c. The maximum allowable containment leakage rate, L4, at P., shall be 0.50% of containment air weight per day.d. Leakage rate acceptance criteria are: 1) Containment leakage rate acceptance criterion is < 1.0 L,. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.75 L, for Type A tests < 0.60 La for all penetrations and valves subject to Type B and Type C testess ange 0.03 L. for all penetrations that are secondary SIR 3.6.3.7 {contain en yass l~eaage ppaths;See ITS]5.5A 2) A single pen/bIation leakage rate of< 0X. L. for each containm 5 f( purge penetration;
- 3) Air lock acceptance criteria are: a) Overall air lock leakage rate is < 0.015 L, when tested at > P, b) For each door, seal leakage rate is < 0.01 La when the volume between the door seals is pressurized to > 10 psig.e. The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.f. The provisions of Specification 4.0.3 are applicable to the Containment Leakage Rate Testing Program.See ITS j 5.5]DAVIS-BESSE, UNIT I 6-21 Amendment No. 240; 276 Page 6 of 6 Attachment 1, Volume 11, Rev. 0, Page 58 of 189 Attachment 1, Volume 11, Rev. 0, Page 59 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.A02 CTS 3.6.3.1 and CTS 3.6.1.7 Actions provide requirements to be taken for each containment isolation valve that is inoperable.
The ITS includes an explicit Note (ACTIONS Note 2) that provides instructions for the proper application of the ACTIONS for ITS compliance (i.e., Separate Condition entry is allowed for each penetration flow path). This changes the CTS by providing explicit direction as to how to utilize the ACTIONS when a containment isolation valve is inoperable.
This change is acceptable because the addition of the Note reflects the CTS allowance to take the appropriate Actions on a per valve basis (the change to a penetration basis is discussed in DOC M01). This change is designated as administrative since it does not result in a technical change to the CTS.A03 CTS 3.6.3.1 does not specifically require Conditions to be entered for systems supported by inoperable containment isolation valves. OPERABILITY of supported systems is addressed through the definition of OPERABILITY for each system, and appropriate LCO Actions are taken. ITS 3.6.3 ACTIONS Note 3 states "Enter applicable Conditions and Required Actions for system(s) made inoperable by containment isolation valves." ITS LCO 3.0.6 provides an exception to ITS LCO 3.0.2, stating "When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered." This changes the CTS by adding a specific statement to require supported system Conditions and Required Actions be entered, whereas in the CTS this would be done without the Note.This change is acceptable because the addition of the ITS Note reflects the CTS requirement to take applicable Actions for inoperable systems. The ITS Note is required because of the addition of ITS LCO 3.0.6, and because the requirement to declare supported systems inoperable is being retained.
This change is designated as administrative because it does not result in any technical changes to the CTS.A04 CTS 3.6.3.1 does not include a reference to entering applicable Actions of the CONTAINMENT INTEGRITY LCO (CTS 3.6.1.1) (changed to containment OPERABILITY in the ITS). ITS 3.6.3 ACTIONS Note 4 states "Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria." This changes the CTS by explicitly stating an existing requirement that the Containment Specification Actions be taken when the Davis-Besse Page 1 of 13 Attachment 1, Volume 11, Rev. 0, Page 59 of 189 Attachment 1, Volume 11, Rev. 0, Page 60 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES Containment LCO is not met as a result of containment isolation valve leakage exceeding limits.This change is acceptable because it reinforces the existing CTS requirement to meet overall containment leakage limits. This change is designated as administrative because it does not result in any technical changes to the CTS.A05 When one or more of the containment isolation valves are inoperable, CTS 3.6.3.1 Action a requires restoring the inoperable valve(s) to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or taking one of the other specified compensatory actions. ITS 3.6.3 does not state the requirement to restore an inoperable isolation valve to OPERABLE status, but includes other compensatory Required Actions to take within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, as applicable.
This changes the CTS by not explicitly stating the requirement to restore an inoperable valve to OPERABLE status. The change in the time allowed to meet the compensatory Required Action (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) is discussed in DOCs M01 and L01.This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action and it is the convention in the ITS to not state such "restore" options explicitly unless it is the only action or is required for clarity. This change is designated as administrative because it does not result in any technical changes to the CTS.A06 CTS 3.6.3.1 Actions b and c provide the actions for inoperable containment isolation valves and include Note **, which states that the provisions of Specification 3.0.4 are not applicable.
ITS 3.6.3 does not include this Note. This changes the CTS by deleting the specific exception to Specification 3.0.4.This change is acceptable because it results in no technical change to the Technical Specifications.
CTS 3.0.4 has been revised as discussed in the Discussion of Changes for ITS Section 3.0. ITS LCO 3.0.4, in part, states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. ITS 3.6.3 ACTIONS A, B, and C require the plant to isolate the affected penetration flow path and allow operation to continue for an unlimited period of time. Therefore, because the ITS still allows the plant to change a MODE or other specified condition in the Applicability, this change is considered to be consistent with the current allowances.
This change is designated as administrative because it does not result in a technical change to the CTS.A07 CTS 3.6.3.1 Actions b and c Note ** states that selected valves may be opened on an intermittent basis under administrative control. However, the CTS Note does not specifically define what are "selected" valves. ITS 3.6.3 ACTIONS Note 1 states that penetration flow paths "except for 48 inch purge and exhaust valve penetration flow paths" may be unisolated intermittently under administrative controls.
This changes the CTS by specifically delineating which containment isolation valves cannot utilize the CTS Note allowance.
Davis-Besse Page 2 of 13 Attachment 1, Volume 11, Rev. 0, Page 60 of 189 Attachment 1, Volume 11, Rev. 0, Page 61 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES The purpose of the CTS 3.6.3.1 Actions b and c Note ** is to provide reasonable operational flexibility regarding containment penetrations.
This change is acceptable because the excluded purge and exhaust valves are precluded from being opened by CTS 3.6.1.7. CTS 3.6.1.7 requires that the purge and exhaust valves be closed in MODES 1,2, 3, and 4, the same MODES CTS 3.6.1.3 is applicable.
Thus, this addition is a clarification as to which valves can utilize the CTS 3.6.1.3 Actions b and c Note ** allowance, and is consistent with the current requirements.
This change is designated as administrative because it does not result in a technical change to the CTS.A08 CTS 4.6.3.1.3 requires the isolation time of each power operated or automatic containment isolation valve be determined to be within its limit when tested pursuant to Specification 4.0.5. ITS SR 3.6.3.5 requires verifying the isolation time of each automatic power operated containment isolation valve is within limits in accordance with the Inservice Testing Program. This changes the CTS by stating that the Frequency is in accordance with the Inservice Testing Program, in lieu of Specification 4.0.5. The change to the valves being tested is discussed in DOC L04.The purpose of CTS 4.6.3.1.3 is to verify the isolation time of each power operated or automatic containment isolation valve is tested in accordance with Specification 4.0.5, which provides the requirements for the Inservice Testing Program. This change is acceptable because the Frequencies regarding the containment isolation valves remain the same. The inservice testing requirements of CTS 4.0.5 have been moved to the Inservice Testing Program contained in Section 5.5 of the ITS. This change is designated as administrative because it does not result in a technical change to the CTS.A09 CTS 3.6.1.7 provides additional requirements for the containment purge and exhaust valves, above those required in the Containment Isolation Valve Specification, CTS 3.6.3.1. The ITS combines these two CTS Specifications into one Specification, ITS 3.6.3. This changes the CTS by deleting the specific LCO statement for containment purge and exhaust valves and combines it into the Containment Isolation Valve Specification.
The CTS 3.6.1.7 statement is an additional OPERABILITY requirement for the containment purge and exhaust valves. This change is acceptable because the two CTS Specifications have been combined into a single specification in ITS 3.6.3, and this additional containment purge and exhaust valve requirement is ensured by ITS SR 3.6.3.1, which verifies the containment purge and exhaust valves are closed with control power removed. This change is designated as administrative because it does not result in any technical changes to the CTS.MORE RESTRICTIVE CHANGES M01 CTS 3.6.3.1 Action b and c allow 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to isolate the affected penetration when one or more containment isolation valves are inoperable.
ITS 3.6.3 Required Action B.1 will only allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to isolate the affected penetration flow path when both valves in the same penetration flow path are inoperable.
This changes the CTS by decreasing the time allowed to isolate the affected Davis-Besse Page 3 of 13 Attachment 1, Volume 11, Rev. 0, Page 61 of 189 Attachment 1, Volume 11, Rev. 0, Page 62 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES penetration when both containment isolation valves in the same penetration are inoperable.
The purpose of the CTS 3.6.3.1 Action is to provide compensatory actions for inoperable containment isolation valves. However, when both valves in the same penetration are inoperable, the time allowed to isolate the affected penetration should be the same as that allowed to restore an inoperable containment, since the containment isolation valves support the leak tightness of the containment.
Therefore, this change is acceptable since the new time allowed is consistent with the time allowed when the containment is inoperable.
This change is considered more restrictive because a shorter amount of time is provided to isolate the affected penetration in the ITS than is allowed in the CTS.RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 -Removing Details of System Design and System Description, Including Design Limits) CTS 4.6.3.1.2.a requires verification of the automatic isolation of the containment isolation valves on a "containment isolation" test signal. ITS SR 3.6.3.6 does not state the specific type of signal, but only specifies an actual or simulated "actuation" signal. This changes the CTS by moving the type of actuation signal (e.g., containment isolation) to the Bases.The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that the required valve automatically actuate. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA02 (Type 1 -Removing Details of System Design and System Description, Including Design Limits) CTS 4.6.1.2.2 requires the containment purge and exhaust valve leakage rate to be within the limits specified in the Containment Leakage Rate Testing Program. CTS 6.16 provides the requirements for the Containment Leakage Rate Testing Program, and CTS 6.16.d.2 states that the leakage limits for a single containment purge penetration is < 0.15 La. ITS SR 3.6.3.5 requires performance of the containment purge and exhaust valve leakage test, but does not include the value for the leakage limit; it only requires the leakage to be within limits. This changes the CTS by moving the leakage limit to the Bases.Davis-Besse Page 4 of 13 Attachment 1, Volume 11, Rev. 0, Page 62 of 189 Attachment 1, Volume 11, Rev. 0, Page 63 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that the containment purge and exhaust valves leakage is within the limits.Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA03 (Type 3 -Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)
CTS 4.6.1.2.2 requires performance of containment purge and exhaust valve leakage rate testing, and describes that the testing is performed "by pressurizing the piping section including one valve inside and one valve outside the containment to a pressure greater than or equal to 20 psig." ITS SR 3.6.3.5 requires containment purge and exhaust valve leakage rate testing, but does not include the details on how to perform the testing. This changes the CTS by moving the details of how to perform the test to the Bases.The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that containment purge and exhaust valve leakage rate testing be performed.
Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES L01 (Category 3 -Relaxation of Completion Time) CTS 3.6.3.1 Actions b and c allows 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to isolate the affected penetration when one or more of the containment isolation valve(s) are inoperable.
ITS 3.6.3 ACTION C, which only applies to penetration flow paths with only one containment isolation valve, will allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to isolate the affected penetration when the single containment isolation valve in the penetration is inoperable.
This changes the CTS by extending the Completion Time from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when the inoperable containment isolation valve is in a single valve penetration.
The purpose of CTS 3.6.3.1 Actions b and c is to provide a degree of assurance that the penetration flow path with an inoperable containment isolation valve maintains the containment penetration isolation boundary.
This change is acceptable because the Completion Time is consistent with safe operation under Davis-Besse Page 5 of 13 Attachment 1, Volume 11, Rev. 0, Page 63 of 189 Attachment 1, Volume 11, Rev. 0, Page 64 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES the specified Condition, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the allowed Completion Time. In the case of a single valve penetration with an inoperable valve, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is a reasonable time period considering the relative stability of a system (hence, reliability) to act as a penetration isolation boundary, since it does not communicate with the containment atmosphere or reactor coolant pressure boundary (for certain valves in Type III penetrations);
the small pipe diameter of the penetration (hence, reliability) (for certain valves in Type II, III and IV penetrations);
that the valves isolate Engineered Safety Features Systems that normally operate following an accident (for most valves in Type IV penetrations);
and the relative importance of supporting containment OPERABILITY in MODES 1, 2, 3, and 4. This change is designated as less restrictive because additional time is allowed to restore the components to within the LCO limits than was allowed in the CTS.L02 (Category 4 -Relaxation of Required Action) CTS 3.6.3.1 Actions b and c state that with one or more of the containment isolation valve(s) inoperable, isolate each affected penetration by use of at least one deactivated automatic valve secured in the isolation position (Action b), closed manual valve (Action c), or blind flange (Action c). CTS 4.6.1.1 .a.1 requires a periodic verification that the affected penetration remains isolated by the same methods. When one or more penetration flow paths with one containment isolation valve inoperable, ITS 3.6.3 Required Action A.1 requires that the affected penetration flow path be isolated by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. In addition, ITS 3.6.3 Required Action A.2 requires a periodic verification that the affected penetration remains isolated by one of the methods required by ITS 3.6.3 Required Action A.1. This changes the CTS by allowing penetration flow paths with two containment isolation valves that have one containment isolation valve inoperable to use a check valve with flow through the valve secured as the means of isolating the penetration flow path.The purpose of CTS 3.6.3.1 Actions b and c and CTS 4.6.1.1 .a.1 is to provide assurance that the affected penetration flow path is isolated.
This change is acceptable because the ITS Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features.
The ITS Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. This change allows the flow path to be isolated by one check valve with flow through the valve secured. The requirement to isolate the flow path is retained, and using a check valve with flow through the valve secured is an appropriate method of isolation.
This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.L03 (Category 5 -Deletion of Surveillance Requirement)
CTS 4.6.3.1.1 describes tests that must be performed prior to returning a valve to service after maintenance, repair or replacement work is performed on the valve or its Davis-Besse Page 6 of 13 Attachment 1, Volume 11, Rev. 0, Page 64 of 189 Attachment 1, Volume 11, Rev. 0, Page 65 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES associated actuator, control or power circuit. The ITS does not include these testing requirements.
This changes the CTS by deleting this post-maintenance Surveillance.
The purpose of CTS 4.6.3.1.1 is to verify OPERABILITY of containment isolation valves following their maintenance, repair or replacement.
This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions.
Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function.
Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post-maintenance testing is required to demonstrate the OPERABILITY of the system or component.
This is described in the Bases for ITS SR 3.0.1 and required under SR 3.0.1. The OPERABILITY requirements for the containment isolation valves are described in the Bases for ITS 3.6.3. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control), provide adequate controls for test programs to ensure that testing incorporates applicable acceptance criteria.
Compliance with 10 CFR 50, Appendix B, is required under the unit operating license. As a result, post-maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary.
This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.L04 (Category 6- Relaxation Of Surveillance Requirement Acceptance Criteria)CTS 4.6.3.1.3 states that the isolation time of each "power operated or automatic" containment isolation valve shall be determined to be within its limit.In addition, CTS LCO 3.6.3.1 Note
- states that Surveillance testing of main steam isolation valves (MSIVs) MS100 and MS101 and atmospheric vent valves (AVVs) ICS1 1A and ICS1 1 B is not required prior to entering MODE 4 but shall be performed prior to entering MODE 3. ITS SR 3.6.3.4 requires verification that the isolation time of each automatic power operated containment isolation valve is within limits. Furthermore, no Note allowance similar to the CTS Note allowance is provided for the MSIVs or the AVVs. This changes the CTS by deleting the requirement to test the power operated containment isolation valves that are not automatic.
The purpose of CTS 4.6.3.1.3 is to provide assurance that automatic containment isolation valves actuate within the times assumed in the DBA analyses.
This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions.
Remote manual (i.e., non-automatic) power operated valves do not have an isolation time assumed in the DBA analyses since they require operator action. Deleting reference to power operated, non-automatic isolation valve stroke time testing reduces the potential for misinterpreting the requirements of the Surveillance Requirement while maintaining the assumptions of the accident analysis.Furthermore, since the MSIVs and AVVs are both designated as remote manual (i.e., non-automatic) containment isolation valves, the CTS Note allowance has also been deleted. This change is designated as less restrictive because less Davis-Besse Page 7 of 13 Attachment 1, Volume 11, Rev. 0, Page 65 of 189 Attachment 1, Volume 11, Rev. 0, Page 66 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.L05 (Category 6 -Relaxation Of Surveillance Requirement Acceptance Criteria)CTS 4.6.3.1.2.a requires verification of the automatic isolation of the containment isolation valves on a containment isolation "test" signal. ITS SR 3.6.3.6 specifies that the signal may be from either an "actual" or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.The purpose of CTS 4.6.3.1.2.a is to ensure that the containment isolation valves operate correctly upon receipt of an isolation signal. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions.
Equipment cannot discriminate between an "actual,""simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements.
The change also allows a simulated signal to be used, if necessary.
This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.L06 (Category 5 -Deletion of Surveillance Requirement)
CTS 4.6.3.1.2.a requires verification that each containment isolation valve actuates to its isolation position.ITS SR 3.6.3.6 requires verification that each automatic containment isolation valve "that is not locked, sealed, or otherwise secured in position" actuates to the isolation position.
This changes the CTS by excluding those automatic valves that are locked, sealed or otherwise secured in position from the verification.
The purpose of CTS 4.6.3.1.2.a is to provide assurance that the automatic valves required to actuate in case of a design basis accident (DBA) isolate containment properly.
This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions.
Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to provide confidence that the equipment can perform its assumed safety function.
