L-17-042, Request for Licensing Action to Revise the Technical Specifications

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Request for Licensing Action to Revise the Technical Specifications
ML17159A720
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 06/08/2017
From: Hamilton D
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-17-042
Download: ML17159A720 (69)
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Text

FENOC Perry Nuclear Power Plant PO Box 97 10 Center Road FirstEnergy Nuclear Operating Company Per^ Ohl° 44081 David B. Hamilton 440-280-5382 Vice President June 8, 2017 L-17-042 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Request for Licensing Action to Revise the Technical Specifications Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) is requesting an amendment to the Perry Nuclear Power Plant Technical Specifications.

An evaluation of the proposed amendment is enclosed. FENOC is requesting Nuclear Regulatory Commission (NRC) staff approval by June 11, 2018, and an implementation period of 180 days following issuance of the amendment.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June £.2017.

Sincerely, David B. Hamilton

Enclosure:

Evaluation of Proposed License Amendment cc: NRC Region III Administrator NRC Resident Inspector NRC Project Manager Branch Chief, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

EVALUATION OF PROPOSED LICENSE AMENDMENT Page 1 of 13

Subject:

Request to Amend the Perry Nuclear Power Plant Technical Specifications 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 SYSTEM RUNTIME AND HEATER OPERATION 2.1.1 Proposed Changes to SR 3.7.3.1 2.1.2 Proposed Changes to SR 3.6.4.3.1 2.2 TECHNICAL SPECIFICATIONS NO LONGER ALIGNED WITH LICENSE BASIS 2.3 SECONDARY CONTAINMENT BYPASS LEAKAGE 2.4 VENTILATION FILTER TESTING PROGRAM 2.5 TECHNICAL SPECIFICATIONS TABLE OF CONTENTS

3.0 TECHNICAL EVALUATION

S 3.1 SYSTEM RUNTIME AND HEATER OPERATION 3.2 TECHNICAL SPECIFICATIONS NO LONGER ALIGNED WITH LICENSE BASIS 3.3 SECONDARY CONTAINMENT BYPASS LEAKAGE 3.4 VENTILATION FILTER TESTING PROGRAM

4.0 REGULATORY EVALUATION

4.1 Significant Hazards Consideration 4.2 Applicable Regulatory Requirements/Criteria 4.3 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Attachments:

1. Proposed Technical Specification Changes (MARK-UP)
2. Proposed Technical Specification Changes (RETYPED)
3. Planned Technical Specification Bases Changes

Page 2 of 13 1.0

SUMMARY

DESCRIPTION This evaluation supports a FirstEnergy Nuclear Operating Company (FENOC) request to:

  • Revise TS 3.6.4.3, "Annulus Exhaust Gas Treatment (AEGT) System," to change the runtime requirement from "10 continuous hours" to "15 continuous minutes," and to delete "with heaters operating" in SR 3.6.4.3.1 to align it with proposed changes to SR 3.7.3.1.
  • Delete TS 3.7.8, "Fuel Handling Building," to align with the license basis.
  • Delete TS 3.7.9, "Fuel Handling Building Ventilation Exhaust System," to align with the license basis.
  • Revise TS 3.7.7, "Fuel Pool Water Level," to add a parenthetical note at the bottom of the page, which cites the next TS page number. This is necessary due to the deletion of TS pages associated with TS 3.7.8 and TS 3.7.9.
  • Revise TS 5.5.7, "Ventilation Filter Testing Program (VFTP)," to align with the license basis and other proposed changes to the TS.
  • Revise the TS table of contents to delete two TS sections and to align the table of contents with changes associated with previously issued license amendments.

The proposed TS changes are marked in Attachment 1; the TS retyped pages incorporating the proposed changes are provided in Attachment 2. The planned TS Bases changes in Attachment 3 are provided for information only.

2.0 DETAILED DESCRIPTION On December 9, 2002, FENOC submitted a license amendment request supporting partial implementation of alternative source term (AST) for the Perry Nuclear Power Plant (PNPP). On March 4, 2003, NRC staff issued License Amendment No. 122, which established a license basis that included the following AST aspects for a design basis fuel handling accident (FHA):

  • No credit taken for the fuel handling building exhaust system (FHBES).
  • No credit taken for fuel handling building (FHB) integrity.
  • A fission product decay period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (time period from the reactor shutdown to the first fuel movement).

The current PNPP TS for the FHB and the FHBES are applicable during the movement of recently irradiated fuel (irradiated fuel that has been subcritical < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). The current TS are not aligned with the license basis that was established with Amendment No. 122.

On December 6, 2013, FENOC submitted a license amendment request supporting full implementation of AST for the PNPP. On March 30, 2015, NRC staff issued License Amendment No. 166, which established a license basis that included the following AST aspects:

Page 3 of 13

  • Design basis loss of coolant accident (LOCA) credits an 80 percent removal efficiency of elemental iodine and organic iodide by the CRER system charcoal filters.
  • None of the radiological consequence analyses credit any removal of elemental and organic iodines by the AEGT system charcoal filters.

The current PNPP TS allowable secondary containment bypass leakage criterion is >

0.0504 La. The current ventilation filter testing program TS is based on a 95 percent removal efficiency by the CRER system charcoal filters and credits removal of elemental iodine and organic iodides by the AEGT system charcoal filters. The current TS are not aligned with the license basis that was established with Amendment No. 166.

On September 20, 2012, the NRC approved Technical Specification Task Force (TSTF)

Traveler TSTF-522, which identified the following AEGT and CRER system surveillance enhancements:

  • Licensees can revise AEGT and CRER system surveillance requirements to only require operation of the systems for 15 continuous minutes.
  • Licensees can revise AEGT and CRER system surveillance requirements to delete "with heaters operating," if a 95 percent (%) relative humidity (RH) charcoal testing criterion is also adopted.

The current PNPP TS surveillance requirements for the AEGT and CRER systems require operation of the systems for 10 continuous hours with heaters operating.

FENOC proposes to revise the PNPP TS as follows.

2.1 SYSTEM RUNTIME AND HEATER OPERATION FENOC proposes to amend TS 3.7.3, "Control Room Emergency Recirculation (CRER)

System," by revising SR 3.7.3.1 to align with NUREG-1434, Revision 4, Volume 1, "Standard Technical Specifications - General Electric BWR/6 Plants," the NRC-approved Technical Specification Task Force (TSTF) Traveler 522, "Revise Ventilation System Surveillance Requirement to Operate for 10 Hours per Month," and RG 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," Revision 4.

FENOC also proposes to amend TS 3.6.4.3, "Annulus Exhaust Gas Treatment (AEGT)

System," to align SR 3.6.4.3.1 with the changes proposed for SR 3.7.3.1.

2.1.1 Proposed Changes to SR 3.7.3.1 PNPP SR 3.7.3.1 currently requires operating each CRER subsystem for greater than or equal to (£) 10 continuous hours with the heaters operating in accordance with the Surveillance Frequency Control Program.

With the proposed change, PNPP SR 3.7.3.1 will read "Operate each CRER subsystem for > 15 continuous minutes." The requirement "with heaters operating" will also be deleted. There is no change to the frequency requirement, which remains, "In accordance with the Surveillance Frequency Control Program."

Page 4 of 13 2.1.2 Proposed Changes to SR 3.6.4.3 PNPP SR 3.6.4.3.1 currently requires operating each AEGT subsystem for > 10 continuous hours with the heaters operating.

The proposed amendment to PNPP TS 3.6.4.3, "Annulus Exhaust Gas Treatment (AEGT)

System," will align PNPP SR 3.6.4.3.1 to the changes proposed for SR 3.7.3.1.

With the proposed change, PNPP SR 3.6.4.3.1 will read "Operate each AEGT subsystem for > 15 continuous minutes." The requirement "with heaters operating" will be deleted.

There is no change to the frequency requirement, which remains "In accordance with the Surveillance Frequency Control Program."

2.2 TECHNICAL SPECIFICATIONS NO LONGER ALIGNED WITH LICENSE BASIS FENOC proposes to delete the following technical specifications because the FHB and FHBES are not credited in the current FHA analysis, and their APPLICABILITY statements, which read "During movement of recently irradiated fuel assemblies in the FHB," are not applicable. Where necessary, the word "Deleted" will be added to the TS.

  • Delete TS 3.7.8, "Fuel Handling Building," in its entirety.
  • Delete TS 3.7.9, "Fuel Handling Building Ventilation Exhaust System," in its entirety.

TS 3.7.7, "Fuel Pool Water Level," will be revised to add a parenthetical note (next page is 3.7-19) at the bottom of page 3.7-14. This change is necessary due to the deletion of TS pages associated with TS 3.7.8 and TS 3.7.9. This proposed change is a non-technical administrative change and further discussion in Section 3.0, TECHNICAL EVALUATIONS, is not required.

2.3 SECONDARY CONTAINMENT BYPASS LEAKAGE Revision to SR 3.6.1.3.9 FENOC proposes to revise the TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)," SR 3.6.1.3.9, to align the secondary containment bypass leakage rate criterion to the license basis. With the revision, SR 3.6.1.3.9 will read "Verify the combined leakage rate for all secondary containment bypass leakage paths is < 0.1008 La when pressurized to > Pa." No other changes are proposed for this SR.

2.4 VENTILATION FILTER TESTING PROGRAM v Revision to TS 5.5.7. "Ventilation Filter Testing Program (VFTP)"

FENOC proposes to revise TS 5.5.7 as follows:

  • All references to the "Fuel Handling Building" will be deleted. Testing of the FHB ventilation system in TS 5.5.7.a.b, 5.5.7.b.b, 5.5.7.c.b, 5.5.7.d.b, and 5.5.7.e.b will also be deleted. Additionally, TS 5.5.7.a.c will be renumbered to TS 5.5.7.a.b, and TS 5.5.7.d.c will be renumbered to TS 5.5.7.d.b.
  • Charcoal adsorber testing requirements associated with the annulus exhaust gas treatment (AEGT) system will be deleted. Specifically, testing of the AEGT system charcoal adsorbers in TS 5.5.7.b.c and 5.5.7.c.c will be deleted.

Page 5 of 13

and TS 3.7.3, "Control Room Emergency Recirculation (CRER) System," previously discussed the deletion of the requirement "with the heaters operating." TS 5.5.7.e for heater testing will be deleted in its entirety.

  • For the CRER system, the license basis currently requires charcoal adsorbers during a design basis loss of coolant accident. With no operating heaters (that is, no humidity control), TS 5.5.7.c.a will list the required 95% RH test criterion for the charcoal adsorber sample. Additionally, the charcoal adsorber methyl iodine penetration testing criterion will be changed from 2.5% to 10%.
  • For TS 5.5.7, references to Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.52, Revision 2, "Design, Testing, and Maintenance Criteria for Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Absorption Units of Light-Water-Cooled Nuclear Power Plants," will be replaced with a reference to RG 1.52, Revision 4.

