Text

Units I and 2 - Request to Revise Technical Specifications Control Room Habitability
	ML042400220
Person / Time
Site:	Farley
Issue date:	08/25/2004
From:	Stinson L; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML042400220 (52)
	v • d • e

L M. Stinson (Mike)

Southern Nuclear Vice President Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.5181 Fax 205.992.0341 SCUTHERNIZJ COMPANY August 25, 2004 Energy to Serve Your World"'

Docket Nos.:

50-348 NL-04-1473 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Units I and 2 Request to Revise Technical Specifications Control Room Habitability Ladies and Gentlemen:

In accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to revise the Technical Specifications (TS) to establish a new Control Room Integrity Program for the Farley Nuclear Plant (FNP), Units 1 and 2, Facility Operating License Nos. NPF-2 and NPF-8.

The proposed change is based on the model TS and Bases provided by the NRC as an acceptable means to implement Regulatory Guide (RG) 1.196. With implementation of this change, FNP will comply with the guidelines of RG 1.196 and RG 1.197 with the exceptions noted in Enclosure 1. The Final Safety Analysis Report (FSAR) will be revised to contain these exceptions. This is consistent with the process approved by the NRC in SER dated May 1, 1997 to FNP related to issuance of amendments 127 and 121 (Unit I and Unit 2, respectively) for the Control Room Emergency Filtration /

Pressurization System (CREFS), Penetration Room Filtration (PRF) System, and Containment Purge System TS. As required by the NRC per a recent conference call with SNC, revision of the FNP TS consistent with the model TS is necessary to implement the change to Limiting Condition for Operation (LCO) 3.9.3, Containment Penetrations, submitted by SNC letter dated August 29, 2003 and followed-up with RAI responses submitted by SNC letters dated November 11, 2003, May 5, 2004, June 10, 2004, and August 5, 2004.

A new section, TS 5.5.18, "Control Room Integrity Program (CRIP)" is added to the FNP TS by the proposed change, while existing sections TS 3.7.10, "Control Room Emergency Filtration/Pressurization System (CREFS)" and TS 5.5.11, "Ventilation Filter Testing Program (VFTP)" are revised. The pagination of this TS amendment request is based on, and assumes the prior approval of, the Steam Generator Program TS amendment request submitted by SNC letter dated August 5, 2004.

Enclosure I provides the basis for the proposed change, including an evaluation determining that the proposed change involves no significant hazards consideration as

U. S. Nuclear Regulatory Commission NL-04-1473 Page 2 defined in 10 CFR 50.92, an evaluation that this change satisfies the criteria of 10 CFR 51.22 for categorical exclusion from the requirements for an environmental assessment, and a listing of the major inputs and outputs for the Loss of Coolant Accident (LOCA) calculation related to the control room inleakage. Enclosures 2 and 3 include the marked-up and clean-typed TS and Bases pages incorporating the proposed change. With the adoption of the proposed TS amendment, new and revised surveillance requirements will become effective. SNC intends to treat all new requirements as being "met" at the time of implementation, with the first performance of these new surveillance requirements scheduled to be completed within the required interval from the date of implementation.

The SNC schedule for performing new and revised surveillance requirements is provided in Enclosure 4.

SNC requests approval of the proposed change by September 30, 2004 to support replacement of the Unit I Reactor Vessel Head currently scheduled to be performed during the FNP Unit I fall 2004 refueling outage. The amendment will be implemented within 30 days of approval.

A copy of the proposed change has been sent to Dr. D. E. Williamson, the Alabama State Designee, in accordance with 10 CFR 50.9 1(b)(1).

Mr. L. M. Stinson states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

This letter contains no NRC commitments. If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY L -M.-Stinson S

Fn 4d idd sbs re me this clays ofJ 2004.

N rarbs Public

'M l, conlission expires:

LMS/WAS

Enclosures:

1. Basis for Proposed Change

2. Marked-Up Technical Specifications and Bases Pages

3. Clean Typed Technical Specifications and Bases Pages

4. Schedule for Performing New and Revised Surveillance Requirements

U. S. Nuclear Regulatory Commission NL 1473 Page 3 cc:

Southern Nuclear Operating Comnany Mr. J. B. Beasley, Jr., Executive Vice President Mr. D. E. Grissette, General Manager - Plant Farley RTYPE: CFA04.054; LC# 14113 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Mr. S. E. Peters, NRR Project Manager-Farley Mr. C. A. Patterson, Senior Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farlcy Nuclear Plant Units 1 and 2 Request to Revise Technical Specifications Control Room Habitability Basis for Proposed Change

Joseph MI. Farlcy Nuclear Plant Units 1 and 2 Request to Revise Technical Specifications Control Room Habitability Basis for Proposed Change 1.0 Description The proposed change revises the Farley Nuclear Plant (FNP) Units I and 2 Technical Specifications (TS) to address Control Room boundary unfiltered inleakage by revising Limiting Condition for Operation (LCO) 3.7.10, "Control Room Emergency Filtration/Pressurization System (CREFS)" and TS 5.5.1 1, "Ventilation Filter Testing Program (VFTP)" and adding a new section, TS 5.5.18, "Control Room Integrity Program (CRIP)."

2.0 Proposed Change The name and LCO statement of LCO 3.7.10, "Control Room Emergency Filtration/Pressurization System (CREFS)," are revised to specify that the LCO applies to both the CREFS and the Control Room Envelope (CRE).

The ACTIONS of LCO 3.7.10, are revised to:

Provide new ACTIONS for an inoperable CRE which:

Require mitigating actions to be initiated immediately.

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , require restoration of the CRE to OPERABLE status or verification that General Design Criterion (GDC) 19 is met using the mitigating actions.

If it is verified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that GDC 19 is met using the mitigating actions, the new ACTIONS provide 30 days to restore the CRE to OPERABLE status.

Revise Condition E and replace Condition F with revised Condition C. This clarifies and simplifies the presentation without changing the requirements, with one exception. If two CREFS trains are inoperable, the proposal directs a shutdown instead of the current requirement to enter LCO 3.0.3. This is a more restrictive change because the one hour provided by LCO 3.0.3 to prepare for a shutdown is eliminated. This change is consistent with other NRC and industry initiatives to address loss of function within the specification instead of referring to LCO 3.0.3.

Surveillance Requirements SR 3.7.10.1 and 3.7.10.3 are revised to reflect the guidance of Regulatory Guide 1.52, Revision 3 for testing. Surveillance Requirement SR 3.7.10.4 is deleted and replaced with a new surveillance requirement which adopts the requirements of the NRC model TS to verify that the CRE Ap is within limits with one CREFS train in operation.

A new Surveillance is added which requires verification of the CRE integrity in accordance with the Control Room Integrity Program. The Frequency is set in accordance with the Control Room Integrity Program.

Control Room Habitability NL-04-1473 Enclosure I Page 2 of 9 TS 5.5.1 1, "Ventilation Filter Testing Program (VFTP)," is revised to reflect the guidance of Regulatory Guide 1.52, Revision 3 for testing and to make editorial changes.

A new TS 5.5.18, "Control Room Integrity Program" is added to the Administrative Controls Programs and Manuals section. This program requires the establishment of a new Program to ensure control room envelope integrity is maintained.

The Bases are revised to reflect these changes and to update the discussion based on current experience, knowledge, regulatory requirements, and an accurate reflection of the purpose of the Specification.

