ML040680923

Addendum to License Amendment Request Submitted May 21, 2003

ML040680923
Person / Time
Site:	Ginna
Issue date:	03/01/2004
From:	Mecredy R Rochester Gas & Electric Corp
To:	Clark R Document Control Desk, Office of Nuclear Reactor Regulation
References
RG-1.196, TAC MB9123
Download: ML040680923 (30)

Text

Robert C. Mecredy R OWg Vice President Always at Your Service March 1, 2004 Nuclear Operations Mr. Robert L. Clark Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C. 20555-0001

Subject:

Addendum to License Amendment Request submitted May 21, 2003.

R.E. Ginna Nuclear Power Plant Docket No. 50-244

References:

1. Letter from Robert C. Mecredy (RG&E) to Robert L. Clark (NRC) dated May 21, 2003, License Amendment Request Regarding Revision of Ginna Technical Specification Sections 1.1, 3.3.6, 3.4.16, 3.6.6, 3.7.9, 5.5.10, 5.5.16, and 5.6.7 Resulting From Modification of the Control Room Emergency Air Treatment System and Change in Dose Calculation Methodology to Alternate Source Term.

2. Letter from Robert C. Mecredy (RG&E) to Robert L. Clark (NRC) dated September 30, 2003, Summary of Public Meeting Between RG&E and NRC Staff Held on August 19, 2003.

3. Letter from Robert L Clark (NRC) to Robert C. Mecredy (RG&E) dated January 20, 2004, Request for Additional Information Regarding R.E. Ginna Nuclear Power Plant License Amendment Request Relating to the Control Room Emergency Air Treatment System Modification (TAC No. MB9123).

Dear Mr. Clark:

On May 21, 2003, Rochester Gas and Electric (RG&E) submitted a License Amendment Request (LAR) as indicated in Reference 1. Subsequent to the submittal, RG&E committed to "resubmit appropriate Technical Specification sections based on resolution of Technical Specification Task Force (TSTF)-448" in Reference 2. TSTF-448 is not yet approved.

Therefore, in a conference call on February 5, 2004 between RG&E and your staff, RG&E agreed to resubmit the appropriate sections per Regulatory Guide 1.196, Control Room Habitability at Light Water Nuclear Power Reactors, Appendix B. Additionally, Reference 3, items 13 and 14, requested information on section 5.5.10.b. The attachments to this letter provide the above information and should be docketed as an addendum to Reference 1.

I declare under penalty of perjury under the laws of the United States of America that I am authorized by Rochester Gas and Electric Corporation to submit this documentation and that the foregoing is true and correct.

If you have questions regarding this submittal please contact Mr. Mike Ruby at (585) 771-3572.

Very truly yours, Executed on March 1, 2004 011 An equal opportunity employer Robert C. Mecredy 89 East Avenue I Rochester, NY 14649 tel (585) 546-2700 www.rge.comi An Energy East Company

Attachments:

1.

Tech Spec Sections 3.7.9, 5.5.16, 5.6.7 and 5.5.10.b Markup

2.

Tech Spec Section 3.7.9, 5.5.16 and 5.6.7 Typed

3.

Bases Section 3.7.9 Markup

4.

List of Regulatory Commitments Cc:

Mr. Robert L. Clark (Mail Stop 0-8-C2)

Project Directorate I Division of Licensing Project Management Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector Mr. Peter R. Smith New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. Paul Eddy NYS Department of Public Service 3 Empire State Plaza, 10 th Floor Albany, NY 12223 Tech Spec Sections 3.7.9,5.5.16,5.6.7 and 5.5.10.b Markup

3.7.X 9

3.7 PLANT SYSTEMS

<i 7R 3.7.,

Control Room Emergency System (REF£)

LCO 3.7.A Two GREFS trains shall be OPERABLE.

- NOTE -

The control room boundary may be opened intermittently under administrative control.

MODES 1, 2,3, 4[6, aid 6],

During movement of {*eeeRy] irradiated fuel assemblies.

APPLICABILITY:

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One GREFS train A.1 Restore GREFS train to 7 days inoperable.

OPERABLE status.

