Text

Proposed License Amendment Request Consolidated Line Item Improvement Process Technical Specification Improvement Control Room Habitability
	ML071970301
Person / Time
Site:	Surry
Issue date:	07/13/2007
From:	Gerald Bichof; Virginia Electric & Power Co (VEPCO)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	07-0488
	Download: ML071970301 (85)
	v • d • e

VIRGINIA ELECTRIC AND POWER COMPANY

RICHMOND, VIRGINIA 23261 July 13, 2007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Serial No.

07-0488 NLOSIGDM R1 Docket Nos.

50-280, 281 License Nos. DPR-32, 37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS I AND 2 PROPOSED LICENSE AMENDMENT REQUEST CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS TECHNICAL SPECIFICATION IMPROVEMENT CONTROL ROOM HABITABILITY Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) requests amendments, in the form of changes to the Technical Specifications (TS) to Facility Operating License Numbers DPR-32 and DPR-37 for Surry Power Station Units 1 and 2, respectively. The proposed amendment modifies the Surry Power Station Units 1 and 2 Technical Specifications (TS) requirements related to Main Control RoomIEmergency Switchgear Room (MCRIESGR) envelope habitability. The changes are consistent with the NRC-approved lndustrylTechnical Specification Task Force (TSTF) Traveler TSTF-448, Revision 3, Control Room Habitability (TSTF-448). The availability of this TS improvement was published in the Federal Register on January 17, 2007, as part of the consolidated line item improvement process (CLIIP).

The license amendment request has been prepared in accordance with the NRC's CLIIP. Additional supporting TS and Bases changes are being proposed to facilitate incorporation of the TSTF-448 revisions into Surry's custom TS format. A description and assessment of the proposed amendment is provided in Attachment 1. The marked-up and typed proposed TS pages are provided in Attachments 2 and 3, respectively.

The associated Bases changes are provided for information only and will be implemented in accordance with the TS Bases Control Program and 10 CFR 50.59.

It should be noted that the marked-up and proposed pages of the Surry Units 1 and 2 Operating Licenses included in Attachments 2 and 3, respectively, also include License Condition 3.Q that was previously proposed in Dominion's February 26, 2007 (Serial No. 07-0109) license amendment request. That submittal requested temporary 45-day and 14-day allowed outage times to facilitate replacement of MCRIESGR Air Conditioning System chilled water piping and is currently being reviewed by the NRC.

We have evaluated the proposed amendment and have determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. The basis for our determination is included in Attachment I. The proposed amendment has been reviewed and approved by the Station Nuclear Safety and Operating Committee.

Serial No. 07-0488 Docket Nos. 50-2801281 Page 2 of 3 The proposed amendment is also being submitted consistent with Dominion's response to Generic Letter (GL) 2003-001, Control Room Habitability.

In a letter dated April 22, 2004 (Serial No. 03-373C), Dominion committed to submit a license amendment request to incorporate a control room habitability program into the TS within six months following either the approval of TSTF-448 or TSTF-448 being made available for adoption, whichever was later. This submittal completes that commitment for Surry Power Station.

Dominion requests approval of the license amendments by December 31, 2007 with a 180-day implementation period.

If you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.

Sincerely,

~ e r a l d T. Bischof u Vice President - Nuclear Engineering Commitments made in this letter: None Attachments

1. Description and Assessment

2. Proposed Technical Specifications Pages (Mark-Up)

3. Proposed Technical Specifications Pages (Typed)

COMMONWEALTH OF VIRGINIA 1

)

COUNTY OF HENRICO 1

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this /3 Tday of

,2007.

My Commission Expires: ( llllr,~

-3 I.

I) commonwm of m@n~a Notary Public

Serial No. 07-0488 Docket Nos. 50-2801281 Page 3 of 3 cc:

U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. E. Riggs NRC Senior Resident Inspector Surry Power Station State Health Commissioner Virginia Department of Health James Madison Building - 7'h Floor 109 Governor Street Room 730 Richmond, Virginia 2321 9 Mr. S. P. Lingam NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North 11 555 Rockville Pike Mail Stop 8G9A Rockville, Maryland 20852 Mr. R. A. Jervey NRC Project Manager - North Anna U. S. Nuclear Regulatory Commission One White Flint North I

1555 Rockville Pike Mail Stop 8G9A Rockville, Maryland 20852

Serial No. 07-0488 Docket Nos. 50-2801281 ATTACHMENT I DESCRIPTION AND ASSESSMENT Virginia Electric and Power Company (Dominion)

Surry Power Station Units I and 2

Serial No. 07-0488 Docket Nos 50-280150-281 Description and Assessment

1.0 DESCRIPTION

The proposed amendment would modify the Surry Power Station Units 1 and 2 Technical Specifications (TS) requirements related to Main Control RoomIEmergency Switchgear Room (MCRIESGR) envelope habitability. The changes are consistent with the Nuclear Regulatory Commission (NRC) approved l ndustryrrechnical Specification Task Force (TSTF) Traveler TSTF-448, Revision 3, Control Room Habitability (TSTF-448). The availability of this TS improvement was published in the Federal Register on January 17, 2007, as part of the consolidated line item improvement process (CLIIP). The license amendment request has been prepared in accordance with the NRC's CLllP and pursuant to the requirements of 10 CFR 50.90. Additional supporting TS changes are being proposed to facilitate incorporation of the TSTF-448 revisions into Surry's custom TS format. Associated TS Bases changes are also being made to facilitate incorporation of the TSTF-448 Bases changes, and these changes will be implemented at the same time as the proposed TS changes. The TS Bases changes are provided for the NRC's information.

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Virginia Electric and Power Company (Dominion) has reviewed the safety evaluation dated January 17, 2007, as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-448.

Dominion has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Surry Units 1 and 2 and justify this amendment for the incorporation of the changes into the Surry Units 1 and 2 TS.

2.2 Optional Changes and Variations Dominion is not proposing any significant variations or deviations from the TS changes described in the TSTF-448 or the applicable parts of the NRC staff's model safety evaluation dated January 17, 2007. Specifically, Evaluations 2 and 4 of Section 3.3 of the Technical Evaluation section of the model safety evaluation are applicable to Surry Units 1 and 2.

Minor variationsldeviations from the TS terminology used in NUREG-1431, Standard Technical Specifications - Westinghouse Plants, and TSTF-448 are required because the Surry Units 1 and 2 TS are custom TS. Consequently, the Surry TS wording and format do not directly correspond to the Standard Technical Specifications (STS) and TSTF-448 wording and format. For example, the term "control room envelope (CRE)"

used in STS and TSTF-448 is expressed as the "Main Control RoomIEmergency Switchgear Room (MCRIESGR) envelope" in the Surry TS. Also, the Surry TS do not Page 1 of 5

Serial No. 07-0488 Docket Nos 50-280150-281 use the NUREG-I431 STS defined terms, such as, CONDITION, REQUIRED ACTION and COMPLETION TIME or their associated table format. The Surry TS typically use a more narrative format. However, the intent of the CLllP wording has been maintained in the proposed TS change and has been used verbatim to the extent possible. In addition, the Surry TS format separates Limiting Conditions for Operation (LCOs) and Action Statements (ASS) from Surveillance Requirements (SRs) by placing them in different TS sections (i.e., Sections 3 and 4, respectively). Also, the MCRIESGR EVS requirements during REFUELING OPERATIONS and when moving recently irradiated fuel are only included in TS 3.10, Refueling, rather than in the MCRIESGR EVS TS, which only addresses operating conditions above COLD SHUTDOWN. TS 3.19, Main Control Room Bottled Air System, is also being revised to reflect the TSTF-448 TS requirements associated with an inoperable MCRIESGR envelope boundary, as this system works in conjunction with the MCRIESGR EVS as part of the MCRIESGR Emergency Habitability System (EHS) to maintain protection of the MCRIESGR envelope occupants from radiological, hazardous chemical and smoke hazards.

Additionally, Surry TS do not use the ITS MODE terminology convention for reactor operating conditions. Surry TS use specific definitions for each operating condition

instead, e.g.,

POWER OPERATION, HOT

SHUTDOWN, INTERMEDIATE

SHUTDOWN, REACTOR

CRITICAL, COLD SHUTDOWN and REFUELING SHUTDOWN. While not identical, the reactor operating MODES specified in the CLllP are generally consistent with the defined REACTOR OPERATION conditions used in the Surry TS and the license amendment request.

The minor variations andlor deviations from the specific wordinglformat provided in the CLllP do not change the meaning, intent or applicability of the CLIIP.

A table summarizing the minor variations andlor deviations from the TS changes described in TSTF-448 is provided in Attachment A for reference.

