L-MT-08-025, Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

ML080950329
Person / Time
Site:	Monticello
Issue date:	04/03/2008
From:	O'Connor T Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-08-025, TSTF-448, Rev 3
Download: ML080950329 (23)

Text

Monticello Nuclear Generatina Plant Operated by Nuclear Management Company, LLC April 3, 2008 L-MT-08-025 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Dockets 50-263 Renewed License No. DPR-22 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448. REVISION 3, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

References:

1) NMC Letter to NRC, Generic Letter 2003-01: Control Room Habitability-Design Bases, Licensing Bases and In-leakage Testing Results, dated November 18,2004.

2) NMC Letter to NRC, Generic Letter 2003-01: Control Room Habitability -

Smoke Assessment, dated February 23,2004.

3) NRC to NMC letter - NRC Receipt of Response to Generic Letter 2003-01 "Control Room Habitability", dated August 30,2006.

4) NRC Issuance of CLllP for TSTF-448, Rev.3, dated January 17, 2007.

In accordance with the provisions of 10 CFR 50.90, Nuclear Management Co., LLC (NMC) is requesting an amendment to the technical specifications (TS) for Monticello Nuclear Generating Plant.

The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with Technical Specification Task Force traveler (TSTF)-448, Revision 3, "Control Room Habitability." provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS and operating license pages marked up to show the proposed changes. Enclosure 3 provides existing TS Bases pages marked up. These Bases pages are being submitted for information only and do not require issuance by the NRC.

2807 West County Road 75 Monticello, Minnesota 55362-9637 Telephone: 763.295.5151

Document Control Desk Page 2 NMC requests approval of the proposed License Amendment by May 1, 2009, with the amendments being implemented within 180 days of issuance of the approved amendment. NMC is developing the Control Room Envelope Habitability Program consistent with the requirements specified in TSTF-448, Revision 3 and described in the Enclosure 2 TS mark-up pages. The final retyped pages will be made available prior to NRC issuance of this amendment.

In accordance with 10 CFR 50.91(b) (I), a copy of this application, with attachments., is being provided to the designated state official for the State of Minnesota.

Summaw of Commitments This submittal does not contain any new commitments and no revisions to existing commitments.

This license amendment request satisfies the following commitment made in NMC correspondence to the NRC (L-MT-04-049) dated November 18,2004, Generic Letter 2003-01: Control Room Habitability- Design Bases, Licensing Bases and In-leakage Testing Results:

"MNGP commits to submit to the NRC proposed changes to the Technical Specifications (and any associated plant modifications) based upon the final, approved version of Technical Specification Task Force (TSTF) traveler - 448, adjusted, as needed, to account for plant-specific MNGP Control Room Envelope design and licensing basis, within 180 days following NRC approval of TSTF-448."

The revised commitment date for the Technical Specifications submittal, as described in NMC to NRC letter L-HU-08-001; dated January 15,2008 is April 6,2008.

I declare under penalty of perjury that the foregoing is true and correct.

Generating Plant

~uclearManagement Company, LLC

Enclosures:

1. Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

2. Markup of the Facility Operating License and Technical Specifications

3. Markup of Technical Specification Bases pages (for information only)

Document Control Desk Page 3 cc: Regional Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC State of Minnesota Representative

ENCLOSURE 1 License Amendment Request Monticello Nuclear Generating Plant APPLICATION TO REVISE TECHNICAL SPECIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448, REVISION 3, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL EVALUATION

Enclosure 1 L-MT-08-025

1.0 DESCRIPTION

The proposed amendment would modify the Monticello Nuclear Generating Plant (MNGP) Technical Specification (TS) requirements related to control room habitability in TS 3.7.4 Control Room Emergency Filtration System (CREFS) and TS Section 5.5.13, Programs and Manuals.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/-rechnical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-448, Revision 3, "Control Room Habitability." The availability of this TS improvement was published in the Federal Register on January 17, 2007 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Nuclear Management Company (NMC) has reviewed the safety evaluation dated January 17, 2007 as part of the CLIIP. This review included a review of the NRC staff evaluation, as well as the supporting information provided to support TSTF-448. NMC has concluded that the justification presented in the TSTF proposal and the safety evaluation prepared by the NRC staff is applicable to MNGP, and justify this amendment for the incorporation of the changes to the MNGP TS.

