L-06-076, Supplement to License Amendment Request Nos. 325 and 195 Control Room Habitability Systems

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Supplement to License Amendment Request Nos. 325 and 195 Control Room Habitability Systems
ML061360076
Person / Time
Site: Beaver Valley
Issue date: 05/12/2006
From: Lash J
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-06-076
Download: ML061360076 (28)
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Text

fENOC FirstEnergy Nuclear Operating Company Jamnes H. Lash 724-682-5234 Site Vice President Fax: 724-643-8069 May 12, 2006 L-06-076 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Supplement to License Amendment Request Nos. 325 and 195 Control Room Habitability Systems By letter dated February 17, 2005, the FirstEnergy Nuclear Operating Company (FENOC) submitted License Amendment Request (LAR) Nos. 325 and 195 that would revise the control room habitability systems Technical Specifications for Beaver Valley Power Station Unit Nos. 1 and 2. In subsequent telephone conversations on April 5 and April 12, 2006, the NRC staff expressed a need for some clarifications and updated information regarding the FENOC submittals. The FENOC response to this request is provided in Attachment A. It is important to note that the clarifications provided by this submittal do not require any modification to the Technical Specification changes proposed in the February 17, 2005 submittal. The only changes being provided by this submittal are an update of the radiological analysis to incorporate full implementation of the Alternative Source Term methodology and the necessary modifications of the Technical Specification Bases changes provided by the February 17, 2005 submittal. The F revised Technical Specification Bases pages, provided for information only, are contained in Attachment B and replace the pages in the February 17, 2005 submittal.

These revised bases are the same for both units and would replace the existing Bases 3/4.7.6 (currently identified as unused) and 3/4.7.7 in their entirety.

Approval of LARs 325 and 195 is requested concurrent with or immediately following approval of the Extended Power Uprate LARs. The Extended Power Uprate LARs were submitted by FENOC letter L-04-125, dated October 4, 2004, and approval is expected in July 2006 The amendments approving LARs 325 and 195 will be implemented for both units at the same time and concurrent with the Unit No. 2 Extended Power Uprate amendment. Implementation is expected prior to the first entry into Mode 4 during plant startup from the 2R12 refueling outage planned for the fall of 2006. This implementation LaosC

Beaver Valley Power Station, Unit Nos. 1 and 2 Supplemental Information for LAR Nos. 325 and 195 L-06-076 Page 2 schedule will ensure that control room habitability systems Technical Specifications are consistent between the two units and that the Extended Power Uprate analyses and full implementation of the Alternative Source Term methodology are in each unit's licensing basis when the changes proposed by LARs 325 and 195 are implemented.

It has been determined that the No Significant Hazards Consideration Determination contained in the February 17, 2005 submittal is not affected by the information provided in this submittal.

No new regulatory commitments are contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Gregory A. Dunn, Manager - FENOC Fleet Licensing, at (330) 315-7243.

I declare under penalty of perjury that the foregoing is true and correct. Executed on May 12- .2006.

Sincerely, H. Lash

Beaver Valley Power Station, Unit Nos. 1 and 2 Supplemental Information for LAR Nos. 325 and 195 L-06-076 Page 3 Attachments A. Supplemental Information B. Proposed Unit Nos. 1 and 2 Technical Specification Bases

References:

1. Beaver Valley Unit Nos. 1 and 2 License Amendment Request Nos. 325 and 195 -

Control Room Habitability Systems, FENOC letter L-05-015, dated February 17, 2005.

2. Beaver Valley Unit Nos. 1 and 2 License Amendment Request Nos. 302 and 173 -

Extended Power Uprate, FENOC letter L-04-125, dated October 4, 2004.

c: Mr. T. G. Colburn, NRR Senior Project Manager Mr. P. C. Cataldo, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. A. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

Attachment A to L-06-076 Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2)

License Amendment Request Nos. 325 and 195 Control Room Habitability Systems Supplemental Information By letter dated February 17, 2005, FirstEnergy Nuclear Operating Company (FENOC) submitted a license amendment request regarding BVPS-1 and 2 control room habitability systems. As discussed in telephone conversations on April 5 and April 12, 2006, the following clarifications and updated information is provided to assist in the NRC Staff review of the LAR.

Use of Defined Term "Staggered Test Basis" The NRC staff requested clarification regarding proposed Surveillance Requirements (SR) 4.7.7.1.d.3 (BVPS-1) and 4.7.7.1.e.4 (BVPS-2), which would contain a requirement to demonstrate Control Room Emergency Ventilation System (CREVS) operability by verifying that each train maintains the specified control room pressure. The verification would be performed "...at least once every 36 months on a STAGGERED TEST BASIS..." to achieve equality with the surveillance interval in the Improved Technical Specifications (ITS) for BVPS.

Clarification was requested because the iTS specify 18 months on a STAGGERED TEST BASIS.

The ITS definition of STAGGERED TEST BASIS would require "testing of one of the...

subsystems.. .during the interval specified..." which is 18 months. However, the 36 month test interval specified in current TS would pertain to the entire system rather than to the interval between testing of subsystems as in ITS. The current TS definition of STAGGERED TEST BASIS applies "a test schedule for n... trains ... obtained by dividing the specified test interval into n equal subintervals" and "...testing one... train.. .each subinterval." For a 2-train system, the specified 36 month STAGGERED TEST BASIS using the current TS definition would require testing of one train during each 18 month subinterval. In practice, this is the same as an 18 month STAGGERED TEST BASIS using the ITS definition, so no change in the actual surveillance frequency would occur when ITS are implemented at BVPS. The LAR did not propose revising the definition of STAGGERED TEST BASIS in the current TS because use of the terminology throughout TS would have required other revisions to compensate for a changed definition.