2.5 TECHNICAL SPECIFICATIONS TABLE OF CONTENTS Revision to TS Table of Contents FENOC proposes to revise the TS table of contents (TOC) as described below:

  • The title of TS 3.3.6.1 will read "Primary Containment and Drywell Isolation Instrumentation." This TOC change, which adds the text "and Drywell" into the title, aligns the TOC with the title of TS 3.3.6.1 established by License Amendment No. 69, issued June 23, 1995 [Ref. 1].
  • The title of TS 3.6.1.9 will read "Main Steam Shutoff Valves." This TOC change, which deletes the text "Isolation Valve (MSIV) Leakage Control System (LCS)" and replaces it with the text "Shutoff Valves," aligns the TOC with the title of TS 3.6.1.9 established by License Amendment No. 103, issued March 26, 1999 [Ref. 2].
  • The title of TS 3.6.3.1, "Primary Containment Hydrogen Recombiners," will be removed in its entirety and replaced with "Deleted." This change aligns the TOC with License Amendment No. 135, issued on April 19, 2005 [Ref. 3].
  • The title of TS 3.7.8, "Fuel Handling Building," will be removed in its entirety and replaced with "Deleted." This deletion is associated with a TS change proposed in this license amendment request.
  • The title of TS 3.7.9, "Fuel Handling Building Ventilation Exhaust System," will be removed in its entirety and replaced with "Deleted." This deletion is associated with a TS change proposed in this license amendment request.

These proposed changes are considered non-technical administrative changes and further discussion in Section 3.0, TECHNICAL EVALUATIONS, is not required.

3.0 TECHNICAL EVALUATION

S 3.1 SYSTEM RUNTIME AND HEATER OPERATION Revised SR 3.6.4.3.1 and SR 3.7.3.1 Surveillance Requirements The revised SR 3.7.3.1 system runtime requirement of 15 continuous minutes, as proposed, will align with NUREG-1434, Revision 4, Volume 1, "Standard Technical Specifications - General Electric BWR/6 Plants." The revised runtime requirement also aligns with the NRC-approved Technical Specification Task Force (TSTF) Traveler 522,

Page 6 of 13 "Revise Ventilation System Surveillance Requirement to Operate for 10 Hours per Month,"

and RG 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," Revision 4.

According to the updated safety analysis report (USAR), Section 6.5.1, the AEGT and CRER systems are engineered safety features (ESF) filter systems. Both systems have the same design bases and design functions, and charcoal adsorber plenum components.

Both systems include heaters currently used to maintain RH of the exhaust air at 70% or less. These system similarities support the following discussion regarding the proposed changes to SR 3.6.4.3.1 and their alignment to the changes proposed for SR 3.7.3.1.

The revised SR 3.6.4.3.1 system runtime requirement of 15 continuous minutes, as proposed, will align the AEGT system requirement to the CRER system runtime changes proposed for SR 3.7.3.1 (a similar ESF filter system, as described above).

NUREG-1434 and RG 1.52 provide the basis for changing the ventilation system runtime requirements from 10 continuous hours to 15 continuous minutes. From NUREG-1434, Volume 2, Bases for SR 3.7.3.1, "Systems without heaters need only be operated for > 15 minutes to demonstrate the function of the system." From RG 1.52, Section C.6.a, "Each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the system and all its components."

Though currently equipped with heaters, FENOC will no longer require the AEGT and CRER systems to operate with their heaters. Revising SR 3.6.4.3.1 and SR 3.7.3.1 to remove the text "with the heaters operating," as proposed, is considered acceptable because FENOC is also revising the applicable charcoal adsorber testing requirements consistent with ventilation systems without heaters.

RG 1.52, Revision 4, Section C.4.i, states "systems without humidity control should perform laboratory testing of representative samples of activated carbon at a relative humidity of 95%." TSTF-522 states that "Plants which test ventilation system adsorption at a relative humidity of 95% do not require heaters for the ventilation system to perform its specified safety function" and "may eliminate the reference to heaters in the Surveillance Requirements and Bases." FENOC proposes to revise TS 5.5.7 to reflect changes in testing requirements for the AEGT and CRER systems consistent with TSTF-522 and RG 1.52, Revision 4.

3.2 TECHNICAL SPECIFICATIONS NO LONGER APPLICABLE TS 3.7.8 and TS 3.7.9 are only applicable during movement of recently irradiated fuel assemblies in the FHB. Deletion of these two technical specifications, TS 3.7.8 and TS 3.7.9, as proposed, is considered acceptable since their deletion will align the technical specifications with the license basis and the FHA analysis submitted to the NRC by FENOC on December 9, 2002 [Ref. 4]. In the submittal, FENOC identified use of an alternative source term radiological calculation to update the design basis for the FHA.

The submitted calculation took no credit for FHB integrity and no credit for the FHBES.

After its review, the NRC issued License Amendment No. 122 on March 4, 2003 [Ref. 5],

approving FENOC's requested license amendment.

Page 7 of 13 USAR Section 15.7.4, states "This accident [fuel handling accident outside containment] is not reanalyzed as part of the reload analysis as the fuel handling accident inside containment analysis is bounding." USAR Section 15.7.6 states, "Handling of 'recently irradiated fuel' is prohibited, because no dose calculations exist to address a fuel handling accident within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the core is subcritical." Additionally, the current configuration of the PNPP and the actions necessary to access and move irradiated fuel do not enable the movement of irradiated fuel that has been subcritical < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (that is, "recently irradiated fuel"). As such, a technical specification whose APPLICABILITY, CONDITION, or REQUIRED ACTION related to the allowed movement of "recently irradiated fuel" or irradiated fuel that has been subcritical < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> should not apply, exist, or be performed.

The proposed deletion of TS 3.7.8 and TS 3.7.9 was reviewed against 10 CFR 50.36, "Technical specifications," and its criteria. Of the four criterion in 10 CFR 50.36, the following two criterion are cited in the Bases for TS 3.7.8 ancTTS 3.7.9.

Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

FENOC concludes that the proposed deletion of TS 3.7.8 and TS 3.7.9 is acceptable based on the following:

  • The license basis prohibits the movement of irradiated fuel that has been subcritical < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (recently irradiated fuel).
  • The current configuration of the PNPP and the actions necessary to access and move irradiated fuel do not enable the movement of irradiated fuel that has been subcritical < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (recently irradiated fuel).
  • The license basis does not credit the FHB or the FHBES in mitigating the consequences of a FHA in the FHB.
  • The FHB and the FHBES no longer meet the 10 CFR 50.36 criteria for establishing a technical specification limiting condition for operation based on:

o The FHB and the FHBES are not relied upon to mitigate a FHA in the FHB.

o FENOC does not intend to revise existing accident analyses (FHA dose calculations) to re-credit the FHB or the FHBES during the movement of recently irradiated fuel.

  • TS whose APPLICABILITY, CONDITION, or REQUIRED ACTION is only related to the movement of recently irradiated fuel should not apply, exist, or be performed.

The FHB will remain categorized as a safety-related, Seismic Category I structure and the FHBES will remain a safety-related, Seismic Category I system.

Page 8 of 13 3.3 SECONDARY CONTAINMENT BYPASS LEAKAGE Revised SR 3.6.1.3.9 The revised surveillance requirement, as proposed, is considered acceptable since it will align with the license basis, USAR Section 15.6.5.5.1.4, which states "The analysis conservatively assumes 10.08% [percent] of the primary containment leakage bypasses the secondary containment..," The license basis was updated as part of the alternative source term initiative submitted to the NRC by FENOC on December 6, 2013 [Ref. 6]. In the submittal, FENOC identified use of an alternative source term radiological calculation to revise the allowable secondary containment bypass leakage rate to 10.08%. After its review, the NRC issued License Amendment No. 166 on March 30, 2015 [Ref. 7],

approving FENOC's requested license amendment.

This SR revision does not require a change to existing testing methods and prescribed testing will continue to be performed in accordance with approved procedures, thus ensuring the secondary containment is capable of performing its design basis function.

3.4 VENTILATION FILTER TESTING PROGRAM Revised TS 5.5.7. "Ventilation Filter Testing Program (VFTPV The revised TS, as proposed, is considered acceptable since it will align with the license basis and the proposed TS changes discussed herein.

Revised TS 5.5.7.a.b, 5.5.7.b.b, 5.5.7.c.b, 5.5.7.d.b, and 5.5.7.e.b, which deletes all references to the "Fuel Handling Building," is considered acceptable since these changes will align with the current FHA analysis. The analysis took no credit for the FHB or the FHBES. Additionally, TS 3.7.9, "Fuel Handling Building Exhaust System," is proposed for deletion. With the system deleted from the technical specifications, there is no basis to provide testing criteria for the system in TS 5.5.7.

Revised TS 5.5.7.b.c and 5.5.7.c.c, which deletes charcoal adsorber testing requirements for the AEGT system, is considered acceptable since they will align with USAR Section 15.6.5.5.1. According to the license basis, none of the accident analyses credit iodine removal by charcoal adsorbers in the annulus exhaust gas treatment (AEGT) system. With no requirement to have charcoal adsorbers, there is no need to provide testing criteria for the charcoal adsorbers in TS 5.5.7.

Revised TS 5.5.7.e deletes heater testing in its entirety based on the following

  • The previously discussed revisions to TS 3.6.4.3, "Annulus Exhaust Gas Treatment (AEGT) System," and TS 3.7.3, "Control Room Emergency Recirculation (CRER)

System," propose deleting the requirement "with the heaters operating." With no requirement to have the heaters operating, testing of the AEGT and CRER system heaters in TS 5.5.7.e.a and 5.5.7.e.c will be deleted.

  • The previously discussed deletion of the FHBES TS removes the requirement to test the FHBES heaters in TS 5.5.7.e.b.

Revised TS 5.5.7.C, which changes the CRER system's charcoal adsorber testing criterion from 70% RH to 95% RH and the methyl iodine penetration criterion from 2.5% to 10%, is considered acceptable since they align with NUREG-1434 and the license basis as discussed below. ^

Page 9 of 13

  • Deleting requirements for heaters is justified because the testing requirements of ASTM D3803-1989 for a system without heaters will be utilized. However, this results in a CRER system without humidity control and compliance with the current PNPP TS 5.5.7.C testing criterion of 70% RH may not be achievable at all times.

NUREG-1434, TS 5.5.8.C, specifically addresses RH criterion as follows:

ASTM D3803-1989 is a more stringent testing standard because it does not differentiate between used and new charcoal, it has a longer equilibrium period performed at a temperature of 30°C (86°F) and a relative humidity (RH) of 95% (or 70% RH with humidity control) and it has more stringent tolerances that improve repeatability of the test.

For the PNPP, ASTM D3803-1989 is already cited in TS 5.5.7. However, not having heaters results in a lack of humidity control. As such, the CRER charcoal adsorber testing criterion shall reflect the NUREG-1434, TS 5.5.8 testing criterion of 95% RH (with no humidity control).

  • Changing the methyl iodine penetration criterion from 2.5% to 10% for the CRER system is consistent with USAR Section 15.6.5.5.1, which states "The LOCA analysis is based on... utilizing elemental and organic iodine removal efficiencies of 80 percent for the control room emergency recirculation system charcoal adsorbers." The LOCA analysis is the only accident analysis that credits the control room emergency recirculation system charcoal adsorbers. NUREG-1434, TS 5.5.8, provides the methodology for determining methyl iodine allowable penetration criterion as follows:

Allowable Penetration = [(100% - Methyl Iodine Efficiency for Charcoal Credited in Licensee's Accident Analysis) / Safety Factor]

When ASTM D3803-1989 is used with 30°C (86°F) and 95% RH (or 70% RH with humidity control) is used, the staff accepts a safety factor > 2 for systems with or without humidity control.