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

Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of Main Control Room/Emergency S witchgear Room (MCWES G R) envelope unfiltered air inleakage as required by TS SR 4.18 in accordance with TS 6.4. R.3.a, the assessment of MCWESGR envelope habitability as required by Specification 6.4. R.3. b, and the measurement of MCWESGR envelope pressure as required by Specification 6.4. R. 4, shall be considered met. Following implementation:

(a) The first performance of SR 4.18, in accordance with Specification 6.4. R. 3. a, shall be within the specified frequency of 6 years plus the ?&month allowance of SR 4.0.2, as measured from January 18, 2004, the date of the most recent successful tracer gas test, as stated in the April 22, 2004 letter response to Generic Letter Page 2 of 5

Serial No. 07-0488 Docket Nos 50-280150-281 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of MCWESGR envelope habitability, Specification 6.4. R. 3. b, shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from January 18, 2004, the date of the most recent successful tracer gas test, as stated in the April 22, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of MCWESGR envelope pressure, Specification 6.4.R.4, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from January 19, 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 3.1. I lncorporation of TSTF-448, Revision 3 Dominion has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

Dominion has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Surry Power Station Units 1 and 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.1.2 Changes to Accommodate lncorporation of TSTF-448, Revision 3 Dominion has also performed a NSHCD for the TS changes associated with terminology and format differences between the Surry TS and the STS, as well as additional conforming changes to facilitate incorporation of the changes described in TSTF-448.

Dominion has concluded that the proposed changes do not involve a significant hazards consideration because the changes do not:

1. Involve a significant increase in the probability or consequences of an accident previouslv evaluated.

The proposed changes consist of TS wording, format and conforming changes to facilitate incorporation of TSTF-448 into the Surry custom TS and for consistency with NUREG-1431, Revision 3, to the extent practical.

The proposed changes are administrative in nature and, as such, do not impact the condition or performance of any plant structure, system or component. The proposed changes do not affect the initiators of any previously analyzed event or the assumed mitigation of accident or transient events. As a result, the proposed administrative changes to the Surry TS do Page 3 of 5

Serial No. 07-0488 Docket Nos 50-280150-281 not involve any increase in the probability or the consequences of any accident or malfunction of equipment important to safety previously evaluated since neither accident probabilities or consequences are being affected by the proposed changes.

2. Create the possibilitv of a new or different kind of accident from any accident previouslv evaluated.

The proposed changes are administrative in nature, and therefore do not involve any changes in station operation or physical modifications to the plant. In addition, no changes are being made in the methods used to respond to plant transients that have been previously analyzed. No changes are being made to plant parameters within which the plant is normally operated or in the setpoints, which initiate protective or mitigative actions, and no new failure modes are being introduced. Therefore, the proposed changes to the Surry Technical Specifications do not create the possibility of a new or different kind of accident or malfunction of equipment important to safety from any previously evaluated.

3. Involve a significant reduction in a margin of safetv.

The proposed changes consist of TS wording, format and conforming changes to facilitate incorporation of TSTF-448 into the Surry custom TS and for consistency with NUREG-1431, Revision 3. The proposed changes are administrative in nature, and do not impact station operation or any plant structure, system or component that is relied upon for accident mitigation. Furthermore, the margin of safety assumed in the plant safety analysis is not affected in any way by the proposed changes. Therefore, the proposed administrative changes to the Surry Technical Specifications do not involve a reduction in a margin of safety.

4.0 ENVIRONMENTAL EVALUATION 4.1 lncorporation of TSTF-448, Revision 3 Dominion has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007, as part of the CLIIP. Dominion has concluded that the staffs findings presented in that evaluation are applicable to Surry Power Station Units 1 and 2 and the evaluation is hereby incorporated by reference for this application.

4.2 Changes to Accommodate lncorporation of TSTF-448, Revision 3 Dominion has further determined that the TS changes associated with terminology, format and other differences between the Surry TS and the STS to facilitate incorporation of the changes described in TSTF-448 will not result in any significant increases in the amounts of any effluents that may be released offsite or any significant increases in individual or cumulative occupational radiation exposure.

Page 4 of 5

Serial No. 07-0488 Docket Nos 50-280150-281 The proposed changes are administrative in nature and, as such, do not affect the operation of the plant. Therefore, the proposed changes are eligible for categorical exclusion as set forth in 10 CFR 51.22(~)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed changes since the changes will not result in an undue risk to the health and safety of the public.

Page 5 of 5

Serial No. 07-0488 Docket Nos 50-280150-281 Attachment A Section I---=--

LC0 3.7.10 ACTION B LC0 3.7.10 ACTIONS D and E Surry TS Section Table of Contents 3.19.B.3 and 5 Variation from Improved STS and/or the TSTF-448 Wording for Surry Power Station Units 1 and 2 Custom TS The Surry Technical Specifications (TS) Table of Contents has been revised to reflect the new TS sections 3.21, Main Control RoomEmergency Switchgear Room (MCRESGR) Emergency Ventilation System (EVS) and 4.18, Main Control RoomEmergency Switchgear Room (MCWESGR) Emergency Ventilation System (EVS) Testing, as well as the revised TS 3.23 section title, Main Control Room (MCR) and Emergency Switchgear Room (ESGR) Air Conditioning System, which is being revised for terminology consistency.

The TSTF-448 TS requirements for an inoperable control room envelope (CRE) are being included in TS 3.19, Main Control Room Bottled Air System, for consistency with new TS 3.21 (see below),

since TS 3.19 currently contains an 8-hours to HOT SHUTDOWN requirement for an inoperable CRE. The term "control room envelope (CRE)" has been changed to the term "Main Control RoomlEmergency Switchgear Room (MCRIESGR) envelope" or "MCRIESGR envelope" for consistency with Surry's system terminology.

The applicability statement for the Main Control Room Bottled Air System has also been revised to note that the TS applies whenever either unit is above COLD SHUTDOWN, since the system requirements during Refueling and the movement of recently irradiated fuel are included in TS 3.10, Refueling.

The revised MCRIESGR EVS TS requirements during refueling and during the movement of irradiated fuel have been incorporated into Surry TS 3.10, Refueling, for consistency with the current Surry TS, which keeps all of the TS requirements associated with refueling and movement of irradiated fuel in the same TS section. MCR Bottled Air System requirements during the movement of recently irradiated fuel that currently reside in TS 3.10 have also been revised to reflect the revised TS requirements for an inoperable MCRIESGR envelope boundary. The current term "irradiated fuel" has been changed to "recently irradiated fuel" for consistency with TSTF-448 and Standard TS. The associated TS 3.10 Basis revision defines recently irradiated fuel as follows: "The MCRIESGR EVS and the MCR Bottled Air System are only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within a time frame established by analysis),

due to radioactive decay. The term recently is defined as all irradiated fuel assemblies, until analysis is performed to determine a specific time." Therefore, adding the word "recently" to the term "irradiated fuel" in TS 3.10, together with the definition of "recently irradiated fuel" that is being added to the TS 3.1 0 Basis, does not change the way irradiated fuel assemblies are handled at Surry.

Page 1 of 3

Serial No. 07-0488 Docket Nos 50-280150-281 Attachment A LC0 3.7.10 ACTIONS A B, C and F B3.7.10 Bases The Surry TS format separates Limiting Conditions for Operation (LCOs) and Action Statements (ASS) from Surveillance Requirements (SRs) by placing them in different TS sections (i.e., Sections 3 and 4, respectively).

Therefore:

The STS 3.7.10 LCO, Conditions, Required Actions and Completion Times, as revised by TSTF-448 have been incorporated, for the most part, into the Surry TS as TS 3.21. The plant system name, Control Room Emergency Filtration System (CREFS), is changed to the comparable Surry plant system name Main Control Room/Emergency Switchgear Room (MCWESGR) Emergency Ventilation System (EVS). In addition, Surry's TS format and reactor operating condition terminology is retained vs. the format and MODE terminology used in the improved STS.

Surry TS 3.23, Main Control Room and Emergency Switchgear Room Ventilation and Air Conditioning System, has been revised to delete the current TS requirements associated with the MCRIESGR EVS. TS 3.23 will now only address the MCR and ESGR Air Conditioning System, since the EVS requirements will now be included in new TS 3.21.

The STS 3.7.10 SRs, as revised by TSTF-448, have been incorporated into the Surry TS as TS 4.18, Main Control RoomEmergency Switchgear Room (MCRIESGR) Emergency Ventilation System (EVS) Testing.

The plant system name, Control Room Emergency Filtration System (CREFS), is changed to the comparable Surry plant system name Main Control RoomEmergency Switchgear Room (MCWESGR) Emergency Ventilation System (EVS).

STS Surveillance Requirement SR 3.7.10.3 that requires verification of MCRIESGR EVS train actuation is not included in the SPS TS since the system is not required to automatically actuate.