CKk: a-Tf5 B. TwoGRefStrains inoperable due to inoperable control room boundary in MODE-i -2, 33-or-4r,

B.1 Restore control room boundary to OPERABLE status.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 4

4 Required Action and associated Completion Time of Condition A or B not metin -MODE-1 i-2e 3,

-or-4 AN1 AND Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours 4'r

,-e4%SOA$ tAs-c tjta&s CL'ic',"JC.

•  me2.

A.)

• r R.F.

A;<Hs1>

r-r PG.

WGG^

A4TO 9

376-1 Rev. 2, 01l0n1

GREFS 3.7X; ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C Required Action and Xi F

associated Completion NOTE Time of Condition A not

[Placetoxic gas mete MODE 6

during movement of automatic to toxic Meeentel irradiated fuel gas pr ction mo is 7'assemblies.

ierable. ]

cRrdrS Place OPERABLE eREFS Immediately train in emergency mode.

,OR

,02 4:Suspend movement of Immediately irradiated fuel assemblies.

• Eg Co C.KEtt75 Two GREFS trains -

inoperable [in MODE '

eF 6, oer during movement of [reeently]

irradiate fuel assemblies,

)zg1 Suspend movement of CG oeently] irradiated fuel assemblies.

Immediately 4

4

,f<

Two eREFS trains H'

inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition E2 Xi Enter LCO 3.0.3 Immediately A r rea 6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY CIEW$T.

SR 3.7.g.1 Operate each GREF& train for [a 10 ecntinuwus 31 days 9

-hours with the heatres oporating or (for systems without heate"e 2 15 minutest.

SR 3.7.y%2 Perform required GREFS filter testing in accordance In accordance with the.Ventilation Filter Testing Program (VFTP4.

withVFTP1 QE.

0,..Vsac let, -ie P*A wee aT 3.7.,X-22 Rev. 2, 04,'0,'01

CACAT-S GREFS 3.7.)

.9 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.)I.3 Verify each eREFS train actuates on an actual or Jj8rmonths simulated actuation signal.

,U/

37i one CREFS train can maintain a positive n s on a 7

pressue5iches watereto STAGGERED the adjacent [turbing the TEST BASIS pres de of operation at am rate of

[3000] cfm.

a, E, 3.7P-3s TWO)GS T£ Am i a, 4/dsledL t Rey. 2, 04/30/01 3.7.X-3 q7

TS 3.7.9 Inserts C. Surveillance Requirement 3.7.9.4 not met.

C.1 Initiate compensatory measures.

AND C.2 Restore inleakage to s acceptable inleakage as established in Specification 5.5.16.

Immediately 14 days D. Required Action C.2 and D.1 Issue a report in 90 days associated Completion accordance with Time not met.

Specification 5.6.7.

SR 3.7.9.4 Verify control room measured inleakage is

• In accordance with acceptable inleakage established in accordance with Control Room Specification 5.5.16.

Integrity Program (CRIP)

@

Programs and Manuals 5.5 Leakage Rate acceptance criteria are:

a.

Containment leakage rate acceptance criterion is

• 1.0 La. During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are 5 0.60 La for the Type B and Type C tests and

• 0.75 La for Type A tests;

b.

Air lock testing acceptance criteria are:

1.

For each air lock, overall leakage rate is 5 0.05 La when tested at 2 P.a and

2.

For each door, leakage rate is

• 0.01 La when tested at 2 Pa.

c.

Mini-purge valve acceptance criteria is

• 0.05 La when tested at 2 Pax The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 3.0.3 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

-e R.E. Ginna Nuclear Power Plant 5.5-1 0 Amendment 81

TS Section 5.5 Inserts 5.5.16 Control Room Integity Program (CRIP)

A Control Room Integrity Program shall be established and implemented to ensure that the criterion described in 10 CFR 50, Appendix A, General Design Criteria 19 is maintained. The program will provide controls to maintain main control room envelope integrity and shall include:

a.

Establishing acceptable amounts of radioactive and hazardous chemical inleakage for the main control room.

b.

Maintaining configuration control and managing breaches of the main control room envelope to ensure that the values for inleakage remain below the established acceptable values.

c.