Those automatic containment isolation valves that are locked, sealed, or otherwise secured in position are not required to actuate on a containment isolation signal in order to perform their safety function because they are already in the required position.Testing such valves would not provide any additional assurance of OPERABILITY.
Valves that are required to actuate will continue to be tested.This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.L07 (Category 4 -Relaxation of Required Action) CTS 4.6.1.1 .a requires verification that all non-automatic containment isolation valves that are required to be closed are closed every 31 days. If a non-automatic valve that is supposed to be closed is found open, the CTS 3.6.1.1 Action applies. CTS 3.6.1.1 Action states, in part,"Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour." ITS 3.6.3 ACTIONS A, B, and C do not Davis-Besse Page 8 of 13 Attachment 1, Volume 11, Rev. 0, Page 66 of 189 Attachment 1, Volume 11, Rev. 0, Page 67 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES differentiate between automatic and non-automatic valves and allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to isolate the affected flow path. In addition, ITS 3.6.3 ACTIONS Notes 2, 3 and 4 allow separate condition entry for each penetration flow path, require entry into the applicable Conditions and Required Actions for system(s) made inoperable by containment isolation valves, and require entry into the applicable Conditions and Required Actions for LCO 3.6.1,"Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.
This changes the CTS by providing 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to isolate a penetration flow path affected by an inoperable non-automatic containment isolation valve. This also changes the CTS by allowing separate condition entry for each penetration flow path with an inoperable non-automatic containment isolation valve, requiring entry into the applicable Conditions and Required Actions for system(s) made inoperable by inoperable non-automatic containment isolation valves, and requiring entry into the applicable Conditions and Required Actions for LCO 3.6.1, "Containment," when isolation valve leakage due to an inoperable non-automatic containment isolation valve results in exceeding the overall containment leakage rate acceptance criteria.The purpose of the CTS 3.6.1.1 Action is to ensure that overall containment leakage rate does not exceed the accident analysis assumptions.
This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features.
The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. This change makes the actions for an inoperable non-automatic containment isolation valve consistent with the actions for all other types of containment isolation valves and ensures that leakage through a penetration flow path affected by an inoperable non-automatic containment isolation valve is properly controlled.
This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.L08 (Category 6 -Relaxation Of Surveillance Requirement Acceptance Criteria)CTS 4.6.1.1.a.1 requires verification that specified containment penetrations are closed. ITS 3.6.3 Required Actions A.2 and C.2, ITS SR 3.6.3.2, and ITS SR 3.6.3.3 include similar requirements, but contain a Note that allows valves and blind flanges (i.e., isolation devices) in high radiation areas to be verified administratively.
In addition, ITS 3.6.3 Required Actions A.2 and C.2 include a second Note that allows verification of isolation devices that are locked, sealed, or otherwise secured to also be performed using administrative means. This changes the CTS by allowing certain valves and blind flanges to not require physical verification.
The purpose of CTS 4.6.1.1 .a.1 is to provide assurance that containment penetrations are closed when necessary.
This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required Davis-Besse Page 9 of 13 Attachment 1, Volume 11, Rev. 0, Page 67 of 189 Attachment 1, Volume 11, Rev. 0, Page 68 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES functions.
The position of containment isolation valves and blind flanges in high radiation areas that are required to be closed can be verified administratively in a manner not requiring physical verification.
Access to high radiation areas is limited, making access to the valves and blind flanges more difficult, and mispositioning less likely. For those isolation devices that are locked, sealed, or otherwise secured, plant procedures control their operation.
Therefore, the potential for inadvertent misalignment of these devices after locking, sealing, or securing is low. In addition, all the isolation devices are verified to be in the correct position (as required by ITS 3.6.3 Required Actions A.1, B.1, and C.1)prior to locking, sealing, or otherwise securing.
This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.L09 (Category 6 -Relaxation Of Surveillance Requirement Acceptance Criteria)CTS 4.6.1.1 .a.1 requires a verification that all penetrations not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves, secured in their positions.
ITS SR 3.6.3.2 and ITS SR 3.6.3.3 require a verification that each containment isolation manual valve and blind flange that is located outside containment (ITS SR 3.6.3.2) or inside containment (ITS SR 3.6.3.3) and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. This changes the CTS by not requiring valves locked, sealed or otherwise secured be verified closed as part of the Technical Specification Surveillance Requirements.
The purpose of CTS 4.6.1.1 .a.1 is to provide assurance that valves required to be closed are closed. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions.
Valves are verified in position prior to being locked, sealed, or otherwise secured, and are not expected to change position because other controls are placed on them by the means of securing their position.
Valves that are locked, sealed, or otherwise secured in the closed position do not require verification as part of ITS SR 3.6.3.2 or ITS SR 3.6.3.3 because these valves were verified to be in the correct position upon locking, sealing, or securing.
This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.L10 (Category 4 -Relaxation of Required Action) CTS 4.6.1.2.2 requires verification that the containment purge and exhaust valves leakage rate is within limits. If a containment purge and exhaust valve leakage rate is not within limits, the CTS 3.6.1.2 Action applies. CTS 3.6.1.2 Action states, in part, "With containment leakage rate(s) not within limit(s), restore containment leakage rate(s) within limit(s) within one hour." ITS 3.6.3 ACTION D requires the affected penetration flow path to be isolated by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (ITS 3.6.3 Required Action D.1), verification that the penetration flow path remains isolated similar to that required for an inoperable containment isolation valve (ITS 3.6.3 Required Action D.2), and performance of ITS SR 3.6.3.5 every 92 days if a resilient seal purge or exhaust valve is used to isolate the penetration flow path (ITS 3.6.3 Required Action D.3). This changes the CTS by providing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to isolate the Davis-Besse Page 10 of 13 Attachment 1, Volume 11, Rev. 0, Page 68 of 189 Attachment 1, Volume 11, Rev. 0, Page 69 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES affected penetration flow path and allowing continued operation with a containment purge or exhaust valve not meeting the leakage rate limits.The purpose of the CTS 3.6.1.2 Action is to ensure that overall containment leakage rate does not exceed the accident analysis assumptions.
This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features.
The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. This change allows continued operation with a containment purge or exhaust valve not meeting the leakage rate limits, provided the affected penetration flow path is isolated.Furthermore, the isolated penetration flow path must be periodically verified isolated, and if isolated using a purge or exhaust valve with a resilient seal, the valve must be periodically tested to ensure its leak tightness.
However, this change does not allow operation to continue if the containment purge and exhaust valve leakage results in exceeding the overall Type A or the Type C leakage limits. If this occurs, ITS 3.6.3 ACTIONS Note 4 will require the applicable Conditions and Required Actions of LCO 3.6.1, "Containment," to be entered. Thus, while in the new ACTION, the overall Type A and the Type C leakage limits are still being met. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.L11 (Category 4 -Relaxation of Required Action) CTS 3.6.1.7 provides additional requirements (above those required by CTS 3.6.3.1, the Containment Isolation Valve Specification) for the containment purge and exhaust valves. If one valve is open or power is not removed in a containment purge and/or exhaust penetration, the CTS 3.6.1.7 Action requires verifying the remaining valve in the associated penetration meets the requirements of CTS 4.6.1.7 (valve closed and power removed) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and requires closing the open valve and removing control power within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Furthermore, no actions are provided if both valves are open in a containment purge and/or exhaust penetration; thus CTS LCO 3.0.3 (which requires a unit shutdown) must be entered. ITS 3.6.3 ACTIONS A and B do not differentiate between containment purge and exhaust isolation valves and other types of containment isolation valves and allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to isolate the affected flow path. ITS 3.6.3 ACTION A provides 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to isolate the affected penetration when one valve is inoperable and ITS 3.6.3 ACTION B provides 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to isolate the penetration when both valves are inoperable.
Furthermore, ITS 3.6.3 ACTIONS A and B allow continued operation with an inoperable containment isolation valve, i.e., restoration of the inoperable valve is not required provided the associated penetration is isolated (and periodically verified isolated per ITS 3.6.3 Required Action A.2). This changes the CTS by allowing continued operation with an inoperable (due to being open or power not removed) purge or exhaust containment isolation valve provided the affected penetration is isolated and periodically verified isolated.This also changes the CTS by providing 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to isolate a penetration flow path Davis-Besse Page 11 of 13 Attachment 1, Volume 11, Rev. 0, Page 69 of 189 Attachment 1, Volume 11, Rev. 0, Page 70 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES when two containment purge and/or exhaust isolation valves in the same penetration are inoperable (due to being open or power not removed).The purpose of the CTS 3.6.1.7 Action is to ensure that the containment isolation function is maintained when a containment purge supply and/or exhaust isolation valve is inoperable.
This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features.
The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. This change makes the actions for an inoperable (due to being open or power not removed) containment purge or exhaust isolation valve consistent with the actions for all other types of containment isolation valves. Once the associated penetration is isolated as required by ITS 3.6.3 Required Actions A.1 and B.1, closure of the inoperable containment purge or exhaust isolation valve is not necessary since the isolation function has been achieved.
Furthermore, the additional time allowed to isolate the affected penetration when both containment purge and/or exhaust isolation valves are open is consistent with the time currently allowed in CTS 3.6.1.1 to restore the containment to OPERABLE status (which is the function supported by maintaining closed the containment purge and exhaust valves). This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.L12 (Category 4 -Relaxation of Required Action) CTS 4.6.1.2.1 requires verification that the containment leakage rates are within limits. CTS 6.16.d.1) includes a secondary containment bypass leakage limit. If the secondary containment bypass leakage limit is not met, the CTS 3.6.1.2 Action applies. CTS 3.6.1.2 Action states, in part, "With containment leakage rate(s) not within limit(s), restore containment leakage rate(s) within limit(s) within one hour." ITS 3.6.3 ACTION E requires restoration of secondary containment bypass leakage within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This changes the CTS by providing 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore the secondary containment bypass leakage to within the limit.The purpose of the CTS 3.6.1.2 Action is to ensure that overall containment leakage rate does not exceed the accident analysis assumptions.
This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features.
The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. As stated in the Bases for ITS 3.6.3 ACTION E, restoration of secondary containment bypass leakage to within the limit can be accomplished by isolating the penetration(s) that caused the limit to be exceeded by use of one closed and deactivated automatic valve, closed manual valve, or blind flange. When a penetration is isolated the leakage Davis-Besse Page 12 of 13 Attachment 1, Volume 11, Rev. 0, Page 70 of 189 Attachment 1, Volume 11, Rev. 0, Page 71 of 189 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. Thus, this change allows continued operation with a secondary containment bypass leakage pathway causing the combined secondary containment bypass leakage to be exceeding the leakage rate limits, provided the affected penetration flow path is isolated.
The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time for secondary bypass leakage not within limit is reasonable considering the time required to restore the leakage by isolating the penetration(s) and the relative importance of secondary containment bypass leakage to the overall containment function.
However, this change does not allow operation to continue if the secondary containment bypass leakage results in exceeding the overall Type A or the Type C leakage limits. If this occurs, ITS 3.6.3 ACTIONS Note 4 will require the applicable Conditions and Required Actions of LCO 3.6.1,"Containment," to be entered. Thus, while in the new ACTION, the overall Type A and the Type C leakage limits are still being met. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.Davis-Besse Page 13 of 13 Attachment 1, Volume 11, Rev. 0, Page 71 of 189 Attachment 1, Volume 11, Rev. 0, Page 72 of 189 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 72 of 189 Attachment 1, Volume 11, Rev. 0, Page 73 of 189 CTS I All changes are unless otherwise noted 9 Containment Isolation Valves 3.6:3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves 3.6.3.1, 3.7.1.7 LCO 3.6.3 Each containment isolation valve shall be OPERABLE.APPLICABILITY:
MODES 1, 2, 3, and 4.ACTIONS exhaust 3.6.3.1 Actions b and c Note 7 4.6.1.1.a.1 1.Penetration flow pathsljexcept for 48 inclvpurgeivalve penetration flow pathsJmay be unisolated intermittently under administrative controls.
-nment DOC A02 2. Separate Condition entry is allowed for each penetration flow path.DOC A03 3. Enter applicable Conditions and Required Actions for system(s) made inoperable by containment isolation valves.DOC A04 4. Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.CONDITION REQUIRED ACTION COMPLETION TIME A. --.-----..--
NOTE ------------
A.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Only applicable to penetration flow path by penetration flow paths use of at least one closed with two [L r moreM and de-activated automatic containment isolation valve, closed manual valve, valves, blind flange, or check valve---------
--- with flow through the valve secured.One or more penetration flow paths with one AND containment isolation valve inoperablemFor reasons other than urge valve lea ge not th limit.Condition D or E 3.6.3.1 Actions b and c, 3.6.1.1 Action, 3.6.1.7 Action 0 BV\OG STS 3.6.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 73 of 189 Attachment 1, Volume 11, Rev. 0, Page 74 of 189 CTS Containment Isolation Valves 3.6.3 ACTIONS (continued)
CONDITION REQUIRED-ACTION COMPLETION TIME A.2 ------NOTES--------
- 1. Isolation devices in high radiation areas may be verified by use of administrative means.2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.4.6.1.1.a.1 including Note Verify the affected penetration flow path is isolated.Once per 31 days for isolation devices outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment BWOG STS 3.6.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 74 of 189 Attachment 1, Volume 11, Rev. 0, Page 75 of 189 CTS I All changes are unless otherwise noted 9 Containment Isolation Valves 3.6.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. -----....NOTE-......
.Only applicable to penetration flow paths with two @or moreE containment isolation valves.B.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 3.6.3.1 Actions b One or more penetration and c, flow paths with two Mr 3.6.1.1 Action, moreM containment DOC L11 isolation valves inoperable jfor reasons other than purge alvyelCondition D orE ea not witjnimit C. ------------
NOTE ------------
Only applicable to penetration flow paths with only one containment isolation valveand a gosed.1 One or more penetration flow paths with one containment isolation valve inoperable.
C.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 0 3.6.3.1 Actions b and c, 3.6.1.1 Actions BWOG STS 3.6.3-3 Rev. 3.0, 03/31104 Attachment 1, Volume 11, Rev. 0, Page 75 of 189 Attachment 1, Volume 11, Rev. 0, Page 76 of 189 CTS Containment Isolation Valves 3;6.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C.2 --------NOTES-------
- 1. Isolation devices -in high radiation areas may be verified by use of administrative means.2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.Verify the affected Once per 31 days penetration flow path is isolated.4.6.1.1.a.1, including Note" 3.6.1.2 Action D. [One or more penetration flow paths with one or more or exhaust containment purge#-valves not within purge and exhaust valve leakage limits.D.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flangel 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 0 0 0 0 AND BWOG STS 3.6.3-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 76 of 189 Attachment 1, Volume 11, Rev. 0, Page 77 of 189 CTS Containment Isolation Valves 3.6.3 ACTIONS (continuedý CONDITION REQUIRED ACTION COMPLETION TIME D.2 ------NOTES--------
- 1. Isolation devices in high radiation areas may be verified by use of administrative means.2. Isolation devices that are locked, sealed, or otherwise secured may ,be verified by use of administrative means.Verify the affected Once per 31 days for penetration flow path is isolation devices isolated.
outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment AND[containment._ D.3 Perform SR 3. for the Once per [_days resilient seal urge~valves Sand exhaust -closed to comply with Required Action D.1.Required Action and C-".1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND F 12 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 3.6.3.1 Act 3.6.1.1 Ac 3.6.1.2 Ac 3.6.1.7 A I NSERT lion d, ction, ction, ct 100 020 0D BWOG STS 3.6.3-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 77 of 189 Attachment 1, Volume 11, Rev. 0, Page 78 of 189 3.6.3 CTS 0 INSERT I DOC L12 E. Secondary containment bypass leakage not within limit.E.1 Restore secondary containment bypass leakage to within limit.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Insert Page 3.6.3-5 Attachment 1, Volume 11, Rev. 0, Page 78 of 189 Attachment 1, Volume 11, Rev. 0, Page 79 of 189 CTS Containment Isolation Valves 316.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY I otinment 4.6.1.7 SR 3.6:3.1 MVerify each P48Einch purgeaIve is ead closed em .except for.e .purge valv in a penetra on flow with control power removed path whil in Condition Dof the LCO.31 days M 01 (D/Verify each [8] inch purg valve is closed excep when the [8] inch purge'halves are open for pressure control, ALARA or air quality considerations for perbnnel entry, or for Surveillances that req ire the valves to be op n.4.6.1.1.a.1 4.6.1.1.a.1 LCO 3.6.3.1, 4.6.3.1.3 SR 3-.6.3. --. ...-- ----- NOTE ------- .......----
3U Valves and blind flanges in high radiation areas may be verified by use of administrative means.Verify each containment isolation manual valve and 31 days blind flange that is located outside containment and not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.SR 3 ----------------------------
NOTE -----------------
Valves and blind flanges in high radiation areas may be verified by use of administrative means.Verify each containment isolation manual valve and Prior to entering blind flange that is located inside containment and MODE 4 from not locked, sealed, or otherwise secured and MODE 5 if not required to be closed during accident conditions is performed within closed, except for containment isolation valves that the previous are open under administrative controls.
92 days SR 3.6.3. Verify the isolation time of each automatic power Rln accordance operated containment isolation valve is within limits, with the Inservice Testing Program Ior9 a2-ys]l 09 0 09 0 B'AOG STS 3.6.3-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 79 of 189 Attachment 1, Volume 11, Rev. 0, Page 80 of 189 CTS Containment Isolation Valves 3,6.3 SURVEILLANCE REQUIREMENTS (continued).