The MCRIESGR EVS is manually started approximately one hour after the discharge of the MCR Bottled Air System, and the manual actuation of the EVS is verified by SR 3.7.10.1 (SPS TS SR 4.18.A).

STS B3.7.10, as modified by TSTF-448, is divided into two parts to address the SPS TS format.

Specifically, the Background, Applicable Safety Analyses, Limiting Conditions for Operation, Applicability, Actions and References sections are included with the TS 3.21 Bases (with portions applicable to the movement of irradiated fuel and to the TS requirements for an inoperable MCRIESGR envelope duplicated in Surry TS 3.10, Refueling, and TS 3.19, Main Control Room Bottled Air System, respectively), and the Surveillance Requirements and References (as applicable) are included in the TS 4.18 Bases. The sections have been modified where necessary to reflect the design of the Surry MCRIESGR EVS (e.g., Surry has four redundant EVS trains). The TS 3.21 Bases also note that the MCRIESGR EVS together with the MCR Bottled Air System make up the Page 2 of 3

Serial No. 07-0488 Docket Nos 50-280150-281 Attachment A Emergency Habitability System (EHS) and that both systems are used to pressurize the MCRIESGR envelope.

The word MODE(S) is changed to the term REACTOR OPERATION condition(s) since Surry TS do not use the MODE convention to describe reactor operation parameters or include it as a defined TS term. Surry TS use specific definitions for each operating condition (MODE) instead, e.g., POWER OPERATION, HOT SHUTDOWN, INTERMEDIATE SHUTDOWN, REACTOR CRITICAL, COLD SHUTDOWN and REFUELING OPERATION.

The terms Completion Time and Required Action are changed to Allowed Outage Time and Action Statement for consistency with Surry TS terminology.

Surry TS 4.20, Control Room Air Filtration System, has been revised to delete: 1) SR 4.20.A.10, which requires monthly testing of each EVS filter train circuit and manual initiation from the control room, and SR 4.20.B.6, which requires a minimum period of filter train air flow of 15 minutes per month. These SRs are now included in new SR 4.18.A and its associated Basis section. A sentence in the TS 4.20 Basis associated with the 15 minute run time was also deleted since the 15 minute run requirement is now included in TS 4.18.

STS program 5.5.18, Control Room Envelope Habitability Program, as included in TSTF-448, is incorporated into the Surry TS as TS 6.4. R, Main Control RoomEmergency Switchgear Room (MCWESGR) Envelope Habitability Program. Two changes have been made to the TSTF-448 wording as follows:

1) Surry specific text has been added to the first paragraph to note that MCRIESGR envelope habitability is maintained at Surry by the Emergency Habitability System, which consists of the MCRIESGR EVS

[Surry TS 3.211 and the MCR Bottled Air System [Surry TS 3.191, and

2) The phrase "18 month" has been deleted before the word "assessment" in TS 6.4.R.4 [ITS 5.5.18.dl to avoid confusion with the MCRIESGR habitability 3-year assessment frequency discussed in TS 6.4. R.3(b) [ITS 5.5.18.c(ii)].

Page 3 of 3

Serial No. 07-0488 Docket Nos. 50-280 and 281 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGES (MARK-UP)

Virginia Electric and Power Company (Dominion)

Surry Power Station Units 1 and 2

(2) The Updated Final Safety Analysis Report supplement as revised on July 25, October I, November 4, and December 2, 2002, shall be included in the next scheduled update to the licensee's Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59, and otherwise complies with the requirements in that section.

Q. As discussed in the footnote to Technical Specifications 3.23.C.2.a.l and 3.23.C.Z.b.1, the use of temporary 45-day and 14-day allowed outage times to permit replacement of the Main Control Room and Emergency Switchgear Room Air Conditioning System chilled water piping shall be in accordance with the basis, risk evaluation, equipment unavailability restrictions, and compensatory actions provided in the licensee's submittal dated February 26, 2007 (Serial No. 07-01 09).

L

4. This renewed license is effective as of the date of issuance, and shall expire at midnight on May 25, 2032.

FOR THE NUCLEAR REGULATORY COMMISSION Samuel J. Collins, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A, Technical Specifications Date of Issuance: March 20, 2003 SURRY - UNIT I

P. Updated Final Safety Analysis Report (1) The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d), as revised on July 25, 2002, October 1, 2002, November 4, 2002, and December 2, 2002 describes certain future inspection activities to be completed before the period of extended operation. The licensee shall complete these activities no later than January 29, 2013, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

(2) The Updated Final Safety Analysis Report supplement as revised on July 25,2002, October 1,2002, November 4,2002, and December 2,2002, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

Q. As discussed in the footnote to Technical Specifications 3.23.C.2.a.l and 3.23.C.2.b.1, the use of temporary 45-day and 14-day allowed outage times to permit replacement of the Main Control Room and Emergency Switchgear Room Air Conditioning System chilled water piping shall be in accordance with the basis, risk evaluation, equipment unavailability restrictions, and compensatory actions provided in the licensee's submittal dated February 26, 2007 (Serial No. 07-01 09).

This renewed license is effective as of the date of issuance, and shall expire at midnight on January 29, 2033.

FOR THE NUCLEAR REGULATORY COMMISSION Samuel J. Collins, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A, Technical Specifications Date of Issuance: March 20, 2003 SURRY - UNIT 2

INSERT 1 (New License Condition 3.R)

R. Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of Main Control RoomIEmergency Switchgear Room (MCRIESGR) envelope unfiltered air inleakage as required by TS SR 4.18 in accordance with TS 6.4.R.3.a, the assessment of MCRIESGR envelope habitability as required by Specification 6.4.R.3.b, and the measurement of MCRIESGR envelope pressure as required by Specification 6.4.R.4, shall be considered met.

Following implementation:

1. The first performance of SR 4.18, in accordance with Specification 6.4.R.3.a, shall be within the specified frequency of 6 years plus the 18-month allowance of SR 4.0.2, as measured from January 18, 2004, the date of the most recent successful tracer gas test, as stated in the April 22, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

2. The first performance of the periodic assessment of MCRIESGR envelope habitability, Specification 6.4.R.3.b, shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from January 18, 2004, the date of the most recent successful tracer gas test, as stated in the April 22, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

3. The first performance of the periodic measurement of MCRIESGR envelope pressure, Specification 6.4.R.4, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from January 19, 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

TECHNICAL SPECIFICATION TABLE (SF CONTENTS SECTION TITLE PAGE 3.15 DELETED 3.16 EMERGENCY POWER SYSTEM TS 3.16-1 3.17 LOOP STOP VALVE OPERATION TS 3.17-1 3.18 MOVABLE INCORE INSTRUMENTATION TS 3.18-1 3.19 MAIN CONTROL ROOM BOTTLED AIR SYSTEM TS 3.19-1 3.20 SHOCK SUPPRESSORS (SNUBBERS)

TS 3.20- 1 Main coo&\\

Roam,kmcrgcnrj 5r~.

&. h, y ~

3.21 BE.f=ETE* X O O ~ C H C

/ S S G ~ gnep3h.\\ry &&'\\rbh

~'3121

-I s s c e o &VS) 3 -22 AUXILIARY GENTILATION EXHAUST FILTER TRAINS TS 3.22-1 4.0 SURVEILLANCE REQUIREMENTS 4.1 OPERATIONAL SAFETY REVIEW 4.2 AUGMENTED INSPECTIONS 4.3 DELETED 4.4 CONTAINMENT TESTS SPRAY SYSTEMS TESTS TS 4.5-1 EMERGENCY POWER SYSTEM PERIODIC TESTING TS 4.6-1 MAIN STEAM LINE TRIP VALVES AUXILIARY FEEDWATER SYSTEM RADIOACTIVE GAS STORAGE MONITORING SYSTEM TS 4.9-1 REACTIVITY ANOMALIES TS 4.10-1 SAFETY INJECTION SYSTEM TESTS TS 4.11-1 VENTILATION FILTER TESTS TS 4.12-1 RCS OPERATIONAL LEAKAGE TS 4.13-1 DELETED Amendment Nos.

TS iii TECHNICAL SPECIFICATION TABLE OF CONTENTS SECTION TITLE PAGE AUGMENTED INSERVICE INSPECTION PROGRAM FOR HIGH TS 4.15-1 ENERGY LINES OUTSIDE OF CONTAINMENT LEAKAGE TESTING OF MISCELLANEOUS RADIOACTIVE TS 4.16-1 MATERIALS SOURCES SHOCK SUPPRESSORS (SNUBBERS)

TS 4.17-1

~,,. t 4 I l &, e, ~ / ~ n s u g h ~

5d:k5cw f h ~ ~

l3-c~~

n ~rzce',

h-e3-3

\\/* 3' 1 &I h Ys-km ~5 J. p,.-I

<sL's, -~c?sA'n STEAM GENERATOR (SG) &BE INTEGRITY TS 4.19-1

-1 CONTROL ROOM AIR FILTRATION SYSTEM TS 4.20-1 DESIGN FEATURES 5.1

' SITE 5.2 CONTAINMENT 5.3 REACTOR.