3.0

Background

The TS require that the control room ventilation system be capable of maintaining positive pressure in the control room relative to adjacent areas. The Bases for this surveillance state that it verifies the integrity of the control room enclosure and the assumed inleakage rates of the potentially contaminated air. Integrated inleakage testing has been performed at FNP and demonstrated that the measured inleakage rates were slightly greater than the inleakage rates originally assumed in the safety analyses. While FNP, which has a positive pressure control room, has passed its positive pressure surveillance acceptance criteria, this testing did not verify the assumed inleakage rate.

Also, it has been determined that even with the pressurization system maintaining a positive pressure in the control room envelope, there are certain areas that still may be subject to inleakage that could contribute to operator radiation exposure.

4.0 Technical Analvsis The proposed change will modify TS to address the potential for excessive inleakage that can increase the radiation exposure to the operators. The proposed changes will establish a Control Room Integrity Program that will contain several programmatic elements that work together to maintain the control room habitability requirements that are specified in 10 CFR 50, Appendix A, GDC 19. A new Surveillance is added to invoke this Program.

The existing SR which verifies ability of the control room ventilation system to pressurize the control room is being revised to verify that the CRE Ap is within limits with one CREFS train in operation. With the CREFS pressurizing the CRE with respect to adjacent areas, it limits any inleakage to only those small surface areas like duct seams, fan shafts, housing inspection doors, etc. that are at a negative pressure relative to the control room envelope. The requirements represent a more comprehensive approach to control room habitability. Thus, these changes to the TS are consistent with the current knowledge and experience in those areas that need to be controlled to assure a habitable post-accident environment for the operators.

The new ACTION, with a 30 day Completion Time, is appropriate for exceeding the control room inleakage limits when control room habitability can still be maintained with mitigating actions. This is described in the Bases for the new Condition B. The 30 day Completion Time recognizes the low probability of a DBA occurring during the time period when the boundary is degraded and the value of the mitigating actions that are implemented to assure continued protection of the operators. The existing action for an inoperable control room boundary applies when control room habitability cannot be

Control Room Habitability NL-04-1473 Enclosure I Page 3 of 9 maintained, even with mitigating actions. In this case, the existing 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is appropriate.

Dose Calculation - The limiting accident for exposure to the control room operators is the large break loss of coolant accident (LOCA.) A conservative analysis was performed to determine the radiological consequences to control room personnel following the LOCA. This analysis was performed using the same methodology that is used in the current licensing bases that is described in the FNP Final Safety Analysis Report (FSAR),

with the changes identified below:

1. Elemental iodine plateout is modeled as a time independent function, consistent with Standard Review Plan (SRP) 6.5.2 Revision 2, dated December 1988, "Containment Spray as a Fission Product Cleanup System Review Responsibilities." The plateout rate is unchanged from the current FSAR analysis.

2. Elemental iodine spray washout is continued until the decontamination factor (DF) = 21. This value is consistent with the current calculated minimum sump pH based on the minimum tri-sodium phosphate (TSP) basket volume required by Technical Specification 3.5.6, "ECCS Recirculation Fluid pH Control System" and SRP 6.5.2 Revision 2. The spray removal rate is unchanged from the current FSAR analysis.

3. Particulate iodine spray washout is revised consistent with the latest spray pump capacity calculations. Note that the spray pump flow decreases slightly at the initiation of recirculation which resulted in a slight decrease of particulate washout at recirculation. The time dependence is modeled consistent with SRP 6.5.2 Revision 2.

4. The time to reach the elemental DF is revised consistent with item I above.

5. Control room unfiltered inleakage is assumed to be 53 cfm.

6. The control room X/Q values were provided to the NRC in Enclosure 3 of SNC letter dated May 5, 2004.

The changes identified above are the result of removing conservatisms that SNC had placed in the calculations that were above and beyond the requirements of SRP 6.5.2.

The parameters used in analysis of post-LOCA control room doses are provided in Table 1.

This new LOCA analysis resulted in a decrease in the offsite thyroid doses while the thyroid dose received by the control room operators remained unchanged. The resulting dose values are provided in Table 2.

Control Room Habitability NL-04-1473 Enclosure I Page 4 of 9 5.0 Regulatorv Analysis 5.1 No Significant Hazards Consideration The proposed change revises the Farley Nuclear Plant (FNP) Units 1 and 2 Technical Specifications (TS) to address Control Room boundary unfiltered inleakage by revising Limiting Condition for Operation (LCO) 3.7.10, "Control Room Emergency Filtration/Pressurization System (CREFS)" and TS 5.5.1 1, "Ventilation Filter Testing Program (VFTP)" and adding a new section, TS 5.5.18, "Control Room Integrity Program (CRIP)." Associated changes are made to the Bases of the TS.

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

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

The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, or configuration of the facility. The proposed changes do not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. This is a revision to the TS for the control room ventilation system which is a mitigation system designed to minimize inleakage and to filter the control room atmosphere to protect the operator following accidents previously analyzed. An important part of the system is the control room envelope (CRE). The CRE integrity is not an initiator or precursor to any accident previously evaluated. Editorial changes and implementation of the guidance in Regulatory Guide 1.52, Revision 3 for testing cannot be initiators of any accident. Therefore, the probability of any accident previously evaluated is not increased. Performing tests and implementing programs that verify the integrity of the CRE and control room habitability ensure mitigation features are capable of performing the assumed function. Therefore, the consequences of any accident previously evaluated are not increased.

Therefore, it is concluded that this change does not significantly increase the probability or consequences of an accident previously evaluated.

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

The changes will not alter the requirements of the control room ventilation system or its function during accident conditions. No new or different accidents result from performing the new or revised actions and surveillances or programs required. The changes do not involve a physical alteration of

Control Room Habitability NL-04-1473 Enclosure I Page 5 of 9 the plant (i.e., no new or different type of equipment will be installed) or a significant change in the methods governing normal plant operation. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.

Therefore, the possibility of a new or different kind of accident from any accident previously evaluated is not created.

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

The proposed changes do not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined.

The safety analysis acceptance criteria are not affected by these changes.

The proposed changes will not result in plant operation in a configuration outside the design basis for an unacceptable period of time without mitigating actions. The proposed changes do not affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condition.

Therefore, it is concluded that this change does not involve a significant reduction in the margin of safety.

Based on the above, SNC concludes that the proposed change presents no significant hazards considerations under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicablc Regzulatorv Requirements/Criteria The proposed change to the TS will ensure that the requirements contained in 10 CFR 50, Appendix A, GDC 19 are maintained. The new Control Room Integrity Program will ensure that control room habitability is maintained. In conclusion, based on the considerations discussed above, (I) 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 approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

FNP has reviewed the guidance provided in RG 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," May 2003. FNP complies with this RG with the following exceptions:

1. FNP will implement a TS change that is an acceptable alternative to TS change identified in RG 1.196 which includes CRE integrity testing and periodic assessments. These TS will implement a Control Room Integrity Program.

Control Room Habitability NL-04-1473 Enclosure I Page 6 of 9

2. FNP currently is using RG 1.52, Revision 0 for the design. FNP will update to Revision 3, Dated June 2001 for testing only.

3. FNP uses RG 1.140 as information only for non-safety related air filtration systems.

4. FNP uses ASHRAE Guideline 1-1996 as reference only for maintenance programs for systems that handle hazardous chemicals and smoke challenges.

5. FNP will use RG 1.197 dated May 2003 for testing of the CRE. FNP has completed testing, and will perform future testing, of the CRHS, in accordance with RG 1.197 with the exceptions as defined in NEI 99-03, Rev I Appendix EE "ASTM E741 Exceptions."