2.2 Optional Chancres and Variations NMC is not proposing any significant variations or deviations from the TS changes described in the TSTF-448, Revision 3, or the applicable parts of the NRC staff model safety evaluation dated January 17, 2007.

As part of the NMC response to NRC Generic Letter 2003-01 (References 1 and 2), NMC provided the required information addressing the effects to Control Room Envelope (CRE) occupants following hazardous chemicals and smoke events at MNGP. The licensing basis for MNGP related to hazardous chemicals and smoke events include manual isolation of the CREFS by placing the Control Room Ventilation (CRV) in the recirculation mode to minimize the effects of these events to CRE occupants.

2.3 License Condition Regardinq Initial Performance of New Surveillance and Assessment Requirements NMC proposes the following as a license condition to support implementation of the proposed TS changes:

Upon implementation of this Amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air in-leakage as required

Enclosure 1 L-MT-08-025 by SR 3.7.4.4, in accordance with TS 5.5.13.c(i), the assessment of CRE habitability as required by Specifications 5.5.13.c(ii), and the measurement of CRE pressure as required by Specification 5.5.13.d, shall be considered met.

Following implementation:

(a) The first performance of SR 3.7.4.4, in accordance with Specifications 5.5.13.c (i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from June 4, 2004, the date of the most recent successful tracer gas test, as stated in the letter (L-MT-04-049, dated November 18,2004) in response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specifications 5.5.13 c (ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from June 4, 2004, the date of the most recent successful tracer gas test, as stated in the letter (L-MT-04-049, dated November 18,2004) in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.13 dl shall be within 24 months, plus the 184 days allowed by SR 3.0.2, as measured from September 19, 2006, the date of the most recent pressure measurement test, or within 184 days if not performed previously.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination NMC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register on January 17, 2007 (FR 72 2022) as part of the CLIIP. NMC has concluded that the proposed NSHCD is applicable to MNGP, and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

4.0 ENVIRONMENTAL EVALUATION NMC has reviewed the environmental evaluation included in the model safety evaluation dated January 17,2007 as part of the CLIIP. NMC has concluded that the staffs findings presented in that evaluation are applicable to MNGP, and the evaluation is hereby incorporated by reference for this application.

ENCLOSURE 2 License Amendment Request Monticello Nuclear Generating Plant TSTF-448 Control Room Envelope Habitability Proposed Technical Specification and Operating License Changes (Mark-up)

E. Northern States Power Company shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

F. NMC shall observe such standards and requirementsfor the protection of the environment as are validly imposed pursuant to authority established under Federal and State law and as determined by the Commission to be applicable to the facility covered by this renewed facility operating license.

G. The Updated Safety Analysis Report supplement, as revised, submitted pursuant to 10 CFR 54.21(d), shall be included in the next scheduled update to the Updated Safety Analysis Report required by 10 CFR 50.71(e)(4) following the issuance of this renewed operating license. Until that update is complete, NMC may make changes to the programs and activities described in the supplement without prior Commission approval, provided that NMC evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

H. The Updated Safety Analysis Report supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. NMC shall complete these activities no later than September 8, 2010, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

I. All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of the most recent NRC-approved version of the Boiling Water Reactor Vessels and lnternals Project (BWRVIP)

Integrated Surveillance Program (ISP) appropriate for the configuration of the specimens in the capsule. All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements must be approved by the NRC, as required by 10 CFR Part 50, Appendix H.

J. This renewed operating license is effective as of the date of issuance and shall expire at midnight, September 8, 2030.

