ML042790237

Technical Specifications, Addressing the Control Room Habitability Guidance of Regulatory Guide 1.196

ML042790237
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Site:	Farley
Issue date:	09/30/2004
From:	Office of Nuclear Reactor Regulation
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References
RG-1.196
Download: ML042790237 (16)

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Control Room I 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room I LCO 3.7.1 0 Two Control Room Emergency Filtration/Pressurization System (CREFS) trains and the Control Room Envelope (CRE) shall be OPERABLE. I ONOTE ---u-n 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. OPERABLE status.

B. CRE inoperable. B.1 Initiate mitigating actions. Immediately AND B.2.1 Restore CRE to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE status.

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

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

Farley Units 1 and 2 3.7.10-1 Amendment No. 16 6 (Unit 1)

Amendment No. 158 (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 <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. C.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 /> OR Two CREFS trains inoperable in MODE 1, 2, 3, or 4.

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. 16 6 (Unit 1)

Amendment No. 158 (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. I SURVEILLANCE REQUIREMENTS _

SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREFS Pressurization train with the 31 days I 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 D -

Not required to be performed in MODES 5 and 6.

Verify each CREFS train actuates on an actual or 18 months simulated actuation signal.

Farley Units 1 and 2 3.7.10-3 Amendment No. 166 (Unit 1)

Amendment No. 158 (Unit 2)

Control Room l 3.7.10 SURVEILLANCE REQUIREMENTS .

SURVEILLANCE FREQUENCY SR 3.7.10.4 Verify CRE Ap within limits in the Control Room Integrity 24 months on a Program (CRIP). STAGGERED TEST BASIS SR 3.7.10.5 Verify CRE integrity in accordance with the CRIP. In accordance with the CRIP Farley Units 1 and 2 3.7.10-4 Amendment No.1 66 (Unit 1)

Amendment No.1 58 (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. 16 6(Unit 1)

Amendment Nol 58 (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 I specified below.

ESF Ventilation Svstem 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%

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

• 301C and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration RH CREFS Recirculation 2.5% 70%

CREFS Filtration 2.5% 70%

CREFS Pressurization 0.5% 70%

PRF Post LOCA Mode 5% 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.

Delta P Flowrate ESF Ventilation System (in. water gauge) (CFM)

CREFS Recirculation 2.3 2,000 + 10%

CREFS Filtration 2.9 1,000+ 10%

CREFS Pressurization 2.2 300 + 25% to - 10%

PRF Post LOCA Mode 2.6 5,000 + 10%

(continued)

Farley Units 1 and 2 5.5-9 Amendment No.1 66 (Unit 1)

Amendment No.1 58 (Unit 2)

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 L. when pressurized to > 10 psig.

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

• 0.05 L, 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 Control Room Envelope (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 1and 2 5.5-14 Amendment No. 166 (Unit 1)

Amendment No. 158 (Unit 2)

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

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 the below values. The values listed below do not include 10 cfm assumed in accident analysis for ingress I egress.

i) 43 cfm when the control room ventilation systems are aligned in the emergency recirculation mode of operation, ii) 600 cfm when the control room ventilation systems are aligned in the isolation mode of operation, and iii) 2,340 cfm when the control room ventilation systems are aligned in the normal 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. Maintain a CRE configuration control and a design and licensing bases control program and a preventative maintenance program. As a minimum, the CRE configuration control program will determine whether the i) CRE differential pressure relative to adjacent areas and ii) the control room ventilation system flow rates, as determined in accordance with ASME N510-1989 or ASTM E2029-99, are consistent with the values measured at the time the ASTM E741 test was performed. If item i or ii has changed, determine how this change has affected the inleakage characteristics of the CRE. If there has been degradation in the inleakage characteristics of the CRE since the E741 test, then a determination should be made whether the licensing basis analyses remain valid. If the licensing basis analyses remain valid, the CRE remains OPERABLE.

d. Test the CRE in accordance with the testing methods and at the frequencies specified in RG 1.197, Revision 0, May 2003.

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

Farley Units 1 and 2 5.5-15 Amendment No.166 (Unit 1)

Amendment No.1 58 (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, valves or dampers, ESF HVAC equipment housings, 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. This space is protected for normal operation, natural events, and accident conditions.

Maintaining the integrity of the CRE minimizes the infiltration of unfiltered air from areas adjacent to the CRE, thereby minimizing the possibility that the effects of a radiological challenge would result in a radiological dose which exceeds General Design Criteria (GDC) 19. It also minimizes the possibility that a fire challenge would result in a condition where the operator would be disabled or impaired such that the reactor could not be controlled from the control room or the hot shutdown panels. In addition, the CRE minimizes the possibility that a hazardous chemical challenge would result in a condition where the operator would be disabled or impaired such that the reactor could not be controlled from the control room. While the CRE provides a boundary for the CREFS to operate in, the CRE is independent from the CREFS and its OPERABILITY requirements are separate from the 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 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, and instrumentation which form the system.