6.0 Environmental Consideration SNC has reviewed the proposed change pursuant to 10 CFR 50.92 and determined that it does not involve a significant hazards consideration. In addition, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite and there is no significant increase in individual or cumulative occupational radiation exposure. Consequently, the proposed TS change has no significant effect on the human environment and satisfies the criteria of 10 CFR 51.22 for categorical exclusion from the requirements for an environmental assessment.

7.0 References 10 CFR 50, Appendix A, General Design Criterion 19.

Control Room Habitability NL-04-1473 Enclosure 1 Page 7 of 9 Table I (page 1 of 2)

Parameters Used in Analysis of Post-LOCA Control Room Doses (Data from FSAR Tables 15.4-14 and 15.4-16)

Core thermal power.........................................

2,831 MWt (2,775 x 1.02)

Containment (CTMT) free volume.........................................

2.03 x 106 jf3 Volume fractions Sprayed.........................................

0.822 Unsprayed.........................................

0.178 Mixing rate between sprayed and unsprayed CTMT volumes.......

1 2,000 fl3/min Core fission product inventories.........................

................ See FSAR Table 15.1-4 Activity released to CTMT Noble gases..........................................

100 % of core inventory lodines.........................................

50 % of core inventory Plateout of elemental iodine activity released to CTMT................ 2.7 h-'

Form of iodine activity in CTMT available for release Elemental.........................................

95.5 %

Organic.........................................

2.0 %

Particulate.........................................

2.5 %

Spray removal constants Elemental.........................................

10 h-l ' (DF < 21) 0.0 Wf' (DF > 21)

Methyl.........................................

0.0 Particulate.........................................

5.4 I' (Injection) 5.0 I' (Recirc, DF < 50) 0.5 f' (DF>50,t<8 hr) 0.0 h-' (t > 8 hr)

Time to reach decontamination factor Elemental.........................................

24 min Methyl.........................................

N/A Particulate.........................................

8 h Containment leak rate 0-24 h.........................................

0.1 5 %/day 1-30 days.........................................

0.075 %/day

Control Room Habitability NL-04-1473 Enclosure I Page 8 of 9 Table I (page 2 of 2)

Parameters Used in Analysis of Post-LOCA Control Room Doses (Data from FSAR Tables 15.4-14 and 15.4-16)

Filtered pressurization rate...................

375 ft3/min Filtered recirculation rate...................

2,700 fl3/min Unfiltered inleakage rate...................

53 ft3/min Filter efficiencies (all forms of iodine)

(Note: Filter efficiencies have been reduced by 0.5% for all forms of iodine to account for bypass leakage)

Pressurization air...................

98.5 %

Recirculation air...................

94.5 %

Volume of Control Room...................

114,000 ft3 Operator breathing rate...................

3.47 x 104 m3/s Percent of time operator is in control room following LOCA 0-1 day...................

1 00 %

1-4 days...................

60 %

4-30 days...................

40 %

Atmospheric dilution estimate 0-2 h...................

1.64x 103s/m3 2-8 h....................

1.36x 103 s/m3 8-24 h...................

6.58 x 104 s/m3 1-4 days....................

5.58 x104 s/m3 4-30 days...................

4.21 x 104 s/i 3

Control Room Habitability NL-04-1473 Enclosure 1 Page 9 of 9 Table 2 Dose Values Resulting from a LOCA (Data from FSAR Tables 15.4-15 and 15.4-17)

Offsitc Doses from LOCA Thyroid Dose (rem)

LOCA w/o Mini-Purge Mini-Purge Incremental 10 CFR 100 Limit Total Site boundary Low-population zone 164.2 85.7 5.7 2.1 169.9 87.8 300 300 Whole Body (rem)(a)

LOCA w/o Mini-Purge Mini-Purge Incremental 10 CFR 100 Limit Total Site boundary Low-population zone 3.2 1.6 8.7x 10-2.2x 10-3 3.2 1.6 25 25 (a) Offsite doses are based on a LOCA plus the incremental dose resulting from purging prior to isolation of the mini-purge system 6 seconds following a LOCA.

Control Room Doses Following a LOCA Dose (rem)

Thyroid Whole Body 26.9 0.4 Beta-Skin 9.0

Joseph M. Farlcy Nuclear Plant Units 1 and 2 Request to Revise Technical Specifications Control Room Habitability Marked-Up Technical Specifications and Bases Pages

Two Control Room Emergency Filtration/Pressurization System (CREFS) trains and the Control Room Envelope (CRE) shall be OPERABLE.

3.7 PLANT SYSTEMS I

Control Room 3.7.10 Control Room vtrat4Prsyrzatie Sytem (GREPS

,-1 1

1 YF-3.7.10

=

LCO 3.7.1 0

[Twe^ GREFS1 taiRs shall be OPERCARI -MI I CRE Them control.

REFS

NOTE ---------------------------------------------

may be opened intermittently under administrative APPLICABILITY:

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

I Insert LCO 3.7.10 - B, see next p ACTIONS efor reasons other than Condition B I

CONDITION

/

REQUIRED ACTION COMPLETION TIME A. One CREFS train inoperable.

A.1 Restore CREFS train to OPERABLE status.

7 days C.

Required Action and C.1 Be in MODE 3.

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

C.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months I

I-D.

Required Action and associated Completion Time of Condition A not met during movement of irradiated fuel assemblies or during CORE ALTERATIONS.

D.1 Place OPERABLE CREFS train in emergency recirculation mode.

OR D.2.1 Suspend CORE ALTERATIONS.

Immediately Immediately AND (continued)

Insert LCO 3.7.10- C,see next page Farley Units 1 and 2 3.7.10-1 Amendment No. 161 (Unit 1)

Amendment No. 154 (Unit 2)

Insert 3.7.10 - B B.

Inoperable CRE in MODE 1,2,3, or4.

B.1 Initiate mitigating actions.

AND B.2.1 Restore CRE to OPERABLE status.

OR B.2.2.1 Verify General Design Criteria (GDC) 19 met using mitigating actions in B.1.

AND B.2.2.2 Restore CRE to OPERABLE status.

Immediately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours 30 days I

L Insert 3.7.10 - C

.OR Two CREFS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

\\

ACTIONS Insert LCO 3.7.10p

- E l

~see next page_

l I

Control Room CONDITION REQUIRED ACTION COMPLETION TIME D.

(continued)

D.2.2 Suspend movement of Immediately irradiated fuel assemblies.

E.

Two CREFS trains E.1 Suspend CORE Immediately inoperable during ALTERATIONS movement of irradiated fuel assemblies or during AND CORE ALTERATIONS.

E.2 Suspend movement of Immediately irradiated fuel assemblies.

F Twd'CREVS trairs' F.1 Ent~r LCO 3/0.3.

imediaely Perabe in M9DE1,

/

f X, or 4/or reasons oth er~ta

/than ponditiqfi B. /

/

f lfor reasons other than Condition B l

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREFS Pressurization train i 31 days 10 cnnowith the heaters operating and each CREFS Recirculation and Filtration train for 2 15 minutes.

SR 3.7.10.2 Perform required CREFS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP).

VFTP SR 3.7.10.3 KI^Tr

.I.

Not required to be performed in MODES 5 and 6. ----

Insert SR 3.7.10.5 1 see next page months Verify each CREFS train actuates on an actual or simulated actuation signal.