K. (See Insert 1)

FOR THE NUCLEAR REGULATORY COMMISSION J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments: 1. Appendix A - Technical Specifications

2. Appendix B - (Deleted per Amendment 15, 12117182)

3. Appendix C - Additional Conditions Date of Issuance: NwemW "*,

Renewed License No. DPR-22

INSERT 1 PAGE 7 K. Upon implementation of this Amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air in-leakaqe as required by SR 3.7.4.4, in accordance with TS 5.5.1 3.c(i), the assessment of CRE habitability as required bv Specifications 5.5.1 3.c(ii), and the measurement of CRE pressure as required by Specification 5.5.13.d. shall be considered met. Following implementation:

(a) The first performance of SR 3.7.4.4, in accordance with Specifications 5.5.1 3.c (i), shall be within the specified frequency of 6 vears. plus the 18-month allowance of SR 3.0.2, as measured from June 4, 2004. the date of the most recent successful tracer gas test, as stated in the letter (L-MT-04-049. dated November 18.2004) in response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specifications 5.5.13 c (ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2. as measured from June 4,2004, the date of the most recent successful tracer gas test, as stated in the letter (L-MT-04-049. dated November 18,2004) in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 vears.

(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.13 d, shall be within 24 months, plus the 184 days allowed by SR 3.0.2. as measured from September 16, 2006. the date of the most recent pressure measurement test, or within 184 davs if not performed previouslv.

3.7 PLANT SYSTEMS 3.7.4 Control Room Emergency Filtration (CREF) System LC0 3.7.4 Two CREF subsystems shall be OPERABLE.

............................................. NOTE............................................

The &control room envelope (CRE) boundary may be opened intermittently under administrative control.

I APPLICABILITY: MODES I,2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME inoperable-,for reasons to OPERABLE status.

other than Condition B.

subsystems inoperable mitiqatinq actions due to inoperable MODE 1, 2, or 3.

B.2 Verify mitiqatinq actions ensure CRE occupant exposures to radioloqical, chemical and smoke hazards will not exceed B.13 Restore GW&&WFR=

boundary to OPERABLE 24-hews90 days Monticello Amendment No. 446 I

CONDITION REQUIRED ACTION COMPLETION TIME not met in MODE 1, 2, or 3. C.2 Be in MODE 4.

D. Required Action and .................... NOTE-------------------

met during movement of subsystem in pressurization secondary containment or during OPDRVs.

D.2.1 Suspend movement of recently irradiated fuel assemblies in the secondary containment.

D.2.2 Initiate action to suspend inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

NO CHANGES - REFORMATTING ONLY I1 Monticello Amendment No. 44.6 1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME NOTE-------------------

LC0 3.0.3 is not applicable.

movement of recently ................................................

irradiated fuel assemblies in the F.l Suspend movement of secondary containment recently irradiated fuel or during OPDRVs. assemblies in the secondary containment.

OR One or more CREF due to an inoperable CRE boundarv durinq movement of recently irradiated fuel assemblies in the secondarv containment SURVEILLANCE REQUIREMENTS SURVEILLANCE I FREQUENCY SR 3.7.4.1 Operate each CREF subsystem for 2 10 continuous 31 days hours with the heaters operating.

SR 3.7.4.2 Perform required CREF filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.7.4.3 Verify each CREF subsystem actuates on an actual 24 months or simulated initiation signal.

SR 3.7.4.4 Perform rewired CRE unfiltered air in-leakaue testinq in accordance with the Control Room

-1 Envelo~eHabitabilitv Proqram In accordance with the Control Room Envelope Habitability Monticello 3.7.4-3 Amendment No. 4-46 1

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.1 3 Control Room Envelope Habitabilitv Program A Control Room Envelope (CRE) Habitability Proqram shall be established and implemented to ensure that CRE habitabilitv is maintained such that, with an OPERABLE Control Room Emerqencv Filtration (CREF) Svstem, CRE occupants can control the reactor safelv under normal conditions and maintain it in a safe condition followinq a radioloaical event, hazardous chemical release, or a smoke challenge.