Testing for main control room inleakage in accordance with and at the frequencies specified in Regulatory Guide 1.197.

d.

Providing preventative maintenance of doors, wall/roof/floor penetrations, dampers and floor drains that are part of the main control room envelope.

e.

Assessing main control room habitability at the frequencies specified in Regulatory Guide 1.197.

Reporting Requirements 5.6 September 29,1997, as supplemented by letter from R.C.

Mecredy, RG&E, to Guy S. Vissing, NRC, "Corrections to Proposed Low Temperature Overpressure Protection System Technical Specification," October 8, 1997.

2.

WCAP-1 4040-NP-A, "Methodology used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves," Sections 1 and 2, January, 1996.

d.

The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for revisions or supplement thereto.

61 R.E. Ginna Nuclear Power Plant 5.6-5 Amendment 80

TS Section 5.6 Inserts 5.6.7 Control Room Emergency Air Treatment System Report

6)

A report shall be submitted within 90 days outlining the compensatory measures, the cause of Condition C in Specification 3.7.9, and the plans and schedule for restoring inleakage to

• the acceptable inleakage established in Specification 5.5.16.

Programs and Manuals 5.5

b.

SG tubes that have imperfections > 40% through wall, as indicated by eddy current, shall be repaired by plugging or sleeving.

c.

SG sleeves that have imperfections > 30% through wall, as indicated by eddy current, shall be repaired by plugging.

5.5.9 Secondary Water Chemistry Proaram This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. This program shall include:

a.

Identification of a sampling schedule for the critical variables and control points for these variables;

b.

Identification of the procedures used to measure the values of the critical variables;

c.

Identification of process sampling points;

d.

Procedures for the recording and management of data;

e.

Procedures defining corrective actions for all off control point chemistry conditions; and

f.

A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

5.5.10 Ventilation Filter Testing Proaram (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature filter ventilation systems and the Spent Fuel Pool (SFP) Charcoal Adsorber System. The test frequencies will be in accordance with Regulatory Guide 1.52, Revision 2. except that in lieu of 18 month test intervals, a 24 month interval will be implemented.

The test methods will be in accordance with Regulatory Guide 1.52, Revision 2, except as modified below.

tainmen Post-Accident Charcoal System

1.

Demon e pressure drop across the charcoal adso bank is < 3 inches er at a design flow r.

2.

.ban~~Fows a penetration and syonm when tested under ambient conditions.

R.E. Ginna Nuclear Power Plant 5.5-5 Amendment--

Programs and Manuals 5.5

.strate that a laboratory test of a sample of the r, when obtained as desccrei regulatory Guide 1.52, Revisio ws a iodide penetration of less than 14.5%/c whh~~i-eGQnce with ASTM D3803-1 9

tst temperature of 3 0

n ue'humidity of 95%.

c>/{

Containment Recirculation Fan Cooler System

1.

Demonstrate the pressure drop across the high efficiency particulate air (HEPA) filter bank is < 3 inches of water at a design flow rate (+/- 10%).

2.

Demonstrate that an in-place dioctylphthalate (DOP) test of the HEPA filter bank shows a penetration and system bypass

< 1.0%.

bKef Control Room Emergency Air Treatment System (CREATS)

1.

Demonstrate the pressure drop across the I I filteban! is in l ~

<ysJ)

<3 of water at a design flow rate (+/- 1 0%).

rZ.O.

2 Demn rate that an in-place DOP test of the HEPA filter

~bank shows a penetration'and system bypass <

Cv,,.jc.( JjrP,4 4 e

1,w-eval c-d.5vrbe-,

a-,d f&C POSY
';

3.

Demonctrato the proccurP drop acrocc the charceal dcorbor bankis ic inhe: of kater at a desin flew rate (~ 1%

I)V I~e~rhue C. h' dde,-~~c

.~i4~f'f 4~~r-A~cLO.

-.ee Demonstrate that an in-place Freon test of the charcoal adsorber bank shows a penetration and system bypass

<4-IG% when tested under ambient conditions.