As stated, the license basis cites an 80 percent removal efficiency for the CRER system. Inserting the 80 percent value into the NUREG-1434 equation results in the following methyl iodine penetration criterion:

Allowable Penetration = [(100% - 80%) / 2] = 10 percent.

  • Changing from RG 1.52, Revision 2, to RG 1.52, Revision 4, is considered acceptable based on the following:

o RG 1.52, Revision 4, is the latest edition of this document.

o Per RG 1.52, Revision 4, Section C.4.i, "...systems without humidity control

[without heaters] should perform laboratory testing of representative samples of activated carbon at a relative humidity of 95%." This supports the previously discussed revisions to delete the "with heater operating" requirement from TS 3.6.4.3, "Annulus Exhaust Gas Treatment (AEGT) System," and TS 3.7.3, "Control Room Emergency Recirculation (CRER) System."

o Per RG 1.52, Revision 4, Section C.6.a, "Each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with heaters on (if so equipped), to justify the operability of the system and all of its components." This supports the previously discussed system runtime revisions in TS 3.6.4.3 and TS 3.7.3.

Page 10 of 13 o Per RG 1.52, Revision 4, Section C.7.b, "Sampling and analysis should be performed... at least once every 24 months." The 24-month testing frequency aligns with the current PNPP 24-month operating cycle.

o The NRC-approved Technical Specification Task Force (TSTF) Traveler 522, "Revise Ventilation System Surveillance Requirement to Operate for 10 Hours per Month," used the guidance in RG 1.52, Revision 3, in support of changing system runtime and heater operating requirements. RG 1.52, Revision 4, maintains the same system runtime and heater operating requirements.

4.0 REGULATORY EVALUATION

The proposed amendment to the Perry Nuclear Power Plant (PNPP) Technical Specifications (TS) would:

  • Revise TS 3.7.3, "Control Room Emergency Recirculation (CRER) System," to change the runtime requirement from "10 continuous hours" to "15 continuous minutes," and to delete "with heaters operating" in Surveillance Requirement (SR) 3.7.3.1.
  • Revise TS 3.6.4.3, "Annulus Exhaust Gas Treatment (AEGT) System," to change the runtime requirement from "10 continuous hours" to "15 continuous minutes," and to delete "with heaters operating" in SR 3.6.4.3.1 to align it with proposed changes to SR 3.7.3.1.
  • Delete TS 3.7.8, "Fuel Handling Building," to align with the license basis.
  • Delete TS 3.7.9, "Fuel Handling Building Ventilation Exhaust System," to align with the license basis.
  • Revise TS 3.7.7, "Fuel Pool Water Level," to add a parenthetical note at the bottom of the page, which cites the next TS page number. This is necessary due to the deletion of TS pages associated with TS 3.7.8 and TS 3.7.9.
  • Revise TS 5.5.7, "Ventilation Filter Testing Program (VFTP)," to align with the license basis and other proposed changes to the TS.
  • Revise the TS table of contents to delete two TS sections and to align the table of ^

contents with changes associated with previously issued license amendments.

4.1 Significant Hazards Consideration FirstEnergy Nuclear Operating Company (FENOC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed amendment involves incorporating technical specification changes that reflect previously approved license basis changes as part of the alternative source term (AST) initiative, aligns some TS sections with NUREG-1434, Revision 4, and deletes two

Page 11 of 13 TS sections. The proposed amendment does not affect any accident mitigating feature or increase the likelihood of malfunction for plant structures, systems and components.

Verification of operating the plant within prescribed limits will continue to be performed, as currently required by the applicable TS surveillance requirements. Compliance with and continued verification of the prescribed limits support the capability of the systems to perform their required design functions during all plant operating, accident, and station blackout conditions, consistent with the plant safety analyses.

The proposed amendment will not change any of the analyses associated with the PNPP Updated Safety Analysis Report Chapter 15 accidents because accident initiators and accident mitigation functions remain unchanged. The proposed amendment does not alter any assumptions previously made relative to evaluating the consequences of an accident.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed amendment does not involve physical alterations to the plant. No new or different type of equipment will be installed and there are no physical modifications required to existing installed equipment associated with the proposed changes. The proposed amendment does not create a credible failure mechanism, malfunction, or accident initiator not already considered in the design and licensing basis.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Safety margins are applied to design and licensing basis functions and to the controlling values of parameters to account for various uncertainties and to avoid exceeding regulatory or licensing limits. The proposed amendment does not require a physical change to the plant, or affect design and licensing basis functions or controlling values of parameters for plant systems, structures, and components.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the responses to the three questions above, FENOC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 12 of 13 4.2 Applicable Regulatory Requirements/Criteria The following regulatory requirements and criteria were reviewed during development of the proposed license amendment:

  • NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Section 15.0.1, "Radiological Consequence Analyses Using Alternative Source Terms," Revision 0.
  • RG 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," Revision 4.

FENOC has determined that the proposed amendment is consistent with the regulatory requirements and criteria described in the above cited documents. No new or revised radiological consequence analyses are necessary to support the changes proposed by this amendment. Radiological dose consequences resulting from a design basis accident are unchanged within the PNPP license basis. In accordance with technical specification requirements, the necessary quality of systems and components is maintained, facility operation will be within safety limits, and limiting conditions for operation will be met.

4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Nuclear Regulatory Commission letter to Centerior Service Company,

Subject:

Amendment No. 69 to Facility Operating License No. NPF Perry Nuclear Power Plant, Unit No. 1 (TAC No. M88400), June 23, 1995.

[Accession No. ML021830716]

2. Nuclear Regulatory Commission letter to FirstEnergy Nuclear Operating Company,

Subject:

Amendment No. 103 to Facility Operating License No. NPF Perry Nuclear Power Plant, Unit 1 (TAC No. M96931), March 26, 1999.

[Accession No. ML021840462]

Page 13 of 13

3. Nuclear Regulatory Commission letter to FirstEnergy Nuclear Operating Company,

Subject:

Perry Nuclear Power Plant, Unit 1 - Issuance of Amendment Re:

Elimination of Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process (TAC No. MC5024),

April 19, 2005. [Accession No. ML050400059]

4. FirstEnergy Nuclear Operating Company letter to Nuclear Regulatory Commission,

Subject:

License Amendment Request Pursuant to 10 CFR 50.90: Alternative Source Term Update of the Design Basis Analyses for the Fuel Handling Accident, December 9, 2002. [Accession No. ML023610200]

5. Nuclear Regulatory Commission letter to FirstEnergy Nuclear Operating Company,

Subject:

Perry Nuclear Power Plant, Unit 1 - Issuance of Amendment (TAC No. MB6928), March 4, 2003. [Accession No. ML023580025]

6. FirstEnergy Nuclear Operating Company letter to Nuclear Regulatory Commission,

Subject:

Request for Licensing Action Pursuant to 10 CFR 50.59, 50.67, and 50.90; Full Implementation of Alternative Accident Source Term Design Basis Accident Analyses, and an associated Technical Specification Change, December 6, 2013.

[Accession No. ML13343A013]

7. Nuclear Regulatory Commission letter to FirstEnergy Nuclear Operating Company,

Subject:

Perry Nuclear Power Plant, Unit No. 1 - Issuance of Amendment Concerning Full Implementation of Alternative Source Term (TAC No.

MF3197)(L-13-306), March 30, 2015. [Accession No. ML15075A139]

Attachment 1 Proposed Technical Specification Changes (MARK-UP)

(14 Pages Follow)

lTSMARK-uF TABLE OF CONTENTS 1.0 USE AND APPLICATION 1.1 Definitions 1.0-1 1.2 Logical Connectors 1.0-8 1.3 Completion Times 1.0-11 1.4 Frequency 1.0-24 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.0-1 2.2 SL Violations 2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 3.0-4 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN MARGIN (SDM) 3.1-1 3.1.2 Reactivity Anomalies 3.1-5 3.1.3 Control Rod OPERABILITY 3.1-7 3.1.4 Control Rod Scram Times 3.1-12 3.1.5 Control Rod Scram Accumulators 3.1-15 3.1.6 Control Rod Pattern 3.1-18 3.1.7 Standby Liquid Control (SLC) System 3.1-20 3.1.8 Scram Discharge Volume (SDV) Vent and Drain Valves 3.1 -24 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) 3.2-1 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR) '. 3.2-2 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) 3.2-3 3.3 INSTRUMENTATION 3.3.1.1 Reactor Protection System (RPS) Instrumentation 3.3-1 3.3.1.2 Source Range Monitor (SRM) Instrumentation 3.3-10 3.3.2.1 Control Rod Block Instrumentation 3.3-15 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation 3.3-20 3.3.3.2 Remote Shutdown System .3.3-24 3.3.4.1 End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation 3.3-26 3.3.4.2 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation 3.3-29 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation 3.3-32 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation 3.3-44 3.3.6.1 Primary Containment and Drvweil Isolation Instrumentation 3.3-48 3.3.6.2 Residual Heat Removal (RHR) Containment Spray System Instrumentation 3.3-60 (continued)

PERRY - UNIT 1 i Amendment No. 60

ITS MARK-UP l TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.6.3 Suppression Pool Makeup (SPMU) System Instrumentation 3.3-64 3.3.6.4 Relief and Low-Low Set (LLS) Instrumentation 3.3-68 3.3.7.1 Control Room Emergency Recirculation (CRER) System Instrumentation 3.3-70 3.3.8.1 Loss of Power (LOP) Instrumentation 3.3-74 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring 3.3-77 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 Recirculation Loops Operating 3.4-1 3.4.2 Flow Control Valves (FCVs) 3.4-6 3.4.3 Jet Pumps 3.4-8 3.4.4 Safety/Relief Valves (S/RVs) 3.4-10 3.4.5 RCS Operational LEAKAGE 3.4-12 3.4.6 RCS Pressure Isolation Valve (PIV) Leakage 3.4-14 3.4.7 RCS Leakage Detection Instrumentation 3.4-16 3.4.8 RCS Specific Activity 3.4-19 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown 3.4-21 3.4.10 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown 3.4-24 3.4.11 RCS Pressure and Temperature (PfT) Limits 3.4-26 3.4.12 Reactor Steam Dome Pressure 3.4-32 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating 3.5-1 3.5.2 ECCS - Shutdown 3.5-6 3.5.3 RCIC System 3.5-10 3.6 CONTAINMENT SYSTEMS 3.6.1.1 Primary Containment - Operating 3.6-1 3.6.1.2 Primary Containment Air Locks 3.6-3 3.6.1.3 Primary Containment Isolation Valves (PCIVs) 3.6-9 3.6.1.4 Primary Containment Pressure 3.6-20 3.6.1.5 Primary Containment Air Temperature 3.6-21 3.6.1.6 Low-Low Set (LLS) Valves 3.6-22 3.6.1.7 Residual Heat Removal (RHR) Containment Spray System 3.6-24 3.6.1.8 Feedwater Leakage Control System (FWLCS) 3.6-26 3.6.1.9 Main Steam Shutoff Valveslsolation Valvo (MSIV) Leakage Control Syctom

{LGS) 3.6-27 3.6.1.10 Primary Containment - Shutdown 3.6-29 3.6.1.11 Containment Vacuum Breakers 3.6-31 3.6.1.12 Containment Humidity Control 3.6-34 3.6.2.1 Suppression Pool Average Temperature 3.6-36 (continued)