SURVEILLANCE FREQUENCY 4.6.1.2.2 S R .63 Perform leakage rate testing for containment purge valves with resilient seals.exhaust 184 days 0 AND 0 Wthin 2 days after pening the INSERT 2 (2'valv 4.6.3.1.2.a SR 3ý.6.3.I Verify each automatic containment isolation valve that is not locked, sealed, or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.months 00 0 I SR 3.6.3.8 A Verify each [ ] inch coat~inment purge valve is/ [18] months blocked to restrict the vave from opening > [50;4.m INSERT 3 BWOG STS 3.6.3-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 80 of 189 Attachment 1, Volume 11, Rev. 0, Page 81 of 189 3.6.3 CTS 0 INSERT 2 4.6.1.2.2 Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each valve closure, if valve opened in MODE 1, 2, 3, or 4 AND Prior to entering MODE 4 from MODE 5 if valve opened in other than MODE 1, 2, 3, or 4 AND Prior to entering MODE 2 from MODE 3 each time the plant has been in any combination of MODE 3, 4, 5, or 6 for > 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, if not performed in the previous 184 days.0 INSERT 3 6.16.d.1)
SR 3.6.3.7 Verify the combined leakage for all secondary containment bypass leakage paths is < 0.03 La.In accordance with the Containment Leakage Rate Testing Program Insert Page 3.6.3-7 Attachment 1, Volume 11, Rev. 0, Page 81 of 189 Attachment 1, Volume 11, Rev. 0, Page 82 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.3, CONTAINMENT ISOLATION VALVES 1. The brackets have been removed and the proper plant specific information/value has been provided.2. ISTS SR 3.6.3.2 and ISTS SR 3.6.3.8 have not been adopted. The Davis-Besse design includes only the 48 inch containment purge and exhaust valves. These valves are required to be closed with control power removed and are tested in ITS SR 3.6.3.1. In addition, due to these deletions, subsequent SRs have been renumbered.
- 3. Changes made to reflect plant specific nomenclature.
- 4. The Davis-Besse Frequencies for performing the containment purge and exhaust valves resilient seal testing has been provided.
These Frequencies were approved by the NRC as documented in the NRC Safety Evaluation for Amendment 90, dated November 27, 1985.5. The term "closed system" has been deleted, since this is not a term used to describe the Davis-Besse containment isolation penetrations.
Many Davis-Besse containment penetrations contain only one isolation valve, as approved by the NRC. These penetrations are either: a) of a small diameter; b) do not communicate with either the containment atmosphere or the reactor coolant boundary; or c) are part of an Engineered Safety Features System that normally operates (thus the penetration is not isolated) during a design basis accident.
This is also consistent with the Davis-Besse current licensing basis, which provides actions for all inoperable containment isolation valves, including those valves that are in single valve penetrations.
- 6. NUREG-1430 does not include any secondary containment bypass leakage requirements.
Davis-Besse includes a specific limit on secondary containment bypass leakage. ITS 3.6.3 ACTION E and SR 3.6.3.7 have been added to address secondary containment bypass leakage. SR 3.6.3.7 requires verification that the combined secondary containment bypass leakage is < 0.03 La at a Frequency that is according to the Containment Leakage Rate Testing Program, consistent with current requirements.
ITS 3.6.3 ACTION E has been added to provide 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore secondary containment bypass leakage to within the limit. The new ACTION is consistent with the ACTION provided in the other PWR NUREGs (NUREG-1431 and NUREG-1432).
Due to this new ACTION, ISTS 3.6.3 Condition A and B have been modified to exclude secondary containment bypass leakage from those Conditions, similar to the exclusion provided for purge valve leakage. Also, similar to the PWR NUREGs, in lieu of describing the type of leakage, only the Conditions (Conditions D and E) are listed. ISTS 3.6.3 ACTION E has also been renumbered to ITS 3.6.3 ACTION F due to this new ACTION.Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 82 of 189 Attachment 1, Volume 11, Rev. 0, Page 83 of 189 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 83 of 189 Attachment 1, Volume 11, Rev. 0, Page 84 of 189 I All changes are unless otherwise noted 9 Containment Isolation Valves B 3.6.3 B 3.6 CONTAINMENT SYSTEMS B 3.6.3 Containment Isolation Valves BASES BACKGROUND The containment isolation valves form part of the containment pressure boundary and provide a means for fluid penetrations not serving accident consequence limiting systems to be provided with two isolation barriers that are closed on an automatic isolation signal. These isolation devices consist of either passive devices or active (automatic) devices. Manual valves, de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured), blind flanges, and closed systems are considered passive devices. Check valves, or other automatic valves designed to close following an accident without operator action, are considered active devices. Two barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analyses.
One of these barriers may be a closed system. These barriers (typically containment isolation valves) make up the Containment Isolation System.Containment isolati n occurs upon receipt of a Igh containment pressure or diverse contain nt isolation signal. The co tainment isolation signal closes automatic ontainment isolation valves 'n fluid penetrations not required for oper tion of engineered safeguarý systems to prevent leakage of radio ctive material.
Upon actua tin of high pressure injection, auto tic containment valves also isolate systems not required for containme or Reactor Coolant System (RCS) heat removal. Other penetrations are isolated by the use of valves in the closed position or blind flanges. As a result, the containment isolation valves (and blind flanges) help ensure that the containment atmosphere will be isolated in the event of a release of radioactive material to containment atmosphere from the RCS following a Design Basis Accident (DBA).OPERABILITY of the containment isolation valves (and blind flanges)supports containment OPERABILITY during accident conditions.
The OPERABILITY requirements for containment isolation valves help ensure that containment is isolated within the time limits assumed in the safety analysis.
Therefore, the OPERABILITY requirements provide assurance that the containment function assumed in the safety analysis will be maintained.
INSERT -1 BWOG STS B 3.6.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 84 of 189 Attachment 1, Volume 11, Rev. 0, Page 85 of 189 B 3.6.3 0 INSERT I Containment vessel isolation occurs upon receipt of an actuation signal from the Safety Features Actuation System (SFAS). Closure of the specific containment isolation valves is dependent upon the SFAS Incident Level. SFAS Incident Level 1 (either a high containment pressure or a low Reactor Coolant System (RCS) pressure) isolates the Containment Purge and Exhaust System and Sample System valves in order to prevent radiation from leaving the vessel through non-essential lines. SFAS Incident Level 2 (low RCS pressure or a high containment pressure) initiates high pressure injection and closes the Containment Isolation System 1 valves. SFAS Incident Level 3 (low-low RCS pressure or high containment pressure) closes Containment Isolation System 2 valves. SFAS Incident Level 4 (high-high containment pressure), indicating a major loss of coolant accident, closes Containment Isolation System 3 valves.Insert Page B 3.6.3-1 Attachment 1, Volume 11, Rev. 0, Page 85 of 189 Attachment 1, Volume 11, Rev. 0, Page 86 of 189 All changes are unless otherwise noted 9 Containment Isolation Valves B 3.6.3 BASES BACKGROUND (continued)
{ ,SER 2 --Reactor Building Purge:System part of the Reacto/ Building lVentilation jSysem. ThePurge Syst was designed f 'r intermittent operation, pro iding a means of rer oving airborne radii actiVity causedminor lea ge from the RCS pr* r to personnel entr into containment.
adExast)The Containment Purq e ystenn so one N48 inch line for exhaust and one M48M inch line for supply, with supply and exhaust fans capable of purging the containment atmosphere at a rate of approximately
@50,OO (7 ft 3/min. This flow rate is sufficient to reduce the airborne radioactivity Ito pemtacs ihna level within containment to levels defined in 10 CFRý 20 ORef.. 1fr a reraitnables wthinm 41- 14 hour/Workweek within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> o~lpurge initiation duringq -operatjfr.
The containment purge supply and exhaust lines each contain one located inside containment two isolation valves that recei an isolation ignal on a vent highR and one located outside 1ra-a io ono ition.containment Ir 0 t fand exhaust c ntaiment Failure of the~purge valves to close following a design basis event would cause a significant increase in the radioactive release because of the large containment leakage path introduced by these inch purge lines. 0 Failure of the purge valves to close would result in leakage considerabl 0 in excess of the containment design leakage rate of 00 D of containment air weight per day (La) (Ref. 2). Because of their large size, containment the j48q inch purge valves in ore u itslare not qualified for automatic closure from their open position under DBA conditions.
Therefore the with control a u JjMmin urgevalves are maintained se ed closedf(SR 3.6.3.1) in o ower removed MODES 1, 2, 3, and 4 to ensure the containment boundary is maintained.
The [8 inch] con inment minipurge v yves operate to: a. Reduce th concentration of no le gases within con ainment prior to and during personnel access a b. Equalize i ternal and external ressures.Since the min purge valves are de gned to meet the r quirements for automatic co tainment isolation va yes, these valves ay be opened as needed in M DES 1,2, 3, and 4.APPLICABLE The containment isolation valve LCO was derived from the assumptions SAFETY related to minimizing the loss of reactor coolant inventory and ANALYSES establishing containment boundary during major accidents.
As part of the containment boundary, containment isolation valve OPERABILITY supports leak tightness of the containment.
Therefore, the safety analysis of any event requiring isolation of containment is applicable to this LCO.BWOG STS B 3.6.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 86 of 189 Attachment 1, Volume 11, Rev. 0, Page 87 of 189 B 3.6.3 0 INSERT 2 The Containment Purge and Exhaust System is designed to provide clean fresh air to the containment vessel or to the shield building and penetration rooms. Containment vessel may be purged in MODES 5 and 6. The shield building and mechanical penetration rooms may be purged at any time.Insert Page B 3.6.3-2 Attachment 1, Volume 11, Rev. 0, Page 87 of 189 Attachment 1, Volume 11, Rev. 0, Page 88 of 189 ( All changes are 1 unless otherwise noted , o Containment Isolation Valves B 3.6.3 BASES APPLICABLE SAFETY ANALYSES (continued)
The DBAs that-result in a release of radioactive material within containment are a loss of coolant accident (LOCA), a main steam line control rod break, and .. ejection accident (Ref. 3). In the analysis for each of assembly J these accidents, it is assumed that containment isolation valves are either closed or function to close within the required isolation time following event initiation.
This ensures that potential paths to the environment through containment isolation valves (including containment purge[ andexhaust valves) are minimized.
The safety analysis assumes that the M48M inch purge valves are closed at event initiation.
The DBA analysis assumes that, within 60 seconds after the accident, isolation of the containment is complete and leakage terminated except for the design leakage rate, La. The containment isolation total response time of 60 seconds includes signal delay, iesel generator startup (for emergency loss of offsite power), and containment isolation valve stroke times.The single-failure criterion required to be imposed in the conduct of unit aea safety analyses was considered in the original design of the containment
{ and exhaust purge-valves.
Two valves in a series on eachipurgehline provide assurance that both the supply and exhaust lines could be isolated even if tnment a single failure occurred.
IThe inboard and outboard isol tion v~alves on The contaiment purge and exhaust each line are provided with diverse pawer sources, motur operated and valves are air operated spring closedm be u t c i S spneumatinly operated spring close4, respectively, Thes arrangement T"rhe a eoved f i t c c asit whc a. Again, thil urge o a Exhaustl or instrument air. I was desm lea to precluve common noe failures from cmaplisin otg cotimntbdt avaryes onaa lnurae line. s is operaste ianment'T------f urge~alves may be unable to clo .se in the environment followi'ng a LOCA. Therefore, each of the*purge~valIves is required to remain s eadl I (-cseidduring MODES 1, 2, 3, and 4. In this case, the single-failure p wthconro Icriterion remains applicable to the containment purge valves because of[.ower reEmove failure in the control circuit associated with each valve. Again,
/sAstem valve design prevents a single failure from compromising tf--containment boundary as long as the system is operated in accordance "Cnanet with the subject LCO.The containment isolation valves satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
BVVOG STS B 3.6.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 88 of 189 Attachment 1, Volume 11, Rev. 0, Page 89 of 189 I All changes are unless otherwise noted 9 Containment Isolation Valves B 3.6.3 BASES LCO Containment isolation valves form a part of the containment boundary.The containment isolation valve safety function is related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a DBA.The automatic power operated isolation valves are required to have .a.nd .haust].~inmn isolation times within limits and to actuate on an automatic isolation
.--__ _ signal. The M48MinchJ:)urge'ivalves must be maintained closed 3 (2 with control power removed ave installedjt prevent tfl eninnl Bloc ed ur e valv s also-actua on an toma si na. The valves covered by this LCO are listed along with their associated stroke times in _heFSAR (Ref. 4).The normally closed isolation valves are considered OPERABLE when manual valves are closed, check valves have flow through the valve nandsecondar ,secured, blind flanges are in place, and closed systems are intact. These xnd passive isolation valves/devices are listed in Reference[4-F4f con S leakage paths adexas1 ---leakagepat and ext urg alves with resilient seals -nust meet additional leakage rate[C~ntainment The other containment isolation valve leakage rates are addressed by LCO 3.6.1, "Containment," as Type C testing.Q This LCO provides assurance that the containment isolation valves F u ywill perform their designated safety functions to minimize the loss of reactor coolant inventory and establish the containment boundary during accidents.
APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment.
In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment isolation valves are not required to be OPERABLE in MODE 5. The requirements for containment isolation valves during MODE 6 are addressed in LCO 3.9.3, "Containment Penetrations." ACTIONS and exhaust The ACTIONS are modified by a Note allowing penetration flow paths,)except for 48M inch purgeivalve penetration flow paths, to be unisolated ncment intermittently under administrative controls.
These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for containment isolation is indicated.
Due to the size of the containment purge'line penetration and exhaust and the fact that those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow paths containing these valves may not be opened under administrative controls.
single purge valve i a penetration flow path/nay be opened to effect r pairs toW an inoperabJ valve, as allowed by 3.6.3.1./BWOG STS B 3.6.3-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 89 of 189 Attachment 1, Volume 11, Rev. 0, Page 90 of 189 B 3.6.3INSERT 3 However, the main steam isolation valves and main feedwater stop valves are not covered by this LCO. Requirements for these valves are provided in LCO 3.7.2, "Main Steam Isolation Valves (MSIVs)," and LCO 3.7.3, "Main Feedwater Stop Valves (MFSVs), Main Feedwater Control Valves (MFCVs), and associated Startup Feedwater Control Valves (SFCVs)." Insert Page B 3.6.3-4 Attachment 1, Volume 11, Rev. 0, Page 90 of 189 Attachment 1, Volume 11, Rev. 0, Page 91 of 189 Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued)
A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable , since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable containment isolation valve. Complying with the Required.Actions may allow for continued operation, and subsequent inoperable containment isolation valves are governed by subsequent Condition entry and application of associated Required Actions.The ACTIONS are further modified by a third Note, which ensures appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve.In the event isolation valve leakage results in exceeding the overall containment leakage rate, Note 4 directs entry into the applicable Conditions and Required Actions of LCO 3.6.1.A.1 and A.2)n and exhaust Scontainment
]In the event one containment isolation valve in one or more penetration flow paths is inoperable, except foripurgea yve leakage ot within limi (DO the affected penetration flow path must be isolated.
The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment containment bypass isolation valve, a closed manual valve, a blind flange, and a check valve leakage paths with flow through the valve secured. For a penetration isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment.
Required Action A.1 must be completed within the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time. The specified time period is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4.For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time and that have been isolated in accordance with Required Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic basis. This periodic verification is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of BWAOG STS B 3.6.3-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 91 of 189 Attachment 1, Volume 11, Rev. 0, Page 92 of 189 Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued) being automatically isolated will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation.
Rather,,it involves verification that those isolation devices outside containmentand capable of being mispositioned are in the correct position.
The Completion Time of "once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.
Condition A has been modified by a Note indicating this Condition is only applicable to those penetration flow paths with two Mr moreM containment (S isolation valves. For penetration flow paths with only one containment isolation valve [and a ee ssten, Condition C provides appropriate actions.Required Action A.2 is modified by two Notes. Note 1 applies to isolation devices located in high radiation areas and allows the devices to be verified by use of administrative means. Allowing verification by administrative means is considered acceptable since access to these areas is typically restricted.
Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned.
Therefore, the probability of misalignment of these devices, once they have been verified to be in the proper position, is small.B.1 and exhaust 2 With two Mor moreq containment isolation valves in one or more n3 penetration flow paths inoperable, 'xcept fo purg a ve eakageot 0 owithin limi the afecte penetration low pat must be isolated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active or secondary 2 containment bypass leakage paths BWOG STS B 3.6.3-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 92 of 189 Attachment 1, Volume 11, Rev. 0, Page 93 of 189 Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued) failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is consistent with the ACTIONS of LCO 3.6.1. In the event the affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be isolated on a periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure leak tightness of containment and that penetrations requiring isolation following an accident are isolated.
The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative controls and the probability of their misalignment is low.Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two @or moreM] containment isolation valves. Condition A of this LCO addresses the condition of one containment isolation valve inoperable in this type of penetration flow path.C.1 and C.2 With one or more penetration flow paths with one containment isolation valve inoperable, the inoperable valve must be restored to OPERABLE status or the affected penetration flow path must be isolated.
The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. A check valve may not be used to isolate the affected penetration.
Required Action C.1 must be-LD completed within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time. The specified time period is reasonable, consideringhthe relative stability of thec-esystem INSERT 4 (hence, reliability) to act as a penetration isolation bounda and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4. In the event the affected penetration is isolated in accordance with Required Action C.1, the affected penetration flow path must be verified to be isolated on a periodic basis. This periodic verification is necessary to assure leak tightness of containment and that containment penetrations requiring isolation following an accident are isolated.