Use of the Phrase "Outside Atmosphere" The NRC staff requested clarification regarding proposed SRs 4.7.7.1.d.3 (BVPS-1) and 4.7.7.1.e.4 (BVPS-2) which would contain a requirement to demonstrate CREVS operability by verifying that each train maintains the specified control room pressure relative to "outside atmosphere." The NRC staff asked FENOC to consider replacing the phrase with "adjacent area" because the meaning of "outside atmosphere" was unclear.

The phrase "outside atmosphere" was used in the LAR because the same words appear in the current TS. This was done to simplify the review by maintaining the existing licensing basis rather than introducing additional changes. The same terminology has been carried over to the

Attachment A to L-06-076 Page 2 proposed Improved Technical Specifications (ITS) for BVPS. The BVPS ITS would be implemented subsequent to the changes proposed in LARs 325 and 195. Surveillance relative to adjacent areas is subject to- a previous commitment provided in a letter dated March 22, 2004, to adopt TSTF-448 at BVPS after TSTF-448 is approved by the NRC. The NRC staff has indicated that maintaining the current licensing basis pending adoption of TSTF-448 would be acceptable.

Updates to Radiological Analysis Information The control room habitability LAR reflected radiological analyses that were current at the time of submittal because newer radiological analyses supporting other license amendments were expected to be implemented after implementation of the control room habitability amendment.

LAR supporting information now needs to be updated because the license for BVPS-1 has since been amended for Replacement Steam Generators (RSGs) and the amended license is supported by radiological analyses that supersede those described in the control room habitability LAR.

Since changes to BVPS-2 analyses have also been prepared in support of an anticipated Extended Power Uprate (EPU) license amendment and some of these analyses are common to both units, it is desirable to coordinate implementation of the control room habitability amendment with the EPU amendment. This would achieve more consistency between both units' control room habitability technical specifications, because common supporting analyses could be credited. If the control room habitability amendment is implemented concurrent with the BVPS-2 EPU amendment, the following updated information regarding radiological analyses would apply. These changes have either been reviewed by the NRC in support of already approved BVPS-1 amendments or will be reviewed by the NRC in support of pending amendments (for either unit) by the time the control room habitability amendment is to be approved.

Design Basis Accidents Crediting CREVS Alternative Source Term (AST) methodology would be applied to additional design basis accident analyses. As a result, the only accidents crediting control room isolation (i.e.

crediting operation of CREVS) would be loss of coolant, main steam line break, and control rod ejection accidents at either unit. The locked rotor accident mentioned in the LAR would no longer credit CREVS. The LAR indicates that some analyses assumed 10 cfm unfiltered control room envelope inleakage while others assumed 30. Upon consistent application of the newer AST analyses the 10 cfm analyses would be superseded. As a result, all analyses crediting CREVS would assume 30 cfm inleakage.

The following information is provided in lieu of the third paragraph of Page 4 of the LAR:

There are three design basis accidents that credit operability of the CREVS to mitigate the radiological consequences of the accidents. These are the Loss of Coolant Accident (LOCA - Unit 1/2), Main Steam Line Break (MSLB - Unit 1/2), and Control Rod Ejection Accident (CREA - Unit 1/2). Analyses for these accidents assume 30 cfm unfiltered leakage into the control room envelope after CREVS initiation.

I Attachment A to L-06-076 Page 3 The following information is provided in lieu of the second paragraph of Page 8 of the LAR:

The safety analyses which address control room operator radiological consequences credit a post-DBA control room isolation capability for Main Steam Line Break (MSLB) for both Units in Modes 1-4, for Control Rod Ejection Accident (CREA) for both Units in Modes 14, and for a Loss of Coolant Accident (LOCA) for both Units in Modes 1-4.

Design Basis Accidents Crediting Puree Function of Control Room Emergency Air Cooling System (CREACS)

Revised analyses would reflect BVPS-1 and 2 credit for the purge function of CREACS in mitigating control room dose consequences for a steam generator tube rupture accident at either unit in addition to the other accidents mentioned in the LAR. In addition, a common purge rate would replace unit-specific rates described in the LAR, allowing use of either unit's purge system to mitigate doses in the common control room envelope following an accident at either unit. The following information is provided in lieu of the last sentence of the third paragraph of Page 5 of the LAR:

The post-accident control room purge function of CREACS is also credited to mitigate radiological consequences in the design basis accident radiological safety analyses calculations for MSLB (Unit 1/2), Steam Generator Tube Rupture (SGTR, Unit 1/2) and Fuel Handling Accident (FHlA, Unit 1).

The following information is provided in lieu of the first paragraph of Page 9 of the LAR:

The BVPS safety analyses which address control room operator radiological consequences also credit a post-DBA control room purge capability provided by CREACS for MSLB for both units in Modes 1-4, SGTR for both units in Modes 1-4 and FHA for Unit 1 when performing fuel handling involving non-recently irradiated fuel.

Therefore BVPS post-DBA purge capability is addressed in the proposed CREACS TS requirements. This addition to the TS (beyond the Inproved Standard Technical Specifications requirements for a heat removal function) is acceptable because the CREACS purge requirement is a necessary post-accident mitigation function to limit the radiological exposure of control room personnel. The purge flow rate credited in the accident analyses for either unit (16,200 cfm) can be supplied by one train of either unit's equipment and would adequately purge the entire control room envelope post-DBA.

BVPS-1 Fuel Handling Accident Control Room Isolation & Heat Removal Functions The LAR describes an assumed control room isolation following a BVPS-1 FHA. Isolation was not required to mitigate doses, but instead was assumed in the analysis to maximize calculated doses by trapping airborne accident effluent in the control room rather than exhausting it through continuous normal ventilation. The discussion was provided to emphasize that the CREACS heat removal function was not credited for the accident even though control room isolation (i.e. CREVS operation) was assumed. Since the FHIA analysis supporting EPU does not assume control room isolation, the explanation of why CREACS is

Attachment A to L-06-076 Page 4 not credited is no longer needed. The following information is provided in lieu of the last paragraph of Page 8 of the LAR:

The radiological safety analysis for the Unit 1 FHA (movement of non-recently irradiated fuel) does not require the control room to be isolated to mitigate control room operator radiological consequences. Therefore, the heat removal function of CREACS (required only when the control room is isolated) would not be required when Unit 1 is performing fuel handling involving non-recently irradiated fuel.