.1 Demonstrate that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows a methyl iodide penetration of less than 14.5% when tested in accordance with ASTM D3803-1989 at a test temperature of 301C (861F) and a relative humidity of 95%.

Cd<

SFP Charcoal Adsorber System

1.

Demonstrate that the total air flow rate from the charcoal adsorbers shows at least 75% of that measured with a complete set of new adsorbers.

2.

Demonstrate that an in-place Freon test of the charcoal adsorbers bank shows a penetration and system bypass

< 1.0%, when tested under ambient conditions.

R.E. Ginna Nuclear Power Plant 5.5-6 Amendment-B+

Tech Spec Sections 3.7.9, 5.5.16 and 5.6.7 Typed

CREATS 3.7.9 3.7 3.7.9 PLANT SYSTEMS Control Room Emergency Air Treatment System (CREATS)

I LCO 3.7.9 Two CREATS trains shall be OPERABLE.

-NOTE-The control room boundary may be opened intermittently under administrative control.

APPLICABILITY:

MODES 1, 2,3, and 4, During movement of irradiated fuel assemblies.

I I

I I

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One CREATS train A.1 Restore CREATS train to 7 days inoperable.

OPERABLE status.

B.

Two CREATS trains B.1 Restore control room 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inoperable due to boundary to OPERABLE inoperable control room status.

boundary in MODE 1, 2, 3, or 4, for reasons other than Condition C not met.

C.

Surveillance Requirement C.1 Initiate compensatory Immediately SR 3.7.9.4 not met.

measures.

AND C.2 Restore inleakage to

• 14 days acceptable inleakage as established in Specification 5.5.16.

D.

Required Action C.2 and D.1 Issue a report in accordance 90 days associated Completion with Specification 5.6.7.

Time not met.

l R.E. Ginna Nuclear Power Plant 3.7.9-1 Amendment

CREATS 3.7.9 CONDITION REQUIRED ACTION COMPLETION TIME E.

Required Action and E.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4.

E.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> F.

Required Action and F.1 Place OPERABLE CREATS Immediately associated Completion train In emergency mode.

Time of Condition A not met during movement of OR irradiated fuel assemblies.

F.2 Suspend movement of Immediately irradiated fuel assemblies.

S Two CREATS trains GO Suspend movement of Immediately inoperable during irradiated fuel assemblies.

movement of irradiated fuel assemblies for reasons other than Condition C.

H.

Two CREATS trains H.1 Enter LCO 3.0.3.

Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B or C.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Operate each CREATS train for 2 15 minutes.

31 days SR 3.7.9.2 Perform required CREATS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP).

VFTP SR 3.7.9.3 Verify each CREATS train actuates on an actual or 24 months simulated actuation signal..

SR 3.7.9.4 Verify control room measured Inleakage is

• In accordance with acceptable inleakage established in accordance with the Control Room Specification 5.5.16.

Integrity Program (CRIP)

I I

R.E. Ginna Nuclear Power Plant 3.7.9-2 Amendment

Programs and Manuals 5.5 5.5.16 Control Room Intearitv Proaram (CRIP)

A Control Room Itegrity Program shall be established and implemented to ensure that the criterion described in 10 CFR 50, Appendix A, General Design Criteria 19, is maintained. The program will provide controls to maintain main control room envelope integrity and shall include:

a.

Establishing acceptable amounts of radioactive and hazardous chemical inleakage for the main control room.

b.

Maintaining configuration control and managing breaches of the main control room envelope to ensure that the values for inleakage remain below the established acceptable values.

c.

Testing for main control room inleakage in accordance with and at the frequencies specified in Regulatory Guide 1.197.

d.

Providing preventative maintenance of doors, wallroof/floor penetrations, dampers, and floor drains that are part of the main control room envelope.

e.

Assessing main control room habitability at the frequencies specified in Regulatory Guide 1.197.

R.E. Ginna Nuclear Power Plant 5.5-1 0 Amendment

Reporting Requirements 5.6 Proposed Low Temperature Overpressure Protection System Technical Specification,' October 8, 1997.

2.

WCAP-1 4040-NP-A, 'Methodology used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves," Sections 1 and 2, January, 1996.

d.