The program shall ensure that adequate radiation protection is provided to permit access and occupancv of the CRE under desiqn basis accident

{DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The proqram shall include the following elements:

a. The definition of the CRE and the CRE boundarv.

b. Requirements for maintaininq the CRE boundarv in its desian condition includinq confiquration control and preventive maintenance.

c. Requirements for (i) determininn the unfiltered air in-leakaqe past the CRE boundarv into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.l and C.2 of Requlatorv Guide 1.197, "Demonstratinq Control Room Envelope Inteqritv at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessinq CRE habitability at the Frequencies specified in Sections C.l and C.2 of Requlatorv Guide 1.197, Revision 0.

d. Measurement, at desiqnated locations, of the CRE pressure relative to all external areas adiacent to the CRE boundarv during the pressurization mode of operation bv one subsvstem of the CREF Svstem, operatinq at the flow rate required bv the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CRE boundarv.

e. The quantitative limits on unfiltered air in-leakaqe into the CRE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air in-leakage measured bv the testing described in paraqraph c. The unfiltered air in-leakaqe limit for radioloqical challenges is the in-leakaqe flow rate assumed in the licensinq basis analvses of DBA consequences. Unfiltered air in-leakaqe limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensinq basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitabilitv, determining CRE unfiltered in-leakaqe, and measuring CRE pressure and assessinq the CRE boundarv as required bv paraqraphs c and d, respectivelv.

Monticello 5.5-12 Amendment No. -

ENCLOSURE 3 License Amendment Request Monticello Nuclear Generating Plant TSTF-448 Control Room Envelope Habitability Proposed Technical Specification Bases (Mark-up)

(FOR INFORMATION ONLY)

CREF System B 3.7.4 B 3.7 PLANT SYSTEMS B 3.7.4 Control Room Emergency Filtration (CREF) System BASES BACKGROUND The CREF System provides a protected environment from which occupants can control the unit followinq an uncontrolled release of radioactivity, hazardous chemicals, or smoke.-

The safety related function of m C R E F System includes two independent and redundant high efficiency air filtration subsystems for I

emergency treatment of outside supply air and a CRE boundary that limits the in-leakaqe of unfiltered air. Each CREF subsystem consists of a low efficiency filter, an electric heater, a high efficiency particulate air I

(HEPA) filter, two activated charcoal adsorber sections, a second HEPA filter, an emergency filter fan, an air handling unit (excluding the condensing unit), an exhaust/recirculation fan, and the associated ductwork, valves or dampers, doors, barriers. and instrumentation&

&wipes. Low efficiency filters and HEPA filters remove particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay.

I 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 durinq 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 durinq normal operation. natural events, and accident conditions. The CRE boundarv is the combination of walls, floor, roof, ductina, doors, penetrations and equipment that ~hvsicallyform the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the in-leakage of unfiltered air into the CRE will not exceed the in-leakage assumed in the licensinq basis analysis of desinn basis accident jDBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Prwram.

The CREF System is a standby system, parts of which also operate during normal unit operations to maintain the CRE

~ n v i r o n m e n tUpon . receipt of a Reactor Vessel Water Level - Low Low, Drywell Pressure - High, Refueling Floor Radiation - High or Reactor Building Ventilation Exhaust Radiation - High initiation signal the CREF System automatically switches to the pressurization mode of operation to minimize infiltration of contaminated air into the CRE (the main control room and portions of the first and second floors of the Emergency Filtration Train (EFT) building).

Monticello B 3.7.4-1 Revision No.

CREF System 9.3.7.4 BASES A system of dampers isolates the r r , , , , , l CRE from untreated outside air. Outside air is taken in at the normal ventilation I

intake and is passed through one of the charcoal adsorber filter subsystems for removal of airborne radioactive particles. This air is then combined with return air from the CRE and passed through an 11 exhaust/recirculation fan, which is then passed through the air handling unit into the CRE.

The CREF System is designed to maintain the CRE 1 environment for a 30 day continuous occupancy after a DBA without exceeding 5 rem TEDE. -A single CREF subsystem operatinq at a flow rate of 5 1100 d m will pressurize the CRE relative to I

external areas adiacent to the CRE boundary to minimize &+we&-

infiltration of air from all--surroundinq areas adiacent to the CRE I boundary-. CREF System operation in maintaining aWmkxm+

CRE habitability is discussed in the USAR, Section 14.7.2.4.3. (Ref. 1)

I APPLICABLE The ability of the CREF System to maintain the habitability of the SAFETY cs&wkemCRE b w w h r y i s an explicit assumption for the LOCA analysis I ANALYSES presented in the USAR, Section 14.7.2.4.3 (Ref. I). The pressurization mode of the CREF System is assumed to operate following a W DBA. No single active failure will prevent the CREF System from performing its safety function.