The Completion Time of once per 31 days for verifying that each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative controls and the probability of their misalignment is low.BWOG STS B 3.6.3-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 93 of 189 Attachment 1, Volume 11, Rev. 0, Page 94 of 189 B 3.6.3 0 INSERT 4 , since it does not communicate with the containment atmosphere or reactor coolant pressure boundary (for certain valves in Type III penetrations);
the small pipe diameter of the penetration (hence, reliability) (for certain valves in Type II, III and IV penetrations);
that the valves isolate Engineered Safety Features Systems that normally operate following an accident (for most valves in Type IV penetrations);
Insert Page B 3.6.3-7 Attachment 1, Volume 11, Rev. 0, Page 94 of 189 Attachment 1, Volume 11, Rev. 0, Page 95 of 189 Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued)
Condition C is modified by a Note indicating that this Condition is only applicable to those penetration flow paths with only one containment isolation valve land a a_.sIoe-d-syte. ITheý closed systemn m eet h requiren-nts of Reference G. Thiý Note is necessary sire this Condition iswriftten to spcfcally address t~ose penetration flow in a closed Required Action C.2 is modified by two Notes. Note 1 applies to valves and blind flanges located in high radiation areas and allows these devices to be verified by use of administrative means. Allowing verification by administrative means is considered acceptable since access to these areas is typically restricted.
Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned.
Therefore, the probability of misalignment of these devices, once verified to be in the proper position, is small.D D.1, D.2, and D.3 In the event one or more containment purgevalves in one or more. and exhaus penetration flow paths are not within the purgeialve leakage limits, purge and exhaust valve leakage must be restored to within limits or the affected penetration flow path must be isolated.
The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a Mclosed and de-activated automatic valve, closed manual valve, and blind flangeq A purge valve with resilient seals utilized to satisfy Required Action D.1 r-Timust have been demonstrated to meet the leakage requirements of SR 3.6. ..The specified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containment does not exist. and exhaust In accordance with Required Action D.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be in the isolation position should an event occur. This BWAOG STS B 3.6.3-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 95 of 189 Attachment 1, Volume 11, Rev. 0, Page 96 of 189 Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued)
Required Action does ndttrequire any testing or valve manipulation.
Rather, it involves verification that those isolation devices outside containment and potentially capable of being mispositioned are in the correct position.
Forthe isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.
e For the containment purge&'alve with resilient seal that is isolated in &92 accordance with Required Action DA, SR 3.6.3.1 must be performed at least once everyL] days. This provides assurance that degradation of the resilient seal is detected and confirms that the leakage rate of the containment purge valve does not increase durinn the time the 2 penetration is isolated.
The normal equency for SR 3.6.3.6/184 days, Jis based on iýn N RC initiative, Genef ic Issue B-20 (Ref. 8). Since more reliance is placed on a single valve while in this Condition, it is prudent to perform the SR more often. Therefore, a Frequency of once per[]days was chosen and has been shown acceptable based on operating experience.
Required Action D.2 is modified by two Notes. Note 1 applies to isolation devices located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted.
Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned.
R__ 0 FIi~. T4Aý 0 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCO does not apply.To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.BWOG STS B 3.6.3-9 Rev. 3.0, 03131/04 Attachment 1, Volume 11, Rev. 0, Page 96 of 189 Attachment 1, Volume 11, Rev. 0, Page 97 of 189 B 3.6.3 0 INSERT4A E.1 With the combined secondary containment bypass leakage (SR 3.6.3.7) not within limit, the assumptions of the safety analyses are not met. Therefore, the leakage must be restored to within limit. Restoration can be accomplished by isolating the penetration(s) that caused the limit to be exceeded by use of one closed and deactivated automatic valve, closed manual valve, or blind flange. When a penetration is isolated the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices.The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time for secondary bypass leakage not within limit is reasonable considering the time required to restore the leakage by isolating the penetration(s) and the relative importance of secondary containment bypass leakage to the overall containment function.Insert Page B 3.6.3-9 Attachment 1, Volume 11, Rev. 0, Page 97 of 189 Attachment 1, Volume 11, Rev. 0, Page 98 of 189 I All changes are unless otherwise noted 9 Containment Isolation Valves B 3;6.3 BASES f'll ......BASES SURVEILLANCE SR 3.6.3.1 and exhaust REQUIREMENTS EachR148MJinch containment purgvalve is required to be verified se ed closedat 31 day intervals.
This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of the purge h valves faileto conclusively emonstrate their ability to close during a with control powe-rremoved LOCA in time to limit offsite doses. Therefore, these valves are required to be in the se-e closed positionrduring MODES 1, 2, 3, and 4. A containment urge valve that is s aled closed must have motive pcer to the valve oerator removedF This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator.
J-n thii~sýpplicati'on, the term "s~al~ed"Chas no connotat" on of leakI igtns. The F/fequency is a result f nNR iitiative, Gen ric:ls e ý 2 4 (Ref,/ 7, related to oo ntain rr/ent purge valve use d ~ring unit Ioperatins Inteent purge valvej Iakage requires entry ir/to ICondition D, t Surveillance permits/opening one purge .va e -a r Ipenetration f/w path to perform rep irs. ]/0 G0 0 0 0 0 SR 3.6.3.2 This SR ensure that the minipurge v Ives are closed as equired or, if open, open for n allowable reason. f a purge valve is o en in violation of this SR, the alve is considered in perable. If the ino rable valve is not otherwise nown to have excessi e leakage when cl sed, it is not considered to ave leakage outside f limits. The SR is ot required to be met when t e minipurge valves a e open for pressur control, ALARA or air quality c nsiderations for pers nnel entry, or for S rveillances that require the va yes to be open. The inipurge valves ar capable of closing in the nvironment following a LOCA. Therefor ,these valves are allowed to be open for limited perio s of time. The 31 ay Frequency is consistent wi h other containment i olation valve requir ments discussed in SR 3.6.3.3.S R 3.6.3.This SR requires verification that each containment isolation manual valve and blind flange located outside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within BWOG STS B 3.6.3-10 Rev. 3.0, 03131/04 Attachment 1, Volume 11, Rev. 0, Page 98 of 189 Attachment 1, Volume 11, Rev. 0, Page 99 of 189 Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued) design limits. This SR does not require any testing or valve manipulation.
Rather, it involves verification that those containment isolation valves outside containment and capable of being mispositioned are in the correct position.
Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions.
The SR specifies that containment isolation valves open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be in the correct position upon locking, sealing, or securing.The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position, is low.This SR requires verification that each containment isolation manual valve and blind flange that is located inside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is appropriate, since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. The SR specifies that containment isolation valves open under administrative controls are not required to meet the SR during the time they are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be in the correct position upon locking, sealing, or securing.BMVOG STS B 3.6.3-11 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 99 of 189 Attachment 1, Volume 11, Rev. 0, Page 100 of 189 Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued)
The Note allows valves and .blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the access to these areas is typically restricted during MODES 1, 2, 3, and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small.Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY.
The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses.OThe isolation time and Frequency of this SR are in accordance with the Inservice Testing Program o SR 36I and exhaust 0 00 (D)0 0 0 For containment purgevalves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, Option F[BMEis required to ensure OPERABILITY.
Operating experience has INSERT 5 demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), a Frequency of INET ---once per io4 a ys was estaolisnea a part oT tne Nrit.; r soiurion OT Generic Issue !-20, "Containment L akage Due to Seal eterioration" (Ref. 8).Additionally, s SR must be perfor d within 92 days fter opening the valve. The 92 day Frequency was hosen recognizing hat cycling the valve could in roduce additional se I degradation (grea er than that occurring to valve that has not be n opened). Thus, ecreasing the interval (fro 184 days) is a prude t measure after a v lve has been opened.BWOG STS B 3.6.3-12 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 100 of 189 Attachment 1, Volume 11, Rev. 0, Page 101 of 189 B 3.6.3 0 INSERT 5 The test is performed by pressurizing the piping section, including one valve inside and one valve outside containment, to a pressure > 20 psig. The leakage limit for each containment purge or exhaust penetration is < 0.15 La.0 INSERT 6 prior to entering MODE 2 from MODE 3 each time the plant has been in any combination of MODE 3, 4, 5, or 6 for > 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, if not performed in the previous 92 days has been established.
Additionally, if a valve is opened in MODE 1, 2, 3, or 4, this SR must be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after closing the valve. Alternately, if a valve is opened in other than MODE 1, 2, 3, or 4, this SR must be performed prior to entering MODE 4 from MODE 5. These two additional Frequencies were chosen recognizing that cycling a valve could introduce additional seal degradation.
Thus, these additional Frequencies are a prudent measure after a valve has been opened.Insert Page B 3.6.3-12 Attachment 1, Volume 11, Rev. 0, Page 101 of 189 Attachment 1, Volume 11, Rev. 0, Page 102 of 189 Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued)
SR Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. This SR is not required for valves that are locked, sealed, or otherwise secured in position under administrative controls.________8]
month Frequency is based on the need to perform this S ilance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 248] meonth Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
Q 0 S R 3.6.3.8----------
". .REVlEWE 'S NOTE--------------
This SR is onl required for those unts with resilient seal purge valves allowed to be pen during [MODE 1,/2, 3, or 4] and havi g blocking devices on th valves that are not p. rmanently installed Verifying that ea h [48] inch contain nt purge valve is bl cked to restrict opening to -< [5 k] is required to ensu e that the valves c n close under DBA conditions/
thin the times assu d in the analyses of References 3 and 4. If a LO A occurs, the purge v Ives must close to intain containment le kage within the value assumed in the a cident analysis.At other times vhen purge valves ar required to be cap ble of closing (e.g., during rwvement of [recently]
rradiated fuel asse blies), pressurizationiconcerns are not pre ent, thus the purge .alves can be fully open. Tle [18] month Frequenly is appropriate be ause the blocking devi ýes are typically remo ed only during a ref eling outage.INSRTL 0 BWOG STS B 3.6.3-13 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 102 of 189 Attachment 1, Volume 11, Rev. 0, Page 103 of 189 B 3.6.3 O INSERT 7 SR 3.6.3.7 This SR ensures that the combined leakage rate of all secondary containment bypass leakage paths is less than or equal to the specified leakage rate. This provides assurance that the assumptions in the safety analysis are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. The Frequency is required by the Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria.
Bypass leakage is considered part of La.Insert Page B 3.6.3-13 Attachment 1, Volume 11, Rev. 0, Page 103 of 189 Attachment 1, Volume 11, Rev. 0, Page 104 of 189 B 3.6.3 0 Containment Isolation Valves B 3.6.3 BASES REFERENCES
- 1. 10 CFR 20.2 *SAR, Section D3FSAR, Sectionls
[14.yand 14.-2]iýil
- 4. FSAR, [5.3] Ta62 00 5. F R, Secti n [5.3].6. St ndard R view Pla, 6.2.4.7. G neric Iss e B-24.0 I I I ..BWOG STS B 3.6.3-14 Rev. 3.0, 03/31/04 Insert Page B 3.6.3-13 Attachment 1, Volume 11, Rev. 0, Page 104 of 189 Attachment 1, Volume 11, Rev. 0, Page 105 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.3 BASES, CONTAINMENT ISOLATION VALVES 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. Changes are made to reflect changes made to the Specification.
- 3. The brackets have been removed and the proper plant specific information/value has been provided.4. This Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement.
This is not meant to be retained in the final version of the plant specific submittal.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 105 of 189 Attachment 1, Volume 11, Rev. 0, Page 106 of 189 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 11, Rev. 0, Page 106 of 189 Attachment 1, Volume 11, Rev. 0, Page 107 of 189 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.3, CONTAINMENT ISOLATION VALVES There are no specific NSHC discussions for this Specification.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 107 of 189 Attachment 1, Volume 11, Rev. 0, Page 108 of 189 ATTACHMENT 4 ITS 3.6.4, CONTAINMENT PRESSURE Attachment 1, Volume 11, Rev. 0, Page 108 of 189 Attachment 1, Volume 11, Rev. 0, Page 109 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 109 of 189 Attachment 1, Volume 11, Rev. 0, Page 110 of 189 ITS 3.6.4 ITS CONTAINMENT SYSTEMS INTERNAL PRESSURE LIMITING CONDITION FOR OPERATION 3.6.4 3.6.1.4 Primary containment internal pressure shall be maintained between +25" and -14" W.G. from/the shi/eld buildingS.
APPLICABILITY:
MODES 1, 2, 3 and 4.ACTION: LAe ACTION A ACTION B With the containment internal pressure outside of the limits above, restore the internal pressure to within the limits within l hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE REQUIREMENTS 4.6.1.4 The primary containment internal pressure shall be determined to within the limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.SR 3.6.4.1 IDAVIS-BESSE, UNIT 1 3/4 6-7 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 110 of 189 Attachment 1, Volume 11, Rev. 0, Page 111 of 189 DISCUSSION OF CHANGES ITS 3.6.4, CONTAINMENT PRESSURE ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I -Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.6.1.4 states that containment pressure be maintained between +25" and -14" water gauge, relative to the shield building.
ITS 3.6.4 includes a similar requirement, but does not specify that it is relative to the shield building.
This changes the CTS by moving the detail that the containment pressure limits are relative to the shield building to the Bases.The removal of this detail, which is related to system design, from the CTS is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.6.4 still retains a requirement to maintain containment pressure within limits. Also, this change is acceptable because these type of details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the CTS.LESS RESTRICTIVE CHANGES None Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 111 of 189 Attachment 1, Volume 11, Rev. 0, Page 112 of 189 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 112 of 189 Attachment 1, Volume 11, Rev. 0, Page 113 of 189 CTS Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure I-14 inches water g j+25 inches water gauge LCO 3.6.4 Containment pressure shall be _ [-2. psig and i 5 0i~i.3.6.1.4 0 APPLICABILITY:
ACTIONS MODES 1, 2, 3, and 4.Action Action 4.6.1.4 CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure A.1 Restore containment 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> not within limits, pressure to within limits.B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met- AND B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> BWOG STS 3.6.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 113 of 189 Attachment 1, Volume 11, Rev. 0, Page 114 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.4, CONTAINMENT PRESSURE 1. The brackets have been removed and the proper plant specific information/value has been provided.Davis-Besse Page 1 of I Attachment 1, Volume 11, Rev. 0, Page 114 of 189 Attachment 1, Volume 11, Rev. 0, Page 115 of 189 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 115 of 189 Attachment 1, Volume 11, Rev. 0, Page 116 of 189 I All changes are unless otherwise noted 9 Containment
- Pressure B 3.6.4 B3.6 CONTAINMENT SYSTEMS B 3.6.4 Containment Pressure BASES BACKGROUND The containment pressure is limited during normal operation to preserve the initial conditions assumed in the accident analyses for a loss of M Ecoolant accident (LOCA) orsteam line break SLB). These limits also prevent the containment pressure from exceeding the containment design negative pressure differential with respect to the outside atmosphere in the event of inadvertent actuation of the Containment Spray System.Containment pressure is a process variable that is monitored and controlled.
The containment pressure limits are derived from the input conditions used in the containment functional analyses and the containment structure external pressure analysis.
Should operation occur outside these limits coincident with a Design Basis Accident (DBA), post accident containment pressures could exceed calculated values.APPLICABLE SAFETY ANALYSES Containment internal pressure is an initial condition used in the DBA analyses to establish the maximum peak containment internal pressure.The limiting DBAs considered, relative to containment pressure, are the LOCA and_ LB, which are analyzed using computer pressure transients.
The worst-case LOCA generates larger mass and energy release than the worst-case LB. Thus, the LOCA event bounds the, LB event from the containment peak pressure standpoint (Ref. 1). .The initial pressure condition used in the containment analysis was (0.9 psig)p This resulted in a maximum peak pressure from aLOCAo [. psig. The LCO limit of nsures that, in the event of an accident, the design pressure of sig or containment is not 4 :(N exceeded.
In addition, the buildingý for an internal pressure (D equal to " psig above external pressure during a tornado. The H.-&conainmen._also designed for an internal pressure equal to .pstg below external pressure, to withstand the resultant pressure drop from an with the containment'
-14 inches accidental actuation of the Containment Spray Systemr. The LCO limit of vacuum breakers water gauge ensures that operation within the design limit of -" psig is limiting the pressure (-0.5 psig) maintained (Ref. 2). E p. -0'- 6 transient.
2 For certain aspects of transient accident analyses, maximizing the 2 calculated containment oressure is not conservative.
In Darticular the cooling effectiveness of the Emergency Core Cooling Systems during the core reflood phase of a LOCA analysis increases with increasing containment backpressure.
Therefore, for the reflood phase, the BVWOG STS B 3.6.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 116 of 189 Attachment 1, Volume 11, Rev. 0, Page 117 of 189 I All changes are unless otherwise noted Containment Pressure B 3.6.4 BASES IBAC ROUND (continued)
T containment backpressure is calculated .in a manner designed to APPLICABLE SAFETY ANALYSES conservatively minimize, rather than maximize, the containment pressure response in accordance with 10 CFR 50, Appendix K (Ref..L__.
Containment lressure satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
0 LCO Maintaining containment pressure less than or equal to the LCO upper pressure limit ensures that, in the event of a DBA, the resultant peak containment accident pressure will remain below the containment design C along with the containment) pressure.
Maintainin containment pressure greater than or equal to the pressure is vacuum breakers, LCO lower pressure limit ensures that the containment will not exceed the measured relative design negative differential pressure following the inadvertent actuation of to the shield the Containment Spray System. building pressure.APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment.