The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for revisions or supplement thereto.

5.6.7 Control Room Emeraency Air Treatment System (CREATS) Report A report shall be submitted within 90 days outlining the compensatory measures, the cause of Condition C in LCO 3.7.9, and the plans and schedule for restoring inleakage to < the acceptable inleakage established in LCO 5.5.16.

R.E. Ginna Nuclear Power Plant 5.6-5 Amendment Bases Section 3.7.9 Markup Note: These bases pages are being provided for information only to show the changes that RG&E intends to make following approval of the LAR. The bases are under RG&E control for all changes in accordance with Specification 5.5.13. RG&E requests that the NRC document acceptance of these bases changes in the SER.

83.7 90 B 3.7 PLANT SYSTEMS B 3.7.;k Control Room Emergency Filtration System (CREFS)

BASES BACKGROUND The eHEFS provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivitg, chemicals, or toxic gag TheGriEFs' consists of two independent, redundant trains that recirculate and filter the control room ar Each train consists of a prefilter or demisier, a high efficiency particulate air (HEPA) filter, an' activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, and instrumentation also form part of the system, ac Awoll arc domictorc to remove woator erepltei from the air ctroat;'. A second bank of HEPA filters follows the adsorber section to collect carbon fines and provide backup in case of failure of the main HEPA filter bank.

The GREFSis an emergency system, pa;rt of Which may alc oporatGe~

duringR ormal unit oporationo in the ctandby mod: of oporation. Upon receipt of the actuating signal(s), normal toFtecntrol room is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilterseB demirs4e~ remove any large particles in the air, and ant ontrain2d locator droplots procon. to prevent excessive loading of the HEPA filters and charcoal adsorbers. Getnuous oporation f

htrin for at Ions: 10 hou~E pr month, "ith the hU6 r en. Fedcee: mo1ictur b

eildup n

Gho HEPA filtor; and a-dorbore Both the domictor and hoator aro important to tho offoctivonooc of the oharooAl

~c-eX A

Actuation of the EGREFS places the system in either of tRo Scparatc tats: (emergcnoY radiadien stato or toxic gasb ovsvatat

_ ek-_ the emergency mode of operation, deponding on tho initiation

-eit~+ Actuation of the systerrq to the omorgonc5' radiation tate of !he emergency mode ot operatiorrolo-c: the unfiltered outside air intalte end g1d/5z0 Z-AC M~rd"AJI Cr#.the C.,JY4-0(

JT(ca t

( unfiltered exhaust danmpore, and aligns the.svstem for recirculation of the control room air through the redundant trains of HEPA and the charcoal filters. The eme

-Rey radiation

-to9-aRbco initiatoc Paim iartio;n;;'

and 4ltzriod vrentibation of theOT air S-Uppl-- t the cnrol room.

r is feitered, diluted with building air fromth equipment ande e

d to the air being recirculet control room infltration of unfiltered air from the surrounding

-Wee-STIB3&)d<

o.2 O'O'-

B 3.7-Z 1 17 Re4,. 2, 94,19elei-12e-v ts / o,,j

B 3.7.X 1

I BASES BACKGROUND (continued) aions taken in the toxic gas isolation stat excet tat te s

gl; l

=

n to n iolation O utsid~~~e air from entrn l

r

/'

L The air entering the control room is continuously monitored by radiation and toxic gas detectors. One detector output above the setpointiV'll cause actuation of the e o en cdtionatR ofto omrg oxic radiation utto.

F itiead A eei teatns of the meigency radiation state.

p.-

'*~.*.

• A ringle trainRil Orm'Mr~; tht; controgl r~oom to about [t.1 253 inchea.

wate-gauge. The operation in maintaining the control room habitable is disdussed in thFSAR, SectionV6.4)(Ref. 1).

Redundant suply aWdrecirculation trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally open isolation dampers are arranged in series pairs so that the failuren rftjmper to shut will not result in a breach of isolation. The is designed in accordance with Seismic Category I requirements.

The eREFS is designed to maintain the control room environment for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem ef the body.