PERRY-UNIT 1 ii Amendment No. 69

lTSMARK-UP"l TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS (continued) 3.6.2.2 Suppression Pool Water Level 3.6-39 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling 3.6-40 3.6.2.4 Suppression Pool Makeup (SPMU) System 3.6-42 3.6.3.1 DeletedPrimarv Containment Hydrogen Recombiners 3 6 44 3.6.3.2 Primary Containment and Drywell Hydrogen Igniters 3.6-46 3.6.3.3 Combustible Gas Mixing System 3.6-49 3.6.4.1 Secondary Containment 3.6-51 3.6.4.2 Secondary Containment Isolation Valves (SCIVs) 3.6-53 3.6.4.3 Annulus Exhaust Gas Treatment (AEGT) System 3.6-56 3.6.5.1 Drywell 3.6-59 3.6.5.2 Drywell Air Lock 3.6-61 3.6.5.3 Drywell Isolation Valves 3.6-65 3.6.5.4 Drywell Pressure 3.6-69 3.6.5.5 Drywell Air Temperature 3.6-70 3.6.5.6 Drywell Vacuum Relief System 3.6-71 3.7 PLANT SYSTEMS 3.7.1 Emergency Service Water (ESW) System - Divisions 1 and 2 3.7-1 3.7.2 Emergency Service Water (ESW) System - Division 3 3.7-3 3.7.3 Control Room Emergency Recirculation (CRER) System 3.7-4 3.7.4 Control Room Heating, Ventilation, and Air Conditioning (HVAC)

System 3.7-8 3.7.5 Main Condenser Offgas 3.7-11 3.7.6 Main Turbine Bypass System 3.7-13 3.7.7 Fuel Pool Water Level 3.7-14 3.7.8 DeletedFuel Handling Building 3.7 15 3.7.9 DeletedFuel Handling Building Ventilation Exhaust Syctom 3.7-16 3.7.10 Emergency Closed Cooling Water (ECCW) System 3.7-19 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating 3.8-1 3.8.2 AC Sources - Shutdown 3.8-17 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8-21 3.8.4 DC Sources-Operating 3.8-24 3.8.5 DC Sources - Shutdown 3.8-28 3.8.6 Battery Cell Parameters 3.8-32 3.8.7 Distribution Systems - Operating 3.8-36 3.8.8 Distribution Systems - Shutdown 3.8-38 3.9 REFUELING OPERATIONS 3.9.1 Refueling Equipment Interlocks 3.9-1 3.9.2 Refuel Position One-Rod-Out Interlock 3.9-2 3.9.3 Control Rod Position 3.9-4 3.9.4 Control Rod Position Indication 3.9-5 (continued)

PERRY-UNIT 1 iii Amendment No. §9

ltsmark-up1 PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.9 -NOTES-

1. Only required to be met in MODES 1, 2, and 3.
2. Main Steam Line leakage is not included.

Verify the combined leakage rate for all secondary In accordance containment bypass leakage paths is £ 0.0504 with the Primary 0.1008 U when pressurized to £ Pa. Containment Leakage Rate Testing Program SR 3.6.1.3.10 -NOTE-Only required to be met in MODES 1, 2, and 3.

Verify leakage rate through each main steam line is In accordance

£ 100 scfh when tested at £ Pa, and the total with the Primary leakage rate through all four main steam lines is Containment

£ 250 scfh, when tested at £ Pa. Leakage Rate Testing Program (continued)

PERRY-UNIT 1 3.6-18 Amendment No.

TS MARK-UP"! AEGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each AEGT subsystem for £ 150 continuous In accordance hours with heators oporatinq continuous minutes. with the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required AEGT filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.4.3.3 Verify each AEGT subsystem actuates on an actual In accordance or simulated initiation signal. with the Surveillance Frequency Control Program PERRY-UNIT 1 3.6-58 Amendment No.

lTS MARK-UP l CRER System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CRER subsystems F.1 Suspend movement of Immediately inoperable during recently irradiated fuel movement of recently assemblies in the primary irradiated fuel assemblies containment and fuel in the primary handling building.

containment or fuel handling building, or AND during OPDRVs.

F.2 Initiate action to suspend Immediately OR OPDRVs.

One or more CRER subsystems inoperable -

due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CRER subsystem for £ .1544 In accordance continuous minutes, hours with the heatorc with the operating. Surveillance Frequency Control Program SR 3.7.3.2 Perform required CRER filter testing in accordance In accordance with the Ventilation Filter Testing Program (VTFP). with the VFTP (continued)

PERRY-UNIT 1 3.7-6 Amendment No. 474

lts mark-up"! Fuel Pool Water Level 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Fuel Pool Water Level LCO 3.7.7 The fuel pool water level shall be £ 23 ft over the top of the irradiated fuel assemblies seated in the fuel handling building (FHB) and upper containment fuel storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the associated fuel storage pools.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel pool water level not A.1 MOTP

_________ -.l^ly^ l £-____ ____________

within limit. LCO 3.0.3 is not applicable.

Suspend movement of Immediately irradiated fuel assemblies in the associated fuel storage pool(s).

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify the fuel pool water level is -_ 23 ft over the top In accordance of irradiated fuel assemblies seated in the storage with the racks. Surveillance Frequency Control Program PERRY-UNIT 1 3.7-14 (next page is 3.7-19) Amendment No. 474-

lTS MARK-UP... DELETED PAGE l fuel Handling Euci Handling Dulli Iho fuel )iond11ngJui;1;dfng (niD) shall fe During fnovcmcfijt of Pjecently irradiated fuel TTl the THD; "

ACTIONS liCQ. 3.0,3 is not opplfeabie.

CONDXTiQ>l  ; RCQUIRCP Att^j 'i coMPilnoN im .

& ri)D: inopiDPOblG, l Arl Suspend movement of Iritncdiotciy recently i/tailaled ,

fUeT asseftibiieis, in  ;

SURVPttANCC PRCQUCWCY SB 3,,7*8* 1 Vcri.% oil fllD floor hatches and the shield In.accordahce blocks adjacent tothe shield building are with the installed, and the. ffP railroad track ddor i is closed.

1 each niD occcss door is closed, In accordance When, the access^ opening is being ' wi th the for entry and exit/ Survei1lanoe rrequency Control Program; U..,i XJ Anidndment

ruel Handling Building Ventilation Xxhaust System TS MARK-UP... DELETED PAGE 3J 'PLANT SYSTEMS '

'3,7,9 fuel Uandiing, Building Ventilation Exhaust System, LCD 3.7,9 Thi?ee fuel handling building (HID) ventilation exhaust subsystems shall be.OPERAOLL APPUCADILITY: During movement of rfrtcfltly irradiated fuel assemblies in 8he. RID.

is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A, One. required fMB veritiiotibn exhaust ventilation exhaust bsystem inKI subsystem to OPERABLE Status..

Required Action and PI oca two OPERABLE Ifnmediately associated Completion HIB ventilation Time of Condition A exhaust subsystems in not met, operation.

Suspend'movement of Immediately recently irradiated fuel- assemblies in the F1ID, Tv^o or three TUB: Suspend movement of Immediiitely ventIiation exhaust- recently irradiated subsystems inoperable. fuel .assemblies in the HID.

(continued) mm

tfl H4j>>Uiiii§ Ouiidihg; i?, £xtijlusi TS MARK-UP... DELETED PAGE CONDITION REQUIREP tmc hid Ob'taif* :4 Atfars.

g of wonitor (noble gas) TUB cxtiausl effiaient Unit

'vent Place

, ekhaust jn the:

tnp]pjci cohditi60, UNIT 1 Amendment No. 69

TS MARK-UP... DELETED PAGE fuel Hanoi ing Building j/entUfliipn ICxhaust System RtQUlRCMCKTS SUMEILtAfiCt rREQUflJCY 3,J,Q,S Operate cpch flip ventilation exhaust Tn acGprdance sUpsygteni for * -IO* continuous houri with K the h

heaters operating. SurvciiioncE Control:

5rR XT&2 Perform flltt ventilation.cxhftust filter in QCGdrdonce testing .in occ^Pdanee with the Ventilation ir Testing; Program (VfTPlv -

$R Perfbrtff <a syst'ew functional test. iin dccor with the frequenc (Control '

ncrfonn ^a CHANNd niNCTlONAL TCST of the ;In accordance, Tl;IO VcKittJflition exhouiit rodiatioh monitor wilth the (noble

  • Amendment Ho.1171

lTS MARK-UPl Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.6 Deleted.

5.5.7 Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies

° specified in Regulatory Guide 1.52, Revision 42.

(continued)

PERRY - UNIT 1 5.0-10 Amendment No.

ITS MARK-UP I Programs and Manuals I 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 24 and ANSI N510-1980 at the system flowrate specified below

+/- 10%:

ESF Ventilation System Flowrate a) Control Room Emergency Recirculation 30,000 cfm fe) Fuel Handling Building 15,000 ofm bG) Annulus Exhaust Gas Treatment 2,000 cfm

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 24 and ANSI N510-1980 at the system flowrate specified below +/- 10%:

ESF Ventilation System Flowrate a) Control Room Emergency Recirculation 30,000 cfm b) Fuel Handling Building 15,000 cfm g) Annulus Exhaust Gac Treatmont 2,000 cfm

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 24, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and equal to the relative humidity (RH) specified below:

ESF Ventilation System Penetration RH a) Control Room Emergency Recirculation 2t510% 7©%95%

b) Fuol Handling Building 2^5% 70%

g) Annulus Exhaust Gas Troatmont 0rS% 70%

(continued)

PERRY - UNIT 1 5.0-11 Amendment No. 443

lTS MARK-UP I Programs and Manuals

^^^ 5.5 5.5 Programs and Manuals 5-5.7 Ventilation Filter Testing Program (VFTP1 (continued)

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 24 and ANSI N510-1980 at the system flowrate specified below

+/- 10%:

ESF Ventilation System Delta P Flowrate a) Control Room Emergency Recirculation 4:9" H2O 30,000 cfm te) Fuel Handling Building 4.9" H^Q 15,000 cfm be) Annulus Exhaust Gas Treatment 6.0" H2O 2,000 cfm

& Domonctrato that the heatorc for oaoh of the ESF cyctomc dissipate tho valuo specified below +/- 10% when corrected to nominal input voltago when toctod in accordanco with ANSI N510 1980.