SR 3.7.10.4 Veyly oni CREFS trair/ 6an maintain a positive I

\\/Ipysessurx of 2/12s irldhes wafer gauge, relati e to f / the ou side atmosoh're durina svsterrA ooerat on.

X r

l Insert SR 3.7.10.4 see next page 24 months on a STAGGERED TEST BASIS Amendment No. 161 (Unit 1)

Amendment No. 154 (Unit 2)

Farley Units 1 and 2 3.7.10-2

Insert LCO 3.7.10 - E Required Action and associated Completion Time of Condition B not met during movement of irradiated fuel assemblies or during CORE ALTERATIONS.

OR Insert SR 3.7.10.4 Verify CRE Ap within limits with one CREFS train operating in the emergency recirculation mode at a flowrate of 300 cfm + 25 % to - 10 % for pressurization filter, 2,000 cfm

10 % for recirculation filter, and 1,000 cfm r

10 % for filtration filter.

Insert SR 3.7.10.5 SR 3.7.10.5 Verify CRE integrity in accordance with the Control In accordance with Room Integrity Program (CRIP).

the CRIP

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The 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, which shall include monitoring the condenser hotwells for evidence of condenser in leakage;

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.

Ventilation Filter Testinq Program (VFTP) 5.5.11 A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in, and in accordance with, ASME N510-1989. The FNP Final Safety naysiseport identifies the relevant surveillance testing requirements.

/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 < 0.5% when tested in accordance with ASME N510-1989 at the system flowrate specified below.

l Regulatory Guide 1.52, I Revision 3 ESF Ventilation System CREFS Recirculation CREFS Filtration CREFS Pressurization PRF Post LOCA Mode Flowrate (CFM) 2,000 + 10%

1,000 + 10%

300 +25% to -10%

5,000 + 10%

(continued)

Farley Units 1 and 2 5.5-8 Amendment No.

Amendment No.

(Unit 1)

(Unit 2) I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program (VFTP) (continued)

b.

Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.5% when tested in accordance ASME N510-1989 at the system flowrate specified below.

ESF Ventilation System Flowrate (CFM) l with CREFS Recirculation CREFS Filtration CREFS Pressurization PRF Post LOCA Mode 2,000 + 10%

1,000 + 10%

300 + 25% to - 10%

5,000 + 10%

c.

Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in ASME N510-1989, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of

300C and greater than or equal to the relative humidity specified below.

ESF Ventilation SVstem CREFS Recirculation CREFS Filtration CREFS Pressurization PRF Post LOCA Mode Penetration 2.5%

2.5%

0.5%

5%

RH 70%

70%

95%

NOTE: CREFS Pressurization methyl iodide penetration limit is based on a 6-inch bed depth.

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 ASME N510-1989 at the system flowrate specified below.

ESF Ventilation System CREFS Recirculation CREFS Filtration CREFS Pressurization PRF Post LOCA Mode Delta P (in. water aauae) 2.3 2.9 2.2 2.6 Flowrate (CFM) 2,000 + 10%

1,000 + 10%

300 + 25% to - 10%

5,000 + 10%

(continued)

Farley Units 1 and 2 5.5-9 Amendment No.

Amendment No.

(Unit 1)

(Unit 2) I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.17 Containment Leakage Rate Testing Program (continued)

Leakage rate acceptance criteria are:

a.

Containment overall leakage rate acceptance criterion is

1.0 La. During plant startup following testing in accordance with this program, the leakage rate acceptance criteria are

0.60 La for the combined Type B and C tests, and

0.75 La for Type A tests;

b.

Air lock testing acceptance criteria are:

1.

Overall air lock leakage rate is

0.05 La when tested at 2 Pa.

2.

For each door, leakage rate is

0.01 La when pressurized to 2 10 psig.

c.

During plant startup following testing in accordance with this program, the leakage rate acceptance criterion for each containment purge penetration fTowpath is

0.05 La.

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 are applicable to the Containment Leakage Rate Testing Program.

I Insert 5.5.18 Farley Units 1 and 2 5.5-14 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Insert 5.5.18 5.5.18 Control Room Integrity Pro-gram (CRIP)

A Control Room Integrity Program (CRIP) shall be established and implemented to ensure that the control room integrity is maintained such that a radiological event, hazardous chemicals, or a fire challenge (e.g., fire byproducts, halon, etc.)

will not prevent the control room operators from controlling the reactor during normal or accident conditions. The program shall require testing as outlined below. Testing should be performed when changes are made to structures, systems and components which could impact CRE integrity. These structures, systems and components may be internal or external to the CRE. Testing should also be conducted following a modification or a repair that could affect CRE inleakage. Testing should also be performed if the conditions associated with a particular challenge result in a change in operating mode, system alignment or system response that could result in a new limiting condition. Testing should be commensurate with the type and degree of modification or repair. Testing should be conducted in the alignment that results in the greatest consequence to the operators.

An assessment of CRE pressure relative to adjacent areas shall be performed in accordance with SR 3.7.10.4. This assessment determines whether the CRE's diff erential pressure, relative to adjacent areas, has changed since the ASTM E741 test was performed. If the differential pressure has changed, a determination should be made as to how this change has affected the inleakage characteristics of the CRE. If there has been a degradation in the inleakage characteristics of the CRE, then a determination should be made as to whether the licensing basis analyses remain valid.

A CRIP shall be established to implement the following:

a.

Demonstrate, using Regulatory Guide (RG) 1. 197 and ASTM E74 1, that CRE inleakage is less than:

i) 53 cfm when the control room ventilation systems are aligned in the pressurization mode of operation, and ii) 2,350 cfrn when the control room ventilation systems are aligned in the hazardous chemical mode of operation;

b.

Demonstrate that the leakage characteristics of the CRE will not result in simultaneous loss of reactor control capability from the control room and the hot shutdown panels;

c.

Demonstrate that in the normal alignment, makeup and exhaust flows to the CRE are within the design ranges of 1,650 + 1 0% to 1, 100 cfm -1 0 % and 1,300 + 10% to 1,000 cfm -10 %, respectively, when tested in accordance with Industrial Ventilation - Manual of Recommended Practice, 20 t edition (an ASME N51 0 endorsed air flow measurement methodology);

d.

Demonstrate that in the pressurization alignment, makeup and recirculation flows to the HEPA filter and charcoal adsorber are 300 cfm +25 % -10 %

and 3,000 cfm +/-10 % when tested in accordance with Industrial Ventilation Manual of Recommended Practice, 2 0th edition (an ASME N510 endorsed air flow measurement methodology);

e.

Maintain a CRE configuration control and a design and licensing bases control program and a preventative maintenance program;

f.

Demonstrate CRE differential pressure relative to adjacent areas is consistent with the differential pressure measurements at the time of the ASTM E741 test conducted to determine CRE integrity;

g.

Test the Control Room Envelope (CRE) in accordance with the testing methods and at the frequencies specified in Regulatory Guide 1.197, Revision 0, May 2003, with the exceptions listed in the Final Safety Analysis Report (FSAR).

The provisions of SR 3.0.2 are applicable to the control room inleakage testing frequencies.

B 3.7.10 l Control Room B 3.7 PLANT SYSTEMS B 3.7.10 Control Room Mr,- ~- -

=

ffr=-!f1UFkjfdFiby I aytitum cntrol room l

, chemicals, or toxic gas I

BASES I

BACKGROUND The HIprovides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity This environment is The Unit 1 and 2 control room is a common room served by a shared protected by the integrity CREFS Insert B 3.7.10-1, see next page l l ilteuit nf the Contrnl Rnnm E

l n

Envelope (CRE) and the operation of the Control Room Emergency Filtration/Pressurization System (CREFS).