5.4 FUEL STORAGE ADMINISTRATIVE CONTROLS ORGANIZATION, SAFETY AND OPERATION REVIEW GENERAL NOTIFICATION AND REPORTING REQUIREMENTS ACTION TO BE TAKEN IF A SAFETY LIMIT IS EXCEEDED UNIT OPERATING PROCEDURES AND PROGRAMS STATION OPERATING RECORDS STATION REPORTING REQUIREMENTS ENVIRONMENTAL QUALIFICATIONS PROCESS CONTROL PROGRAM AND OFFSITE DOSE CALCULATION MANUAL Amendment Nos. m.

F V

3.1 0 REFUELING Applicability Applies to operating limitations during REFUELING OPERATIONS movement in the Fuel Building.

1 Objective To assure that no accident could occur during REFUELING OPERATIONS fuel movement in the Fuel Building that would affect public health and safety.

1 Specification A. During REFUELING OPERATIONS the following conditions are satisfied:

1. The equipment access hatch and at least one door in the personnel airlock shall be capable of being closed. For those penetrations which provide a direct path from containment atmosphere to the outside atmosphere, the containment isolation valves shall be OPERABLE or the penetration shall be closed by a valve, blind flange, or equivalent or the penetration shall be capable of being closed.

Amendment Nos. !?%h&H+

10. A spent fuel cask or heavy loads exceeding 110 percent of the weight of a fuel assembly (not including fuel handling tool) shall not be moved over spent fuel, and only one spent fuel assembly will be handled at one time over the reactor or the spent fuel pit.

13. Three chillers shall be OPERABLE in accordance with the power supply J\\

requirements of Specification 3.23.C. With one of the required OPERABLE chillers inoperable or not powered as required by Specification 3.23.C. 1, return the inoperable chiller to OPERABLE status within 7 days or comply with Specification 3.10.C. With two of the required OPERABLE chillers inoperable or not powered as required by Specification 3.23.C.1, comply with Specification 3.10.C.

14. Eight air handling units (AHUs) shall be OPERABLE in accordance with the operability requirements of Specification 3.23.C. With two AHUs inoperable on the shutdown unit, ensure that one AHU is OPERABLE in each unit's main control room and emergency switchgear room, and restore an inoperable AHU to OPERABLE status within 7 days, or comply with Specification 3.10.C. With more than two AHUs inoperable, comply with Specification 3.10.C.

B. ~uringirradiated fuel movement in the Fuel Building the following conditions are satis fie-

1. The fuel pit bridge area monitor and the ventilation vent stack 2 particulate and gas monitors shall be OPERABLE and continuously monitored to identify the occurrence of a fuel handling accident.

2.

A spent fuel cask or heavy loads exceeding 110 percent of the weight of a fuel assembly (not including fuel handling tool) shall not be moved over spent fuel, and only one spent fuel assembly will be handled at one time over the reactor or the spent fuel pit.

This restriction does not apply to the movement of the transfer canal door.

Amendment Nos. -5ShaCU

INSERT 2 (TS 3.1 O.A)

11. Two Main Control RoomIEmergency Switchgear Room (MCRIESGR) Emergency Ventilation System (EVS) trains shall be OPERABLE.

a. With one required train inoperable for reasons other than an inoperable MCRIESGR envelope boundary, restore the inoperable train to OPERABLE status within 7 days. If the inoperable train is not returned to OPERABLE status within 7 days, comply with Specification 3.1 0.C.

b. If two required trains are inoperable or one or more required trains are inoperable due to an inoperable MCRIESGR envelope boundary, comply with Specification 3.10.C.

12. Two Main Control Room Bottled Air System trains shall be OPERABLE.

a. With one train inoperable for reasons other than an inoperable MCRIESGR envelope boundary, restore the inoperable train to OPERABLE status within 7 days. If the inoperable train is not returned to OPERABLE status within 7 days, comply with Specification 3.10.C.

b. If two trains are inoperable or one or more trains are inoperable due to an inoperable MCRIESGR envelope boundary, comply with Specification 3.1 0.C.

3. A spent fuel cask shall not be moved into the Fuel Building unless the Cask

-mily with Specification 3.10.C.

6. Three chillers shall be OPERABLE in accordance with the power supply requirements of Specification 3.23.C. With one of the required OPERABLE 1

chillers inoperable or not powered as required by Specification 3 X. C. 1, return the inoperable chiller to OPERABLE status within 7 days or comply with Specification 3.10.C. With two of the required OPERABLE chillers inoperable or not powered as required by Specification 3.23.C. 1, comply with Specification 3.10.C.

7.

Eight air handling units (AHUs) shall be OPERABLE in accordance with the operability requirements of Specification 3.23.C. With two AHUs inoperable on either unit, ensure that one AHU is OPERABLE in each unit's main control room and emergency switchgear room, and restore an inoperable AHU to OPERABLE status within 7 days, or comply with Specification 3.10.C. With more than two comply with Specification 3.10.C.

limiting conditions for refueling is not met, REFUELING fuel movement in the Fuel Building shall cease and in a safe position, work shall be initiated to correct the conditions so that the specified limit is met, and no operations which increase the reactivity of the core shall be made.

R D. After initial fuel loading and after each core refueling operation and prior to reactor operation at greater than 75% of rated power, the movable incore detector system shall be utilized to verify proper power distribution.

E. The requirements of 3.0.1 are not applicable.

Amendment Nos.

INSERT 3 (TS 3.1 O.B)

4.

Two MCRIESGR EVS trains shall be OPERABLE.

a.

With one required train inoperable for reasons other than an inoperable MCRIESGR envelope boundary, restore the inoperable train to OPERABLE status within 7 days. If the inoperable train is not returned to OPERABLE status within 7 days, comply with Specification 3.10.C.

b.

If two required trains are inoperable or one or more required trains are inoperable due to an inoperable MCRIESGR envelope boundary, comply with Specification 3.1 0.C.

5.

Two Main Control Room Bottled Air System trains shall be OPERABLE.

a. With one train inoperable for reasons other than an inoperable MCRIESGR envelope boundary, restore the inoperable train to OPERABLE status within 7 days. If the inoperable train is not returned to OPERABLE status within 7 days, comply with Specification 3.10.C.

b. If two trains are inoperable or one or more trains are inoperable due to an inoperable MCRIESGR envelope boundary, comply with Specification 3.1 0.C.

Detailed instructions, the above specified precautions, and the design of the fuel handling equipment, which incorporates built-in interlocks and safety features, provide assurance that an accident, which would result in a hazard alth and safety, will not occur during unit REFUELING OPERATIONS fuel movement in the Fuel B Building. When no change is being made in core geometry, one neutron detector is \\

sufficient to monitor the core and permits maintenance of the out-of-function instrumentation. Continuous monitoring of radiation levels and neutron flux provides immediate indication of an unsafe condition.

Potential escape paths for fission product radioactivity within containment are required to be closed or capable of closure to prevent the release to the environment. However, since there is no potential for significant containment pressurization during refueling, the Appendix J leakage criteria and tests are not applicable.

The containment equipment access hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of the containment. During REFUELING OPERATIONS, the equipment hatch must be capable of being closed.

The containment airlocks, which are also part of the containment pressure boundary, provide a means for personnel access during periods when CONTAINMENT INTEGRITY is required. Each airlock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening. During periods of unit shutdown when containment closure is not required, the door interlock mechanism may be disabled, allowing both doors to remain open for extended periods when frequent containment entry is necessary. During REFUELING OPERATIONS, containment closure does not have to be maintained, but airlock doors may need to be closed to establish containment closure.

Therefore, the door interlock mechanism may remain disabled, but one airlock door must be capable of being closed.

P Amendment Nos.

Containment penetrations that terminate in the Auxiliary Building or Safeguards and provide direct access from containment atmosphere to outside atmosphere must be isolated or capable of being closed by at least one barrier during REFUELING OPERATIONS. The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated by at least one barrier during REFUELING OPERATIONS. Isolation may be achieved by an OPERABLE isolation valve, a closed valve, a blind flange, or by an equivalent isolation method.

Equivalent isolation methods must be evaluated and may include use of a material that can provide a temporary, atmospheric pressure ventilation barrier.

For the personnel airlock, equipment access hatch, and other penetrations, 'capable of being closed' means the openings are able to be closed; they do not have to be sealed or meet the leakage criteria of TS 4.4. Station procedures exist that ensure in the event of a fuel handling accident, that the open personnel airlock and other penetrations can and will be closed. Closure of the equipment hatch will be accomplished in accordance with station procedures and as allowed by dose rates in containment. The radiological analysis of the fuel handling accident does not take credit for closure of the personnel airlock, equipment access hatch or other penetrations.