Since maintaining containment pressure within design basis limits is essential to ensure initial conditions assumed in the accident analysis are maintained, the LCO is applicable in MODES 1, 2, 3, and 4.In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment pressure within the limits of the LCO is not required in MODES 5 and 6.ACTIONS A.1 When containment pressure is not within the limits of the LCO, containment pressure must be restored to within these limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The Required Action is necessary to return operation to within the bounds of the containment analysis.
The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is consistent with the ACTIONS of LCO 3.6.1, "Containment," which requires that containment be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.B.1 and B.2 If containment pressure cannot be restored within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.BWOG STS B 3.6.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 117 of 189 Attachment 1, Volume 11, Rev. 0, Page 118 of 189 Containment Pressure B 3.6.4 BASES SURVEILLANCE SR 3.6.4.1 REQUIREMENTS Verifying that containment pressure is within limits ensures that operation remains within the limits assumed in the containment analysis.
The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency of this SR was developed after taking into consideration operating experience related to trending of containment pressure variations during the applicable MODES. Furthermore, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal containment pressure condition.
REFERENCES z4w FSAR, Section C- 10 CFR 50, Appendix K.2. UFSAR, Section 3.8.2.1.4.
00©(D 0 0 BWAOG STS B 3.6.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 118 of 189 Attachment 1, Volume 11, Rev. 0, Page 119 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.4 BASES, CONTAINMENT PRESSURE 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. The brackets have been removed and the proper plant specific information/value has been provided.3. Typographical error corrected.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 119 of 189 Attachment 1, Volume 11, Rev. 0, Page 120 of 189 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 11, Rev. 0, Page 120 of 189 Attachment 1, Volume 11, Rev. 0, Page 121 of 189 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.4, CONTAINMENT PRESSURE There are no specific NSHC discussions for this Specification.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 121 of 189 Attachment 1, Volume 11, Rev. 0, Page 122 of 189 ATTACHMENT 5 ITS 3.6.5, CONTAINMENT AIR TEMPERATURE Attachment 1, Volume 11, Rev. 0, Page 122 of 189 Attachment 1, Volume 11, Rev. 0, Page 123 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 123 of 189 Attachment 1, Volume 11, Rev. 0, Page 124 of 189 ITS 3.6.5 ITS jCONTAINMENT SYSTEMS AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.6,5 3.6.1.5 Primary containment-average 1200i.air Abt exceed ACTION A---ACTION B--APPLICABILITY:
MODES 1, 2, 3 and 4.ACTION: With the containment average air temperature
> 120*F, reduce the average air temperature to within the limit within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />,\or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE REQUIREMENTS 4.6.1.5 The primary containment average air temperature shall be the L arithmetical avefage of the inlet temper ture(s to the opera in containment air/cooler(s)
(1-1, 1-2, a 1-3) andisball be determined at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.3.6.5.1 DAVIS-BESSE, UNIT 1 3/4 6-8 Amendment No. So Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 124 of 189 Attachment 1, Volume 11, Rev. 0, Page 125 of 189 DISCUSSION OF CHANGES ITS 3.6.5, CONTAINMENT AIR TEMPERATURE ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 -Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)
CTS 4.6.1.5 requires verifying that the primary containment average air temperature "shall be the arithmetical average of the inlet temperature(s) to the operating containment air coolers(s)
(1-1, 1-2, and 1-3)." ITS SR 3.6.5.1 requires a similar verification, but does not state the specific method for attaining the average air temperature (i.e., the arithmetical average of specific air cooler inlet temperatures location).
This changes the CTS by moving the method of calculating the average air temperature to the Bases.The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify the containment air temperature is within limit. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES None Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 125 of 189 Attachment 1, Volume 11, Rev. 0, Page 126 of 189 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 126 of 189 Attachment 1, Volume 11, Rev. 0, Page 127 of 189 CTS Containment Air Temperature 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature 120 3.6.1.5 LCO 3.6.5 Containment average air temperature shall be %5 ýO~F.0 APPLICABILITY:
ACTIONS MODES 1, 2, 3, and 4.Action Action 4.6.1.5 CONDITION REQUIRED ACTION COMPLETION TIME A. Containment average air A.1 Restore containment 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> temperature not within average air temperature to limit, within limit.B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment average air temperature is within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit.BWOG STS 3.6.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 127 of 189 Attachment 1, Volume 11, Rev. 0, Page 128 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.5, CONTAINMENT AIR TEMPERATURE
- 1. The brackets have been removed and the proper plant specific information/value has been provided.Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 128 of 189 Attachment 1, Volume 11, Rev. 0, Page 129 of 189 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 129 of 189 Attachment 1, Volume 11, Rev. 0, Page 130 of 189 Containment Air Temperature B 3.6.5 B 3.6 CONTAINMENT SYSTEMS B 3.6.5 Containment Air Temperature BASES BACKGROUND The containment structure serves to contain radioactive material, which may be released from the reactor core following a Design Basis Accident:(DBA). The containment average air temperature is limited during normal operation to preserve the initial conditions assumed in the accident m analyses for a loss of coolant accident (LOCA) orsteam line break ISLB).The containment average air temperature limit is derived from the input conditions used in the containment functional analyses and the containment structure external pressure analysis.
This LCO ensures that initial conditions assumed in the analysis of a DBA are not violated during unit operations.
The total amount of energy to be removed UR(he L ontainment
ýooling System during post accident conditions is dependent upon the energy released to the containment due to the event as well as the initial containment temperature and pressure.
The higher the initial temperature, the higher the resultant peak containment pressure and temperature.
Exceeding containment design pressure may result in leakage greater than that assumed in the accident analysis.Operation with containment temperature in excess of the LCO limit violates an initial condition assumed in the accident analysis.0 0 0 APPLICABLE SAFETY ANALYSES Containment average air temperature is an initial condition used in the DBA analyses.
Average air temperature is also used to establish the containment environmental qualification operating envelope.
The limit for containment average air temperature ensures that operation is maintained within the assumptions used in the DBA analysis for containment.
Several accidents (primarily LOCA and4SLB) result in a marked increase in containment temperature and pressure due to energy release within the containment.
Of these, the LAesults in the greatest sustained increase in containment temperature.
By maintaining containment air temperature at less than the initial temperature assumed in the analysis, th reactor/building design condition will not be exceeded.containment 0 0 0 I he LUUA hat wa -'dentitiea as presenting tne grepKest challenge to containment OPEABILITY was a cold leg React Coolant System break, of spetified size, at a reactor coolant pLjrp suction.0 0)Containment a $ir,4mperature satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
BVVOG STS B 3.6.5-1 Rev. 3.0, 03131/04 Attachment 1, Volume 11, Rev. 0, Page 130 of 189 Attachment 1, Volume 11, Rev. 0, Page 131 of 189 Containment Air Temperature B 3.6.5 BASES LCO During a DBA, with an initial containment average air temperature less than orequal to the LCO temperature limit, the resultant accident temperature profile assures that the containment structural temperature is maintained
'below its design temperature and that required safety related equipment will continue to perform its function.APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material tocontainment.
In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment average air temperature within the limit is not required in MODE 5 or 6.ACTIONS A.1 When containment average air temperature is not within the limit of the LCO, it must be restored within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This Required Action is necessary to return operation to within the bounds of the containment analysis.
The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time is acceptable considering the sensitivity of the analysis to variations in this parameter and provides sufficient time to correct minor problems.B.1 and B.2 If the containment average air temperature cannot be restored to within its limit within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.BVVWG STS B 3.6.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 131 of 189 Attachment 1, Volume 11, Rev. 0, Page 132 of 189 Containment Air Temperature B 3.6.5 BASES SURVEILLANCE REQUIREMENTS SR 3.6.5.1 Verifying that containment average air temperature is within the LCO limit ensures that containment operation remains within the limit assumed for the containment analyses.
In order to determine the containment averaae air temperature, an arithmetic average is calculated usin-peratinginecontainm en t m eatr~irtcoesh
..1e measurements ta n at locations within the containrp~
t sel~ete to (ie,1-1, 1-2, ad-3. Iprovide a repro sentative sample of the overall cog.erainment atmosphere.
The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency of this SR is considered acceptable based on observed slow rates of temperature increase within containment as a result of environmental heat sources (due to the large volume of containment).
Furthermore, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal containment temperature condition.
0 REFERENCES None.BWOG STS B 3.6.5-3 Rev. 3.0, 03/31104 Attachment 1, Volume 11, Rev. 0, Page 132 of 189 Attachment 1, Volume 11, Rev. 0, Page 133 of .189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.5 BASES, CONTAINMENT AIR TEMPERATURE 1, Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2, Changes made to be consistent with the Specification.
3, Grammatical error corrected.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 133 of 189 Attachment 1, Volume 11, Rev. 0, Page 134 of 189 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 11, Rev. 0, Page 134 of 189 Attachment 1, Volume 11, Rev. 0, Page 135 of 189 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.5, CONTAINMENT AIR TEMPERATURE There are no specific NSHC discussions for this Specification.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 135 of 189 Attachment 1, Volume 11, Rev. 0, Page 136 of 189 ATTACHMENT 6 ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS Attachment 1, Volume 11, Rev. 0, Page 136 of 189 Attachment 1, Volume 11, Rev. 0, Page 137 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 137 of 189 ITS Attachment 1, Volume 11, Rev. 0, Page 138 of 189 3/4.6,2DEPRESSURIZAT7ON AND COOLING SYSTEMS ITS 3.6.6&DWEN SPRY YM4 LIMITING CONDITION FOR OPERATION LCO 3.6.6 3.6.2.1 Two in ependent ntainmet spray systems shall be OPERABLE eachsystem of taking suction from O~e BWST on a contanment spy actuation L0 Isignal and m iually transferring suction to l containment emergency sup during the Irecir, ulatiog phase of operatin//
APPLICABILITY:
MODES 1, 2,3 and 4.ACTION: ACTION A With one containment spray system inoperable, restore the inoperable spray system to OLQPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 ACTION B Sors; restore e inoperabe spray system to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> SrVbEin COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. A02propo~sed ACIND4Dd rpseCIN SURVEILLANCE REQUIREMENTS SR 3.6.6.1 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE: a. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed or otherwise secured in position, is in its correct position.b. At least once each REFUELING INTERVAL, by: SR 3.6.6.6 SR 3.6.6.7 1. Verifying that each automatic position on a looaipAent spn 2. Verifying that ewah spray pump DAVIS-BESSE, UNIT I 3146-11 Amendment No. 36,213, 253 Page 1 of 3 Attachment 1, Volume 11, Rev. 0, Page 138 of 189 Attachment 1, Volume 11, Rev. 0, Page 139 of 189 ITS 3.6.6 ITS Revised by NRC Letter Dated June 6, 1995 CONTAINMENT SYSTEMS SURVEILgLANCE REOUIREMENTS (Continued)
C. Deleted d. At least once pr 0 ears by performing an aik or smoke flow :13I test through e ch spray header and verifying each spray nozzle is unobstructed.
SR 3.6.6.8 Add proposed SR 3..6.31 M0 1 DAVIS-BESSE, UNIT 1 3/4 6-12 Amendment No. %0%,196 Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 139 of 189 Attachment 1, Volume 11, Rev. 0, Page 140 of 189 IITS 3.6.6 IT__SS CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM LIMITING CONDITION FOR OPERATION/ / .(LA01)LCO3.6.6 3.5.2.2 At east tqo inde endent containment cooling units shall be OPERABLE.APPLICABILITY:
MODES 1, 2 F 3/. @ACTION: I day L03 ACTION C W~th one of the above required containment cooling unif erable, rtore at least two units- to QPE-RABLE status within f2/ our [r be ii M02)ACTION F %H1T1nnwN within the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />.i 1 ACTIO FrpsdATO 0 Add proposed ACTION E L03* I ~1Add proposed ACTION" SURVEILLANCE REQUIREMENTSA0 4.6.2.2 At least the above required containment cooling units shall be demonstrated OPERABLE: a. At least once per 31 days on a STAGGERED TEST BASIS by: I. Starti g (unless alreadyiperating) each k.it from the- LA04 contr I room, and)SR3.6.6.2
- 2. Verifying that each unit operates for at least 15 minutes.SR3.6.6.4
- b. At least once per 18 months by verifying that each unit starts automatically Ion 10 speed] upon receipt of a S AS test signal.actual or L02 actuation LA02 LA04 4 Add proposed SRý 3.6.6.5 M0 DAVIS-BESSE, UNIT 1 3/4 6-13 Page 3 of 3 Attachment 1, Volume 11, Rev. 0, Page 140 of 189 Attachment 1, Volume 11, Rev. 0, Page 141 of 189 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.A02 The CTS 3.6.2.1 Action provides the actions when one containment spray train is inoperable and the CTS 3.6.2.2 Action provides the actions when one containment cooling train is inoperable.
However, no specific actions are provided when both a containment spray train and a containment cooling train are inoperable.
ITS 3.6.6 ACTION D limits the time one containment spray train and one containment air cooling train are concurrently inoperable to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.This changes the CTS by specifically delineating the actions when a containment spray train and a containment air cooling train are concurrently inoperable.
ITS 3.6.6 combines the Containment Spray and Containment Air Cooling Systems requirements into a single Specification.
The CTS 3.6.2.2 Action time to restore an inoperable containment cooling train to OPERABLE status is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. When a containment spray train and a containment air cooling train are concurrently inoperable, ITS 3.6.6 ACTION D provides 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one of the two inoperable components to OPERABLE status. Thus, the proposed time is identical to the current time under similar conditions; this proposed Action is needed since the ITS has changed the allowed restoration time for an inoperable containment air cooling train to 7 days. This change is designated as administrative since it does not result in any technical changes to the CTS.A03 CTS 3.6.2.1 does not provide an Action for two containment spray trains inoperable and CTS 3.6.2.2 does not provide an Action for two containment cooling trains inoperable.
Thus, CTS LCO 3.0.3 would be required to be entered.In addition, CTS 3.6.2.1 nor CTS 3.6.2.2 provide an Action for any combination of three or more containment spray and containment cooling trains inoperable.
Thus, CTS LCO 3.0.3 would also be required to be entered when this occurs.ITS 3.6.6 ACTION G requires immediate entry into ITS LCO 3.0.3 when two containment spray trains are inoperable or any combination of three required containment spray and air cooling trains are inoperable.
This changes the CTS by providing a specific ACTION for two inoperable containment spray trains and for any combination of three inoperable required containment spray and containment air cooling trains.The purpose of ITS 3.6.6 ACTION G is to require immediate entry into ITS LCO 3.0.3 when two containment spray trains are inoperable or any combination of three required containment spray and containment air cooling trains are inoperable.
If two containment spray trains or two containment air cooling trains were inoperable, then CTS LCO 3.0.3 would be entered because there is no other Action in CTS 3.6.2.1 or 3.6.2.2 that fits these conditions.
This Davis-Besse Page 1 of 6 Attachment 1, Volume 11, Rev. 0, Page 141 of 189 Attachment 1, Volume 11, Rev. 0, Page 142 of 189 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS change is acceptable because this same action is required in the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES M01 ITS SR 3.6.6.5 requires verifying each required containment air cooling train cooling water flow rate is > 1150 gpm every 24 months. ITS SR 3.6.6.3 requires verifying each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head in accordance with the Inservice Testing Program. The CTS does not include these Surveillance Requirements.
This changes the CTS by adding two new Surveillance Requirements.
The purpose of ITS SR 3.6.6.5 is to ensure the cooling water flow rate to the air cooling unit assumed in the accident analysis can be achieved.
The purpose of ITS SR 3.6.6.3 is to ensure the containment spray pump performance has not degraded during the cycle. These changes are acceptable since these two new Surveillances help ensure the OPERABILITY of the Containment Air Cooling and Containment Spray Systems. These changes are designated as more restrictive because Surveillance Requirements are being added to the ITS that are not required by the CTS.M02 CTS 3.6.2.2 requires two containment cooling units be OPERABLE in MODES 1, 2 and 3. The CTS 3.6.2.2 Action also requires the unit to be shut down to HOT SHUTDOWN (MODE 4) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if an inoperable containment cooling train is not restored to OPERABLE status within the allowed restoration time.ITS 3.6.6 requires two containment air cooling trains be OPERABLE in MODES 1, 2, 3, and 4. ITS 3.6.6 ACTION F requires the unit to be shut down to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if the inoperable containment air cooling trains are not restored within the allowed restoration time.This changes the CTS by requiring the containment cooling trains to be OPERABLE in MODE 4 and providing actions to exit this new Applicability.
The purpose of CTS 3.6.2.2 is to provide requirements for the containment cooling trains in order to maintain containment peak temperature below the design limits. This change is acceptable because a DBA in MODE 4 could cause an increase in containment temperature, requiring operation of the containment air cooling trains. Requiring the containment air cooling trains to be OPERABLE in MODE 4 provides a means to remove the heat, and is consistent with the Applicability requirements for the Containment Spray System in CTS 3.6.2.1.Furthermore, due to this change, the MODE the unit must enter if a containment air cooling train is not restored has been changed to be consistent with the new Applicability.
The time to reach this new MODE is consistent with the time to reach this new MODE in other Actions in the CTS and ITS. This change is designated more restrictive because the containment air cooling trains are now required to be OPERABLE in MODE 4.Davis-Besse Page 2 of 6 Attachment 1, Volume 11, Rev. 0, Page 142 of 189 Attachment 1, Volume 11, Rev. 0, Page 143 of 189 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 -Removing Details of System Design and System Description, Including Design Limits) CTS 3.6.2.1 states that two "independent" containment spray systems shall be OPERABLE "with each spray system capable of taking suction from the BWST on a containment spray actuation signal and manually transferring suction to the containment emergency sump during the recirculation phase of operation." CTS 3.6.2.2 states that two "independent" containment cooling units shall be OPERABLE.