The CREFS consists of two independent, redundant trains that recirculate and filter the control room air in conjunction with the CRACS, and two independent, redundant trains that pressurize the and control room with filtered outside air. Each nsiss of a refilter, a high efficiency particulate air (HEPA) filter,fan activated charcoal adsorber section for removal of gaseous activity (principally iodineg) lnd a faR. Each pressurization HI contains a heater-ductwor k

valves or dampers, and instrumentation which Ei form Ea the system.

flcrnc

~htnnonnn ifs nt ~n F

C~I, 4

1#^

su'tfe f.

l The CREFS provides a protected environment from which operators c control the unit followi an uncontrolled release radioactivity.

I 11L, XQJ I

I L.-...

I~iEI

... L-.

I5IL~

I 4

l 15 minutes justifies their OPERABILITY. Durir normal or emergenc operation, the heatei

,an The CREFS is an emergency system, parts of which may also ng operate during normal unit operations in the standby mode of e of operation. Upon receipt of the actuating signal(s), normal air supply to the control room is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers.

IGintinueueOeration ot each pressurization train for at least per month, with the heaters energized reduceM moisturebuildup on the HEPA filters and a sorers.

Iater operation during the t tis

/assured by operating thheaters with fan flow and allowing only the g

protective thermal cutout features of the heater controls to be vy functional. The heater is important to the effectiveness of the rs charcoal adsorbers.

H 15 minute Actuation of the CREFS places the system in the emergency recirculation mode of operation. Actuation of the system to the emergency recirculation mode of operation, closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the control room air through the redundant trains of HEPA and the charcoal filters. The emergency recirculation mode of operation also initiates pressurization and filtered ventilation of the air supply to the control room.

(continued)

Farley Units 1 and 2 B 3.7.1 0-1 Revision 0

Insert B 3.7.10 - 1 The control room boundary is the combination of walls, floor, roof, ducting, ESF HVAC equipment, doors, penetrations and equipment that physically form the CRE. The CRE is the area within the confines of the control room boundary that contains the spaces that control room operators inhabit to control the plant for normal and accident conditions. This space is protected for normal operation, natural events, and accident conditions.

I Control Room IT B 3.7.10 minimizes BASES BACKGROUND (continued)

Maintaining the, tight boundary provides makeup a flow and radiologic dose cleanup for tt control room.

The normal outside air supply is filtered, dilute with building air from the computer rooms, and added to the air beingecirculated from the control room.

i of the control room infiltration unfiltered air from the surrounding areas of the building.

air The air entering the control room is continuously monitored by radiation detectors. One detector output above the setpoint will cause the control room ventilation to be isolated. The CREFS is then started manually.

inns trWn^;11 o-FeswiF~z the Gan~eel remto aou^Lt 0.125 ir

. The CREFS operation in maintaining the control room al habitable is discussed in the FSAR, Section 6.4 (Ref. 1).

ie Redundant supply and recirculation 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 failure of one damper to shut will not result in a breach of isolation. The CREFS is designed in accordance with Seismic Category I requirements.

The CREFS 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 whole body dose or its equivalent to any part of the body.

APPLICABLE SAFETY ANALYSE l

CRE The analysis of toxic c releases demonstrate, that the toxicity limits not exceeded in the control room followinc toxic chemical release The CREFS components are arranged in redundant, safety related

S ventilation trains. The location of components and ducting within the F5t1 room onvolo ensures an adequate supply of filtered air to all rareas requiring access. The CREFS provides airborne radiological protection for the control room operators, as demonstrated by the control room accident dose analyses for the most limiting design basis loss of coolant accident, fission product release presented in the FSAR, Chapter 15 (Ref. 2).

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

Tia

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

Farley Units 1 and 2 B 3.7.10-2 Revision 0

IB 3.7.10 lControl Room l

BASES LCO Two independent and redundant CREFS 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 to the control room operator in the event of a large radioactive release.

ESF HVAC equipmen The CREFS is considered OPERABLE when the individual components necessary to limit operator exposure are OPERABLE in

\\

both trains. A CREFS train is OPERABLE when the associated:

a. Fans are OPERABLE; (recirculation, filtration, Pressurization, and CRACS Fans)

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

OPERABLE Inleakage must also be maintained such that operator exposure limits are not exceeded.

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

jj 3 j In addition, the i-room F56 r

must be maintained, Includin!

the integrity of the walls, floors, ceilings, ductwork, and access doors The LCO is modified by a Note allowing the Econtrol room bouna 5 o l be opened intermittently under administrative controls without C

requiring entry into Condition B for an inoperable p---sure b 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, such as hatches and inspection ports, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for control room isolation is indicated.

APPLICABILITY With either unit in MODES 1, 2, 3, or 4 or during movement of irradiated fuel assemblies or during CORE ALTERATIONS, CREFS must be OPERABLE to control operator exposure during and I-following a DBA.

I an th CR During movement of irradiated fuel assemblies and CORE ALTERATIONS, the CREFS must be OPERABLE to cope with the release from a fuel handlingfaccident.

Farley Units 1 and 2 B 3.7.10-3 Revision 21

I Control Room I

for reasons other than Condition B B 3.7.10 1 t o 1 -

BASES ACTIONS A.1 one CREFS train i inoperable, action must be taken to restore Wt OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREFS train is adequate to perform the control room protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CREFS train could result in loss of CREFS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and Insert B 3.7.10 - B.1 ability of the remaining train to provide the required capability.

See next page B.1 Ba If tlh6 control roorfi boundary is

'operabld in MODE 1, 2, or 4,/he PPEFS rainis annot erform their interded fuyctions.

be takn to restore a OPERABLE coztrol ropm boundary wit in 24 Aours Duri the riod tt the coptrol robin boundary is /

inoperable approp iate c pensatory measures (oonsistelt with tl e in ent f C 19) should be utilized to prptect copfrol roo,,t operators fam po~te ntial I'hzards s'uch as r~dioactjve contatninatio,, toxic,/

/chemicals, s~n6ke, tendperatur and relative huindity, and physical securfty. Pr vplanne* measu ~s shoy~d be available to addreis these corderns foiipnent'*nal and ninte9Aonal eairy into~he condftion. /

The 24 ho, r Conrpletion T)Me is roasonable base on the 6w

/

pobabilit'y of a DBA occurring diuing thisfime pe io, an the us9'of compensatory6ieasure~.

The,.4 hour1Complef'on Tirr is a

/

reaso6 able tirfie to diagnose, plan and possibly repair and ost prolriems wjih the coritrolro,?fnbou dary./

/

C.1 and C.2 F EI\\

In MODE 1, 2, 3, or 4, if i inoperable CREFS train ort[contrl -om Iboundarv cannot be restored to OPERABLE status within the required Completion Tir>, 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 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

or if two CREFS trains are inoperable for reasons other than Condition B, (continued)

Farley Units 1 and 2 B 3.7.10-4 Revision 21

Insert B 3.7.10 - B.1 If the CRE is inoperable, the CREFS trains may not be able to perform their intended functions. During the period that the CRE is inoperable, mitigating actions must be implemented to protect control room operators from potential hazards. These mitigating actions (i.e.,

actions that are taken to offset the consequences of the inoperable control room boundary) should be preplanned for implementation upon entry into the condition.