?S Ie Ace x

D I

APPLICABLE The GREF& components are arranged in redundant, safety related SAFETY ventilation trains. The location of components and ducting within the ANALYSES control room envelope ensurt, pequate supply of filtered air to all areas requiring access. The 4R tprovides airborne radiological protection for the control room operators, as demonstrated by the control 7i0Ait tSCM room accident dose analyses for the -most-limiting design basis los966f Ia -ga cider&on product release presented in the =SAR,

>,e*/ rrcGhpvteFECapcr{q}(Rdef.72A ccS oc/a cdW a it C' te QrC a adore 0I '0 The analysis of toxic gas releases demonstrates that the toxicity limits are

,1 not exceeded in the control room following a toxic chemical release, as t'4 7cceAcd4/,tr

?5 presented in Reference 1..

/;

• .dwdV0 a

d

'X W

z4 X/*

Zi;S LC 0 The worst case single active failure of a'component of the GREFS v..

assuming a loss ot ottsite power, does not impair the ability ot the system to perform its design function.

-w e -s sF B 3.7.X.-

2

[~

,0 3 0 Rev. 2, EW58f8l P"evlstooj

-e A'S A c~r

-eREFe-f hs eeoo 4ie Od7irn?4 GA*/ z1 c c A 7E-BT37.tr ts f

ireptre&$ IM 2e eu -'

of a

&Oa o

9 BASES APPLICABLE SAFETY ANALYSES (continued)

C. a4S 7 TheeREFO satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO CPI9r'5 Two independent and redundant GREFS trains are required to be OPERABLE to ensure that at least one is available assuming a single failure disables the other train. Total system failure could result in exceeding a dose of 5 rem the control room operator in the event of a large radioactive release.

o c

TheREFS is considered OPERABLE when the individual components jlc~,ry to limit operator exposure are OPERABLE in both trains.,

gmtrain is OPERABLE when the associated:

Te,a 5 z re

a.

Fan is OPERABLE,

'eaqe I

^

b.

HEPA filters and charcoal adsorbers are not excessively restricting 0'/ls bcd t flow, and are capable of performing their filtration functions, and

,s-eci fads

~.2t

c.

Hcatcr, demiztci, fictwork, valves, and dampers are OPERABLE, 4, t and air circulation can be maintained.

In addition, the control room boundary'must be maintained, including the

_ r integrity of the walls, floors, ceilings, ductwork, and access doors.

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

' through doors, the administrative control of the opening is performed by

> aprsons entering or exiting the area, or other opening, these controls consist of stationing a dedicated individual at the opening who is a,. rs tCe az in continuous communication with the control room. This individual will

{

Ca^}t{

7.Jt, 7,

f) have a method to a close the opening when a need for control room 5

'.isolation is indicated.

7#ssert 6S t2-4J APPLICABILITY In MODES 1, 2, 3, 4, [6, an,

Ri-j.during mov^enont of [roeontly]

irradiated fuel aecombli o, BRlS must be OPERABLE to control operator exposure during and following a DBA.

In [MODE 5 Or 6], the CREFS is requirod l the ruFture _f a.n eutside waste gas tan.

to cope With tho rolBA en-ff-p CR.E AT's During movement of freeently] irradiated fuel assemblies, the GREF-must be OPERABLE to cope with the release from a fuel handling accidenthinevis g handling

Aooont, AraIdiat_

d fuel]. [The CR=Fa is en)Ly P E. 61-SfJs-rO!,

Pkr B 3.7.4(- 3 3I eV. 2, 4-eJUIU1 Re U/so/aj

B 3.7.X' 9

BASES APPLICABILITY (continued) iaedlERAB E during fuel handling involy recently irradiateuecudpart of a critical reactor erprevius [ ] days), due to adia ACTIONS A.1 CRETSS When one GREF& train is inoperable, action must be taken to restore OPERABLE sjuithin 7 days. In this Condition, the remaining OPERABLE: !train is adequate to perform the control room protection function. However, thpye I reliability is reduced because a Sigliure in the OPERABLEGIxotrain could result in loss of Z

N function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B.1 REVIEWER'S NOTE -

Adoption of Condi ependent on a co the licensee to have written procedures av ng compensatory measures to be taken in the e ntentional or al entry into Condi f Jjje~ntrol room boundary is inoperable in MODE 1, 2,3, or,

e icannot perform their intended functions. Actions must be C.

taken to restore acontrol room boundaryithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

During the period that the control room boundary is inoperable, a ropriate compensatory measures (consistent with the intent of GDC

' 2 19jfh id be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the/ondition. 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 compensatory measures. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion;ne is a typically reasonable time to diagnose, plan and P966!bI repair, and test most problems with the control room boundary.