(continued)

Farley Units I and 2 B 3.7. 10-1 Revision

Control Room I B 3.7.10 BASES BACKGROUND The CREFS is an emergency system, parts of which may also (continued) 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 operation, the heaters reduce moisture buildup on the HEPA filters and adsorbers. 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 control room. The air entering I 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 CREFS train provides makeup air flow and radiological dose cleanup for the control room. The CREFS operation in maintaining I 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.

(continued)

Farley Units 1 and 2 B 3.7.10-2 Revision

Control Room I B 3.7.10 BASES BACKGROUND The CREFS is designed to maintain the control room environment for (continued) 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.

An inoperable CRE does not render the CREFS inoperable or vice versa. The OPERABILITY of the CREFS and the CRE are determined separately and both are required to be OPERABLE.

APPLICABLE The CREFS components are arranged in redundant, safety related SAFETY ANALYSES ventilation trains. The location of components within the CRE and ducting of the CRE ensure an adequate supply of filtered air to all areas 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).

Maintaining the integrity of the CRE limits the quantity of contaminants allowed into the CRE so that the radiological dose criteria of GDC 19 are met. The analysis of toxic gas releases demonstrates that the toxicity limits are not exceeded in the control room following a toxic chemical release. Maintaining the integrity of the CRE helps to ensure that the control room operators mry maintain reactor control from the control room and maintain separation between the control room and the hot shutdown panels.

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.

(continued)

Farley Units 1 and 2 B 3.7.10-3 Revision

Control Room I B 3.7.10 BASES LCO The CREFS is considered OPERABLE when the individual (continued) 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 is OPERABLE and air circulation can be maintained. I In addition, the CRE must~be maintained OPERABLE, including the integrity of the walls, floors, ceilings, ductwork, valves and dampers, ESF HVAC equipment housings, and access doors. Inleakage must also be minimized such that operator exposure limits are not exceeded.

An inoperable CRE does not render the CREFS inoperable or vice versa. The OPERABILITY of the CREFS and the CRE are determined separately and both are required to be OPERABLE.

The LCO is modified by a Note allowing the CRE to be opened I intermittently under administrative controls without requiring entry into Condition B for an inoperable CRE. For entry and exit through doors, I the administrative control of the opening is performed by the person(s) entering or exiting the area. For maintenance access openings, such as hatches and test ports, the administrative control of the opening is performed by the attendant person(s) performing the maintenance.

For other openings, 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 integrity is indicated. I 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 I and following a DBA.

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

Farley Units 1 and 2 B 3.7.10-4 Revision

Control Room l B 3.7.10 BASES ACTIONS A.1 With one CREFS train inoperable, action must be taken to restore it to I 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 operator protection analyses assumption of inleakage may be exceeded. During the period that the CRE is inoperable, mitigating actions must be initiated to protect control room operators from potential hazards. These mitigating actions (i.e.,

actions that are taken to offset the consequences of the inoperable CRE) should be preplanned for initiation upon entry into the condition.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entry into Condition B, Actions must be taken to restore the CRE to OPERABLE status or to verify that the requirements of GDC 19 are met for the facility. GDC 19 is verified to be met by limiting dose from radioactive gas and particulates, 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. 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, the use of mitigating actions, and the time necessary to perform an assessment.

If it is determined that the requirements of GDC 19 are met crediting, as necessary, the mitigating actions required by Required Action B.1, 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.

(continued)

Farley Units 1 and 2 B 3.7.10-5 Revision

Control Room l B 3.7.10 BASES ACTIONS C.1 and C.2 (continued)

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, 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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

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.

E.1 and E.2 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, 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.

Farley Units 1 and 2 B 3.7.10-6 Revision

Control Room l B 3.7.10 BASES 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 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 (Ref. 3). 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. 4).

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 This SR verifies that each CREFS train starts and operates on an actual or simulated Safety Injection (SI) actuation signal. The Frequency of 18 months is based on operating experience and is consistent with the typical industry refueling cycle. 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 This SR verifies that the CRE Ap can be maintained within limits defined in the Control Room Integrity Program (CRIP) with one CREFS train in operation. If the requirements of this SR cannot be met, a determination must be made as to the cause of the failure.

Once identified, the appropriate Condition (for either the CREFS or the CRE) must be entered. For example, if the failure is due to a breach in the integrity of the CRE, the Condition for an inoperable (continued)

Farley Units 1 and 2 B 3.7.10-7 Revision

Control Room I B 3.7.10 BASES SURVEILLANCE SR 3.7.10.4 (continued)

REQUIREMENTS CRE would be entered but the Condition for an inoperable CREFS would not be entered. An inoperable CRE does not render the CREFS inoperable or vice versa. 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 CRIP.

REFERENCES 1. FSAR, Section 6.4.

2. FSAR, Chapter 15.

3. Regulatory Guide 1.52, Rev. 3.

4. ASME N510-1989.

Farley Units 1 and 2 B 3.7.10-8 Revision