The fuel building ventilation exhaust and containment ventilation purge exhaust may be diverted through charcoal filters whenever refueling is in progress. However, there is no requirement for filtration since the Fuel Handling Accident analysis takes no credit for these filters. At least one flow path is required for cooling and mixing the coolant requirements appropriately suspend activities that could that might require isolation of envelope and plac position without delay and operating unit are contained Amendment Nos. 2 t Y h d G A

INSERT 4 (TS 3.1 0 Bases)

During REFUELING OPERATIONS and during the movement of recently irradiated fuel assemblies, the MCRIESGR EVS and the MCR Bottled Air System must be operable to ensure that the MCRIESGR envelope will remain habitable during and following a Design Basis Accident.

Specifically, during REFUELING OPERATIONS and during movement of recently irradiated fuel assemblies, the MCRIESGR EVS and the MCR Bottled Air System must be OPERABLE to respond to the release from a fuel handling accident involving recently irradiated fuel. The MCRIESGR EVS and the MCR Bottled Air System are only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within a time frame established by analysis), due to radioactive decay. The term recently is defined as all irradiated fuel assemblies, until analysis is performed to determine a specific time.

refueling water cavity is filled with approximately 220,000 gal of water borated to at least 2,300 ppm boron. The boron concentration of this water, established by Specification 3.10.A.7, is sufficient to maintain the reactor I

subcritical by at least 5% Aklk in the COLD SHUTDOWN condition with all control rod assemblies inserted. This includes a 1 % Aklk and a 50 ppm boron concentration allowance for uncertainty. This concentration is also sufficient to maintain the core subcritical with no control rod assemblies inserted into the reactor. Checks are performed during the reload design and safety analysis process to ensure the K-effective is equal to or less than 0.95 for each core. Periodic checks of refueling water boron concentration assure the proper shutdown margin. Specification 3.10.A.8 allows the Control Room Operator to inform the I

manipulator operator of any impending unsafe condition detected from the main control board indicators during fuel movement.

In addition to the above safeguards, interlocks are used during refueling to assure safe handling of the fuel assemblies. An excess weight interlock is provided on the lifting hoist to prevent movement of more than one fuel assembly at a time. The spent fuel transfer mechanism can accommodate only one fuel assembly at a time.

Amendment Nos.

INSERT 5 (TS 3.10 Bases) 3.10.A. 1 1 and 12 and 3.1 O.B.4 and 5 When one MCRIESGR EVS or MCR Bottled Air System train is inoperable, for reasons other than an inoperable MCRIESGR envelope boundary, action must be taken to restore OPERABLE status within 7 days. In this condition, the remaining required OPERABLE MCRIESGR EVS or MCR Bottled Air System train is adequate to perform the MCRIESGR envelope occupant protection function. However, the overall reliability is reduced because a failure in the OPERABLE MCRIESGR EVS or MCR Bottled Air System train could result in loss of MCRIESGR EVS or MCR Bottled Air System function. The 7 day Allowed Outage 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.

During REFUELING OPERATIONS or during movement of recently irradiated fuel assemblies, if the required inoperable MCRIESGR EVS or MCR Bottled Air System train cannot be restored to OPERABLE status within the required Allowed Outage Time, or two required MCRIESGR EVS or MCR Bottled Air System trains are inoperable or with one or more required MCRIESGR EVS or MCR Bottled Air System trains inoperable due to an inoperable MCRIESGR envelope boundary, action must be taken to suspend activities that could result in a release of radioactivity that might require isolation of the MCRIESGR envelope. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

Upon each completion of core loading and installation of the reactor vessel head, specific mechanical and electrical tests will be performed prior to initial criticality.

The fuel handling accident has been analyzed based on the methodology outlined in Regulatory Guide 1.183. The analysis assumes 100% release of the gap activity from the assembly with maximum gap activity after a 100-hour decay period following operation at 2605 MWt.

Detailed procedures and checks insure that fuel assemblies are loaded in the proper locations in the core. As an additional check, the movable incore detector system will be used to verify proper power distribution. This system is capable of revealing any assembly enrichment error or loading error which could cause power shapes to be peaked in excess of design value.

References UFSAR Section 5.2 Containment Isolation UFSAR Section 6.3 Consequence Limiting Safeguards UFSAR Section 9.12 Fuel Handling System Section 11.3 Radiation Protection UFSAR Section 13.3 Table 13.3-1 UFSAR Section 14.4.1 Fuel Handling Accidents t \\

FSAR Supplement:

Volume I: Question 3.2 Amendment Nos. %@aml%+

3.19 MAIN CONTROL ROOM BOTTLED AIR SYSTEM Applicability To specify functional requirements for the main control room bottled air system.

Specification A. Requirements adjoining areas of the auxiliary, turbine, and service buildings for one hour. A essure of 0.05 inches of water must be maintained under accident conditions. This capability shall be

1. With one train of the bottled air system inoperabl, restore the inoperable train to rK X

OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or both units shall be placed in OT SHUTDOWN within the same 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

k Amendment Nos. -&G%&XG

INSERT 6 (TS 3.19, replaces existing TS 3.19.B.3)

3. If one or more trains of the bottled air system are inoperable due to an inoperable MCRIESGR envelope boundary, then perform the following:

a. Immediately initiate action to implement mitigating actions;

b. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , verify mitigating actions ensure MCRIESGR envelope occupant exposures to radiological, chemical, and smoke hazards will not exceed limits; and

c. Within 90 days, restore MCRIESGR envelope boundary to OPERABLE status.

If the requirements of Specification

&. l7.2.3 are not met within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after achieving HOT SHUTDOWN, both units shall be placed in COLD SHUTDOWN within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Amendment Nos. 23fhmWW

INSERT 7 (TS 3.19, new TS 3.19.B.5)

5. If the requirements of Specification 3.19.B.3 are not met, both units shall be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

INSERT 8 (TS 3.19 Basis)

The Main Control RoomIEmergency Switchgear Room (MCRIESGR) Emergency Habitability System (EHS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The MCRIESGR EHS consists of the Main Control Room (MCR) Bottled Air System and the MCRIESGR Emergency Ventilation System (EVS) (TS 3.21).

Following a Design Basis Accident (DBA), the containment will be depressurized to 0.5 psig (Unit I),

1.0 psig (Unit 2) in less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and to subatmospheric pressure within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The radiological consequences analysis demonstrates acceptable results provided the containment pressure does not exceed 0.5 psig (Unit 1) and 1.0 psig (Unit 2) for the interval from 1 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following the DBA. Beyond 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , containment pressure is assumed to be less than 0.0 psig, terminating leakage from containment.

The MCRIESGR envelope is maintained at a positive differential pressure using bottled air during the first hour, when the containment leakrate is greatest.

The MCRIESGR envelope is the area within the confines of the MCRIESGR envelope boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the common Main Control Room and the Emergency Switchgear Rooms, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The MCRIESGR envelope is protected during normal operation, natural events, and accident conditions. The MCRIESGR envelope boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the MCRIESGR envelope. The OPERABILITY of the MCRIESGR envelope boundary must be maintained to ensure that the inleakage of unfiltered air into the MCRIESGR envelope will not exceed the inleakage assumed in the licensing basis analysis of DBA consequences to MCRIESGR envelope occupants.

The MCRIESGR envelope and its boundary are defined in the MCRIESGR Envelope Habitability Program (TS 6.4.R).

Upon receipt of the actuating signal(s), normal air supply to and exhaust from the MCRIESGR envelope is isolated, and airflow from the MCR Bottled Air System maintains a positive pressure in the MCRIESGR envelope. Two dampers in series in both the MCRIESGR envelope supply and exhaust ducts close to isolate the MCRIESGR envelope.

Approximately 60 minutes after the actuation of the MCR

Bottled Air System, the MCRIESGR EVS is manually actuated. Each MCRIESGR EVS train provides filtered air from the Turbine Building to the MCRIESGR envelope through HEPA filters and charcoal adsorbers. Prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers.

Pressurization of the MCRIESGR envelope limits infiltration of unfiltered air from the surrounding areas adjacent to the MCRIESGR envelope.

A single train of the MCR Bottled Air System will pressurize the MCRIESGR envelope to 20.05 inches water gauge for at least 60 minutes. The MCRIESGR EHS operation in maintaining the MCRIESGR envelope habitable is discussed in the UFSAR, Section 9.1 3 (Ref. 3).

The MCRIESGR EHS is designed to maintain a habitable environment in the MCRIESGR envelope for 30 days of continuous occupancy after a DBA without exceeding a 5 rem total effective dose equivalent (TEDE).