ESF Ventilation Svctom Wattago a) Control Room Emergency Rooiroulation 100 kW b) Fuel Handling Building 50 kW g) Annuluo Exhauct Gac Troatmont 20 kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the main condenser offgas treatment system, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The program shall include:

a. The limits for concentrations of hydrogen in the main condenser offgas treatment system and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion); and (continued)

PERRY - UNIT 1 5.0-12 Amendment No. 443

Attachment 2 Proposed Technical Specification Changes (RETYPED)

(10 Pages Follow)

TS RETYPED FOR INFORMATION ONLY TABLE OF CONTENTS 1.0 USE AND APPLICATION 1.1 Definitions 1.0-1 1.2 Logical Connectors 1.0-8 1.3 Completion Times 1.0-11 1.4 Frequency  : 1.0-24 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.0-1 2.2 SL Violations 2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 3.0-4 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN MARGIN (SDM) 3.1-1 3.1.2 Reactivity Anomalies 3.1-5 3.1.3 Control Rod OPERABILITY 3.1-7 3.1.4 Control Rod Scram Times 3.1-12 3.1.5 Control Rod Scram Accumulators 3.1-15 3.1.6 Control Rod Pattern 3.1-18 3.1.7 Standby Liquid Control (SLC) System 3.1-20 3.1.8 Scram Discharge Volume (SDV) Vent and Drain Valves 3.1 -24 3.2 POWER DISTRIBUTION LIMITS ^

3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) 3.2-1 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR) 3.2-2 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) 3.2-3 3.3 INSTRUMENTATION 3.3.1.1 Reactor Protection System (RPS) Instrumentation 3.3-1 3.3.1.2 Source Range Monitor (SRM) Instrumentation 3.3-10 3.3.2.1 Control Rod Block Instrumentation 3.3-15 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation 3.3-20 3.3.3.2 Remote Shutdown System 3.3-24 3.3.4.1 End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation 3.3-26 3.3.4.2 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation 3.3-29 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation 3.3-32 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation 3.3-44 3.3.6.1 Primary Containment and Drywell Isolation Instrumentation 3.3-48 3.3.6.2 Residual Heat Removal (RHR) Containment Spray System Instrumentation 3.3-60 (continued)

PERRY-UNIT 1 i Amendment No.

TS RETYPED FOR INFORMATION ONLY TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.6.3 Suppression Pool Makeup (SPMU) System Instrumentation 3.3-64 3.3.6.4 Relief and Low-Low Set (LLS) Instrumentation 3.3-68 3.3.7.1 Control Room Emergency Recirculation (CRER) System Instrumentation 3.3-70 3.3.8.1 Loss of Power (LOP) Instrumentation 3.3-74 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring 3.3-77 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 Recirculation Loops Operating 3.4-1 3.4.2 Flow Control Valves (FCVs) 3.4-6 3.4.3 Jet Pumps 3.4-8 3.4.4 Safety/Relief Valves (S/RVs) 3.4-10 3.4.5 RCS Operational LEAKAGE /. 3.4-12 3.4.6 , RCS Pressure Isolation Valve (PIV) Leakage 3.4-14 3.4.7 RCS Leakage Detection Instrumentation 3.4-16 3.4.8 RCS Specific Activity 3.4-19 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown 3.4-21 3.4.10 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown 3.4-24 3.4.11 RCS Pressure and Temperature (P/T) Limits 3.4-26 3.4.12 ReactorSteam Dome Pressure 3.4-32 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating 3.5-1 3.5.2 ECCS - Shutdown 3.5-6 3.5.3 RCIC System..: 3.5-10 3.6 CONTAINMENT SYSTEMS 3.6.1.1 Primary Containment - Operating 3.6-1 3.6.1.2 Primary Containment Air Locks 3.6-3 3.6.1.3 Primary Containment Isolation Valves (PCIVs) 3.6-9 3.6.1.4 Primary Containment Pressure 3.6-20 3.6.1.5 Primary Containment Air Temperature 3.6-21 3.6.1.6 Low-Low Set (LLS) Valves 3.6-22 3.6.1.7 Residual Heat Removal (RHR) Containment Spray System 3.6-24 3.6.1.8 Feedwater Leakage Control System (FWLCS) 3.6-26 3.6.1.9 Main Steam Shutoff Valves 3.6-27 3.6.1.10 Primary Containment - Shutdown 3.6-29 3.6.1.11 Containment Vacuum Breakers 3.6-31 3.6.1.12 Containment Humidity Control 3.6-34 3.6.2.1 Suppression Pool Average Temperature 3.6-36 (continued)

PERRY-UNIT 1 ii Amendment No.

TS RETYPED FOR INFORMATION ONLY TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS (continued) 3.6.2.2 Suppression Pool Water Level 3.6-39 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling 3.6-40 3.6.2.4 Suppression Pool Makeup (SPMU) System 3.6-42 3.6.3.1 Deleted 3.6.3.2 Primary Containment and Drywell Hydrogen Igniters 3.6-46 3.6.3.3 Combustible Gas Mixing System 3.6-49 3.6.4.1 Secondary Containment 3.6-51 3.6.4.2 Secondary Containment Isolation Valves (SCIVs) 3.6-53 3.6.4.3 Annulus Exhaust Gas Treatment (AEGT) System 3.6-56 3.6.5.1 Drywell 3.6-59 3.6.5.2 Drywell Air Lock 3.6-61 3.6.5.3 Drywell Isolation Valves ) 3.6-65 3.6.5.4 Drywell Pressure 3.6-69 3.6.5.5 Drywell Air Temperature 3.6-70 3.6.5.6 Drywell Vacuum Relief System 3.6-71 3.7 PLANT SYSTEMS 3.7.1 Emergency Service Water (ESW) System - Divisions 1 and 2 3.7-1 3.7.2 Emergency Service Water (ESW) System - Division 3 3.7-3 3.7.3 Control Room Emergency Recirculation (CRER) System 3.7-4 3.7:4 Control Room Heating, Ventilation, and Air Conditioning (HVAC)

System 3.7-8 3.7.5 Main Condenser Offgas 3.7-11 3.7.6 Main Turbine Bypass System 3.7-13 3.7.7 Fuel Pool Water Level 3.7-14 3.7.8 Deleted 3.7.9 Deleted 3.7.10 Emergency Closed Cooling Water (ECCW) System.*. 3.7-19 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating 3.8-1 3.8.2 AC Sources - Shutdown 3.8-17 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8-21 3.8.4 DC Sources - Operating 3.8-24 3.8.5 DC Sources - Shutdown 3.8-28 3.8.6 Battery Cell Parameters 3.8-32 3.8.7 Distribution Systems - Operating 3.8-36 3.8.8 Distribution Systems - Shutdown 3.8-38 3.9 REFUELING OPERATIONS 3.9.1 Refueling Equipment Interlocks 3.9-1 3.9.2 Refuel Position One-Rod-Out Interlock 3.9-2 3.9.3 Control Rod Position 3.9-4 3.9.4 Control Rod Position Indication 3.9-5 (continued)

PERRY - UNIT 1 iii Amendment No.

TS RETYPED PCIVs FOR INFORMATION ONLY 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.9 -NOTES-

1. Only required to be met in MODES 1, 2, and 3.
2. Main Steam Line leakage is not included.

Verify the combined leakage rate for all secondary In accordance containment bypass leakage paths is £ 0.1008 U with the Primary when pressurized to a Pa. Containment Leakage Rate Testing Program SR 3.6.1.3.10 -NOTE-Only required to be met in MODES 1, 2, and 3.

Verify leakage rate through each main steam line is In accordance

£ 100 scfh when tested at 2 Pa> and the total with the Primary leakage rate through all four main steam lines is Containment

£ 250 scfh, when tested at £ Pa. Leakage Rate Testing Program (continued)

PERRY-UNIT 1 3.6-18 Amendment No.

TS RETYPED AEGT System FOR INFORMATION ONLY 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each AEGT subsystem for £ 15 continuous In accordance minutes. with the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required AEGT filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.4.3.3 Verify each AEGT subsystem actuates on an actual In accordance or simulated initiation signal. with the Surveillance Frequency Control Program PERRY-UNIT 1 3.6-58 Amendment No.

TS RETYPED FOR INFORMATION ONLY CRER System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CRER subsystems F.1 Suspend movement of Immediately inoperable during recently irradiated fuel movement of recently assemblies in the primary irradiated fuel assemblies containment and fuel in the primary handling building.

containment or fuel handling building, or AND during OPDRVs.

F.2 Initiate action to suspend Immediately OR OPDRVs.

One or more CRER subsystems inoperable due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CRER subsystem for £ 15 continuous In accordance minutes. with the Surveillance Frequency Control Program t

SR 3.7.3.2 Perform required CRER filter testing in accordance In accordance with the Ventilation Filter Testing Program (VTFP). with the VFTP (continued)

PERRY-UNIT 1 3.7-6 Amendment No.

TS RETYPED FOR INFORMATION ONLY Fuel Pool Water Level 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Fuel Pool Water Level LCO 3.7.7 The fuel pool water level shall be £ 23 ft over the top of the irradiated fuel assemblies seated in the fuel handling building (FHB) and upper containment fuel storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the associated fuel storage pools.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel pool water level not A.1 _.<<...^NOTE within limit. > LCO 3.0.3 is not applicable.

Suspend movement of Immediately s irradiated fuel assemblies in the associated fuel storage pool(s).

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify the fuel pool water level is £ 23 ft over the top In accordance of irradiated fuel assemblies seated in the storage with the racks. Surveillance Frequency Control Program PERRY - UNIT 1 3.7-14 (next page is 3.7-19) Amendment No.

TS RETYPED Programs and Manuals FOR INFORMATION ONLY 5.5 5.5 Programs and Manuals (continued) 5.5.6 Deleted.

5.5.7 Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 4.

(continued)

PERRY - UNIT 1 5.0-10 Amendment No.

TS RETYPED Programs and Manuals FOR INFORMATION ONLY 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 4 and ANSI N510-1980 at the system flowrate specified below

+/- 10%:

ESF Ventilation System Flowrate a) Control Room Emergency Recirculation 30,000 cfm b) Annulus Exhaust Gas Treatment 2,000 cfm

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 4 and ANSI N510-1980 at the system flowrate specified below +/- 10%:

ESF Ventilation System Flowrate a) Control Room Emergency Recirculation 30,000 cfm

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 4, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and equal to the relative humidity (RH) specified below:

ESF Ventilation System Penetration RH a) Control Room Emergency Recirculation 10% 95%

\

(continued)

PERRY - UNIT 1 5.0-11 Amendment No.

TS RETYPED Programs and Manuals FOR INFORMATION ONLY 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 4 and ANSI N510-1980 at the system flowrate specified below

+/-10%:

ESF Ventilation System Delta P Flowrate a) Control Room Emergency Recirculation 4.9" H2O 30,000 cfm b) Annulus Exhaust Gas Treatment 6.0" H2O 2,000 cfm The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the main condenser offgas treatment system, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The program shall include:

a. The limits for concentrations of hydrogen in the main condenser offgas treatment system and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion); and (continued)

PERRY - UNIT 1 5.0-12 Amendment No.

Attachment 3 Planned Technical Specification Bases Changes (PROVIDED FOR INFORMATION ONLY)

(28 Pages Follow)

PLANNED BASES CHANGES PROVIDED FOR INFO ONLY AEGf System B.3V6.4.3 b 3.6 coNtAiNMeNT systems; p.3:6,4.3 Annuiius Exhaust Gas Treatment (AEGT) System BASES BACKGROUND The AEGT System is required by 10 CFR 50; Appendix A.

GQC 41. "Containment.Atmosphere Cleanup" (Ref. 1). %e function of the AEGT System Is tp ensure that radioactive materials that leak from the primary containment into the secondary containment following a Design Basis Accident (DBA) are filtered, arid adsorbed prior to exhausting to the eriyironment.

The AEGT System consists of two independent ancl redundant; subsystems., je^ch with its own set of ductwork; idampersV charcoal, fij'ter train., and controls;.

Each charcoal filter train consists of (con$onent;s Tistfd in order of tjte direction of itHe air flow):

a. A riemtstec;r
b. A roughirig filter,:
c. An oloctric heater'i>>
i. A high efficiency .particuiate air (HEPA) filter;:
e. A charcoal adsorber.:

f, A. second <HEPA filter: and 9.t A centrifugal fan with motor operated control dampers.