ATTACHMENT B Beaver Valley Power Station, Unit Nos. 1 and 2 Supplement to License Amendment Request Nos. 325 and 195 Proposed Technical Specification Bases The following Bases are proposed to replace current Bases in their entirety:

B 3/4 7.6*

B 3/4 7.7

  • Current Technical Specifications and Bases contain only a place-holder for this item. The specification number is unused.

FOR INFORMATION ONLY PLANT SYSTEMS BASES 3/4.7.6 CONTROL ROOM EMERGENCY AIR COOLING SYSTEM (CREACS)

Note The Technical Specification Bases address both Unit 1 and Unit 2 since information on the opposite unit may be useful to address issues involving the control room boundary which encompasses both BVPS Units' control rooms.

Backaround The Control Room Emergency Air Cooling System (CREACS) provides 1) a control room heat removal function following isolation of the control room, and 2) control room atmosphere purge capability for the combined units' main control room. The heat removal function ensures that the control equipment qualification is maintained following isolation of the control room. The purge function is necessary to limit the dose received by control room personnel following certain design basis accidents (DBAs). Each unit has its own CREACS. Each unit's CREACS consists of a single ventilation air intake and two independent and redundant trains consisting of river/service water emergency cooling coils, ventilation ducts, fans and fan controls.

However, the CREACS trains share common ventilation ductwork and normal air inlet and exhaust flow paths. The CREACS heat removal function is discussed in the UFSAR, Section 9.13 (Unit 1) and Section 9.4 (Unit 2). The CREACS control room atmosphere purge function is discussed in the UFSAR, Table 11.3-7 (Unit 1) and Table 15.0-13 (Unit 2).

The CREACS is an emergency system, parts of which operate during normal unit operations. A single train of CREACS on each unit is capable of maintaining its side of the combined control room at < the equipment design limit of 120'F. A single train of CREACS from either unit is capable of providing adequate control room atmosphere purge capability to meet either unit's DBA requirements.

Applicable Safety Analyses

{The design basis of the CREACS heat removal function is to provide emergency air cooling for the control room to maintain the temperature within the equipment design limit for a mild environment (120'F) following certain DBAs when the control room is isolated.

The CREACS also provides an atmosphere purge function for the control room following certain DBAs. Only manual actuation is credited for both CREACS functions at each unit.

BEAVER VALLEY - UNIT 1[23 B 3/4 7-4a Change No. 1-032[2-0371

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY AIR COOLING SYSTEM (CREACS) (Continued)

The CREACS components are arranged in redundant, safety related trains. A single active failure of a component of the CREACS, with a loss of offsite power, does not impair the ability of the system to perform its design function. The CREACS is designed in accordance with Seismic Category I requirements.

During normal and emergency control room operation, the control room air cooling is usually maintained by the non-safety related air conditioning equipment which is integral to the control room ventilation systems. During emergency operation when the control room is isolated, the safety related CREACS is manually initiated to provide air cooling to maintain the temperature < 120'F when the normal non-safety related air conditioning becomes unavailable. The CREACS is capable of removing sensible and latent heat loads from the control room, which include consideration of equipment heat loads to ensure equipment OPERABILITY. The CREACS heat removal function is only required following post-DBA isolation of the control room (when control room isolation is required to meet radiological dose analysis requirements) and the normal non-safety-related air conditioning equipment is unavailable.

The heat removal function of CREACS is credited in design basis accidents for MODES 1, 2, 3, and 4 (e.g., the LOCA, the Main Steam Line Break and Control Rod Ejection DBAs for both units require control room isolation). Since neither unit requires control room isolation (and hence the control room heat function of CREACS) to meet its Fuel Handling Accident (FHA) DBA nor requires control room isolation following any other DBA in MODES 5 and 6 (e.g., Waste Gas Tank Rupture), the heat removal function of CREACS is not required in MODES 5 and 6 or during fuel movement involving non-recently irradiated fuel.

The design basis of the CREACS control room ventilation purge function ensures the capability to manually purge the air from the control room for selected design basis accidents to ensure acceptable dose consequences to the control room personnel following a DBA.

For both Unit 1 and Unit 2, the main steam line break (MSLB) and steam generator tube rupture (SGTR) accident analyses credit a manually initiated 30 minute control room ventilation purge at a flow rate of 2 16,200 cfm after the accident sequence is complete and the environmental release has been terminated. Also for Unit 1 only, the FHA analysis for fuel movement involving non-recently irradiated fuel credits a manually initiated 30 minute control room ventilation purge at a flow rate of 2 16,200 cfm after the accident sequence is complete and the environmental release has been terminated. The dose consequence analyses assume that for the MSLB, the SGTR, and the Unit 1 FHA, control room purge is initiated at T=24 hours, T=8 hours and T=2 hours after accident initiation, respectively.

BEAVER VALLEY - UNIT 1[21 B 3/4 7-4b Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY AIR COOLING SYSTEM (CREACS) (Continued)

Only Unit 1 requires the purge function of CREACS during fuel movement involving non-recently irradiated fuel. Therefore, the purge function of CREACS is required for Unit 1 during fuel movement involving non-recently irradiated fuel. Thus, the control room ventilation purge functions of CREACS are credited in design basis accidents for MODES 1, 2, 3, and 4 at both units, and for fuel movement involving non-recently irradiated fuel assemblies at Unit 1.