ITS 3.6.6 requires two containment spray trains and two containment air cooling trains to be OPERABLE, but does not include the details of what constitutes OPERABILITY.
This changes the CTS by moving the detail that the trains must be "independent" and the description of the capability of the containment spray trains (i.e., taking suction from the BWST on a containment spray actuation signal and manually transferring suction to the containment emergency sump during the recirculation phase of operation) to the Bases.The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that two containment spray trains and two containment air cooling trains shall be OPERABLE.
Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA02 (Type I -Removing Details of System Design and System Description, Including Design Limits) CTS 4.6.2.1 .b.1 requires verification of the automatic actuation of containment spray valves on a "containment spray" test signal and CTS 4.6.2.1 .b.2 requires the containment spray pumps automatically start on a"SFAS" test signal. CTS 4.6.2.2.b requires each containment cooling unit starts on receipt of a "SFAS" test signal. ITS SR 3.6.6.6, SR 3.6.6.7, and SR 3.6.6.4 do not state the specific type of signal, but only specify an actual or simulated"actuation" signal. This changes the CTS by moving the type of actuation signal (e.g., SFAS) to the Bases.The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that appropriate equipment actuates upon receipt of an actuation signal.Also, this change is acceptable because the removed information will be Davis-Besse Page 3 of 6 Attachment 1, Volume 11, Rev. 0, Page 143 of 189 Attachment 1, Volume 11, Rev. 0, Page 144 of 189 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS adequately controlled in the ITS Bases. Furthermore, the containment spray signal identified in CTS 4.6.2.1.6.1 is an SFAS signal, thus this will be the signal identified in the Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA03 (Type 3 -Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)
CTS 4.6.2.1.d states to perform "an air or smoke flow test through each spray header" to verify each spray nozzle is unobstructed.
ITS SR 3.6.6.8 states to verify each spray nozzle is unobstructed.
This changes the CTS by moving the details of how to perform the test to the Bases.The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that spray nozzles are verified unobstructed.
Also, this change is acceptable because these types of procedural details will be adequately controlled the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LA04 (Type 3 -Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)
CTS 4.6.2.2.a.1 requires each containment cooling train be started (unless already operating) from the control room every 31 days.CTS 4.6.2.2.b requires verification that each containment cooling train starts "on low speed" upon receipt of an SFAS test signal. ITS SR 3.6.2.2 requires each containment air cooling train be operated for > 15 minutes, but does not specify it be started from the control room. ITS SR 3.6.2.5 requires each containment air cooling train be started on an actuation signal, but does not specify it be started on low speed. This changes the CTS by moving the detail that the trains are started from the control room and started automatically in low speed to the Bases.The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that each containment cooling train be operated and be automatically started. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled.
This change is designated as a less restrictive removal of Davis-Besse Page 4 of 6 Attachment 1, Volume 11, Rev. 0, Page 144 of 189 Attachment 1, Volume 11, Rev. 0, Page 145 of 189 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES L01 (Category 5 -Deletion of Surveillance Requirement)
CTS 4.6.2.1 .b.1 requires verification that each automatic containment spray valve in the flow path actuates to its correct position.
ITS SR 3.6.6.6 requires verification that each automatic containment spray valve in the flow path "that is not locked, sealed, or otherwise secured in position" actuates to the correct position.
This changes the CTS by excluding those valves that are locked, sealed, or otherwise secured in position from the verification.
The purpose of CTS 4.6.2.1 .b.1 is to provide assurance that if an event occurred requiring containment spray valves to be in their correct position, then those requiring automatic actuation would actuate to their correct position.
This change is acceptable because the deleted Surveillance is not necessary to verify that the equipment used to meet the LCO can perform its required functions.
Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to provide confidence that the equipment can perform its assumed safety function.
Those automatic valves that are locked, sealed, or otherwise secured in position are not required to actuate on a containment spray actuation signal in order to perform their safety function because they are already in the required position.
Testing such valves would not provide any additional assurance of OPERABILITY.
Valves that are required to actuate will continue to be tested. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.L02 (Category 6 -Relaxation Of Surveillance FRequirement Acceptance Criteria)CTS 4.6.2.1.b.1 and 4.6.2.1.b.2 require verification of the automatic actuation of containment spray components on a containment spray or SFAS (respectively)"test" signal. CTS 4.6.2.2.b requires each containment cooling unit be verified to start automatically upon receipt of a SFAS "test" signal. ITS SR 3.6.6.6, SR 3.6.6.7, and SR 3.6.6.4 specify that the signal may be from either an "actual" or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.The purpose of CTS 4.6.2.1 .b.1 and 4.6.2.1 .b.2 is to ensure the containment spray components operate correctly upon receipt of an actuation signal. The purpose of CTS 4.6.2.2.b is to ensure the containment cooling units operate correctly upon receipt of an actuation signal. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions.
Equipment cannot discriminate between an "actual," "simulated," or"test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements.
This change is designated as less restrictive because less Davis-Besse Page 5 of 6 Attachment 1, Volume 11, Rev. 0, Page 145 of 189 Attachment 1, Volume 11, Rev. 0, Page 146 of 189 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.L03 (Category 4 -Relaxation of Required Action) When one containment cooling train is inoperable, the CTS 3.6.2.2 Action provides 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable containment cooling train to OPERABLE status. CTS 3.6.2.2 does not provide an Action for two containment cooling trains inoperable.
Thus, CTS LCO 3.0.3 would be required to be entered, and a unit shutdown commenced.
When one containment air cooling train is inoperable, ITS 3.6.6 ACTION C allows 7 days to restore the inoperable containment air cooling train to OPERABLE status. With two containment air cooling trains inoperable, ITS 3.6.6 ACTION E will allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one inoperable containment air cooling train prior to requiring a unit shutdown.
This changes the CTS by allowing 7 days to restore an inoperable containment air cooling train when one train is inoperable and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one of two inoperable containment air cooling trains prior to requiring a unit shutdown.The purpose of CTS 3.6.2.2 is to require sufficient containment cooling to ensure the containment temperature conditions for the safety analyses are met. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features.
The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. When one containment air cooling train is inoperable, the remaining OPERABLE containment air cooling train and containment spray trains can still provide 150%of the required peak cooling capacity during the post accident conditions.
When both trains of containment air cooling are inoperable, the remaining containment spray trains can still provide 100% of the required peak cooling capacity during the post accident conditions.
This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.Davis-Besse Page 6 of 6 Attachment 1, Volume 11, Rev. 0, Page 146 of 189 Attachment 1, Volume 11, Rev. 0, Page 147 of 189 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 147 of 189 Attachment 1, Volume 11, Rev. 0, Page 148 of 189 CTS Containment Spray andCooling Systems 3:6:6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling Systems 0 0 0 3.6.2.1, 3.6.2.2 LCO 3.6.6 Two containment spray trains and two containmentd'ooing trains shall be OPERABLE.APPLICABILITY:
MODES 1, 2, 3., and 4.3.6.2.1 Action 3.6.2.1 Action 3.6.2.2 Action DOC A02 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray 0j7Jdays train inoperable.
train to OPERABLE status.B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met.B.2 Be in MODE 5. 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> C. One equired@J C.1 Restore equired ir 7 days[ ontain3 entscooling containmentSE6oiing train to train inoperable.
OPERABLE status.D. One containment spray D.1 Restore containment spray 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> train and one~requireca train to OPERABLE status.containment~cooling train inoperable.
OR D.2 Restore requiredl r-)containmenticooling train to OPERABLE status.0 01 0 0 0 BVVOG STS 3.6.6-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 148 of 189 Attachment 1, Volume 11, Rev. 0, Page 149 of 189 CTS Containment Spray ando ng Systems 3.6:6 0 DOC L03 3.6.2.2 Action DOC A03 4.6.2.1.a 4.6.2.2.a.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. Tworequiredj E.1 Restore one frequiredM ai 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Scontainmentcooling containment oling train to[ý]trains inoperable.
OPERABLE status.F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition Cr DA AND not met. _J not F.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G. Two containment spray G.1 Enter LCO 3.0.3. Immediately trains inoperable.
OR Any combination of three or more trains d inoperable.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power 31 days operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.SR 3.6.6.2 Operate each [equired~containmenting train 31 days>215 minutes.0 0 (O0 00 BWOG STS 3.6.6-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 149 of 189 Attachment 1, Volume 11, Rev. 0, Page 150 of 189 CTS Containment Spray and Cooling Systems 3.6.6 0 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY DOC M01 SR Verify each requiredJ containment*'lng train cooling water flow rate is _O g 00O 24 months 0 IL DOC M01 4.6.2.1.b.1 4.6.2.1.b.2 4.6.2.2.b 4.6.2.1.d SR 3.6.6.J] Verify each containment spray pump's developed In accordance head at the flow test point is greater than or equal to with the Inservice the required developed head. Testing Program 0 SR 3.6.6.t] Verify each automatic containment spray valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.months SR 3.6.6. Verify each containment spray pump starts T-E] automatically on an actual or simulated actuation signal.months 00 00 000 SR 3.6.6.T Verify each containment4,ooling train starts automatically on an actual or simulated actuation signal.j1 80 months L SR 3.6.6.8 Verify each spray nozzle is unobstructed.
[At first ref eling]ANDD st 10 years 0 BVVOG STS 3.6.6-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 150 of 189 Attachment 1, Volume 11, Rev. 0, Page 151 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS 1. The brackets have been removed and the proper plant specific information/value has been provided.2. Typographical error corrected.
- 3. The Surveillances have been put in the correct order based on their frequency.
- 4. Change made to the ITS which reflects plant specific nomenclature.
- 5. ISTS SR 3.6.6.3 requires the cooling water flow rate of the containment cooling trains to be verified every 31 days. Davis-Besse does not currently require this test.This flow rate is currently verified at a refueling outage interval during performance of the Service Water System flow balance. The test verifies that the design basis flow rates are delivered to all safety related loads, which includes the containment air coolers. The test requires the installation of precision M&TE at various locations to support obtaining the required flow rates for the safety related loads simultaneously under design basis flow rate conditions.
As such, it is appropriate for the cooling water flow rate to the containment air coolers to be verified at a 24 month Frequency.
- 6. Change made to be consistent with the use of the word "required" in other Conditions in ISTS 3.6.6.Davis-Besse Page 1 of I Attachment 1, Volume 11, Rev. 0, Page 151 of 189 Attachment 1, Volume 11, Rev. 0, Page 152 of 189 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 152 of 189 Attachment 1, Volume 11, Rev. 0, Page 153 of 189 All changes are unless otherwise noted Containment Spray and o~oling Systems B 3.6.6 B 3.6 CONTAINMENT SYSTEMS B 3.6.6 Containment Spray and oding Systems BASES F (CAC)BACKGROUND The Containment Spray and Containmen cooiin stems provide containment atmosphere cooling to limit post accident pressure and temperature in containment to less than the design values. Reduction of containment pressure and the iodine removal capability of the spray reduces the release of fission product radioactivity from containment to the environment, in the event of a Design Basis Accident (DBA), to within []limits. The Containment Spray and Containment Cooling Aystems are designed to meet the requirements of 1IO0CFR 50, Appendix ,,GDC 38, UFSAR, Appendices "Containment H at Removal," GDC 39, 'Inspection of Conta* ment Heat 3D.1.34.3D.1.35.
Removal Systefts," GDC 40, "Testing o Containment Heat emoval 3D.1.36. 3D.1.37, Systems," GD 41, "Containment Atm sphere Cleanup," G C 42, 3D.1.38, and 30.1.39 "Inspection of )ontainment Atmospher Cleanup Systems and GDC 43, Test ng ~~~~ofCntainmen tM Atophere ileanuo Systs (Ref1)-h'-
documents/that were appropriate at toe time of licensing (idontified on a unit speci c basis .Th ontainmentfCooling System and-ontainment Spray System are dSafety Featur(ESF) systems. They are designed to ensure S that teheatred .vlcta that the heat removal capability required during the post accident period can be attained.
The Containment Spray System and Cooling System provide redundant containment heat removal operation.
The Containment Spray System and Containment Gooling System provide redundant methods to limit and maintain post accident conditions to less than the containment design values.Containment Spray System independent The Containment Spray System consists of two separate rains of equal capacity, each capable of meeting the design basis. Each train includes eei a containment spray pump, spray headers, nozzles, valves, and piping.Each train is powered from a separate bus. The borated water storage tank (BVST) supplies borated water to the Containment Spray System during the injection phase of operation.
In the recirculation mode of operation, Containment Spray System pump suction is manually transferred from the BWST to the containment ump.emergency BWOG STS B 3.6.6-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 153 of 189 Attachment 1, Volume 11, Rev. 0, Page 154 of 189 Containment Spray.and4Cing Systems B 3.6.6 0 BASES BACKGROUND (continued)
The Containment Spray System provides a spray of relatively cold borated water lmixed withsbdium hydroxid efrom the spra additive tankýinto the upper regions of containment to reduce the containment pressure and temperature and to reduce the concentration of fission products in the containment atmosphere during a DBA. In the recirculation mode of operation, heat is removed from the containment sump water by the decay heat removal coolers. Each train of the Containment Spray System provides adequate spray coverage to meet the system design requirements for containment heat removal.0 The Containment
ýpray System is actuated autcqmetic-ally by a high pire~ssnure sig al and a low pressure signal. An automatic actuation opens the Containment Spray System pump dischargqe valves and starts the two Containment Spray System/pumps.
MA manual actuation of the Containment Spray System requires the operator to actuate two separate switches on the main control board to begin the same sequence.J Co nta inrmen nlinr stem Air The Containmenticooling System consists of three containment cooling triscon _ected to a common suction header 'ith four verticalI D2 return air ýuct .. Each cooling train is equipped with des ers cooling coils, and an axial flow fan driven by a two speed er ooedelectric motor. [Each unit corection (two per unit) to the common hea er is INSERT 3 rovided with a backressure damper for isolatiq'n purposes.
I During normal operation, two containment cooling trains are required to op0erate.
The third unit is on standby and isolated from the operating units by means of th ac ssure dampers. The swing unit lis equi ed wi ja transteptw tc .It can be manually placed to either the "A" rr "B" Tr train to operate in case one of the operating units fails. Upon receipt of Train 2 an emergency signal, the Rj operating cooling fans running at high speed will automatically7
.The two cooling unit fans connected to theýý-Q-- buses will automatically restart and run at g speed, provided normal or emergency power is available. In post accident operation following an actuation signal, the Containment 4 O.Cooling System fans are designed to start automatically in slow speed if they are not already running. If they are running at high (normal) speed,[the fans au tically stop and res n slow speed The fans are 1 operated at the o ! r peed during accident conditions to prevent motor overload from the higher density atmosphere.
slow control power is interrupted causing the fans to trip out of normal high speed.At the same time a slow speed start is initiated.
A 5 second time delay is initiated to permit fan coastdown prior to being restarted in slow speed.BWOG STS B 3.6.6-2 Rev. 3.1, 12/01105 Attachment 1, Volume 11, Rev. 0, Page 154 of 189 Attachment 1, Volume 11, Rev. 0, Page 155 of 189 B 3.6.6 O INSERT 1 In the event of a loss of coolant accident (LOCA), high containment pressure or low Reactor Coolant System pressure will actuate a Safety Features Actuation System (SFAS) level 2 trip to open the spray isolation valves. High-high containment pressure will actuate an SFAS level 4 signal to start the two containment spray pumps. During switchover of spray suction from the BWST to the containment emergency sump, the containment spray isolation valves are automatically throttled to a position that ensures there is adequate net positive suction head (NPSH) available for the containment spray pump.INSERT 2 that draw air from the containment atmosphere and discharge into a common supply plenum O INSERT 3 The Containment Air Cooling System ductwork required to remain intact following a loss-of-cooling accident consists of the portions of the discharge air ductwork that extend between the containment air cooler fans and the backdraft dampers, upstream of the supply plenum.Insert Page B 3.6.6-2 Attachment 1, Volume 11, Rev. 0, Page 155 of 189 Attachment 1, Volume 11, Rev. 0, Page 156 of 189 Containment Spray and+ong Systems Q B 3.6.6 BASES Air APPLICABLE The Containment Spray System and Containmentcoo ling System limitr_2 SAFETY the temperature and pressure that could be experienced following a ANALYSES DBA The limiting DBAs considered are the loss of coolant accident the team line break. The postulated DBAs are analyzed, with regard to containment ESF systems, assuming the loss of one bus. This is the worst-case single active failure, resulting in one train of the Containment Spray System and one train of the ContainmentCooling System being inoperable.
The analysis and evaluation show that, under the worst-case scenario, 38 the highest peak containment pressure isý[~pýSig (experienced during K a LOCA). The analysis shows that the peak containment temperature is-*[--2 F (experienced during a JLQCAF. I1otn r sults are less tpan the1 0 I desighlalues./J(See the Bases for LCO 3.6.4, "Containment Pressure," and LCO 3.6.5. "Containment Air Temperature," fora d ed 4i LOApeak pressr _ .ý -,0t......LOCA p r discusson.)
The~analyses and evaluations assume a power level of 012 8] MV~ft, one containment spray train and one containment cooling train operating, and initial (pre-accident) conditions of lO]OF and2 1 psig [17. psi .The analyses also assume a response time delayed initiation to provide conservative peak calculated containment pressure and temperature responses.
The effect of an mnadiertent containment spray actuatio has been analyzed.