7We&Sf S B 3.7.;d

-4 fld e-gs i\\64 bI~eterev HI rhe, cc¢<eec/

rA-6s/1,/

-Cor fo -meets,Are 1 /,-/a kv tV f-1e s OF fe 31,17,qy

. ile, dd~taso v/ bycilefg 13 T:

3.7.0 - 4 Re.aw 4S~0

CR£ 1T5 eREFs-B 37j BASES ACTIONS (continued)

X1 and O.2 cRE ATS In MODE 1, 2, 3, or 4, if the inoperable eREFS train or control room boundary cannot be rptorQd to OPERABLE status within the required Completion Time, thertunust be placed n ODE that minimizes accident risk. To achieve this status, the must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times Loe seasonable, based on operating experience, to reach the reqt Wconditiori from full power conditions in an orderly manner and without challenging -

systems.

,K1 and ;.2

[In MODE 6 or 6, or],during m of-[reeently] irradiated fuel assemblies, if the inoperable train cannot be restored to OPERABLE status within the required Compln 1i^;lm e, action must be taken to immediately place the OPERABLE<W train in the emergency mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative to Required ActionO.1 is to immediately suspend activities that could result in a release of ra a *vity that might require isolation of the control room. This places the Win a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

fleqUired Aetien.D13-is, lflVdifi4d by a Noto indientiR-to plaoe th bv-vI Ad

--Xa e-eystemf A A in inn ;n*in nni nrninin nn fiin iinRirir~nTff]nr proto.c. t mod I

snoporao.

Ah

-in

-shiv is v

zv av v

I C,f/ M, vement ofF[reeenty] irradiated fuel Gdal c

a assemblies, with two y

trains inoperable, action must be taken h

6 O er immediately to suspend activities that could result in a release o J $~',. /

.'r co Iradioactivity that might enter the control room. This places the in a or'a

'0 I.-

Icondition that minimizes accident risk. This does not preclude the e7sC (L movement of fuel to a safe position.

re ree0 S CJ't 1224T.5

<we

3. 7- ?.?

If both GREFS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable control room boundarv.(i.e.. Condition O). the (or-C wee S-e8 lv*

,O,3~

B 3.7 -*

5 Rev. 2, 84
38
04 Ize, 1, is
6, 0

B 3.7.8 BASES ACTIONS (continued)

RE A rt5 r---

F may not be capable of performing the intended function and the

'°4,h unitiin a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

9 SURVEILLANCE SR 3.7. 11 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. Monthly h92ter 0P9rati0RG dr' out ay MOiG1t190 accumulatod in the charco2l9 -rom.

humidity in tho ambient oir. [Syctomcr rAith heators must be operated for. 140 continuous hours Axith tho hoaters onorgiFod. SyItOM_

WithOlt hoatorc Ro 0l1' hp X -oy s et$ s-operated for 2 15 minutes to demonstrate the functionred4 te.

qyqtem~ The 31 day Frequency is based on the reliability of the equipment and the two train redundancy availability.

SR 3.7.0.2 C.ea A r-s This SR verifies that the required GREFS testing is performed in A

accordance with thetlentilation Filter Testing Program (VFTP)Z. The aue/

' c We VI FTF~includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the 7 "8'd activated charcoal toct Frequencies and ndrfinion Z C2Sts /5 LaxJ re discu s-a in dstai in #49 tVFTP.

c-1clec o/J eote /

SeR 3.7..3 deXCAfl6d 60e This SR verifies that each enEFs train starts and operates on an actual or simulated actuation signal. The Frequency of months is-epeeifie (CGwre /.S'2(ek

36) 4n-Regulatory Guide 1.52 (Ref. 3).