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into Condition B, Actions must be taken to restore the CRE to OPERABLE status or to verify that the mitigating actions required by Required Action B.1 meet the requirements of General Design Criteria (GDC) 19. GDC 19 is verified to be met by limiting dose from radioactive gas, and exposure to toxic gas and smoke,-to levels that support control room habitability, crediting, as necessary, the mitigating actions required by Required Action B.1.

This verification can be quantitative or qualitative, and be based on analysis, a test or partial test, experience with operating events, engineering judgment, or a combination of these factors. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, the use of mitigating actions, and the time necessary to perform an assessment.

If it is determined that the mitigating actions meet the requirements of GDC 19, 30 days are provided to return the CRE to OPERABLE status. The 30 day Completion Time is a reasonable time to diagnose, plan, and repair most problems with the CRE.

B 3.7.1 0 I Control Room BASES ACTIONS (continued)

D.1, D.2.1, and D.2.2 a

During movemen of irradiated fuel assemblies or during CORE ALTERATIONS, if i inoperable CREFS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CREFS train in the emergency recirculation 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.

if an inoperable CRE cannot be restored to OPERABLE status within the required Completion Time or An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

I Ifor reasons other than Condition B 1, and F 9 r- -D Durina movement of irradiated fuel assemblies or uring CORE to

-J-.

A TjERATIONS, with two CREFS trains inoperable, action must be taken immediately i suspend activities that could result in a release of radioactivity that miqht control room. This places the unit require Isolation in a condition that minimizes accident risk. This does not preclude of the the movement of fuel to a safe position.

SURVEILLANCE REQUIREMENTS SR 3.7.1 0.1 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 (CREFS and Pressurization) once every month provides an adequate check of this system. The CREFS trains are initiated from the control room with flow through the HEPA and charcoal filters. IMnthlyheatef I operatiens dry out any moisture aocumulated in the charcoal-frem I

Systems must be operated for 2 15 minutes to demonstrate the function of the system. Systems with heaters must be operated with the heaters energized.

(continued)

Farley Units 1 and 2 B 3.7.10-5 Revision 21

B 3.7.10 I Control Room I

BASES SURVEILLANCE REQUIREMENTS SR 3.7.10.1 (continued) humidity in the ambientar. Systems with heaters must be epe-ated for Ž 10 continuous hours with the heaters energized. Syst without heaters need only be operated for Ž 15 minuteo to d9m strate the function of the sys

'The 31 day Frequency is based on the reliability of the equipment and the two train redundancy SR 3.7.10.2 available This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREFS filter tests are in accordance with ASME N510-1989 (Ref. 3).

The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.10.3 consistent with the testing frequencies This SR verifies that each CREFS train starts and operates on an I

actual or simulated Safety Injection (SI) actuation signal. The J

Fre uen HaJmonths i specified in Regulatory Guide 1.52 (Ref. 4). This SR is modified by a note which provides an exception to the requirement to meet this SR in MODES 5 and 6. This is acceptable since the automatic SI actuation function is not required in these MODES.

SR 3.7.10.4 Insert B SR 3.7.10.4 and 5 see next page Farley Units 1 and 2 B 3.7.10-6 Revision 21 1

Insert B SR 3.7.10.4 and 5 This SR verifies that the CRE Ap can be maintained within limits with one CREFS train in operation. The CRE Ap is periodically tested to verify proper functioning of the CREFS. The CREFS is designed to maintain the radiological cleanup function with one train. The frequency of 24 months on a STAGGERED TEST BASIS is adequate and has been shown to be acceptable by operating experience.

SR 3.7.10.5 This SR verifies the integrity of the CRE by requiring testing for control room inleakage. The details of the inleakage testing are contained in the Control Room Integrity Program (CRIP).

CREFS B 3.7.1 0 BASES REFERENCES

1. FSAR, Section 6.4.

2. FSAR, Chapter 15.

3. ASME N510-1989.

3

4. Regulatory Guide 1.52, Rev. E.

I Farley Units 1 and 2 B 3.7.10-7 Revision 21 l

Joseph M. Farlcy Nuclear Plant Units 1 and 2 Request to Revise Technical Specifications Control Room Habitability Clean Typed Technical Specifications and Bases Pages Affected Pages Technical Specifications Technical Specification Bases Page 3.7.10-1 3.7.10-2 3.7.10-3 3.7.10-4 5.5-8 5.5-9 5.5-14 5.5-15 5.5-16 Action Replace Replace New New Replace Replace Replace New New Pale B 3.7.10-1 B 3.7.10-2 B 3.7.10-3 B 3.7.10-4 B 3.7.10-5 B 3.7.10-6 B 3.7.10-7 Action Replace Replace Replace Replace Replace Replace Replace

Control Room l 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room I

LCO 3.7.10 Two Control Room Emergency Filtration/Pressurization System (CREFS) trains and the Control Room Envelope (CRE) shall be OPERABLE.

I NOTE ---------------------------------------------

The CRE may be opened intermittently under administrative control.

I APPLICABILITY:

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One CREFS train A.1 Restore CREFS train to 7 days inoperable for reasons OPERABLE status.

other than Condition B.

B.

Inoperable CRE in B.1 Initiate mitigating actions.

Immediately MODE 1, 2, 3, or 4.

AND B.2.1 Restore CRE to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

OR B.2.2.1 Verify General Design 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Criteria (GDC) 19 met using mitigating actions in B.1.

AND B.2.2.2 Restore CRE to 30 days OPERABLE status.

I Farley Units 1 and 2 3.7.10-1 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Control Room l 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

Required Action and C.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or4.

C.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two CREFS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

D.

Required Action and D.1 Place OPERABLE CREFS Immediately associated Completion train in emergency Time of Condition A not recirculation mode.

met during movement of irradiated fuel assemblies OR or during CORE ALTERATIONS.

D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.

Farley Units 1 and 2 3.7.10-2 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Control Room l 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E.

Required Action and E.1 Suspend CORE Immediately associated Completion ALTERATIONS.

Time of Condition B not met during movement of AND irradiated fuel assemblies or during CORE E.2 Suspend movement of Immediately ALTERATIONS.

irradiated fuel assemblies.

OR Two CREFS trains inoperable during movement of irradiated fuel assemblies or during CORE ALTERATIONS for reasons other than Condition B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREFS Pressurization train with the 31 days heaters operating and each CREFS Recirculation and Filtration train for > 15 minutes.

SR 3.7.10.2 Perform required CREFS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP).

VFTP SR 3.7.10.3

NOTE---------------------------------

Not required to be performed in MODES 5 and 6.

Verify each CREFS train actuates on an actual or 24 months simulated actuation signal.

Farley Units 1 and 2 3.7.10-3 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Control Room l 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.4 Verify CRE Ap within limits with one CREFS train 24 months on a operating in the emergency recirculation mode at a STAGGERED flowrate of 300 cfm + 25 % to - 10 % for TEST BASIS pressurization filter, 2,000 cfm +/- 10 % for recirculation filter, and 1,000 cfm +/- 10 % for filtration filter.

SR 3.7.10.5 Verify CRE integrity in accordance with the Control In accordance with Room Integrity Program (CRIP).

the CRIP I

Farley Units 1 and 2 3.7.10-4 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The 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, which shall include monitoring the condenser hotwells for evidence of condenser in leakage;

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.

5.5.11 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 3, and in accordance with ASME N510-1989. The FNP Final Safety Analysis Report identifies the relevant surveillance testing requirements.

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 < 0.5% when tested in accordance with ASME N510-1989 at the system flowrate specified below.