An inad ?rtent spray actuation results in a .5] psig containment pressre drop and is associated with th sudden cooling effect in the inte or of the leak tight containment.
ditional discussion is provided in the/Bases for LCO 3.6.4.The modeled Containment Spray System actuation from the containment analyses is based on a response time associated with exceeding the containment pressure High-High setpoint coincident with a high pressure injection signal to achieve full flow through the containment spray nozzles. The Containment Spray System total response time of gen c (
includes+diesel generator
ý?G) startup (for loss of offsite -(power), block loading of equipment, containment spray pump startup, and CE spray line filling (Ref. 2).ContainrL in'niooling train performance for post accident conditions is containment air 5 given in Reference
- 3. The result of the analysis is that eachtrain can cooling provide,__/o of the required peak cooling capacity during the post accident condition.
The train post accident cooling capacity under varying containment ambient conditions, required to perform the accident analyses, is also shown in Reference 4.BWOG STS B 3.6.6-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 156 of 189 Attachment 1, Volume 11, Rev. 0, Page 157 of 189 B 3.6.6 (0 INSERT 4 An analysis of the containment vessel negative pressure transient due to inadvertent operation of one train of the Containment Spray System has been performed for various spray water temperatures.
A conservative spray flow rate of 2100 gpm has been assumed to account for pump run-out with the containment vessel at ambient pressure.
The transient pressure response of the containment vessel was analyzed for the following two cases: 35°F spray water with eight vacuum breakers operational, and; 60°F spray water with six vacuum breakers operational.
The analysis demonstrated that the number of vacuum breakers required to prevent the containment vessel from exceeding its external pressure loading design value (0.67 psig) is sensitive to spray (BWST) water temperature.
For BWST water temperatures below 60OF a minimum of eight operational vacuum breakers out of the ten installed would protect the containment vessel from external pressure loadings that exceed the design value. When BWST water temperature exceeds 60°F only six operational vacuum breakers would be needed.Insert Page B 3.6.6-3 Attachment 1, Volume 11, Rev. 0, Page 157 of 189 Attachment 1, Volume 11, Rev. 0, Page 158 of 189 Containment Spray andooling Systems (0 B 3.6.6 BASES APPLICABLE SAFETY ANALYSES (continued)
The modeled Containment-ooling System actuation from the containment analysis is based on a response time associated with Air exceedin the containment pressure high setpoint to achieve full Containmen ooling System air and safety grade cooling water flow.The Containmen ooling System total response time ofh seconds includes signal delay,40G startup (for loss of offsite power), and service water pump startup times (Ref. 3).The Containment Spray System and the Containmentooling9ystem satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO During a DBA, a minimum of one containmentcooling train and one (containment spray train are required to maintain the containment peak pressure and temperature below the design limits. Additionally, one containment spray train is required to remove iodine from the containment atmosphere and maintain concentrations below those assumed in the safety analysis.
To ensure that these requirements are met, two eL (containment spray trains and two containment~cooling units must be 0 OPERABLE.
Therefore, in the event of an accident, the minimum requirements are met, assuming the worst-case single active failure occurs.Each dontainment Opray typically includes a spray pump, spray headers, nozzles, valves, piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the BWST upon an JEna e Safety Features Actuation System signal and manually (D transferring suction to the containmen sump. aci i[ emegenc air cooling train emnergency Each ,ontainment Cooling typicaly includes ersters cooling coils, dampers, an axial flow fan driven by a two speed e coo e electrical motor, instruments, and controls to ensure an OPERABLE flow path.APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature, requiring the operation of the containment spray trains and containment ooling trains.In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these "------- D MODES. Thus, the Containment Spray System and the Containment (3 Cooling System are not required to be OPERABLE in MODES 5 and 6.BWOG STS B 3.6.6-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 158 of 189 Attachment 1, Volume 11, Rev. 0, Page 159 of 189 Containment Spray andCoElng Systems (0 B 3.6.6 BASES ACTIONS A.1 With one containment spray train inoperable, action must be taken to restore it to OPERABLE status In this condition, the remaining OPERABLE containment spray train is adequate to perform the heat removal function.
However, the overall reliability is reduced because a single failure to the remaining containment spray train could result in loss of spray function.
Ther7lJday Completion Time is reasonable to ()perform corrective maintenance on the inoperable containment spray train. TheRj7Eday Completion Time is based on the findings of the D deterministic and probabilistic analysis in Reference
- 5. Reference 5 concluded that extendin the Completion Time toR7M days for an 0 inoperable containment spray trai pro es plant operational flexibility (while simultaneously reducing overall plant risk. This is because the risks incurred by having the containment spray train unavailable for a longer time at power will be substantially offset by the benefits associated with avoiding unnecessary plant transitions and by reducing risk during plant shutdown operations.
B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time to attempt restoration of the containment spray train and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.C. 1 remaining OPERABLE1 With one of the required containment olintins inoperable, the containment spray and inoperable containmentlcooling train must be restored to OPERABLE---, air cooling trains status within 7 days. Th comp mentslin this degraded condition provide (D)iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident.
The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and System and the low probability of a DBA 0 occurring during this period.BWOG STS B 3.6.6-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 159 of 189 Attachment 1, Volume 11, Rev. 0, Page 160 of 189 Containment Spray androoling Systems 0 B 3.6:6 BASES ACTIONS (continued)
D.1 and D.2 either one containment With one containment spray and one train a or inoperableone of the required containmentqcooling trains must be remaining train restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The mpnents in this OPERABLE degraded condition provide iodine removal capabilities and are capable of containment providing at least 100% of the heat removal needs after an accident.
The spray and air 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time was developed taking into account the cooling trains redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containmenticooling System, the iodine 3 removal function of the Containment Spray System, and the low probability of a DBA occurring during this period.E.1 With two of the required containmenti gtrains inoperable, one of the 0 remaining OPERABLE required containmentkc.ooling trains must be restored to OPERABLE containment spray trains status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Th camp nents in this degraded condition (both , spray trains are OPERABLE or else Condition G is entered) provideremoval capabilities and are capable of providing at least 100% of the heat removal needs after an accident.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time was developed taking into account the redundant heat removal Air ca abilities afforded by combinations of the Containment Spray System and Containment ooling System and the low probability of a DBA 0 occurring during this period.F.1 and F.2 If the Required Actions and associated Completion Times of Condition C, D, or E of thi LCO are not met, the plant must be brought to a MODE in 0 which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.G.1 With two containment spray trains or any combination of three or more containment spray and containrnentkcooling trains inoperable, the unit is (D (in a condition outside the accident analysis.
Therefore, LCO 3.0.3 must be entered immediately.
BWOG STS B 3.6.6-6 Rev. 3.1, 12101/05 Attachment 1, Volume 11, Rev. 0, Page 160 of 189 Attachment 1, Volume 11, Rev. 0, Page 161 of 189 Containment Spray and ong Systems B 3.6.6 0 BASES SURVEILLANCE REQUIREMENTS SR 3.6.6.1 Verifying the correct alignment for manual, power operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths will exist for Containment Spray System operation.
This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing, or securing.
This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This SR does not require any testing or valve manipulation.
Rather, it involves verification, through a system walkdown, that those valves outside containment and capable of potentially being mispositioned are in the correct position.Initiating from the control room nSi 3.6.6.2 (if not already operatig) and.Operating each @requiredq containment~cooling train for> 15 minutes ensures that all trains are OPERABLE and that all associated controls are functioning properly.
It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The 31 day Frequency was developed considering the known reliability of the fan units and controls, the two train redundancy available, and the low probability of a significant degradation of the containment cooling trains occurring between surveillances and has been shown to be acceptable through operating experience.
00 Move to after SR 3.6.6.4 on Page B 3.6.6-8 SR 3.6.6H Verifying that each requiredE containmentcooling train provides an 11¢50[ essen al rawwater cooling flow rate of -> 1 0pm o each cooling uni provides assurance that the Fegn flow rate assumed in the safety analyses will be achieved (Ref.4). II He Frequency Khas eve ope ('She 24 month Frequenc is -considering the kno reliability of the Cooling Wa er System the two based on the need to redundancy av ilable, and the low probability of a significant perform this Surveilltance Idegradation of flow'occurring between surveillan
_.s.during a plant ou~tage, J 7 --S R 3.6.6.]0}00 10 0o Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal tests of centrifugal pump performance required by the ASME Code (Ref. 6). Since the Containment Spray System pumps cannot be tested with flow through the BWVOG STS B 3.6.6-7 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 161 of 189 Attachment 1, Volume 11, Rev. 0, Page 162 of 189 Containment Spray andCooling Systems B 3.6.6 0 BASES SURVEILLANCE REQUIREMENTS (continued) spray headers, they are tested on recirculation flow. This test confirms one point on the pump design curve and is indicative of overall performance.
Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance.
The Frequency of this SR is in accordance with the Inservice Testing Program.6 Move SR 3.6.6.5 S ...adS ..to here from 3.6.6. SR 3.6.6 Page B 3.6.6-7 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulatediactuation signal. This SR is not required for valves that are locked, sealed, or otherwise secured in position under administrative controls.
The [l__znnthý-ý Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that these components 24 usually pass the Surveillances when performed at the [1 ]_onth Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
0 0 0 SR 3.6.6.air This SR requires verification that each cooling w e train actuatesýpon receipt of an actual or simulated ctuation signal.The r18M month Frequency is based on engineering judgment and has been shown to be acceptable through operating experience.
ISee SR 3.6.6.5 and S 3.6.6.6, above, for further discuission of the basis forI the [18) month F equency.SR 3.6.6.8 With the containment spray header isolated and drained of any solution, low pressure air or smoke can be blown through test connections.
Performance of this Surveillance demonstrates that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded.
Due to the passive nature of the design of the nozzles, a test at 1[the first r gefueTgi and ati 10 year intervals is considered adequate to detect obstruction of the spray nozzles.(D 02 0D 0 BWOG STS B 3.6.6-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 162 of 189 Attachment 1, Volume 11, Rev. 0, Page 163 of 189 Containment.Spray andooling Systems B 3.6.6 0 BASES REFERENCES 1.2.. FSAR, Section 3. FSAR, Section 4 FSAR, JSectioq [14.2] Figure 62-26 0 00 00 00 5. BAW-2295-A, Revision 1, Justification for Extension of Allowed Outage Time for Low Pressure Injection and Reactor Building Spray Systems.6. ASME Code for Operation and Maintenance of Nuclear Power Plants.BVWOG STS B 3.6.6-9 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 163 of 189 Attachment 1, Volume 11, Rev. 0, Page 164 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.6 BASES, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. The brackets have been removed and the proper plant specific information/value has been provided.3. Changes are made to reflect the Specification.
- 4. Editorial change made to be consistent with other similar Bases statements.
- 5. Changes are made to reflect changes made to the Specification.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 164 of 189 Attachment 1, Volume 11, Rev. 0, Page 165 of 189 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 11, Rev. 0, Page 165 of 189 Attachment 1, Volume 11, Rev. 0, Page 166 of 189 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.6, CONTAINMENT SPRAY AND AIR COOLING SYSTEMS There are no specific NSHC discussions for this Specification.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 166 of 189 Attachment 1, Volume 11, Rev. 0, Page 167 of 189 ATTACHMENT 7 ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP)STORAGE Attachment 1, Volume 11, Rev. 0, Page 167 of 189 Attachment 1, Volume 11, Rev. 0, Page 168 of 189 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 11, Rev. 0, Page 168 of 189 Attachment 1, Volume 11, Rev. 0, Page 169 of 189 ITS 3.6.7 ITS EAMRGENCY CORE COOLING SYSTFOR S EmO SBS-YSTEMS
-T-v;ý28E LCO 3.6.7 LNMITIG CONDMTON FOR OPERATION 3.5.2 Two independent EdCS subsystems shall be OPERABLE with each subsystem comprised of: a. One OPERABLE high pressure injection (HPI) pump, *b. One OPERABLE low pressure injection (LPl) pump, c. One OPERABLE decay heat cooler, and d. An OPERABLE flow path capable of taking suction from the borated water storage tank (BWS7)on a safety injection signal and manually transfring suction to the containment sump during the recircultion phase of operatin I A BLITY: MODES 1, 2 and 3[-See ITS ]3.5.2]See ITS 3.5.2 L.5.ION: / [Add proposed ACTIONS A and B a. With oe HPI train inoperable, restore the inoperable HPI train to OPERABLE status within 72 hom or be in HOT SH[7IDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.L With one LPI train or its associated decay heat cooler inoperable, restore the inoperable equipment to OPERABLE status within 7 days or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.c. In dhe event the EOCC is actuated and ibjects water into the Reator Coolant System, a Special Reqpot ,hall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the c of the actuation and the total accumulated actuation cycles to date.SURVEILLANCE REQUIREMENTS 4-5.2 Each ECC subsystem shall be demonstrated OPERABLE: a. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed or otherwise secured in position, is in its correct position.An exeption applies to the IHPI pumps for the purpose of conducting Restart Test Plan inspection afivles. Ths exception is valid during the ongoing Thirteenth Refueling Outage for entries into MODE 3 from MODE 4. Under this erception, neither HPI train is required to be capable of taking suction from the LPI trains when aligned for containment sump recirculation.
The HPI trains will otherwise be OPERABLE.
Operation in MODE ) orMODE 2 while relying upon the provisions of this exception is prohibited DAVIS-BESSE, UNIT I 3/4 5-3 Amendment No. 36,182, 253, 257 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 169 of 189 Attachment 1, Volume 11, Rev. 0, Page 170 of 189 ITS 0 ITS 3.6.7 Revised by HK Letter Dated June 6, 1995 StiRVEILLANCE REQUIREPNRTS (ContinuedQ
- b. At least once each REFUELING INTERVAL, or prior to operatiOn after ECCS piping has been drained by verifying that the ECCS piping is full of water by venting the ECCS pump casings and discharge piping high points.c. By a visual inspection which verifies that no loose debris (raps, trash, clothing, etc.) Is present In the containment which could be transported to the containment emergency sump and cause restriction of the pup suction during LOCA conditions.
This visual inspection shall be performed:
I. For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and 2. For a11 areas of containment affected by an entry, at least once daily while work is ongoing and again during the final exit after completion of work (containment closeout) when CONTAIIMIENT INTEGRITY is established.
See ITS 3 .5.2 SR 3.6.7.1 d. At least once each REFUELING INTERVAL by: 1. Verifying that the interlocks:
a) Close DH-11 and D1H-12 and deenengize the pressrizeaI ineatersjif either e)H-11 or uti-11 is open am a simulated reactor coolant system.pressure.which is greater than the Allowable alue (<328, psig) is applied. The Interlock to close DH-i. anor 011-12 is not required if the valve is closed and 480 V AC power is disconnected from its motor operators.
b) Prevent the opening of DH-11 and DH-19 iamen a simulated or actual reactor coolant system pressure which is greater than the Allowable Value (08 psig)Is applied. """.2. a) A visual inspection of the containment emergenCY sump which verifies'that the ubsystem suction-Inlets are not restricted by debris and that the sumP (trash racks scteens, etc.) show no evidence of structural distress or corrosion.
b) Verifying that on a Borated Water Storage Tank (BWST Low-Low Level interlock trip, with the motor operators for the BVST outlet isolation valves and the containment emergency sump recirculation valves energized, the BRST Outlet Valve HV-DFI7A (HV-M)178) automticall close in ;7S seconds after" the operator manually .pushes the control switch to open the Containment Emergency Sump Valve HV-DH9A (HV-13IgB) which should be verified to open in s75 seconds.See ITS 3.5.2 See ITS 3.4.14[-See ITS]3.5.2.3. Deleted DAVIS-BESSE.
UNIT 1 3/4 S-4 Amendment No. 136v Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 170 of 189 Attachment 1, Volume 11, Rev. 0, Page 171 of 189 ITS 3.6.7 ITS EMERGENCY CORE COOLING SYSTEMS S YRVEILLANCE PEOQUJIMENTS (ContinLed)
.I TSP storage baskets contained SR 3.6.7.1 4.. Verifying thata minimum of"290 cubic feet of trisodium volume is within limits LC .. phosphate dodecahydrate (TSP) is contained within the TSPJ LCO .6. storage baskets. F 5. Deleted 6. Deleted e. At least once each REFUELING INTERVAL, by I. Verifying that each automatic valve in the flow path actuates to its correct position on a safety injection test signal.2. Verifying that each B-PI and LPI pump starts automatically upon receipt of a SFAS test signal.f. Deleted g. By verifying the correct position of each mechanical position stop for valves DH-14A and DH-14B.I .Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following completion of the opening of the valves to their mechanical position stop or following completion of maintenance on the valve when the LPI system is required to be OPERABLE.2. At least once each REFUELING INTERVAL.See ITS 1 3.5.2 DAVIS-BESSE, UNIT I 3/4 5-5 Amendment No.'20,26,40, t:91,207,21-5,2-6, 263 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 171 of 189 Attachment 1, Volume 11, Rev. 0, Page 172 of 189 0 ITS 3.6.7 ITS EMERGENCY CORE COOLING STSTDE ECCS SUBSYSTEY
-TF LIMITING CON'OITION FOR OPERATION 3.5.3 As a minimum, one ECCS subsystem cprised of the following shall be OPERABLE: a. One OPERABLE decay heat (DH) puap, b. One OPERABLE DH cooler, and c. An OPERABLE flow path capable of taking suction from the borated water storage tank (BWST) and manually transferring suction to the containment emergency swip during the recirculatlon phase of operation.