This LCO is also applicable for both units during movement of recently irradiated fuel assemblies (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) and during movement of fuel assemblies over recently irradiated fuel assemblies. The requirement for recently irradiated fuel assemblies is included because there is a potential for a limiting FHA for which the requirements of this Specification may be necessary to limit radiation exposure to personnel occupying the control room to withil\

the requirements of 10 CFR 50.67. Although the movement of recently irradiated fuel is not currently permitted for either unit, the requirements for both the temperature control and purge functions are retained in the Technical Specifications in case the CREACS functions are necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel, consistent with the guidance of NUREG-1431.

The CREACS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The Unit 1 fuel handling accident analysis does not require control room isolation to limit the dose to control room personnel to within the required limits. Therefore, a Note modifying the LCO requirement is included to clarify that the Unit 1 CREACS heat removal function is not required OPERABLE to support fuel movement involving non-recently irradiated fuel. Only the purge function of the Unit 1 CREACS is required to support fuel movement involving non-recently irradiated fuel as only the purge function is required in the Unit 1 accident analysis to limit dose. The Note is only applicable to Unit 1 because operation of the Unit 2 CREACS is not required by the Unit 2 fuel handling accident analysis for fuel movement involving non-recently irradiated fuel. Therefore, operation of the Unit 2 CREACS is not required to limit the dose to control room personnel from a fuel handling accident involving non-recently irradiated fuel.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-4c Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY AIR COOLING SYSTEM (CREACS) (Continued)

Two trains of the CREACS are required to be OPERABLE to ensure that at least one is available, assuming a single failure disabling the other train. Total system failure of the heat removal function could result in the equipment operating temperature exceeding limits in the event of an accident. Total system failure of the control room atmosphere purge function could result in exceeding a dose of 5 rem TEDE to the control room operator in the event of a large radioactive release following a MSLB, SGTR, or a Unit 1 FHA.

With regard to the control room atmospheric purge function only, the LCO requirement for two OPERABLE CREACS trains may be met by crediting OPERABLE Unit 1 train(s) for Unit 2 and crediting OPERABLE Unit 2 train(s) for Unit 1. The control room atmospheric purge flow requirements for each unit are the same and the control room envelope lis common. Therefore, the purge flow assumed in the DBA analysis may

[be accomplished by the manual initiation of a CREACS train from either unit.

'The CREACS is considered to be OPERABLE when the individual components necessary to maintain the control room temperature < 1200 F (when the control room is isolated) and to provide the control room ventilation purge function at the required flow rate are OPERABLE in two trains. These components include the river/service water emergency cooling coils, necessary ductwork and associated dampers, fans, and associated fan controls. The capability to manually operate the components of the CREACS is all that is required for OPERABILITY. In addition, the CREACS must be operable to the extent that air circulation necessary for the required temperature control can be maintained.

The LCO is modified by a footnote

  • that requires emergency backup power for only one CREACS train in Modes 5, 6 and with no fuel assemblies in the reactor pressure vessel. This footnote allows emergency power sources to be taken out of service during a unit shutdown consistent with the shutdown Electrical Power Technical Specifications.

Applicability CREACS must be OPERABLE in MODES 1, 2, 3, 4 at either unit and during fuel movement involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) at either unit. The CREACS ensures that control room temperatures will not exceed equipment operational requirements and that the control room ventilation is capable of purging the control room atmosphere after a DBA to maintain dose within the limit.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-4d Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY AIR COOLING SYSTEM (CREACS) (Continued)

For Unit 1 only, during movement of non-recently irradiated fuel assemblies and during movement of fuel assemblies over non-recently irradiated fuel assemblies, the ventilation purge function of CREACS must be OPERABLE. The Unit 1 temperature control function of CREACS is not required OPERABLE during fuel movement involving non-recently irradiated fuel because the Unit 1 FHA analysis does not require control room isolation to limit dose.

CREACS is not required in MODES 5 or 6 at either unit during no fuel movement nor is it required during fuel movement involving non-recently irradiated fuel movement at Unit 2.

The applicability for fuel movement involving recently irradiated fuel assemblies is included because there is a potential for a limiting FHA for which the requirements of this Specification may be necessary to limit radiation exposure to personnel occupying the control room to within the requirements of 10 CFR 50.67. Although the movement of recently irradiated fuel is not currently permitted for either Unit, the requirements for both the heat removal and purge functions are retained in the Technical Specifications in case the CREACS functions are necessary to support the assumptions of a FHA safety analysis for fuel movement involving recently irradiated fuel.

The retention of Technical Specification requirements for fuel movement involving recently irradiated fuel is consistent with the guidance of NUREG-1431,"Standard Technical Specifications Westinghouse Plants" Rev. 3.

Actions MODES 1. 2, 3 and 4:

Action a.1 With one CREACS train inoperable, action must be taken to restore OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREACS train is adequate to maintain the control room temperature < 120'F when the control room is isolated and provide the required control room atmosphere purge function. However, the overall reliability is reduced because a single failure in the OPERABLE CREACS train could result in loss of CREACS function. The 30 day Completion Time is based on the low probability of an event requiring control room isolation or purge, the consideration that the remaining train can provide the required protection, and that alternate safety or nonsafety related means of cooling the control room air and of purging the control room atmosphere are available.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-4e Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY AIR COOLING SYSTEM (CREACS) (Continued)

In MODE 1, 2, 3, or 4, if the inoperable CREACS train cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes the risk. To achieve this status, the unit must be placed in 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 in 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 unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Action a.2 If both CREACS trains are inoperable, the control room CREACS may not be capable of performing its intended function. Therefore, Specification 3.0.3 must be entered immediately.