Hie sizing of the AEGT System equipment and components is based on the results of an infiltration analysis, as well as ah exfUtration analysis of the secondary containment structure. The internal pressure of the AEGT System boundary, region is maintained at a negative pressure of 0,25 inch water gauge when the system is in operation, which represents the internal pressure required to ensure zero exfiltratipn of air from the building when exposed to a 30 mph wind.

The demister is proyided to remove entrained water in thfe air., while the elect pic hooter reduces the relotivo

- ... a (continued)'

PERRY

  • UNIT 1 B 3.6-118. Revision No.

PLANNED BASES CHANGES AEGT System PROVIDED FOR INFO ONLY B 3.6.4.3 BASES BACKGROUND humidity of the airstreom to less than 70% (Ref. 2). The (continued) roughing filter rempves large particulate matter, while the HEPA filter is provided to remove fine particulate matter and protect the charcoal from fouling. The charcoal adsorbenAromovoo gaseous olomontal iodino and organic locnaes, andTfle final HEPA filter is provided to collect any carbon fines exhausted from the charcoal adsorber.

The AEGT System automatically starts and operates in response to actuation signals indicative of conditions or an accident that could require operation of the system. AEGT System flows are controlled by two motor operated control dampers installed in branch ducts. One duct exhausts air to the unit vent, (AEGT Subsystem A exhausts to the Unit 1 plant vent; AEGT Subsystem B exhausts to the Unit 2 plant vent), while the other recirculates air back to the annulus.

APPLICABLE The design basis for the AEGT System is to mitigate the SAFETY ANALYSES consequences of a loss of coolant accident. For all events analyzed, the AEGT System is shown to be automatically initiated to reduce, via filtration and adsorption, the radioactive material released to the environment.

The AEGT System satisfies Criterion 3 of the NRC Final Policy Statement on Technical Specification Improvements (58 FR 39132) in MODES 1. 2/ and 3. During MODES 4 and 5. there are no accident analyses that credit the AEGT System.

However, it was determined that Specifications should remain in place per Criterion 4 to address OPDRVs and fuel handling accidents.: Criterion 3 would apply if dose calculations are revised to credit the AEGT System during handling of recently irradiated fuel. i.e.. fuel that has occupied part of a critical reactor core within the previous 24 nours.

LCO Following a DBA. a minimum of one AEGT subsystem is required to maintain the secondary containment at a negative pressure with respect to the environment and to process gaseous releases. Meeting the LCO requirements for two independent operable subsystems ensures operation of at least one AEGT subsystem in the event of a single active failure.

(continued)

PERRY - UNIT 1 B 3.6-119 Revision No.

NO CHANGES; PROVIDED FOR CONTEXT ONLY AEGT System B 3.6.4.3 BASES (continued)

APPLICABILITY In MODES 1. 2. and 3. a DBA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, AEGT System OPERABILITY is required during these MODES.

In MODES 4 and 5. the probability and consequences of these events are reduced due to the pressure and temperature r limitations in these MODES. Therefore, maintaining the AEGT System OPERABLE is not required in MODE 4 or 5. except for (continued)

PERRY - UNIT 1 B 3.6-119a Revision No. 4

NO CHANGES; PROVIDED FOR CONTEXT ONLY AEGT System B 3.6.4.3 BASES APPLICABILITY other situations under which significant releases of (continued) radioactive material can be postulated, such as during movement of recently irradiated fuel assemblies in the primary containment, or during operations with a potential for draining the reactor vessel (OPDRVs). Due to radioactive decay, handling of fuel only requires OPERABILITY of the AEGT System when the fuel being handled is recently irradiated, i.e.. fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Although this Function retains APPLICABILITY during "movement of recently irradiated fuel", which could be interpreted to permit fuel handling before 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of radiological decay if certain buildings and filtration systems^are OPERABLE, this is not the case. Fuel handling during that period is prohibited since no dose calculations exist to address a fuel handling accident within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the reactor core is sub-critical (Ref. 5).

OPDRVs assume that one or more fuel assemblies are loaded into the core. Therefore, if the fuel is fully off-loaded from the reactor vessel, the AEGT System is not required to be OPERABLE.

ACTIONS With one AEGT subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE AEGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on consideration of such factors as the availabilit lability of the OPERABLE redundant AEGT subsystem and the low probability of a DBA occurring during this period.

B.I and B.2 If the AEGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3. the (continued)

PERRY - UNIT 1 B 3.6-120 Revision No. 4

NO CHANGES; PROVIDED FOR CONTEXT ONLY AEGT System B 3.6.4.3 BASES ACTIONS B.I and B:2 (continued) 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 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 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.

C.I, C.2.1 and C.2.2 During movement of recently irradiated fuel assemblies in the primary containment, or during OPDRVs, when Required Action A.I cannot be completed within the required Completion Time, the OPERABLE AEGT subsystem should be immediately placed in operation. This Required Action ensures that the remaining subsystem is OPERABLE, that no (continued)

PERRY - UNIT 1 B 3.6-120a Revision No. 4

PLANNED BASES CHANGES AEGT System PROVIDED FOR INFO ONLY B 3.6.4.3 BASES ACTIONS C.I, C.2.1 and C.2.2 (continued) failures that could prevent automatic actuation have occurred, and that any other failure would be readily detected. An alternative to Required Action C.I is to immediately suspend activities that represent a potential for releasing significant amounts of radioactive material, thus placing the unit in a Condition that minimizes risk If applicable, movement of recently irradiated fuel assemblies in the primary containment must be immediately suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

LI If both AEGT subsystems are inoperable in MODE 1. 2. or 3.

the AEGT System may not be capable of supporting the required radioactivity release control function. Therefore.

LCD 3.0.3 must be entered immediately.

E.I and E.2 When two AEGT subsystems are inoperable, if applicable, movement of recently irradiated fuel assemblies in the primary containment must be immediately suspended.

Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS (berating each AEGT^subsystem from the control room for

^-Whcontinuous-hetJps- ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor taiiureTor excessive vibration can be detected for corrective action. Operation with the hootcro on for a. 10

'n+'"Alir houro oliminotoo moioturo on tho odoorbopo and HEPA filtoro.

(continued)

PERRY - UNIT 1 B 3.6-121 Revision No,

PLANNED BASES CHANGES AE6T System PROVIDED! FOR INFO ONLY B 3.6.4.3 BASES SURVEILLANCE SR 3,6.4.3.1 (continued)

REQUIREMENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.3.2 -

This SR verifies that the required AEGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The AEGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 4). The VFTP includes testing HEPA filter efficiency, charcoal adoorbor efficiency and Dypaoc 1oakago\ system flow rate, and general operating parameters of the filtration system. (Note:

Values identified in the VFTP are Surveillance Requirement values.) Specified test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR verifies that each AEGT subsystem starts and isolation dampers open upon receipt of a manual initiation signal from the control room and an actual or simulated initiation and operates throughout its emergency operating sequence for the LOCA signal.

The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.5.1.6 overlaps this SR to provide complete testing of the safety function.

This Surveillance can be performed with the reactor at power. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. 10 CFR 50. Appendix A. GDC 41

2. USAR. Section 6.5.3.
3. USAR, Section 15.6.5.
4. Regulatory Guide 1.52. Rev.
5. USAR. Section 15.7.6.

PERRY - UNIT 1 B 3.6-122 Revision No.

PLANNED BASES CHANGES CRER System PROVIDED FOR INFO ONLY B 3.7.3 B 3.7 PUNT SYSTEMS B 3.7.3 Control Room Emergency Recirculation (CRER) System BASES BACKGROUND The CRER System provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The safety related function of the CRER System used to control radiation exposure consists of two independent and redundant high efficiency air filtration subsystems for treatment of recirculated air and a control room envelope (CRE) boundary that limits the inleakage of unfiltered air.

Each CRER subsystem consists of a demister. an oloctric

  • heaterv a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section, a second HEPA filter, a fan. and the associated ductwork, dampers, and instrumentation. The demister is provided to remove entrainprl watt*r in tho a-ir i.*-si~ +u~ ~i~~4.~*- u^-i..

octric hoator.

ut waiaf 4iia 1">i hmt/H-i of tho airctroam to looo t The prefilter removes large particulate matter, while the upstream HEPA filter is provided to remove fine particulate matter (which may be radioactive) and protect the charcoal from fouling. The charcoal adsorber removes gaseous elemental iodine and organic iodides, and the HEPA after filter is provided to collect any carbon fines exhausted from the charcoal adsorber. When emergency recirculation is activated, the supply fan in the associated control room HVAC subsystem also operates, and its normal flow rate is reduced to be compatible with the CRER fan discussed above (Ref. 2).

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions.

This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected for normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, ceilings, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

(cont i nued)

PERRY - UNIT 1 B 3.7-10 Revision No.

NO CHANGES; PROVIDED CRER System FOR CONTEXT ONLY B 3 7 3 BASES BACKGROUND In addition to the safety related standby emergency (continued) filtration function, parts of the CRER System are operated to maintain the CRE environment during normal operation.

Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to CRE occupants), the CRER System automatically switches to the emergency recirculation mode of operation to minimize infiltration of contaminated air into the CRE. A system of dampers isolates the CRE. and CRE air flow is recirculated and processed through either or both of the two filter subsystems.

The CRER System is designed to maintain a habitable environment in the CRE for a 30 day continuous occupancy after a DBA. without exceeding 5 rem total effective dose equivalent (TEDE). CRER System operation in maintaining the CRE habitability is discussed in the USAR. Sections 6.5.1 and 6.4 (Refs. 1 and 2. respectively).

" " (continued)

PERRY - UNIT 1 B 3.7-10a Revision No. 7

NO CHANGES; PROVIDED CRER System FOR CONTEXT ONLY B 3.7.3 BASES (continued)

APPLICABLE The ability of the CRER System to maintain the SAFETY ANALYSES habitability of the CRE is an explicit assumption for the safety analyses presented in the USAR. Chapters 6 and 15 (Refs. 3 and 4. respectively). The emergency recirculation mode of the CRER System is assumed to operate following a DBA. The radiological doses to CRE occupants as a result of the various DBAs are summarized in Reference 4. No single active or passive failure will cause the loss of ability to recirculate air in the CRE.

The CRER can provide protection from smoke and hazardous chemicals to CRE occupants. However, an evaluation of chemical hazards from onsite. offsite. and transportation sources has determined that the probability of a hazardous chemical spill resulting in unacceptable exposures is less than NRC licensing basis criteria. As a result, the plant licensing basis does not postulate hazardous chemical release events (Refs. 2 and 5). Therefore, no quantitative limits on inleakage of hazardous chemicals into the CRE have been established. A smoke assessment consistent with the guidance in Regulatory Guide 1.196 (Ref. 7) and NEI 99-03 Rev. 0 (Ref. 10) determined that reactor control capability can be maintained from either the Control Room or the remote shutdown controls during a smoke event (Ref. 6). Therefore, no quantitative limits on inleakage of smoke into the CRE have been established. Because inleakage limits for hazardous chemicals and smoke are not necessary to protect CRE occupants, the limit established for radiological events is the limiting value for CRE inleakage.