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

Two redundant subsystems of the CREF System are required to be OPERABLE to ensure that at least one is available, -ia single active failure disables the other subsystem. Total CREF system failure coutd result in exceeding a dose of 5 rem TEDE to the ~ ~ n h k x m C R E occupants in the event of a DBA-MXX.

%Each CREF Sy&m subsystem is considered OPERABLE when the individual components necessary to W i m i t CRE occupant exposure are OPERABLE-. A subsystem is considered OPERABLE when its associated:

a. Emergency filter fan, exhaust/recirculationfan, and air handling unit (excluding the condenser unit) are OPERABLE;

b. Low efficiency filter, HEPA filters, and charcoal adsorbers are not excessively restricting flow and are capable of performing their filtration functions; and

c. Heater, ductwork, and dampers are OPERABLE, and air circulation can be maintained.

Monticello B 3.7.4-2 Revision No.

CREF System B 3.7.4 BASES In order for the CREF subsystems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a larqe radioactive release does not exceed the calculated dose in the licensing basis conseauence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The LC0 is modified by a Note allowing the - a boundary to be opened intermittently under administrative controls. This Note only applies to openinqs in the CRE boundary that can be rapidly restored to the desiqn condition, such as doors, hatches, floor pluss, and access ~anels.For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area.

For other openings, these controls should be ~roceduralizedand consist of I stationing a dedicated individual at the opening who is in continuous communication with the m ? ; n ~ e r a t o r s 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 desiqn condition when a need for main control room boundary isolation is indicated.

Monticello Revision No.

CREF System B 3.7.4 BASES I

APPLICABILITY In MODES 1,2, and 3, the CREF System must be OPERABLE to serrkel

-nsure that the CRE will remain habitable during and following a DBA LOCA, since the DBA LOCA could lead to a fission product release.

I In MODES 4 and 5, the probability and consequences of a DBA are reduced because of the pressure and temperature limitations in these MODES. Therefore, maintaining the CREF System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:

I

a. During operations with %potential for draining the reactor vessel I (OPDRVs); and

b. During movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the CREF System is only required to be OPERABLE during fuel handling involving handling 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 />).

ACTIONS A. 1 With one CREF subsystem inoperable, for reasons other than an inoperable CRE boundary, the inoperable CREF subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE CREF subsystem is adequate to perform c x M t 4 -

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

B.l, B.2, and B.3 If the unfiltered in-leakage of potentially contaminated air past the CRE I

boundary and into the CRE can result in CRE occupant radioloqical dose greater than the calculated dose of the licensina basis analyses of DBA consequences (5 rem TEDEI. or inadequate protection of CRE occupants from hazardous chemicals or smoke. the CRE boundary is inoperable.

Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

Durinq the period that the CRE boundarv is considered inoperable, action must be initiated to implement mitiaatinq actions to lessen the effect on CRE occupants from the potential hazards of a radioloqical or chemical event or a challenqe 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 mitiqating actions will ensure that CRE occupant radioloqical exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE Monticello B 3.7.4-4 Revision No.

CREF System 6 3.7.4 BASES ACTIONS (continued) occupants are ~rotectedfrom hazardous chemicals and smoke. These mitinatinq actions (i.e., actions that are taken to offset the conseauences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, reuardless of whether entry is intentional or unintentional. 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 occurrinq durinq this time period, and the use of mitiqatinq actions. The 90 day Completion Time is reasonable based on the determination that the mitiqatina actions will ensure protection of CRE occupants within analvzed limits while limitinq the probability that CRE occu~antswill have to im~lementprotective measures that mav adverselv affect their abilitv 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 diaqnose, plan and possibly repair, and test most problems with the CRE boundary.

C.l and C.2 In MODE 1,2, or 3, if the inoperable CREF subsystem or 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 I 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.