Durina movement of recently irradiated fuel assemblies and during movement of fuel assemblies over recently irradiated fuel assemblies at both Units. and during fuel movement involving non-recently irradiated fuel at Unit 1:

Action b.1 With one CREACS train inoperable, action must be taken to restore OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREACS train is adequate to maintain temperature < 120'F when the control room is isolated and provide the required control room atmospheric purge function. However, the overall reliability is reduced because a single failure in the OPERABLE CREACS train could result in loss of CREACS function. The 30 day Completion time is based on the low probability of an event requiring control room isolation or control room atmosphere purging, the consideration that the remaining train can provide the required protection, and that alternate safety and non-safety related means of control room air heat removal and purging are available.

iIf the inoperable CREACS train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREACS train must be placed in operation immediately. This action requires that the OPERABLE CREACS ventilation fan be in service and circulating control room air, and if the heat removal function is required by the LCO, with river/service water being supplied to the emergency cooling.

coils. This action ensures the remaining train is OPERABLE and active failures will be readily detected.

BEAVER VALLEY - UNIT 12]B B 3/4 7-4f Change No. 1-032[2-037]

FOR INFORMATION ONLY

' PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY AIR COOLING SYSTEM (CREACS) (Continued)

An alternative to placing the operable CREACS train in operation is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room or a purge of the control room atmosphere. This involves suspending the movement of recently irradiated fuel assemblies and the movement of fuel assemblies over recently irradiated fuel assemblies for both units and suspending the movement of irradiated fuel assemblies and the movement of fuel assemblies over irradiated fuel assemblies for Unit 1. This places the unit in a condition that minimizes accident risk. This Action does not preclude the movement of fuel to a safe position.

Action b.2 If both CREACS trains are inoperable, action must be taken to immediately suspend activities that could release radioactivity that might require isolation of the control room or a purge of the control room atmosphere. This involves suspending the movement of recently irradiated fuel assemblies and the movement of fuel assemblies over recently irradiated fuel assemblies for both units and suspending the movement of irradiated fuel assemblies and the movement of fuel assemblies over irradiated fuel assemblies for Unit 1. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

Surveillance Requirements SR 4.7.6.1 This SR verifies the heat removal capability of the system is sufficient to remove the required heat load to maintain the control room temperature within the equipment design limit (< 120'F). The verification of the CREACS heat removal capability consists of a combination of river/service water flow measurement, fan performance, and mechanical cleaning and inspections of the river/service water cooling coils.

This SR also verifies the control room atmosphere purge capability of the system is sufficient to remove air from the control room for the design basis accidents that require a control room purge to limit dose. The control room purge capability is verified by assuring each train of CREACS can be aligned to purge the control room atmosphere and can achieve the required purge flow rate of 2 16,200 cfm. This part of the SR may be accomplished by measuring fan performance during normal system alignment to verify the fan's capability to purge the control room at the required flow rate. The ability of the BEAVER VALLEY - UNIT 1[2] B 3/4 7-4g Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY AIR COOLING SYSTEM (CREACS) (Continued) required dampers to be aligned for a control room purge can be verified by observing partial movement of the dampers. Realignment of the CREACS to the purge mode of operation and measuring the actual purge flow rate is not required to satisfy this SR. The 18 month Frequency is appropriate since significant degradation of the CREACS is slow and is not expected over this time period.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-4h Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES 3/4.7.7 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

Note The Tech Spec Bases address both Unit 1 and Unit 2 since information on the opposite unit may be useful to address issues involving the control room boundary which encompasses both BVPS Units' control rooms.

Backaround The Control Room Emergency Ventilation System (CREVS) provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity.

BVPS has a common control room pressure envelope for Unit 1 and Unit 2. The CREVS consists of pressurization fan subsystems and the control room isolation subsystems. There are three CREVS pressurization fan subsystems, one (Unit 1) and two (Unit 2). The pressurization fan subsystems draw filtered outside air into the icontrol room.

IThe CREVS control room isolation subsystems isolate the Unit 1 and Unit 2 normal air intake and exhaust penetration flow paths by closing at least one of the two series isolation dampers in each of the four penetration flow paths. Closure of both Units' intake and exhaust isolation dampers may be initiated by an isolation signal from either unit. However, the operation of the intake and exhaust dampers at each unit is dependent upon the availability of that Unit's power sources. The isolation subsystem of a CREVS train consists of all 4 isolation dampers in that train (2 per unit). Both the Unit 1 and Unit 2 isolation dampers associated with a train are required OPERABLE for an OPERABLE CREVS train. The isolation subsystem is OPERABLE for a Unit when the associated Unit 1 and Unit 2 dampers are capable of closing on that Unit's isolation signals or the damper(s) are secured closed.

The CREVS pressurization fan subsystem located on the Unit 1 side of the combined control room consists of one manually started pressurization fan and filter subsystem that provides filtered air to pressurize the control room. The Unit 1 pressurization fan subsystem filter consists of a prefilter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), a high efficiency particulate air (HEPA) filter, and one of the two 100%

capacity Unit 1 fans. Only one of the two Unit 1 fans is required for an OPERABLE CREVS Train.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-5 Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued)

The CREVS pressurization fan subsystems located on the Unit 2 side of the Control Room consists of two automatically started redundant train related subsystems that draw in outside air through filters to provide filtered air to pressurize the control room. Each pressurization fan subsystem filter consists of a moisture separator, a HEPA filter, an activated charcoal adsorber, a second HEPA filter, and a fan. A second bank of HEPA filters follows the adsorber section to collect carbon fines and provide backup in case of failure of the main HEPA filter.

For both Units, ductwork, heaters, valves or dampers, and instrumentation also form part of the system.

Unit 1 can credit any two of the three available CREVS pressurization

'fan subsystems to meet the LCO requirement for two OPERABLE CREVS Strains. However, Unit 2 can only credit the Unit 2 specific pressurization fan subsystems to meet the LCO requirement for two OPERABLE CREVS trains.