ESF Ventilation System Flowrate (CFM)

CREFS Recirculation 2,000 + 10%

CREFS Filtration 1,000 + 10%

CREFS Pressurization 300 + 25% to - 10%

PRF Post LOCA Mode 5,000 + 10%

(continued)

Farley Units 1 and 2 5.5-8 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program (VFTP) (continued)

b.

Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.5% when tested in accordance with ASME N510-1989 at the system flowrate specified below.

I ESF Ventilation System CREFS Recirculation CREFS Filtration CREFS Pressurization PRF Post LOCA Mode Flowrate (CFM) 2,000 + 10%

1,000 +10%

300 + 25% to - 10%

5,000 + 10%

c.

Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in ASME N510-1989, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of < 300C and greater than or equal to the relative humidity specified below.

ESF Ventilation System CREFS Recirculation CREFS Filtration CREFS Pressurization PRF Post LOCA Mode Penetration 2.5%

2.5%

0.5%

5%

RH 70%

70%

95%

NOTE: CREFS Pressurization methyl iodide penetration limit is based on a 6-inch bed depth.

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 ASME N510-1989 at the system flowrate specified below.

ESF Ventilation System CREFS Recirculation CREFS Filtration CREFS Pressurization PRF Post LOCA Mode Delta P (in. water gauge) 2.3 2.9 2.2 2.6 Flowrate (CFM) 2,000 + 10%

1,000 + 10%

300 + 25% to - 10%

5,000 + 10%

(continued)

Farley Units 1 and 2 5.5-9 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.17 Containment Leakage Rate Testinq Program (continued)

Leakage rate acceptance criteria are:

a.

Containment overall leakage rate acceptance criterion is < 1.0 La. During plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the combined Type B and C tests, and < 0.75 La for Type A tests;

b.

Air lock testing acceptance criteria are:

1.

Overall air lock leakage rate is < 0.05 La when tested at 2 Pa.

3.

For each door, leakage rate is < 0.01 La when pressurized to 2 10 psig.

c.

During plant startup following testing in accordance with this program, the leakage rate acceptance criterion for each containment purge penetration fTowpath is < 0.05 La.

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 are applicable to the Containment Leakage Rate Testing Program.

5.5.18 Control Room Integrity Program (CRIP)

A Control Room Integrity Program (CRIP) shall be established and implemented to ensure that the control room integrity is maintained such that a radiological event, hazardous chemicals, or a fire challenge (e.g., fire byproducts, halon, etc.)

will not prevent the control room operators from controlling the reactor during normal or accident conditions. The program shall require testing as outlined below. Testing should be performed when changes are made to structures, systems and components which could impact CRE integrity. These structures, systems and components may be internal or external to the CRE. Testing should also be conducted following a modification or a repair that could affect CRE inleakage. Testing should also be performed if the conditions associated with a particular challenge result in a change in operating mode, system alignment or system response that could result in a new limiting condition. Testing should be commensurate with the type and degree of modification or repair. Testing should be conducted in the alignment that results in the greatest consequence to the operators.

(continued)

Farley Units 1 and 2 5.5-14 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.18 Control Room Integrity Program (CRIP) (continued)

An assessment of CRE pressure relative to adjacent areas shall be performed in accordance with SR 3.7.10.4. This assessment determines whether the CRE's differential pressure, relative to adjacent areas, has changed since the ASTM E741 test was performed. If the differential pressure has changed, a determination should be made as to how this change has affected the inleakage characteristics of the CRE. If there has been a degradation in the inleakage characteristics of the CRE, then a determination should be made as to whether the licensing basis analyses remain valid.

A CRIP shall be established to implement the following:

a.

Demonstrate, using Regulatory Guide (RG) 1.197 and ASTM E741, that CRE inleakage is less than:

i) 53 cfm when the control room ventilation systems are aligned in the pressurization mode of operation, and ii) 2,350 cfm when the control room ventilation systems are aligned in the hazardous chemical mode of operation;

b.

Demonstrate that the leakage characteristics of the CRE will not result in simultaneous loss of reactor control capability from the control room and the hot shutdown panels;

c.

Demonstrate that in the normal alignment, makeup and exhaust flows to the CRE are within the design ranges of 1,650 + 10% to 1,100 cfm -10 % and 1,300 + 10% to 1,000 cfm -10 %, respectively, when tested in accordance with Industrial Ventilation -

Manual of Recommended Practice, 2 0th edition (an ASME N510 endorsed air flow measurement methodology);

d.

Demonstrate that in the pressurization alignment, makeup and recirculation flows to the HEPA filter and charcoal adsorber are 300 cfm +25 % -10 %

and 3,000 cfm +/-10 % when tested in accordance with Industrial Ventilation Manual of Recommended Practice, 2 0th edition (an ASME N510 endorsed air flow measurement methodology);

e.

Maintain a CRE configuration control and a design and licensing bases control program and a preventative maintenance program; (continued)

Farley Units 1 and 2 5.5-15 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.18 Control Room Integrity Program (CRIP) (continued)

f.

Demonstrate CRE differential pressure relative to adjacent areas is consistent with the differential pressure measurements at the time of the ASTM E741 test conducted to determine CRE integrity;

g.

Test the Control Room Envelope (CRE) in accordance with the testing methods and at the frequencies specified in Regulatory Guide 1.197, Revision 0, May 2003, with the exceptions listed in the Final Safety Analysis Report (FSAR).

The provisions of SR 3.0.2 are applicable to the control room inleakage testing frequencies.

Farley Units 1 and 2 5.5-16 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Control Room l B 3.7.10 B 3.7 PLANT SYSTEMS B 3.7.10 Control Room BASES BACKGROUND The control room provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity, chemicals, or toxic gas. This environment is protected by the integrity of the Control Room Envelope (CRE) and the operation of the Control Room Emergency Filtration/Pressurization System (CREFS). The Unit 1 and 2 control room is a common room served by a shared CREFS.

The control room boundary is the combination of walls, floor, roof, ducting, ESF HVAC equipment, doors, penetrations and equipment that physically form the CRE. The CRE is the area within the confines of the control room boundary that contains the spaces that control room operators inhabit to control the plant for normal and accident conditions. This space is protected for normal operation, natural events, and accident conditions.

The CREFS provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity.

The CREFS consists of two independent, redundant trains that recirculate and filter the control room air in conjunction with the CRACS, and two independent, redundant trains that pressurize the control room with filtered outside air. Each filter unit consists of a prefilter, a high efficiency particulate air (HEPA) filter, and an activated l charcoal adsorber section for removal of gaseous activity (principally iodine). Each pressurization filter also contains a heater. Each train contains filter units, fans, ductwork, valves or dampers, and instrumentation which form the system.

The CREFS is an emergency system, parts of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of the actuating signal(s), normal air supply to the control room is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Operation of each pressurization train for at least 15 minutes per month, with the heaters energized, justifies their OPERABILITY. During normal or emergency operation, the heaters reduce moisture buildup on the HEPA filters and adsorbers.

Heater operation during the 15 minute test is assured by operating the (continued)

Farley Units 1 and 2 B 3.7.1 0-1 Revision

Control Room l B 3.7.1 0 BASES BACKGROUND heaters with fan flow and allowing only the protective thermal cutout (continued) features of the heater controls to be functional. The heater is important to the effectiveness of the charcoal adsorbers.