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

TS 3.1 9.B.3 and 5 If the unfiltered inleakage of potentially contaminated air past the MCRIESGR envelope boundary and into the MCRIESGR envelope can result in MCRIESGR envelope occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of MCRlESGR envelope occupants from hazardous chemicals or smoke, the MCRIESGR envelope boundary is inoperable. Actions must be taken to restore an OPERABLE MCRIESGR envelope boundary within 90 days.

During the period that the MCRIESGR envelope boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on MCRIESGR envelope occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that MCRIESGR envelope occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that MCRIESGR envelope

occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable MCRIESGR envelope boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Allowed Outage Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Allowed Outage Time is reasonable based on the determination that the mitigating actions will ensure protection of MCRIESGR envelope occupants within analyzed limits while limiting the probability that MCRIESGR envelope occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Allowed Outage Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the MCRIESGR envelope boundary.

REFERENCES

1. UFSAR, Section 2.1 Geography, Demography And Potential External Hazards

2. UFSAR, Section 9.1 0 Fire Protection

3. UFSAR, Section 9.1 3 Auxiliary Ventilation Systems

4. UFSAR, Chapter 14 Safety Analysis

5. Letters from B. R. Sylvia (VEPCO) to Harold R. Denton (NRC) dated January 19 and June 30, 1981, Response to Item lll.D.3.4, Control Room Habitability Requirements of NUREG-0737 for Surry Power Station.

6. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors"

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

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694)

INSERT 9 (New TS Section 3.21) 3.21 MAIN CONTROL ROOMIEMERGENCY SWITCHGEAR ROOM (MCRIESGR)

EMERGENCY VENTILATION SYSTEM (EVS)

Applicability The following specifications are applicable whenever either unit is above COLD SHUTDOWN.

0 biective To specify the functional requirements for the MCRIESGR EVS.

Specifications A. Two MCRIESGR EVS trains shall be OPERABLE whenever the unit is above COLD SHUTDOWN.

Note: The MCRIESGR envelope boundary may be opened intermittently under administrative control.

B. If one required MCRIESGR EVS train is inoperable for reasons other than Specification 3.21.C, restore the MCRIESGR EVS train to OPERABLE status within 7 days.

C. If one or more required MCRIESGR EVS trains are inoperable due to an inoperable MCRIESGR envelope boundary, then perform the following:

1. Immediately initiate action to implement mitigating actions.

2. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , verify mitigating actions ensure MCRIESGR envelope occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

3. Within 90 days, restore MCRIESGR envelope boundary to OPERABLE status.

D. If the requirements of Specifications 3.21.B or 3.21.C are not met, the unit shall be placed in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

E. If two required MCRIESGR EVS trains are inoperable for reasons other than TS 3.21.C, the unit shall be placed in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

BACKGROUND - The MCRIESGR Emergency Habitability System (EHS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The MCRIESGR EHS consists of the Main Control Room Bottled Air System (TS 3.19) and the MCRIESGR EVS.

The MCRIESGR EVS consists of four full capacity trains that supply filtered air to the MCRIESGR envelope and a MCRIESGR envelope boundary that limits the inleakage of unfiltered air. Each MCRIESGR EVS train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves, dampers, doors, barriers, and instrumentation also form part of the system. One EVS train is capable of performing the safety function of providing outside filtered air for pressurization. Two independently powered EVS trains are required for independence and redundancy.

The MCRIESGR envelope is the area within the confines of the MCRIESGR envelope boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the common Main Control Room and the Emergency Switchgear Rooms, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The MCRIESGR envelope is protected during normal operation, natural events, and accident conditions. The MCRIESGR envelope boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the MCRIESGR envelope. The OPERABILITY of the MCRIESGR envelope boundary must be maintained to ensure that the inleakage of unfiltered air into the MCRIESGR envelope will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to MCRIESGR envelope occupants. The MCRIESGR envelope and its boundary are defined in the MCRIESGR Envelope Habitability Program (TS 6.4.R).

Upon receipt of the actuating signal(s), normal air supply to and exhaust from the MCRIESGR envelope is isolated, and airflow from the MCR Bottled Air System maintains a positive pressure in the MCRIESGR envelope. Two dampers in series in both the MCRIESGR envelope supply and exhaust ducts close to isolate the MCRIESGR envelope. Approximately 60 minutes after the isolation of the MCRIESGR envelope and actuation of the MCR Bottled Air System, the MCRIESGR EVS is manually actuated. Each MCRIESGR EVS train provides filtered air from the Turbine Building to the MCRIESGR envelope through HEPA filters and charcoal adsorbers.

Prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers.

Pressurization of the MCRIESGR envelope limits infiltration of unfiltered air from the surrounding areas adjacent to the MCRIESGR envelope.

A single train of the MCRIESGR EVS will pressurize the MCRIESGR envelope to about 0.05 inches water gauge relative to external areas adjacent to the MCRIESGR envelope boundary. The MCRIESGR EHS operation in maintaining the MCRIESGR envelope habitable is discussed in the UFSAR, Section 9.13 (Ref. 3).

Redundant MCRIESGR EVS supply trains provide the required pressurization and filtration should one train fail to start or should an excessive pressure drop develop across the operating filter train. 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 MCRIESGR EVS is designed in accordance with Seismic Category I requirements.

The MCRIESGR EHS is designed to maintain a habitable environment in the MCRIESGR envelope for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem total effective dose equivalent (TEDE).

APPLICABLE SAFETY ANALYSES - The MCRIESGR EVS components are arranged in redundant, safety related ventilation trains. The MCRIESGR EHS provides airborne radiological protection for the MCRIESGR envelope occupants, as demonstrated by the MCRIESGR envelope occupant dose analyses for the most limiting design basis accident fission product release presented in the UFSAR, Chapter 14 (Ref. 4).

The MCRIESGR EHS provides protection from smoke and hazardous chemicals to the MCRIESGR envelope occupants.

An evaluation of hazardous chemical releases demonstrates that the toxicity limits for chemicals are not exceeded in the MCRIESGR envelope following a hazardous chemical release (Refs. 1 and 5) or that ample time is available for MCRIESGR envelope occupants to isolate the MCRIESGR envelope. The evaluation of a smoke challenge demonstrates that it will not result in the inability of the MCRIESGR envelope occupants to control the reactor either from the MCR or from the remote shutdown panel (Ref. 2).

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

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

LIMITING CONDITIONS FOR OPERATION (LC01 - Two independent and redundant MCRIESGR EVS trains are required to be OPERABLE to ensure that at least one is available to pressurize and to provide filtered air to the MCRIESGR envelope assuming a single active failure disables one of the two required trains. Due to electrical power considerations, one train must be from the other unit. Total system failure, such as from a loss of both ventilation trains or from an inoperable MCRIESGR envelope boundary, could result in exceeding a dose of 5 rem TEDE to the MCRIESGR envelope occupants in the event of a large radioactive release.

Each MCRIESGR EVS train is considered OPERABLE when the individual components necessary to limit MCRIESGR envelope occupant exposure are OPERABLE in the two required trains of the MCRIESGR EVS, one train of which is from the other unit. A MCRIESGR EVS train is OPERABLE when the associated:

a. Fan is OPERABLE;

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

c. Ductwork, valves, and dampers are OPERABLE, and air flow can be maintained.

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

The LC0 is modified by a Note allowing the MCRIESGR envelope boundary to be opened intermittently under administrative controls. This Note only applies to openings in the MCRIESGR envelope boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area.

For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the MCRIESGR envelope.

This individual will have a method to rapidly close the opening and to restore the MCRIESGR envelope boundary to a condition equivalent to the design condition when a need for MCRIESGR envelope isolation is indicated.

APPLICABILITY - In REACTOR OPERATION conditions above COLD SHUTDOWN, the MCRIESGR EVS must be OPERABLE to ensure that the MCRIESGR envelope will remain habitable during and following a DBA.

ACTIONS When one required MCRIESGR EVS train is inoperable, for reasons other than an inoperable MCRIESGR envelope boundary, action must be taken to restore OPERABLE status within 7 days. In this condition, the remaining required OPERABLE MCRIESGR EVS train is adequate to perform the MCRIESGR envelope occupant protection function. However, the overall reliability is reduced because a failure in the OPERABLE MCRIESGR EVS train could result in loss of MCRIESGR EVS function.

The 7 day Allowed Outage 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.

If the unfiltered inleakage of potentially contaminated air past the MCRIESGR envelope boundary and into the MCRIESGR envelope can result in MCRIESGR envelope occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of MCRIESGR envelope occupants from hazardous chemicals or smoke, the MCRIESGR envelope boundary is inoperable. Actions must be taken to restore an OPERABLE MCRIESGR envelope boundary within 90 days.