The CREVS is an emergency system, parts of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of a CREVS actuating signal(s), normal unfiltered outside air supply and exhaust dampers to the control room are closed and (for Unit 2 only) a pressurization fan subsystem is initiated and the emergency air supply damper in the operating CREVS train is opened to bring in outside air through filters to pressurize the control room envelope. The Unit 1 pressurization fan subsystem is manually placed in service if required. The air continues to be recirculated within the control room envelope by CREACS (TS 3/4.7.6) both during normal operation and during CREVS operation.

Pressurization of the control room minimizes infiltration of unfiltered air from surrounding areas of the control room. A single CREVS train will pressurize the control room to maintain a positive pressure relative to the outside atmosphere. The CREVS operation in maintaining the control room habitable is discussed in UFSAR, Section 9.13 (Unit 1) and Section 9.4 (Unit 2)

Redundant CREVS trains are required OPERABLE to ensure the pressurization and filtration function can be accomplished should one Itrain fail. Normally open isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The CREVS is designed in accordance with Seismic Category I requirements.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-5a Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued)

The control room boundary is the combination of walls, floor, roof, ducting, isolation dampers, doors, penetrations and equipment that physically form the control room envelope. The control room envelope includes the "control room" (i.e., the space that operators inhabit to control the plant for normal and accident conditions) as well as other adjacent areas. The control room is protected for normal operation, natural events, and accident conditions.

The CREVS, in conjunction with control room design provisions, is designed to maintain the control room environment for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding 5 rem total effective dose equivalent (TEDE). This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A", 10 CFR 50 and 10 CFR 50.67.

The CREVS is automatically actuated by a Containment Isolation Phase B (CIB) signal or a control room area high radiation signal.

In addition CREVS can be actuated manually. LCO 3.3.2.1, "Engineered Safety Feature Actuation System Instrumentation' contains the OPERABILITY requirements for the CIB actuation instrumentation.

LCO 3.3.3.1, "Radiation Monitoring Instrumentation" contains the OPERABILITY requirements for the Control Room Area High Radiation actuation instrumentation.

The CREVS does not have automatic detection and isolation for toxic gas. If toxic gas were identified to be onsite, the control room would be isolated by closing all supply and exhaust dampers and verifying that CREVS is not in operation. These actions would minimize outside air intake into the control room envelope.

ApDlicable Safety Analyses The CREVS components are arranged in redundant, safety related ventilation trains. The location of most components and ducting within the control room envelope helps to minimize air in-leakage and ensures an adequate supply of filtered air to all areas requiring access. The CREVS provides airborne radiological protection for the control room operators, as demonstrated by the control room habitability analyses for the most limiting design basis accidents:

loss of coolant accident (LOCA), control rod ejection accident (CREA), and main steam line break (MSLB) accident, presented in the UFSAR, Chapter 14 (Unit 1) and Chapter 15 (Unit 2). Control room isolation and operation of CREVS was not credited in other design basis accidents.

The worst case single active failure of a component of the CREVS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-5b Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued)

The LOCA accident analysis assumes an automatic isolation of the control room normal ventilation system following a CIB signal and subsequent manual initiation of a CREVS pressurization fan subsystem for filtered makeup and pressurization of the control room. Although the CIB signal will automatically start one of the two Unit 2 CREVS pressurization fan subsystems, a 30-minute delay to allow for manual initiation of a CREVS pressurization fan subsystem is specifically assumed in the analysis to permit the use of the Unit 1 CREVS pressurization fan subsystem which requires manual operator action to place in service. The CREA and the MSLB accident analyses assume manual initiation of the emergency pressurization mode of operation of control room ventilation (i.e., control room ventilation isolation, filtered makeup and pressurization), within 30 minutes after the accident.

Although the control room dose calculations for the limiting DBAs (i.e., LOCA, CREA, and MSLB) assume that the control room is pressurized in 30 minutes of the accident by manually actuating a pressurization fan subsystem, the specification conservatively requires automatic actuation of a Unit 2 CREVS pressurization fan subsystem.

The current safety analyses do not assume the control room area radiation monitors provide a CREVS actuation signal for any design basis accident. However, requirements for the automatic initiation of CREVS (both isolation and pressurization fan subsystems) on high radiation are retained in the Technical Specifications in case this automatic function is required to support the assumptions of a fuel handling accident analysis for the movement of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) or the movement of fuel over recently irradiated fuel consistent with the guidance of NUREG-1431.

A start time delay is included in the initiation circuitry of the Unit 2 CREVS pressurization fans. The basis for this time delay includes the following considerations:

1. The delay times prevent loading of the pressurization fans onto the emergency busses until after the Emergency Diesel Generator load sequencing is completed.
2. The pressurization fan delay times are staggered to ensure only one fan will be operating.
3. A pressurization fan is started early to minimize dose to the operators.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-5c Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued)

4. The delay times are selected such that sufficient time will be available for the manual initiation of a pressurization fan within 30 minutes after an accident should a pressurization fan fail to start.

An evaluation of all toxic gas hazards from onsite, offsite, and transportation sources has determined that the probability of a toxic chemical spill resulting in unacceptable exposures was less than NRC design basis criteria and, hence, is not included in the plant design basis (Reference BVPS Unit 2 UFSAR, Section 2.2.3.1.2 and 6.4.4.2).

Technical Specification Amendment No. 233 (Unit 1) and No. 115 (Unit 2) removed the control room chlorine detection system. In addition, Technical Specification Amendment No. 257 (Unit 1)/No. 139 (Unit 2), which removed the control room bottled air pressurization system, confirmed that the ability to manually isolate the control room and the availability of self-contained breathing apparatus, are sufficient to address any credible toxic gas or smoke events.

The CREVS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Two CREVS trains including the associated train related inlet and exhaust isolation dampers are required to be OPERABLE to ensure that at least one train is available assuming a single failure disables the other train. A combination of two out of three CREVS pressurization fan subsystems from either Unit 1 or Unit 2 satisfies the LCO requirement for Unit 1. Only the Unit 2 CREVS pressurization fan subsystems may be used to satisfy the LCO requirement for Unit 2.