The Required Actions of Condition D are modified by a Note indicating that L C 0 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.

Monticello B 3.7.4-5 Revision No.

CREF System B 3.7.4 BASES ACTIONS (continued)

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if the inoperable CREF subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREF subsystem may be placed i n the pressurization 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. 1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the cxm&&wm= boundary. This places the unit in a condition that minimizes the accident risk. I If applicable, movement of recently irradiated fuel assemblies in the secondary containment 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 the subsequent potential for fission product release.

Actions must continue until the OPDRVs are suspended.

Monticello Revision No.

CREF System B 3.7.4 BASES ACTIONS (continued)

If both CREF subsystems are inoperable in MODE 1,2, or 3 for reasons other than an inoperable cxMwkmmCRE boundary (i.e., Condition B), the 1 CREF System may not be capable of performing the intended function and the unit is in a condition outside ofthe accident analyses.

Therefore, LC0 3.0.3 must be entered immediately.

I F.l and F.2 The Required Actions of Condition F are modified by a Note indicating that L C 0 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 secondary containment or during OPDRVs, with two CREF subsystems inoperable, or with one or more CREF subsvstems inoperable due to an inoperable CRE boundarv,action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the cm&&wemCRE boundary. This places the unit in a condition that minimizes the accident risk. I If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, actions must be initiated immediately to suspend QPLWRs-OPDRVs to minimize the probability of a 1 vessel draindown and subsequent potential for fission product release.

Actions must continue until the OPDRVs are suspended.

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts on demand from the control room and continues to operate. Standby systems should be checked periodically to ensure that they start and function properly.

As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system. Monthly heater operation dries out any moisture that has accumulated in the charcoal as a result of humidity in the ambient air. Systems with heaters must be operated for 2 10 continuous hours with the heaters energized. Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available.

Monticello 6 3.7.4-7 Revision No.

CREF System B 3.7.4 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR verifies that the required CREF testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test iErequencies and additional information are discussed in I detail in the VFTP.

This SR verifies that on an actual or simulated initiation signal, each CREF subsystem starts and operates. The LOGIC SYSTEM FUNCTIONAL TEST in LC0 3.3.7.1, "Control Room Emergency Filtration (CREF) Instrumentation," overlaps this SR to provide complete testing of the safety function. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

I This SR verifies the OPERABILITY of the CRE boundarv bv testing for unfiltered air in-leakage past the CRE boundarv and into the CRE. The details of the testina are specified in the Control Room Envelo~e Habitabilitv Proqram.

The CRE is considered habitable when the radioloqical dose to CRE occupants calculated in the licensina basis analvses 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 in-leakaqe into the CRE is no qreater than the flow rate assumed in the licensing basis analvses of DBA consequences. When unfiltered air in-leakaae is qreater than the assumed flow rate. Condition B must be entered. Required Action 6.3 allows time to restore the CRE boundarv to OPERABLE status provided mitiqatinq actions can ensure that the CRE remains within the licensinq basis habitabilitv limits for the occupants following an accident. Com~ensatorvmeasures are discussed in Requlatorv Guide 1.196, Section C.2.7.3, (Ref. 2) which endorses, with exceptions. NEI 99-03. Section 8.4 and Appendix F (Ref. 3). These compensatorv measures may also be used as mitiqatinq actions as required bv Required Action B.2. Temporaw analvtical methods may also be used as compensatorv measures to restore OPERABILITY (Ref. 4).

Options for restoring the CRE boundarv to OPERABLE status include changing the licensinn basis DBA consequence analysis, repairinq the CRE boundarv, or a combination of these actions. Dependinq upon the nature of Monticello B 3.7.4-8 Revision No.

CREF System B 3.7.4 1 BASES SURVEILLANCE REQUIREMENTS (continued) the problem and the corrective action, a full scope in-leakaae test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

REFERENCES 1. USAR, Section 14.7.2.4.3 I

2. Requlatory Guide 1.I96

3. NEI 99-03, "Control Room Habitability Assessment," June 2001.

4. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January I

30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

Monticello Revision No.