During the period that the MCRIESGR envelope boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on MCRIESGR envelope occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that MCRIESGR envelope occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that MCRIESGR envelope occupants are protected from hazardous chemicals and smoke.

These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable MCRIESGR envelope boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Allowed Outage Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Allowed Outage Time is reasonable based on the determination that the mitigating actions will ensure protection of MCRIESGR envelope occupants within analyzed limits while limiting the probability that MCRIESGR envelope occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Allowed Outage Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the MCRIESGR envelope boundary.

In REACTOR OPERATION conditions above COLD SHUTDOWN, if the inoperable MCRIESGR EVS train or the MCRIESGR envelope boundary cannot be restored to OPERABLE status within the Allowed Outage Time, the unit must be placed in a REACTOR OPERATION condition that minimizes accident risk. To achieve this status, the unit must be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-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.

If both MCRIESGR EVS trains are inoperable in REACTOR OPERATION conditions above COLD SHUTDOWN for reasons other than an inoperable MCRIESGR envelope boundary (i.e., TS 3.21.C), the MCRIESGR EVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses.

Therefore, the unit must be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

REFERENCES

1. UFSAR, Section 2.1 Geography, Demography and Potential External Hazards

2. UFSAR, Section 9.1 0 Fire Protection

3. UFSAR, Section 9.13 Auxiliary Ventilation Systems

4. UFSAR, Chapter 14 Safety Analysis

5. Letters from B. R. Sylvia (VEPCO) to Harold R. Denton (NRC) dated January 19 and June 30, 1981, Response to Item lll.D.3.4, Control Room Habitability Requirements of NUREG-0737 for Surry Power Station

6. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors"

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

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability" (ADAMS Accession No. ML040300694)

3.23 MAIN CONTROL ROOM AND EMERGENCY SWITCHGEAR ROOM FLC~TTTT-AIR CONDITIONING SYSTEM$

Applicability Applies to the Main Control Room (MCR) and Emergency Switchgear Room (ESGR) Air Conditioning System Objective To specify requirements to ensure the proper function of the Main Control Room and Emergency Switchgear Room Air Conditioning System Specification w -

w m

h trains of the Main ContrcJ,Room and Emergency Switchgear Room Emergency Ventilation System s e OPERABLE whene ither unit is above COLD

(

B. With o rain of the Main Co 01 Room and Emerge Room)

Em ency Ventilation Syste noperable for any reaso, eturn the inoperable train an OPERABLE status thin 7 days or be in t HOT SHUTDOWN within the hours and in COLD SHUTDOWN within the followi

=

The Main Control Room and Emergency Switchgear Room Air Conditioning System shall be OPERABLE as delineated in the following:

1. Chiller Refrigeration Units

'ip

a. Three main control room and emergency switchgear room chillers must be OPERABLE whenever either unit is above COLD SHUTDOWN.

2

b. The three OPERABLE chillers are required to be powered from three of the four emergency buses with one of those chillers capable of being powered from the fourth emergency bus.

c. If one of the OPERABLE inoperable or is not powered as required by an inoperable chiller to bring both units to HOT in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

or are not powered as inoperable chiller to both units to HOT w i t h the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN Amendment Nos. %~MAZJ.

2. If two Unit 2 AHUs on different chilled water loops and in different air conditioning zones (2-VS-AC-7 and 2-VS-AC-8 or 2-VS-AC-6 and 2-VS-AC-9) become inoperable, restore operability of the two inoperable AHUs within seven (7) days or bring Unit 2 to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the following 3 0 hours0 days 0 hours 0 weeks 0 months .

3. If two Unit 2 AHUs in the same air conditioning zone (2-VS-AC-8 and 2-VS-AC-9 or 2-VS-AC-6 and 2-VS-AC-7) become inoperable, restore operability of at least one Unit 2 AHU in each air conditioning zone (2-VS-AC-8 or 2-VS-AC-9 and 2-VS-AC-6 or 2-VS-AC-7) within one (1) hour or bring Unit 2 to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

4. If more than two Unit 2 AHUs become inoperable, restore operability of at least one Unit 2 AHU in each air conditioning zone (2-VS-AC-8 or 2-VS-AC-9 and 2-VS-AC-6 or 2-VS-AC-7) within one (I) hour or bring Unit 2 to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. Both Unit 1 AHUs or both Unit 2 AHUs powered from the respective H buses (1-VS-AC-1 and 1-VS-AC-7 or 2-VS-AC-6 and 2-VS-AC-8) must be OPERABLE whenever both units are above COLD SHUTDOWN.

1. If one or two AHUs on each unit powered from an H bus is inoperable, restore operability of the inoperable AHU(s) on one unit within one (1) hour or bring both units to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

ergency Ventilation System is manually ositive pressure so I

~i~h,c?ffficienc~

particuladr (HEPA) filters are installed before the charcoal adsorbers to

\\ preJ=$ent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce /

the potential intake of radio-iodine to the control room.

Amendment Nos. 4EGhd%%

envelope. From an ACS perspective, the envelope consists of four zones: 1) the Unit 1 side ' D of the control room (including the Unit 1 air conditioning equipment and computer rooms), 2) the Unit 2 side of the control room (including the annex area, the Unit 2 air conditioning equipment and computer rooms), 3) the Unit 1 ESGR and relay room (referred to as the Unit 1 ESGR), and 4) the Unit 2 ESGR and relay room (including MER-3), referr

. The design basis of the MCR and ESGR ACS is to maintain the nvelope temperature within the equipment design limits for 30 da cy after a design basis accident (DBA). The ACS includes five chillers (1-VS-E-4A, 4B, 4C, 4D, and 4E). Chillers 4A, 4B, and 4C are located in MER-3, in the Unit 2 ESGR. Chillers 4D and 4E are located in MER-5, in the Unit 2 Turbine Building. The chillers supply chilled water to eight air handling units (AHUs), arranged in two independent and redundant chilled water loops. Each chilled water loop provides redundant 100% heat removal capacity per unit. Each loop contains four AHUs (one AHU in each unit's air conditioning zones), the necessary power supplies, the associated valves, piping (from the supply header to return header), instrumentation, and controls. Each AHU has 100% capacity for cooling its zone.

The combination of five chillers and two chilled water loops affords considerable flexibility in meeting the cooling requirements. Two chillers are powered from single emergency buses (1-VS-E-4C from 2H, 1-VS-E-4E from 1H). The remaining three chillers can be powered from either of two emergency buses (1-VS-E-4A from IJ or 25, 1-VS-E-4B from 1J or 2H, and 1-VS-E-4D from 1H or 25). The AHUs are powered from the four emergency buses in pairs. For example, the Unit 1 MCR and ESGR AHUs 1-VS-AC-1 and 1-VS-AC-7 are powered from the 1H bus; the redundant Unit 1 MCR and ESGR AHUs 1-VS-AC-2 and 1-VS-AC-6 are powered from the 1J bus. Control of the ACS is by manual action.

The chillers are procedurally aligned by power supply to meet AHU pairs are normally aligned to match the power supplies of For example, chiller 1-VS-E-4E and AHUs 1-VS-AC-I and the 1H emergency bus. However, due to the number of emergency diesel generators (EDGs) and the chiller1AHU piping layout, only one chiller and AHU pair can be powered from each emergency bus at a time. Also, if chilled water is needed in both chilled water loops, two chillers must be operated. Only one chiller can be operated on each chilled water loop at a time, and the 4D and 4E chillers cannot be operated simultaneously. The combinations of OPERABLE chillers1AHUs allowed by procedure ensure that sufficient cooling capacity is available during a DBA with a coincident loss of offsite power (LOOP) and single failure of an EDG, a chiller, or an AHU.

Amendment Nos. -

INSERT 10 (New TS Section 4.18) 4.18 MAIN CONTROL ROOMIEMERGENCY SWITCHGEAR ROOM (MCRIESGR)

EMERGENCY VENTILATION SYSTEM (EVS) TESTING A. Operate each MCRIESGR EVS train for 215 minutes once every 31 days.

B. Perform required Control Room Air Filtration System Testing in accordance with TS 4.20.

C. Perform required MCRIESGR envelope unfiltered air inleakage testing in accordance with the MCRIESGR Envelope Habitability Program.

BASES SURVEILLANCE REQUIREMENTS (SR)

Standby systems should be checked periodically to ensure that they function properly.

As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system.

Systems without heaters need only be operated for 215 minutes to demonstrate the function of the system.

The 31 day frequency is based on the reliability of the equipment and the two train redundancy. Operation of the MCRIESGR EVS trains shall be initiated manually from the MCR.

This SR verifies that the required Control Room Air Filtration System testing is performed in accordance with Specification 4.20. Specification 4.20 includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test frequencies and additional information are discussed in detail in TS 4.20.