The OPERABILITY of CREVS ensures that the control room will remain habitable with respect to potential radiation hazards for operations personnel during and following all credible accident conditions. The OPERABILITY of this system in conjunction with, control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem TEDE. This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "Al, 10 CFR 50 and 10 CFR 50.67. Total system failure could result in exceeding these dose limits in the event of a large radioactive release.

The CREVS is considered OPERABLE when the individual components necessary to limit operator exposure are OPERABLE in both trains. A CREVS train is OPERABLE when the associated:

a. Fan is OPERABLE (including the required automatic start capability for Unit 2 fans),

BEAVER VALLEY - UNIT 12] B 3/4 7-5d Change No. 1-032[2-0371

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued)

b. HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions, and
c. Heater, prefilter (Unit 1), moisture separator (Unit 2),

ductwork, valves, and dampers are OPERABLE (i.e., capable of supporting pressurization of the control room when a CREVS train is actuated). This includes:

1. In MODES 1, 2, 3 and 4, the series normal air intake and exhaust isolation dampers for both units must be OPERABLE and capable of automatic closure on a CIB actuation signal.

The series normal air intake and exhaust isolation dampers for both units may also be considered OPERABLE when secured in a closed position with power removed.

2. During fuel assembly movement involving recently irradiated fuel assemblies, the series normal air intake and exhaust isolation dampers for both units must be OPERABLE and capable of automatic initiation by a Control Room High Radiation signal. The series air intake and exhaust isolation dampers for both units may also be considered OPERABLE when secured in a closed position with power removed.

LCO 3.3.3.1, "Radiation Monitoring", contains the Operability, Action, and Surveillance requirements for the CREVS actuating radiation monitors. LCO 3.3.2.1, "Engineered Safety Feature Actuation System Instrumentation" contains the OPERABILITY, Action, and Surveillance requirements for the CIB actuation instrumentation.

In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors in order to maintain the capability of the CREVS to pressurize the control room.

The LCO is modified by a General Note allowing the control room boundary to be opened intermittently under administrative controls.

For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area.

For other openings (hatches, access panels, floor plugs, etc.), these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening and restore the control room boundary to the design condition when a need for control room isolation is indicated. If the above conditions for utilizing the LCO Note cannot be met, then Action a.2 should be applied.

BEAVER VALLEY - UNIT 12]B B 3/4 7-5e Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued)

The LCO is modified by a footnote

  • that requires emergency backup power for only one CREVS train in Modes 5, 6 and with no fuel assemblies in the reactor pressure vessel. This footnote allows emergency power sources to be taken out of service during a unit shutdown consistent with the shutdown Electrical Power Technical Specifications.

Anplicabilitv In MODES 1, 2, 3, 4, and during the movement of recently irradiated fuel assemblies (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) and the movement of fuel assemblies over recently irradiated fuel assemblies, CREVS is required to be OPERABLE to control operator exposure during and following a DBA.

In Modes 5 and 6, when no fuel movement involving recently irradiated fuel is taking place, there are no requirements for CREVS OPERABILITY consistent with the safety analyses assumptions applicable in these MODES. A FHA involving non-recently irradiated fuel will result in radiation exposure, to personnel occupying the control room, that is within the guideline values specified in 10 CFR 50.67 without any reliance on the requirements of this Specification to limit personnel exposure.

This LCO is applicable during movement of recently irradiated fuel assemblies and during movement of fuel assemblies over recently irradiated fuel assemblies. Recently irradiated fuel is fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. During fuel movement involving recently irradiated fuel, there is a potential for a limiting FHA for which the requirements of this Specification may be necessary to limit radiation exposure to personnel occupying the control room to within the requirements of 10 CFR 50.67. Although the movement of recently irradiated fuel is not currently permitted, these requirements are retained in the Technical Specifications in case the CREVS is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel, consistent with the guidance of NUREG-1431,"Standard Technical Specifications Westinghouse Plants" Rev. 3.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-5f Change No. 1-032[2-0371

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued)

Actions Modes 1. 2. 3 and 4:

a.l With one required CREVS train inoperable (this Action includes the condition of one or more inoperable series isolation dampers in the same train), action must be taken to restore the CREVS train (and/or train of damper(s)) to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREVS train (and train of isolation dampers) is adequate to perform the control room radiation protection function. However, the overall reliability is reduced because a single failure in the OPERABLE train could result in loss of CREVS function. The 7 day Completion time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

If the inoperable train can not be restored to OPERABLE status within the required Completion time, the unit must be placed in at least 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 in MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed Completion times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

a.2 If the control room boundary is inoperable, the required CREVS trains may not be able to perform their intended functions. Therefore, Actions must be taken to restore the control room boundary to OPERABLE status. The CREVS functions to pressurize the control room boundary with filtered air to limit the radiological exposure of control room personnel to within the required limits. During the period that the control room boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room personnel from potential radiological exposure in excess of the required limits. Preplanned measures should be available to address an inoperable control room boundary for intentional and unintentional entry into this Action.

Depending on the location and size of the failure which caused the control room boundary to be inoperable, the use of compensatory measures such as temporary closures and readily available respirators may be employed to support control room habitability requirements.

Administrative controls should ensure adequate compensatory measures are maintained and that control room personnel are aware of the required measures.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-5g Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued)

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion time is reasonable based on the low probability of a DBA occurring during this time period, and the required use of compensatory measures. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary.

If the inoperable control room boundary can not be restored to OPERABLE status within the required Completion time, the unit must be placed in at least 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 in MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed Completion times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

a.3 This Action addresses the condition of two required CREVS trains inoperable for reasons other than an inoperable control room boundary (i.e., Action a.2). Two inoperable trains also include the conditions of one or more inoperable series isolation dampers in both trains or one or more inoperable series isolation dampers in one train and the opposite CREVS train inoperable. In this condition, the CREVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, Specification 3.0.3 must be entered immediately.