The CRER System satisfies Criterion *3 of the NRC Final Policy Statement on Technical Specification Improvements (58 FR 39132) in MODES 1. 2. or 3. During MODES 4 and 5. there are no accident analyses that credit the CRER System.

However, it was determined that Specifications should remain in place per Criterion 4 to address OPDRVs and fuel handling accidents. Criterion 3 would apply if dose calculations are revised tp credit the CRER System during handling of recently irradiated fuel. i.e.. fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

LCO Two redundant subsystems of the CRER System are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other subsystem. Total system failure, such as from a loss of both ventilation subsystems or from an inoperable CRE (continued)

PERRY - UNIT 1 B 3.7-11 Revision No. 7

PLANNED BASES CHANGES CRER System PROVIDED FOR INFO ONLY B 3.7.3 BASES LCO boundary, could result in a failure to meet the dose (continued) requirements of GDC 19 in the event of a DBA.

Each CRER subsystem is considered OPERABLE when the individual components necessary to limit CRE occupant exposure are OPERABLE. A CRER subsystem is considered OPERABLE when its associated:

a. Fans are OPERABLE;
b. HEPA filter and charcoal adsorber are not excessively restricting flow and are capable of performing their

, filtration^unctions; and

c. Hootorv demTster, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In order for the CRER subsystems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

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

This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For such openings (other than doors), these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area.

APPLICABILITY In MODES 1, 2. and 3. the CRER System must be OPERABLE to ensure that the CRE will remain nabitable during and following a DBA, since the DBA could lead to a fission product release.

' (conti nued)

PERRY - UNIT 1 B 3.7-lla Revision No.

NO CHANGES; PROVIDED CRER System FOR CONTEXT ONLY B 3.7.3 BASES APPLICABILITY In MODES 4 and 5, the probability and consequences of a DBA (continued) are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the CRER System OPERABLE is not required in MODE 4 or 5. except for the following situations under which significant radioactive releases can be postulated:

a. During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building; and
b. During operations with a potential for draining the reactor vessel (OPDRVs).

Due to radioactive decay, handling of fuel only requires OPERABILITY of the Control Room Emergency Recirculation System when the fuel being handled is recently irradiated, i.e.. fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Although this Function retains APPLICABILITY during "movement of recently irradiated fuel", which could be interpreted to permit fuel handling before 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of radiological decay if certain buildings and filtration systems are OPERABLE, this is not the case. Fuel handling during that period is prohibited since no dose calculations exist to address a fuel handling accident within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the reactor core fs sub-critical (Ref. 4).

OPDRVs assume that one or more fuel assemblies are loaded into the core. Therefore, if the fuel is fully off-loaded from the reactor vessel, the CRER System is not required to be OPERABLE.

ACTIONS , AJL With one CRER subsystem inoperable for reasons other than an inoperable CRE boundary, the inoperable CRER subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE CRER subsystem is adequate to perform the CRE occupant protection function.

However, the overall reliability is reduced because a failure in the OPERABLE CRER subsystem could result in loss of CRER System function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining CRER subsystem can provide the required capabilities.

.__^___ (continued)

PERRY - UNIT 1 B 3.7-12 Revision No. 7

NO CHANGES; PROVIDED CRER System FOR CONTEXT ONLY B 3.7.3 BASES ACTIONS B.I. B.2. and B.3 (continued)

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 Rem TEDE). or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. As discussed in the Applicable Safety Analyses section, the current PNPP licensing basis identifies that CRE inleakage limits for hazardous chemicals and smoke are not necessary to protect CRE occupants:

therefore the limit established for radiological events is the limiting value for determining entry into Condition B for an inoperable CRE boundary. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or cnemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the Operable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.

These mitigating actions are outlined in the PNPP Control Room Envelope Habitability Program.

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 use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

(continued)

PERRY - UNIT 1 B 3.7-12a Revision No. 7

NO CHANGES; PROVIDED CRER System FOR CONTEXT ONLY B 3.7.3 BASES ACTIONS C.I and C.2 (continued)

In MODE 1. 2. or 3. if the inoperable CRER subsystem or the CRE boundary cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 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.

(continued)

PERRY - UNIT 1 B 3.7-12b Revisior No. 7

NO CHANGES; PROVIDED CRER System FOR CONTEXT ONLY B 3.7.3 BASES ACTIONS D.I. D.2.1 and D.2.2 (continued)

The Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1. 2 or 3. the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown. During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, or during OPDRVs, if the inoperable CRER subsystem cannot be restored to OPERABLE status within the required Completion Time of Condition A, the OPERABLE CRER subsystem may be placed in the emergency recirculation mode. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action D.I is to immediately suspend activities that present a potential for releasing significant amounts of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk.

If applicable, movement of recently irradiated fuel assemblies in the primary containment and fuel handling building must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

LI If both CRER subsystems are inoperable in MODE 1. 2. or 3 for reasons other than an inoperable CRE boundary (i e Condition B). the CRER System may not be capable of '

performing the intended function and the unit is in a condition outside of the accident analyses. Therefore.

LCO 3.0.3 must be entered immediately.

. (conti nued)

PERRY - UNIT 1 B 3.7-13 Revision No. 7

PLANNED BASES CHANGES CRER System PROVIDED FOR INFO ONLY B 3.7.3 BASES ACTIONS F.I and F.2 (continued)

During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, or during OPDRVs. with two CRER subsystems inoperable or with one or more CRER subsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing significant amounts of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk.

If applicable, movement of recently irradiated fuel assemblies in the primary containment and fuel handling building must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended. N SURVEILLANCE SR 3.7.3.1 REQUIREMENTS Operating each CRER subsystem for £ £0-continuous initiating from the control room and ensuring flow through the HEPA filters and charcoal adsorbers ensures that both subsystems are OPERABLE and that all associated controls are functioning properly^ It also ensures that blockage, fan or motor Tanure. or excessive vibration can be detected for corrective action. Opcrotion with the hootoro on for £ 10 continuouo hourG oliminatoo HEPA atoo moioturo on tho adoorboro and HE filtorci The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.3.2 This SR verifies that the required CRER testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testina HEPA filter efficiency, charcoal adsorber efficiency and bypass leakage, system flow Yate. and general operating parameters of the filtration system. (Note: Values identified in the VFTP are Surveillance Requirement values.) Specific test Frequencies and additional information are discussed in detail in the VFTP.

(continued)

PERRY - UNIT 1 B 3.7-14 Revision No.

NO CHANGES; PROVIDED CRER System FOR CONTEXT ONLY B 3.7.3 BASES SURVEILLANCE SR 3.7.3.3 REQUIREMENTS (continued) This SR verifies that each CRER subsystem starts and operates on an actual or simulated initiation signal, and the isolation dampers that establish a portion of the CRE boundary close within 10 seconds. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.5 overlaps this SR to provide complete testing of the safety function. The Survei llance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3 7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke.

This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate. Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196. Section C.2.7.3.

(Ref. 7), which endorses, with exceptions. NEI 99-03, Section 8.4 and Appendix F (Ref. 10). These compensatory measures may be used as mitigating actions as required by Required Action B.2.

Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis;DBA consequence analysis, repairing the CRE boundary, or a combination of these actions (Ref. 11). Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

(continued)

PERRY - UNIT 1 B 3.7-15 Revision No. 11

PLANNED BASES CHANGES CRER System PROVIDED FOR INFO ONLY B 3.7.3 BASES (continued)

REFERENCES 1. USAR. Section 6.5.1.

2. USAR, Section 6.4.
3. USAR. Chapter 6.
4. USAR, Chapter 15.
5. USAR. Section 2.2
6. Letter from L. W. Pearce (FENOC) to Document Control Desk (NRC) dated May 30. 2006. "Perry Nuclear Power Plant Final Response to Generic Letter 2003-01.

'Control Room Habitability' (TAC No. MB9839)."

7. Regulatory Guide 1.196
8. Deleted.
9. Deleted.
10. NEI 99-03. "Control Room Habitability Assessment."

June 2001.

11. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004. "NEI Draft White Paper

-i Source Terms in the Context of Control Room PERRY - UNIT 1 B 3.7-16 Revision No.

Fuel HandlingI Building PLANNED BASES CHANGES

B 3.7VR

--- DELETE B.3.7.8 PROVIDED FOR INFO ONLY B f:7 PLANT SYSTEMS^

B .3,7.8 Fuel HindiirilBMiTd:iiig (FHB),

BASES BACKGROUND, The function of the FHB is to contain, dilute, and hold up fissipn products that are release^ fftp a design baisis Fuel Handling Accident (FHA). in conjunction with operation of the FHB Ventilation Exhaust System, the FHB is designed to reduce the activity levSl of the fission products prior to release to the environment.,

Jhf FHB is a three story.building, loqated betweten the Unit. 1 and 2 reactor buildings. TJie eWtire exterior of the building is reinforced concrete, including the foundation, the walls, and the roof §1lbs. The FHB houses fogr,pools for fuel handling and storage:

a. Cask pit; fa* Spent fuel storage pool;
c. Fuel transfer poolr and
d. Fuel storage and preparation popL Th0 pppls are interconnected, by means of gates, to allow the underwater passage of ftiel assanbli^s fribih one pQpi to another.

Jp prevent ground level exfiItration, the FHB boundaries have been established. The FHBvbouhdanes are:

4. The doors in each accesi to the 620 foot elevation of the FHB 3re closed, except for norrral entry b.. Th<e "FHB rai 1 road track door i:$
c. The FHB floor hatches are th place: and
d. The shield blocks, are installed adjacent to the shield building.

= (continued)

PERRY - UNIT 1 B .3.7-32 Revision No.

Fuel Handling Bui 1 dim PLANNED BASES CHANGES B 3.7 J DELETE B.3.7.8 --

PROVIDED FOR INFO ONLY BASES BACKGROUND With the boundaries in place, the FHB Ventilation Exhaust (continued) System will assure that any releases occurring as a result of a FHA are filtered.

APPLICABLE There are no accidents for which credit is taken for FHB SAFETY ANALYSES OPERABILITY. Although there are no accident analyses that credit the FHB. it was determined that Specifications should remain in place per Criterion 4 of the NrC Final Policy Statement on Technical Specification Improvements (58 FR 39132) to address fuel handling accidents involving handling of recently irradiated fuel (i.e.. fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) in the FHB (Ref. 1). Criterion 3 of the NRC Policy Statement would apply if dose calculations are revised to credit the FHB during handling of recently irradiated fuel.

LCO An.OPERABLE FHB provides a control volume into which fission products can be diluted and processed prior to release to the environment. For the FHB to be considered OPERABLE, it must provide proper air flow patterns to ensure that there is no uncontrolled release of radioactive material during a FHA involving handling of recently irradiated fuel in the FHB. '

APPLICABILITY In plant operating MODES. OPERABILITY of the FHB is not required since leakage from the primary containment-will not be released into the FHB. Regardless of the plant operating MODE, anytime recently irradiated fuel is being handled in the FHB there is the potential for significant radioactive releases due to a FHA. and the FHB is required to mitigate the consequences.

Due to radioactive decay, handling of fuel only requires OPERABILITY of the Fuel Handling Building when the fuel being handled is recently irradiated, i.e.. fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Although this Function retains APPLICABILITY during "movement of recently irradiated fuel", which could be interpreted to permit fuel handling before 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of radiological decay if certain buildings and filtration systems are OPERABLE, this is not the case. Fuel handling during that period is prohibited since no dose calculations exist to address a fuel handling accident within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the reactor core is sub-critical (Ref. 1).