See ITS ]3.5.3 APPLICABILITY:
MODE 4.ACTION: a. With no ECCS subsystem OPERABLE because of the inoperability of the OH pump, the DH cooler or the flow path from the BWST, restore at least one ECCS subsystem to OPERABLE status within one hour or Laintain the Reactor Coolant System Tavg less than 280°F by use of alternate heat removal methods.b. In the event the ECCS is actuated and injects water into the reactor coolant system, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the-total accumulated actuation cycles to date.See ITS 3..5.I LO (Add proposed ACTIONS A and B Y eir""I I plier SR 3.6.7.1, LCO 3.6.7 4.5.3 The ECCS subsystems shall be de-nstrzted applicable Surveillance Requirecnts of 4.5.2.OPERABLE per .the Amendment No. ae; 57 DAVIS-BESSE.
UmIT 1 3/4 5-6 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 172 of 189 Attachment 1, Volume 11, Rev. 0, Page 173 of 189 DISCUSSION OF CHANGES ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP) STORAGE ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1,"Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 3 -Relaxation of Completion Time) CTS 3.5.2 provides requirements for the ECCS when in MODES 1, 2, and 3. CTS 4.5.2.d.4 requires the TSP storage baskets contain > 290 ft 3 of TSP. If this Surveillance is not met, CTS 3.5.2 does not provide any Actions. Thus, CTS LCO 3.0.3 would be required to be entered. CTS LCO 3.0.3 provides 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate action and requires the unit to be placed in HOT STANDBY (MODE 3) within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN (MODE 4) within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.CTS 3.5.3 provides requirements for the ECCS when in MODE 4. CTS 4.5.3 requires the ECCS subsystems to be demonstrated OPERABLE per the applicable Surveillance Requirements of CTS 4.5.2. Thus, for the required ECCS subsystems to be OPERABLE in MODE 4, CTS 4.5.2.d.4 must be met.Since there are no Actions provided in CTS 3.5.3 when the TSP baskets are not within the limit of CTS 4.5.2.d.4, CTS LCO 3.0.3 must also be entered. CTS LCO 3.0.3 requires the unit to be placed in COLD SHUTDOWN (MODE 5) within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.6.7 provides the requirements for the TSP baskets. In the ITS, when the TSP storage baskets contain < 290 ft 3 of TSP, ITS 3.6.7 Condition A is entered. ITS 3.6.7 Required Action A.1 provides 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the TSP baskets to > 290 ft 3 of TSP. If the required TSP volume is not restored, ITS 3.6.7 ACTION B requires the unit to be shut down to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. This changes the CTS by allowing 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the TSP baskets to within the limits and, if not restored, allows 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> for the unit to be placed in MODE 5.Davis-Besse Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 173 of 189 Attachment 1, Volume 11, Rev. 0, Page 174 of 189 DISCUSSION OF CHANGES ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP) STORAGE The purpose of CTS 4.5.2.d.4 is to ensure adequate TSP is in the TSP baskets to assist in reducing the iodine fission product inventory in the containment atmosphere resulting from a design basis loss of coolant accident (LOCA). This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features.
The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. During this period of time, at least one train of the Containment Spray System would still be available as specified in LCO 3.6.6 and would remove some iodine from the containment atmosphere in the event of a LOCA. Furthermore, it would be extremely unlikely for no TSP to be in the baskets; thus the pH in the containment emergency sump would still be close to the required limits necessary to retain the removed iodine in solution.
This change is designated as less restrictive because less stringent Completion Times are being applied in the ITS than were applied in the CTS.Davis-Besse Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 174 of 189 Attachment 1, Volume 11, Rev. 0, Page 175 of 189 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 175 of 189 CTS Attachment 1, Volume 11, Rev. 0, Page 176 of 189 All changes are a unless otherwise noted TSP Storage Sprdy Addiive S stemn 3.6.7 3.6 CONTAINMENT SYSTEMS Trisodium Phosphate Dodecahydrate (TSP) Storage 3.6.7 ISpr ,Addive S temr 3.6.7 jSTSP storage baskets shall contain > 290 ft 3 of TSP 4.5.2.d.4.
4.5.3 LCO 3.6.7 The PSpray Aoditive Systepi shall be qPERABLEýAPPLICABILITY:
MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A. Spra/ Addiive Sy tern TSP storage baskets ] ý ino°erable/
/ I contain < 290 ftV of TSP.A.1 Restore Spray ýdditive S9ys-t e/to OP AL Istat s.nf n~72 hours TSP storage baskets to > 290ft' of TSP.DOC L01 B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND B.2 Be in MODE 5. 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> Q 0D BWOG STS 3.6.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 176 of 189 Attachment 1, Volume 11, Rev. 0, Page 177 of 189 CTS TSP Storage Spriy Add ive S stem 3.6.7 0 SURVEILLANCE RE UIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.7.4 Verify each spray additive utomatic valve in the [18] months flow path actuates to the c rrect;position on an actual or simulated actuati n signal.SR 3.6.7.5 Verify Spray Additive Sys em flow [rate] from each 5 years solution's flow path.0 BWOG STS 3.6.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 177 of 189 Attachment 1, Volume 11, Rev. 0, Page 178 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP) STORAGE 1. The manner in which iodine fission product inventory is reduced at Davis-Besse is utilizing trisodium phosphate dodecahydrate in baskets. Therefore, ITS 3.6.7 has been modified based on this design.2. Deleted Surveillances not relevant to the TSP storage baskets. This is consistent with the Davis-Besse current licensing basis and design.Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 178 of 189 Attachment 1, Volume 11, Rev. 0, Page 179 of 189 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 11, Rev. 0, Page 179 of 189 Attachment 1, Volume 11, Rev. 0, Page 180 of 189 All changes are unless otherwise noted"age Spray Additive SQstem B 3.6.7 B 3.6 CONTAINMENT SYSTEMS Trisodium Phosphate Dodecahydrate B 3.6.7 ISpr4 Add ive S ter (TSP) Storage BASES BACKGROUND Th pra Addite Sy em isla subsystem of the Containment Spray STSP storage System that assists in reducing the iodine fission product inventory in the baskets are containment atmosphere resulting from a Design Basis Accident.(DBA).
TSPstorage The Containment Spray System andlSpr Add ive S stem perform no function during normal operations.
In the event of an accident such as a loss of coolant accident (LOCA), however, the. Spray Ad Rddiive System. will tISRT 1 t be automaticolly actuated high containment pre/ sure signal by the-EngineeredSafety Features Actuation System. /Radioiodine in its various forms is the fission product of primary concern in the evaluation of a DBA. It is absorbed by the spray from the containment atmosphere.
To enhance the iodine absorption capacity of the spray, the spray solution is adjusted to an alkaline pH that promotes iodine hydrolysis, in which iodine is converted to nonvolatile forms.Podium hydro We (NaOH), becau~e of its stability en expose t radiation and/elevated temperat e, is the preferre spray additive.The spray e tank is designed a d located to permi gravity draining into the Contain ent Spray System. th Containment pray System pumps initially ke suction from the orated water stora e tank (BWST)via two indepe dent flow paths. Th spray additive tan has a common header that sp its and feeds each of the Containment S ray System suction lines. he system is design d to inject at a rat commensurate with the drain ng rate of the BWST o that all borated ter injected is mixed with N OH.TSPstorage" baskets Th ltow -te 1s pyoportlled tc provide a spray solution with a pH 7.0 and8.0wihbetween 4.h aof .U (Ref. 1). This r alkalinity was established theandt8 ofW recirculationhours of not only to aid in removal of airborne iodine, but also to minimize the corrosion of mechanical system components that would occur if the acidic borated water were not buffered.
The pH r-ago also considers the environmental qualification of equipment in containment that may be subjected to the spray.APPLICABLE The containment ISpra, Addit ie yem is essential to the effective TSP storage SAFETY removal of airborne iodine within containment following a DBA. baskets are ANALYSES Following the assumed release of radioactive materials into containment, the containment is assumed to leak at its design value following the accident.
The analysis assumes that most of the containment volume is covered by the spray.BVAOG STS B 3.6.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 180 of 189 Attachment 1, Volume 11, Rev. 0, Page 181 of 189 B 3.6.7 O INSERT 1 the containment emergency sump will flood to a level above the TSP storage baskets. This level of water will dissolve the TSP in the storage baskets and mix with the containment emergency sump water.O INSERT 2 The function of the TSP contained in baskets located in the containment normal sump and on the 565 ft elevation of containment adjacent to the normal sump, is to neutralize the acidity of the post-LOCA borated water mixture during containment emergency sump recirculation.
The borated water storage tank (BWST) borated water has a nominal pH of approximately 5.0. A pH of 7.0 is assumed for the containment emergency sump for iodine retention and removal post-LOCA by the containment spray system.Insert Page B 3.6.7-1 Attachment 1, Volume 11, Rev. 0, Page 181 of 189 Attachment 1, Volume 11, Rev. 0, Page 182 of 189 I All changes are 1 unless otherwise noted 9 TSP Storage Spr y Addiive S stem B 3.6.7 0 BASES APPLICABLE SAFETY ANALYSES (continued)
The DBA respo se time assumed fo the Spray Additiv System is the same as for th Containment Spray ystem and is dis ussed in the Bases for LC0 3.6.6, "Containment Spray and Cooliný Systems.'The DBA ana es assume that on train of the ContEinment Spray SysterrlSpra Additive System is i operable and that the entire spray additive tank olume is added to t e remaining Cont inment Spray System flow ath.In the evaluation of the worst-case LOCA, the safety analysis assumed that an alkaline containment spray effectively reduced the airborne iodine.Each Contain mnt Spray System su ion line is equippeq with its own gravity feed fro the spray additive nk. Therefore, in t e event of a single failure the Spray Additive System (i.e., su on valve failure), NaOH will stillbe mixed with the bo ated water, establi hing the alkalinity essential to effective iodine removal. 1 TSP Storage The pr' Aive semisatisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO TSPstoraoge Thepra ite emi necessary to reduce the release of baskets are radioactive material to the environment in the event of a DBA. Iýýe contained in the TSP storage considerLýhe volume land c~ncentrat n ot thee spray baskets (_290 ft') is a Eive solytion n')6st e: sufficient Ito/provide NaUH injectioninto te--spayfow until he Containment Spr.py System suction path/is switchc ol tihe BpS to the containment/sump and to raise the average spray ime argincludesj solution pH to a level conducive to iodine average spray.solution pH i~lbetv/een
[7/2 and/11.nil This pH range maximizes the (D effectiveness of the iodine removal mechanism without introducing conditions that may induce caustic stress corrosion cracking of mechanical system components.
In ddition, it is essentia t at va ves in the Spray Addiyve ,ystem flow pat s are properly positione and that automatic vales are capable of a ivating to their correct pysitions.
APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive C-onta-inment material to containment requiring the operation of the4Sprayi-A-j ei baskts 1 Sste epr A ve stem assist@ in reducing the iodine fission product inventory prior to release to the environment.
In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Thus, the ISpra/ AdditOe Sysfem isI not required to be TSP storage baskets are OPERABLE in MODES 5 and 6.BWVOG STS B 3.6.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 182 of 189 Attachment 1, Volume 11, Rev. 0, Page 183 of 189 I All changes are unless otherwise noted J TSP Storage Spr y Add ye S m B 3.6.7 0 BASES ACTIONS A.1 TSP storage baskets FTSP storage With th containrnent Spray Ad tive Systerr/1noperable], the sWem must lbaskets rnt within 1 be restored to IOPERABLE statusI thin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The pH adjustment of- wit i the Containment Spray System for corrosion protection and iodine removal enhancement is reduced in this Condition.
The Containment Spray System would still be available and would remove some iodine from the containment atmosphere in the event of a DBA. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ED1ý;Completion Time takesinto account Rhe red ndant floW path a iaiiie along with i the low probability of the worst-case DBA occurring during this period.B.1 and B.2 within the limit STSP storage fthl pra/ Ad ive Sstem cannot be restored to K)PERABLE-status baskets within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time TSP storage for restoration of thep.Spr49 Addove S stem and is reasonable when baskets considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.0 SURVEILLANCE REQUIREMENTS SR 3.6.7.1 Verifying the co rect alignment of spr y additive manual, ower operated, and automatic alves in the spray ad itive flow path prov des assurance that the syste is able to provide ad itive to the Contain nt Spray System in the vent of a DBA. This R does not apply t valves that are locked, sealed or otherwise secure in position, since t ese valves were verified to be i the correct position rior to locking, sea ing, or securing.This SR also oes not apply to valv s that cannot be in dvertently misaligned, s ch as check valves. his SR does not r quire any testing or valve man* ulation. Rather, it in olves verification t at those valves outside con inment capable of po entially being misp sitioned are in the correct positi'bn.
0 , [INSERT 3 BWOG STS B 3.6.7-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 183 of 189 Attachment 1, Volume 11, Rev. 0, Page 184 of 189 B 3.6.7 O INSERT 3 To reduce the potential for post-LOCA iodine re-evolution from the water in the containment emergency sump, the containment spray must be an alkaline solution.
Since the BWST contents are normally acidic, the TSP storage baskets must provide sufficient volume of TSP to adjust the pH for all water injected.
The minimum required volume of TSP is the volume that will achieve a post-LOCA borated water mixture pH of -- 7.0, conservatively considering the maximum possible sump water volume and the maximum possible boron concentration.
The amount of TSP required is based on the mass of TSP needed to achieve the required pH. However, a required volume is verified by the SR, rather than the mass, since it is not feasible to weigh the entire amount of TSP in containment.
The minimum required volume is based on the manufactured density of TSP (53 lb/ft 3). Since TSP can have a tendency to agglomerate from high humidity in the containment, the density may increase and the volume decrease during normal plant operation, however, solubility characteristics are not expected to change. Therefore, considering possible agglomeration and increase in density, verifying the minimum volume of TSP in the storage baskets is conservative with respect to ensuring the capability to achieve the minimum required pH. This SR is performed to verify the availability of sufficient TSP in the TSP storage baskets. A volume of_> 290 ft 3 of TSP will produce a pH range between 7.0 and 8.0 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and therefore, will create the desired pH level of the containment spray. The 24 month Frequency is based on the low probability of undetected change in the TSP volume occurring during the SR interval (the TSP is contained in storage baskets located in the containment normal sump and on the 565 ft elevation of containment).
Insert Page B 3.6.7-3 Attachment 1, Volume 11, Rev. 0, Page 184 of 189 Attachment 1, Volume 11, Rev. 0, Page 185 of 189 3v stem B 3.6.7 BASES SURVEILLANCE REQUIREMENTS (continued) 0 SR 3.6.7.2 To provide effec ive iodine removal, t e containment spra must be an alkaline solution Since the BVAST co tents are normally cidic, the volume of the s ray additive tank mu t provide a sufficien volume of spray additive t adjust pH for all wat r injected.
This SIR is performed to verify the availa ility of sufficient Na H solution in the Sp ay Additive System. The 1 4 day Frequency is sed on the low pro ability of an undetected cha ge in tank volume o urring during the R interval (the tank is isolated uring normal unit op rations).
Tank lev I is also indicated and a rmed in the control om, such that ther is a high confidence that a substantial change in level would be d tected.SR 3.6.7.3 This SR provid s verification of the aOH concentration in the spray additive tank a d is sufficient to ens re that the spray so ution being injected into c ntainment is at the c rrect pH level. The ncentration of NaOH in the s ray additive tank mu t be determined by hemical analysis.
The 84 day Frequency is sufficient to ensure that the concentration evel of NaOH in the s ray additive tank r mains within the established Ii its. This is based on he low likelihood o an uncontrolled change in con ntration (the tank is normally isolated) nd the probability that any subst ntial variance in tank volume will be det ed.SR 3.6.7.4 This SR provi es verification that e ch automatic valve in the Spray Additive Syst m flow path actuates to its correct positio .The [18] month Frequency is ased on the need to perform this Surveil ance under the conditions th t apply during a plant outage and the pot ntial for an unplanned tr nsient if the Surveilla ce were performed with the reactor at power. Oper ting experience has hown that these co ponents usually pass the Su eillance when perfor d at the [18] mon Frequency.
Therefore, th Frequency was con luded to be accep ble from a reliability sta dpoint.0 BWOG STS B 3.6.7-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 185 of 189 Attachment 1, Volume 11, Rev. 0, Page 186 of 189 B 3.6.7 0 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3;6.7.5 To ensure that he correct pH level i established in the orated water solution provid d by the Containme Spray System, th flow [rate] in the Spray Additive System is verified on per 5 years. Thi SR provides assurance tha the correct amount f NaOH will be met red into the flow path upon Co tainment Spray Syst m initiation.
Due t the passive nature of the pray additive flow co trols, the 5 year Fr quency is sufficient to i entify component de radation that may ffect flow [rate].0 000 efeeces D- ýFSAR, Section R 3.2 BWOG STS B 3.6.7-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 186 of 189 Attachment 1, Volume 11, Rev. 0, Page 187 of 189 JUSTIFICATION FOR DEVIATIONS ITS 3.6.7 BASES, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP) STORAGE 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. Changes are made to reflect changes made to the Specification.
- 3. The brackets have been removed and the proper plant specific information/value has been provided.4. Typographical error corrected.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 187 of 189 Attachment 1, Volume 11, Rev. 0, Page 188 of 189 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 11, Rev. 0, Page 188 of 189 Attachment 1, Volume 11, Rev. 0, Page 189 of 189 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.7, TRISODIUM PHOSPHATE DODECAHYDRATE (TSP) STORAGE There are no specific NSHC discussions for this Specification.
Davis-Besse Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 189 of 189