§II7 SR 8.7.104 lxhk R verifies the integrity of the control room enclosure, antje, assume akage rates of the potentially contaminate The control room positive p e with respect to potenti ntarninated adjacent areas, is periodically tedl'o verify r cioig of the CREFS. During the emergencv

~of operation, the CREFS is designed to pressurize ontrol roo

.125] inches water gauge positive press respect to adjacent area der to prevent unfilt akage. The CREFS is designed to main s positive ure with one train at a makeup flow rate of [3000] cfm.

WBG ST6 3.7.).O-6 Rev. £, 04130101 (0

J47&-Q4clev PAi A)eu

~a REFS-B 3.7.W'7 BASES SURVEILLANCE REQUIREMENTS (continued) rFerogucy of [118] monthc wih!euidanee preyid-e con a STAGGERED TEST BASIS io eonsistont fI in NURlEG 0800 (Ref. 4).

REFERENCES

1.

c FSAR3 Section $.4

2. JFSAR, Ghaptefj46 cctf.

/:7

3.

Regulatory Guide 1.52, Rev.*.

1.

JUFREG 0800, eootiwn 6.4, Rey. 2, July 1981. s' if j

WGG 6T-Sc IZG 6wuA. p4cfet,- /*(rP (A've B 3.7.X-7

- ev. 2, 04/30fO1 A ev toLl /OJ

AK6 nRom Am CONTROL ROOM (50' x 40')

noAl OM=z oDVJST M AM" RTED4 rAH

= CONTROL ROOM EMERGENCY ZONE BOUNDARY

• = EXISTING CREATS & HEATING/COOLING

= PROPOSED NEW SYSTEMS AW108 tOAMJ m

GINNA CONTROL ROOM HVAC

TS Section 3.7.9 Bases Inserts

d.

The CREATS automatic isolation dampers are OPERABLE. They are considered OPERABLE when the damper can close on an isolation signal or is closed with A~)

4motive force removed. Dampers AKDO3, AKD21, and AKD23 are associated with the A Train. Dampers AKDO2, AKD22, and AKD24 are associated with the B Train.

The ventilation ductwork or system components may also be opened for extended periods provided that the associated CREATS filtration train is declared inoperable. The portion of the system that is open must be isolated from the control room by a damper that is closed with motive force removed or by a passive isolation device. If the above condition for utilizing the LCO note cannot be met, Condition B or G should be entered.

C. 1 and C.2 If SR 3.7.9.4 is not met, General Design Criteria (GDC) 19 may not be met. Actions must be taken to insure that GDC 19 is met. During the period when SR 3.7.9.4 is not met, appropriate compensatory measures (consistent with the intent of GDC 19) must be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for entry into Condition C. The 14 day Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory F

measures.

D.1 Condition D applies when the Required Actions C.2 and its associated Completion Time is not met. This Required Action specifies initiation of actions in Specification 5.6.7, which requires a written report to be submitted to the NRC. This report discusses the compensatory measures, the cause of the Condition C, and plans and schedule for restoring the inleakage to

• the acceptable inleakage established in Specification 5.5.16.

Consistent with LCO 3.0.2, if SR 3.7.9.4 is met before the report is due, the report is not required to be submitted. This action is appropriate in lieu of a shutdown requirement since compensatory measures to insure General Design Criteria 19 is met have been itiated.

SR 3.7.9.4 This SR verifies that the control room habitability requirements are met in accordance (2x-with the Control Room Integrity Program. It addresses both radiological and hazardous chemicals from sources external to the control room. Specific test frequencies and additional information are discussed in detail in the Control Room Integrity Program.

List of Regulatory Commitments The following table identifies those actions committed to by RG&E in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENT DUE DATE Provide CREATS system pressure drop June 15, 2004 (after initial startup testing information for Technical Specification of new CREATS filtration trains) 5.5.10.b, item 1. Submit new typed pages to reflect this change and changes to I

bypass numbers for items 2 and 3.