(continued)

PERRY - UNIT 1 B 3.7-33 Revision No.

Fuel Handling Bulldint B3.7.J PLANNED BASES CHANGES DELETE B.3.7.8 BASES (continued) PROVIDED FOR INFO ONLY ACTIONS The Required Actions have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in-MODE 4 or 5. LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2. or 3. the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require

] a reactor shutdown.

AJ, With the FHB inoperable, the plant must be brought to a condition in which the LCO does not apply since the FHB is incapable of performing its required accident mitigation function. To achieve/this, handling of recently irradiated fuel must be suspended immediately. Suspension shall not preclude completion of fuel movement to a safe position.

SURVEILLANCE SR 3.7.8.1 and SR 3.7.8.2 REQUIREMENTS Verifying that FHB floor hatches and access doors are closed, that the shield blocks are in place adjacent to the shield building, and that the FHB railroad track door is closed ensures that proper air flow patterns will exist in the FHB. and that any release following a FHA involving handling of recently irradiated fuel in the FHB will be filtered prior to release. Verifying that all such openings are closed provides adequate assurance that exfiltration from the FHB will not occur. Maintaining FHB OPERABILITY requires verifying each door in the access opening is closed, except when the access opening is being used for entry and exit.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. USAR. Section 15.7.4 and 15.7.6.

PERRY - UNIT 1 B 3.7-34 Revision No.

PLANNED BASES CHANGES PMR ubrltnvtiAn rvtonct

- delete B.3.7.9 - FHB Verta latw Exhaust PROVIDED FOR INFO ONLY R3.7 PyWT SYSTEMS B 3.7,9 Fu&t Handling BuildingVtFHBy Vehtilatxbn Exhaust System BASIS BACKGROUND Thfe FH? Ventilation Exhaust System is required by 10 GFR 50 Appendix A:, GDC: 41. "Containment Atmosphere ,Cleanup" (R6f.: 1); The function of the FtIB Verifilation Exhaust System ts to ensure that radioacttye jualerials that escape from fuel assemblies damaged followfn^ a desicjn, bails Fue5 Bandling AGcid^nt (FHA) $re filtered and adsorbed prior to exhausti ng. td ih$ envi rQit The FHB Ventilation Exhaust System consists of three fully redundant subsystems,, each with its own set of ductwork..

dimpfrs. £>chaust fan. charcoal filter train.

insWmentatiqn., and controls. Each subsystem is designed for 505; flow.

Each chafcoai filter train consists of Xcomponents listed in orMer of the. .direction of the air flow),:

b, A rouihinQ

>>.fe; EltdttfVq tieatfr cil:?

d. A high; #ffi,cie'ncy partfculate ai-r (HEPA) prefilter;;
e. A, charegal absorber; fnd ft A HEPA ifterfilter.

The demister is provided tp remove entrajfied water in f h)r, while the electric heater rieduces the relative humidity of the airstf^am td less than 70X (Ref. 2X. The roughing filter removes Targe particulate matter,.while the :HEPA prefilter 15 provided to r^nove fine particulate raiatter and protect the charcoal from fouling; Tne charcoal, adsorber removes gaseous elepental iodine and organic iodides, and the H^PA afteffliter is provided to, cp1Tei:t any carbon fines

^hausted from, the chardbal adsorber.

The FHB Ventilation Exhaust System is manually started by the control; room operators; In th^ event that the radiation monitor Upstream of the charcoal filter trains senses a hih PERRY' - UNIT 1 B 3.7-35 .Revision No.

FHB Ventilation Exhaust System B 3.7.9 PLANNED BASES CHANGES DELETE B.3.7.9 BASES PROVIDED FOR INFO ONLY BACKGROUND radiation condition, an alarm will occur in the control (continued) room, and the operating supply fan from the FHB Ventilation Supply System will trip, me exhaust subsystems remain operational to continue exhausting contaminated air from the fuel handling area through the charcoal filter trains, thus precluding any uncontrolled release of radioactivity to the outside environment.

APPLICABLE The design basis for the FHB Ventilation Exhaust System is SAFETY ANALYSES to mitigate the consequences of a FHA involving handling of irradiated fuel. However, there are no longer any dose calculations which credit the FHB Ventilation Exhaust System to reduce, via filtration and adsorption, the radioactive material released to the environment.

Although there are no accident analyses that credit the FHB Ventilation Exhaust System, it was determined that Specifications should remain in place per Criterion 4 to address fuel handling accidents. Criterion 3 would apply if dose calculations are revised to credit the FHB Ventilation Exhaust System during handling of recently irradiated fuel, i.e.. fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ^

LCO Following a FHA involving handling of recently irradiated fuel, a minimum of two FHB ventilation exhaust subsystems are required to maintain the FHB at a negative pressure with respect to the environment and to process gaseous releases.

Meeting the LCO requirements for three OPERABLE subsystems ensures operation of at least two FHB ventilation exhaust subsystems in the event of a single active failure.

APPLICABILITY In plant operating MODES. OPERABILITY of the FHB Ventilation Exhaust System is not required since leakage from the primary containment will not be released into the FHB.

Regardless of the plant operating MODE, anytime recently irradiated fuel is being handled in the FHB there is the potential for significant radioactive releases due to a FHA.

and the FHB Ventilation Exhaust System is required to mitigate the consequences. Due to radioactive decay, handling of fuel only requires OPERABILITY of the Fuel (continued)

PERRY - UNIT 1 B 3.7-36 Revision No.

FHB Ventilation Exhaust System B 3.7.9 PLANNED BASES CHANGES DELETE B.3.7.9 ---

BASES PROVIDED FOR INFO ONLY APPLICABILITY Handling Building Ventilation Exhaust System when the fuel (continued) being handled is recently irradiated, i.e.. fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Although this Function retains APPLICABILITY during "movement of recently irradiated fuel", which could be interpreted to permit fuel handling before 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of radiological decay if certain buildings and filtration systems are OPERABLE, this is not the case. Fuel handling during that period is prohibited since no dose calculations exist to address a fuel handling accident within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the reactor core is sub-critical (Ref. 3).

ACTIONS The Required Actions have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5. LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1. 2. or 3. the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

. _. (continued)

PERRY - UNIT 1 B 3.7-36a Revision No.

PLANNED BASES CHANGES DELETE B.3.7.9 FHB Ventilation lxhaust Sys PROVIDED FOR INFO ONLY BASES ACTIONS LI (continued)

With pne FHB ventilation exhaust Subsystem irioperablei the inoperable subsystem must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE FHB ventilation exhaust subsystems are adequate to perfor/m the required radioactivity release control furictipn, However, t'tfe overall system reliability is reduced because a

$inpe failure in one OPERABLE siibsystem could rfesult in the radioactivity release control function not being adequately pWfdErned,, The 7 day Compieti.dri time is based on cpnsi^altipn of such factors as the availability of the OPERABLE FHB ventilation exhaust subsystems and the low probability df a FHA occurring during Jftis period.

B.I arid B:2 If the FHB ventilation exhaust subsystem cannot be: restored to OPERABLE status within the required Completion time the two remaining OPERABLE FHB yentilatipn exhaust subsystems should be immediately placed in operatipri, this Required Action ensiire$ that ,the r<<lfnaining SMbsystems are OPERABLE, aSd that any other failure would, be readily dttd Ah alternative tp Required Action B.I is to jmn<<diately suspend activities that represent a potential fprr releasing significant ^mounts of radioactive materiali to the FHB. thus pl^cingthe unit in a condition that mini rrri z$i iri# by suspending nioyement of riecently ifradiated fuel assemblies.

Suspen^ipri of this activity shall not [ireclud^ edmpiletiph of fuel mdvement to a safe position.

With two or three FHB ventilation exhaust subsystems inoperable the plant must be brought to a condition in which the LCO/does hot apply since the system is incapable of performing its required accident mitigation function. To achieve this:, handling of recently irradiated fuel In the FHBi rnust be suspended immediately. Suspension shall not preclude completion of fuel movement to a safe position.

- Icoritinued)

PERRY - UNIT 1 Revision No.

FHB Ventilation Exhaust System B 3.7.9 PLANNED BASES CHANGES DELETE B.3.7.9 --

BASES PROVIDED FOR INFO ONLY ACTIONS D.I and D.I (continued)

With the FHB ventilation exhaust radiation monitor inoperable, grab samples must be taken and analyzed for the FHB ventilation exhaust system, and since the FHB ventilation exhaust system exhausts to the plant vent, the plant vent noble gas monitor must be verified to be operable. These compensatory measures assure that the radiation levels in the FHB are monitored. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is based on operating experience, and the probability of a FHB fuel drop accident occurring with the monitor inoperable.

If the FHB ventilation exhaust radiation monitor (noble gas) is inoperable and the Unit 1 vent radiation noble gas monitor becomes inoperable, then actions must be taken to assure that the FHB ventilation system is aligned to its required condition. Placing the FHB ventilation exhaust radiation monitor (noble gas) m the tripped condition will cause the FHB ventilation supply fans to trip which will increase the differential pressure between the FHB and outside atmosphere, which aids in assuring that any exchange of the FHB atmosphere exhaust will be through the FHB exhaust filters. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is based on operating experience and the probability of a FHB fuel drop accident occurring during this time period.

SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Operating each FHB ventilation exhaust subsystem for £ 10 continuous hours after initiating from the control room and ensuring flow through the HEPA filters and charcoal adsorbers ensures that all subsystems 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. Operation with the heaters on for £ 10 continuous hours eliminates moisture on the adsorbers and HEPA filters. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PERRY - UNIT 1 B 3.7-38 Revision No.

FHB Ventilation Exhaust System B 3.7.9 PLANNED BASES CHANGES DELETE B.3.7.9 ---

BASES PROVIDED FOR INFO ONLY SURVEILLANCE SR 3.7.9.2 REQUIREMENTS (continued) This SR verifies that the required FHB ventilation exhaust filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The FHB Ventilation Exhaust System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 4) whenever recently irradiated fuel is going to be handled. The VFTP includes testing HEPA filter efficiency, charcoal adsorber efficiency and bypass leakage, system flow rate, and general operating parameters of the filtration system. (Note: Values identified in the VFTP are Surveillance Requirement values.)

Specified test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.9.3 **

This SR requires verification that each FHB ventilation exhaust subsystem can be started from the control room, and that the FHB ventilation exhaust system performs satisfactorily during an actual or simulated actuation of the FHA instrumentation. This SR will include calibration of the FHB ventilation exhaust radiation monitor (noble gas). This Surveillance can be performed with the reactor at power. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.9.4 This SR requires the performance of a CHANNEL FUNCTIONAL TEST on the FHB ventilation exhaust radiation monitor (noble gas) to ensure the entire channel will perform its intended function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PERRY - UNIT 1 B 3.7-39 Revision No,

FHB Ventilation Exhaust System B 3.7.9 PLANNED BASES CHANGES

-~ DELETE B.3.7.9 BASES (continued) PROVIDED FOR INFO ONLY REFERENCES 1. 10 CFR 50. Appendix A, GDC 41.

2. USAR. Section 6.2.3.
3. USAR. Section 15.7.4 and 15.7.6,
4. Regulatory Guide 1.52. Rev. 2.

PERRY - UNIT 1 B 3.7-40 Revision No

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