Durina Movement of Recently Irradiated Fuel Assemblies and Durincr Movement of Fuel Assemblies Over Recently Irradiated Fuel Assemblies b.1 With one required CREVS train inoperable (this Action includes the condition of one or more inoperable series isolation dampers in the same train), action must be taken to restore the CREVS train (and/or train of damper(s)) to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE train is adequate to perform the control room radiation protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CREVS train could result in loss of CREVS function. The 7 day Completion

[time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

BEAVER VALLEY - UNIT 1[21 B 3/4 7-5h Change No. 1-032[2-037]

-' FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued)

If the inoperable train cannot be restored to OPERABLE status within the required Completion time, the OPERABLE CREVS train must immediately be placed into operation (i.e., the emergency pressurization mode) which consists of isolating the Unit 1 and Unit 2 normal air intake and exhaust penetration flow paths by closing at least one of the two series isolation dampers in each of the four penetration flow paths and starting one CREVS pressurization fan subsystem. This action ensures that the remaining. train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative action is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This involves suspending movement of recently irradiated fuel assemblies and suspending movement of fuel assemblies over recently irradiated fuel assemblies. This places the unit in a condition that minimizes risk. This does not preclude the movement

,of fuel to a safe position.

Qb.2

,If two required CREVS trains are inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require the CREVS function. Two inoperable trains also include the conditions of one or more inoperable series isolation dampers in both trains or one or more inoperable series isolation dampers in one train and the opposite CREVS train inoperable. This Action involves suspending movement of recently irradiated fuel assemblies and suspending movement of fuel assemblies over recently irradiated fuel assemblies. This places the unit in a condition that minimizes accident risk. This Action does not preclude the movement of fuel to a safe position.

Surveillance Recuirements 4.7.7.1.b Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. The CREVS fan and filter flow path is operated for > 15 minutes by initiating flow through the HEPA filter and charcoal adsorber train and with heaters operating to ensure that they are functional. Isolation of the control room is not required to perform this surveillance. The 31 day Frequency is based on the reliability of the equipment and train redundancy availability.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-5i Change No. 1-032[2-037]

A FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued) 4.7.7.1.c. 4.7.7.1.d.1 (Unit 1) 4.7.7.1.c. 4.7.7.1.d, 4.7.7.1.e.1 (Unit 2)

These SRs verify that the required CREVS pressurization fan subsystem testing is performed in accordance with design standards. These surveillances include testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. The surveillance Frequencies are consistent with the applicable (licensing basis) industry guidance and standards.

4.7.7.1.d.2 (Unit 1) 4.7.7.1.e.2 (Unit 2)

This SR verifies that each CREVS train starts and operates on a simulated or actual Containment Isolation Phase B actuation signal (only required in MODES 1-4) and Control Room High Radiation actuation test signal (only required for fuel movement involving recently irradiated fuel). The actuation testing includes verification that the series air intake and exhaust isolation dampers for both units close to isolate the control room from the outside atmosphere. In addition, for Unit 2, the automatic start (following a time delay) of the CREVS fan supplying air to pressurize the control room through the HEPA filters and charcoal adsorber banks is verified. For Unit 1, an automatic start of the CREVS pressurization fan subsystem is not required since the associated fan and filter subsystem are placed in service by manual operator action.

LCO 3.3.2.1, "Engineered Safety Feature Actuation System Instrumentations contains the surveillance requirements for the Containment Isolation Phase B actuation instrumentation.

LCO 3.3.3.1, "Radiation Monitoring Instrumentation" contains the surveillance requirements for the Control Room Area High Radiation actuation instrumentation.

The frequency of 18 months is consistent with the testing frequencies specified in Regulatory Guide 1.52.

4.7.7.1.d.4 (Unit 1) 4.7.7.1.e.5 (Unit 2)

This Surveillance Requirement verifies that the heaters associated with CREVS pressurization fan subsystem are capable of providing the required heat input to ensure that the inlet air to the filtration unit is maintained within the required relative humidity range.

BEAVER VALLEY - UNIT 1[2] B 3/4 7-5j Change No. 1-032[2-037]

FOR INFORMATION ONLY PLANT SYSTEMS BASES CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) (Continued) 4.7.7.1.e (Unit 1) 4.7.7.1.f (Unit 2)

This Surveillance Requirement verifies the capability of the CREVS to pressurize the control room to 2 1/8 inch Water Gauge relative to the outside atmosphere. The capability to pressurize the control room to a positive pressure is periodically tested to confirm the capability of the CREVS to perform its intended safety function. The CREVS is designed to pressurize the control room to a positive pressure with respect to the outside atmosphere in order to minimize unfiltered inleakage. The CREVS is designed to maintain this positive pressure with one train operating at a makeup flow rate of 800 to 1000 cfm.

For Unit 1 the requirement to verify each CREVS train 36 months on a staggered basis results in performing the required test with one of the two 100% capacity fans and one train of isolation dampers every 18 months such that both trains of isolation dampers are tested every 36 months. For Unit 2 staggered testing results in performing the required test with one CREVS train every 18 months such that both Unit 2 CREVS trains are tested every 36 months.

IThe frequency of 36 months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800.

4.7.7.2 (Unit 1)

This Surveillance Requirement provides guidance on the Surveillance Requirements for Unit 2 CREVS equipment that is relied upon to meet the Unit 1 LCO requirements. The applicable Surveillance Requirements pertain to the Unit 2 CREVS pressurization fan subsystems since one or both systems are utilized to meet the Unit 1 LCO requirements. The Unit 1 Surveillance Requirements for the control room isolation subsystems adequately address the Unit 2 normal intake and exhaust penetration flow path isolation function.

BEAVER VALLEY - UNIT 1[2B B, 3/4 7-5k Change No. 1-032[2-037]

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