Actuation of the CREFS places the system in the emergency recirculation mode of operation. Actuation of the system to the emergency recirculation mode of operation, closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the control room air through the redundant trains of HEPA and the charcoal filters. The emergency recirculation mode of operation also initiates pressurization and filtered ventilation of the air supply to the control room The normal outside air supply is filtered, diluted with building air from the computer rooms, and added to the air being recirculated from the control room. Maintaining the air tight boundary of the control room minimizes infiltration of unfiltered air from the surrounding areas of the building.

The air entering the control room is continuously monitored by radiation detectors. One detector output above the setpoint will cause the control room ventilation to be isolated. The CREFS is then started manually.

A single train provides makeup air flow and radiological dose cleanup l for the control room. The CREFS operation in maintaining the control room habitable is discussed in the FSAR, Section 6.4 (Ref. 1).

Redundant supply and recirculation 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 failure of one damper to shut will not result in a breach of isolation. The CREFS is designed in accordance with Seismic Category I requirements.

The CREFS 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 whole body dose or its equivalent to any part of the body.

APPLICABLE The CREFS components are arranged in redundant, safety related SAFETY ANALYSES ventilation trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. The CREFS provides airborne radiological protection for the (continued)

I Farley Units 1 and 2 B 3.7.1 0-2 Revision

Control Room l B 3.7.10 BASES APPLICABLE control room operators, as demonstrated by the control room accident SAFETY ANALYSES dose analyses for the most limiting design basis loss of coolant (continued) accident, fission product release presented in the FSAR, Chapter 15 (Ref. 2).

The analysis of toxic gas releases demonstrates that the toxicity limits are not exceeded in the control room following a toxic chemical release.

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

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

LCO Two independent and redundant CREFS 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 to the control room operator in the event of a large radioactive release.

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

a. Fans are OPERABLE; (recirculation, filtration, Pressurization, and CRACS Fans)

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

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

In addition, the CRE must be maintained OPERABLE, including the integrity of the walls, floors, ceilings, ductwork, ESF HVAC equipment and access doors. Inleakage must also be maintained such that operator exposure limits are not exceeded.

The LCO is modified by a Note allowing the CRE to be opened intermittently under administrative controls without requiring entry into Condition B for an inoperable CRE. 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, such as hatches and (continued)

Farley Units 1 and 2 B 3.7.10-3 Revision

Control Room I B 3.7.10 BASES LCO inspection ports, these controls consist of stationing a dedicated (continued) individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for control room isolation is indicated.

APPLICABILITY With either unit in MODES 1, 2, 3, or 4 or during movement of irradiated fuel assemblies or during CORE ALTERATIONS, CREFS and the CRE must be OPERABLE to control operator exposure during and following a DBA.

During movement of irradiated fuel assemblies and CORE ALTERATIONS, the CREFS and the CRE must be OPERABLE to cope with the release from a fuel handling accident.

I I

ACTIONS A.1 With one CREFS train inoperable for reasons other than Condition B, action must be taken to restore it to OPERABLE status within 7 days.

In this Condition, the remaining OPERABLE CREFS train is adequate to perform the control room protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CREFS train could result in loss of CREFS 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, B.2.1, B.2.2.1. and B.2.2.2 If the CRE is inoperable, the CREFS trains may not be able to perform their intended functions. During the period that the CRE is inoperable, mitigating actions must be implemented to protect control room operators from potential hazards. These mitigating actions (i.e.,

actions that are taken to offset the consequences of the inoperable control room boundary) should be preplanned for implementation upon entry into the condition.

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into Condition B, Actions must be taken to restore the CRE to OPERABLE status or to verify that the mitigating actions required by Required Action B.1 meet the requirements of General Design Criteria (GDC) 19. GDC 19 is verified to be met by limiting dose from radioactive gas, and exposure to toxic gas and (continued)

Farley Units 1 and 2 B 3.7.10-4 Revision

Control Room l B 3.7.1 0 BASES ACTIONS B.1. B.2.1, B.2.2.1, and B.2.2.2 (continued) smoke, to levels that support control room habitability, crediting, as necessary, the mitigating actions required by Required Action B.1.

This verification can be quantitative or qualitative, and be based on analysis, a test or partial test, experience with operating events, engineering judgment, or a combination of these factors. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, the use of mitigating actions, and the time necessary to perform an assessment.

If it is determined that the mitigating actions meet the requirements of GDC 19, 30 days are provided to return the CRE to OPERABLE status. The 30 day Completion Time is a reasonable time to diagnose, plan, and repair most problems with the CRE.

C.1 and C.2 In MODE 1, 2, 3, or 4, if an inoperable CREFS train or CRE cannot be l restored to OPERABLE status within the required Completion Time, or if two CREFS trains are inoperable for reasons other than Condition B, 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 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

D.1, D.2.1, and D.2.2 During movement of irradiated fuel assemblies or during CORE ALTERATIONS, if an inoperable CREFS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CREFS train in the emergency recirculation 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 Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

(continued)

Farley Units 1 and 2 B 3.7.10-5 Revision

Control Room l B 3.7.1 0 BASES ACTIONS E.1 and E.2 (continued)

During movement of irradiated fuel assemblies or during CORE ALTERATIONS, if an inoperable CRE cannot be restored to OPERABLE status within the required Completion Time or with two CREFS trains inoperable for reasons other than Condition B, action must be taken to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room.

This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

SURVEILLANCE SR 3.7.10.1 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 (CREFS and Pressurization) once every month provides an adequate check of this system. The CREFS trains are initiated from the control room with flow through the HEPA and charcoal filters. Systems must be operated for > 15 minutes to demonstrate the function of the system. Systems with heaters must be operated with the heaters energized. The 31 day Frequency is based on the reliability of the equipment and the two train redundancy available.

SR 3.7.10.2 This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREFS filter tests are in accordance with ASME N510-1989 (Ref. 3).

The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.

(continued)

Farley Units 1 and 2 B 3.7.10-6 Revision

Control Room I B 3.7.1 0 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.10.3 This SR verifies that each CREFS train starts and operates on an actual or simulated Safety Injection (SI) actuation signal. The Frequency of 24 months is consistent with the testing frequencies specified in Regulatory Guide 1.52 (Ref. 4). This SR is modified by a note which provides an exception to the requirement to meet this SR in MODES 5 and 6. This is acceptable since the automatic SI actuation function is not required in these MODES.

I SR 3.7.10.4 This SR verifies that the CRE Ap can be maintained within limits with one CREFS train in operation. The CRE Ap is periodically tested to verify proper functioning of the CREFS. The CREFS is designed to maintain the radiological cleanup function with one train. The frequency of 24 months on a STAGGERED TEST BASIS is adequate and has been shown to be acceptable by operating experience.

SR 3.7.10.5 This SR verifies the integrity of the CRE by requiring testing for control room inleakage. The details of the inleakage testing are contained in the Control Room Integrity Program (CRIP).

REFERENCES

1. FSAR, Section 6.4.

2. FSAR, Chapter 15.

3. ASME N510-1989.

4. Regulatory Guide 1.52, Rev. 3.

I Farley Units 1 and 2 B 3.7.10-7 Revision

Joseph M. Farlcy Nuclear Plant Units 1 and 2 Request to Revise Technical Specifications Control Room Habitability Schedule for Performing New and Revised Surveillance Requirements

Joseph M. Farley Nuclear Plant Units 1 and 2 Request to Revise Technical Specifications Control Room Habitability Schedule for Performing New and Revised Surveillance Requirements The schedule for performing new and revised Surveillance Requirements (SRs) shall be as follows:

1. For SRs that are new in this amendment the first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.

2.

For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

3.

For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

ML042400220

Text

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