This SR verifies the OPERABILITY of the MCRIESGR envelope boundary by testing for unfiltered air inleakage past the MCRIESGR envelope boundary and into the MCRIESGR envelope. The details of the testing are specified in the MCRIESGR Envelope Habitability Program (TS 6.4.R).

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

This SR verifies that the

unfiltered air inleakage into the MCRIESGR envelope is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Specification 3.21.C must be entered.

Specification 3.21.C.3 allows time to restore the MCRIESGR envelope boundary to OPERABLE status provided mitigating actions can ensure that the MCRIESGR envelope remains within the licensing basis habitability limits for the occupants following an accident.

Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 1) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 2). These compensatory measures may also be used as mitigating actions as required by Specification 3.21.C.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 3). Options for restoring the MCRIESGR envelope boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the MCRIESGR envelope boundary, or a combination of these actions.

Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the MCRIESGR envelope boundary has been restored to OPERABLE status.

REFERENCES

1. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors"

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

3. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability" (ADAMS Accession No. ML040300694)

8. The procedure for iodine removal efficiency tests shall follow ASTM D3803. The test conditions shall be in accordance with those listed in Specification 4.20.B.4.

9. The pressure drop across the HEPA filter and adsorber banks shall be checked:

a. Initially;

b. Once per 18 months; and 7

c. After each complete or partial replacement of filters or adsorbers.

B. Acceptance Criteria

1. Fan flow tube test shall show a flow rate through any single filter train of 1000

1 0 percent cfrn.

2. In-place cold DOP tests on HEPA filters shall show greater than or equal to 99.5 percent DOP removal. Leaking sources shall be identified, repaired and retested. Any HEPA filter found defective shall be replaced.

3. In-place halogenated hydrocarbon leakage tests on charcoal adsorber banks shall show greater than or equal to 99 percent h'alogenated hydrocarbon removal.

Leakage sources shall be identified, repaired and retested.

Amendment Nos. +Ehd+Ek

4. Laboratory analysis on new charcoal adsorbent shall show the methyl iodide penetration less than or equal to 14 percent, when tested in accordance with ASTM D3803-1989 (with the exception of face velocity which is to be at 24.4 Mlmin), with the relative humidity equal to 95 percent, and the temperature equal to 30°C (86°F).

5. The pressure drop across filter cells and adsorbers shall not exceed 5.0 inches W. G. at design flow rate. If this condition cannot be met, new filter cells shall be installed.

Basis Ventilation system filter components are not subject to rapid deterioration, having lifetimes of many years. The tests outlined above provide assurance of filter reliability and will ensure timely detection of conditions which could cause filter degradation.

A pressure drop across the combined HEPA filters and charcoal adsorbers of less than 5 inches of water will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter. 3 Amendment Nos.

c. The operational LEAKAGE performance criterion is specified in TS 3.1.C,

and 4.13, "RCS Operational LEAKAGE."

3. Provisions for SG tube repair criteria. Tubes found by insemice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thichess shall be plugged.

4. Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy the applicable tube repair criteria. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of 4.a, 4.b, and 4.c below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. An assessment of degradation shall be performed to determine the type and location of flaws to i which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.

a. Inspect 100% of the tubes in each SG during the first refueling outage following SG replacement.

i

b. Inspect 100% of the tubes at sequential periods of 120, 90, and, thereafter, 60 effective full power months. The first sequential period shall be considered to begin after the first inservice inspection of the SGs. In addition, inspect 50% of 1

the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outage nearest the end of the period. No SG shall operate for more than 48 effective full power months or two refueling outages (whichever is less) without being inspected.

c. If crack indications are found in any SG tube, then the next inspection for each SG for the degradation mechanism that caused the crack indication shall not (

exceed 24 effective full power months or one refueling outage (whichever is less). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a (

crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

5. Provisions for monitoring operational primary to secondary LEAKAGE.

Amendment Nos. e.

INSERT 11 (New TS Program 6.4.R)

R.

Main Control RoomIEmergencv Switchgear Room (MCRIESGR) Envelope Habitabilitv Program A Main Control RoomIEmergency Switchgear Room (MCRIESGR) Envelope Habitability Program shall be established and implemented to ensure that MCRIESGR envelope habitability is maintained such that, with an OPERABLE Emergency Habitability System [i.e., the MCRIESGR Emergency Ventilation System (EVS) and the Main Control Room Bottled Air System], MCRIESGR envelope occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the MCRIESGR envelope under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

1.

The definition of the MCRIESGR envelope and the MCRIESGR envelope boundary.

2.

Requirements for maintaining the MCRIESGR envelope boundary in its design condition including configuration control and preventive maintenance.

3.

Requirements for (a) determining the unfiltered air inleakage past the MCRIESGR envelope boundary into the MCRIESGR envelope in accordance with the testing methods and at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (b) assessing MCRIESGR envelope habitability at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1. I 97, Revision 0.

The following is an exception to Sections C.l and C.2 of Regulatory Guide 1.197, Revision 0:

2.C. 1 Licensing Bases - Vulnerability assessments for radiological, hazardous chemical and smoke, and emergency ventilation system testing were completed as documented in the UFSAR.

The exceptions to the Regulatory Guides (RGs) referenced in RG 1.196 (i.e., RG 1.52, RG 1.78 and RG 1.183), which were considered in completing the vulnerability assessments, are documented in the UFSARIcurrent licensing basis.

Compliance with these RGs is consistent with the current licensing basis as described in the UFSAR.

4.

Measurement, at designated locations, of the MCRIESGR envelope pressure relative to all external areas adjacent to the MCRIESGR envelope boundary during the pressurization mode of operation by one train of the MCRIESGR EVS, operating at the flow rate required by TS 4.20, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the assessment of the MCRIESGR envelope boundary.

5.

The quantitative limits on unfiltered air inleakage into the MCRIESGR envelope. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph

3.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of MCRIESGR envelope occupants to these hazards will be within the assumptions in the licensing basis.

6.

The provisions of SR 4.0.2 are applicable to the Frequencies for assessing MCRIESGR envelope habitability, determining MCRIESGR envelope unfiltered inleakage, and measuring MCRIESGR envelope pressure and assessing the MCRIESGR envelope boundary as required by paragraphs 3 and 4, respectively.

Serial No. 07-0488 Docket Nos. 50-280 and 281 ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATIONS PAGES (TYPED)

Virginia Electric and Power Company (Dominion)

Surry Power Station Units 1 and 2

(2) The Updated Final Safety Analysis Report supplement as revised on July 25, October I, November 4, and December 2,2002, shall be included in the next scheduled update to the licensee's Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59, and otherwise complies with the requirements in that section.

Q. As discussed in the footnote to Technical Specifications 3.23.C.2.a.l and 3.23.C.2.b.1, the use of temporary 45-day and 14-day allowed outage times to permit replacement of the Main Control Room and Emergency Switchgear Room Air Conditioning System chilled water piping shall be in accordance with the basis, risk evaluation, equipment unavailability restrictions, and compensatory actions provided in the licensee's submittal dated February 26, 2007 (Serial No. 07-0109).

R. Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of Main Control RoomlEmergency Switchgear Room (MCRIESGR) envelope unfiltered air inleakage as required by TS SR 4.18 in accordance with TS 6.4.R.3.a, the assessment of MCRIESGR envelope habitability as required by Specification 6.4.R.3.b, and the measurement of MCRlESGR envelope pressure as required by Specification 6.4.R.4, shall be considered met. Following implementation:

(1) The first performance of SR 4.18, in accordance with Specification 6.4.R.3.a, shall be within the specified frequency of 6 years plus the 18-month allowance of SR 4.0.2, as measured from January 18, 2004, the date of the most recent successful tracer gas test, as stated in the April 22, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(2) The first performance of the periodic assessment of MCRIESGR envelope habitability, Specification 6.4.R.3.b, shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from January 18, 2004, the date of the most recent successful tracer gas test, as stated in the April 22, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(3) The first performance of the periodic measurement of MCRIESGR envelope pressure, Specification 6.4.R.4, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from January 10,2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

SURRY - UNIT 1

4. This renewed license is effective as of the date of issuance, and shall expire at midnight on May 25, 2032.

FOR THE NUCLEAR REGULATORY COMMISSION Samuel J. Collins, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A, Technical Specifications Date of Issuance: March 20, 2003 SURRY - UNIT I

P. Updated Final Safety Analysis Report

1) The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d), as revised on July 25, 2002, October 1, 2002, November 4, 2002, and December 2, 2002 describes certain future inspection activities to be completed before the period of extended operation. The licensee shall complete these activities no later than January 29, 2013, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

(2) The Updated Final Safety Analysis Report supplement as revised on July 25, 2002, October 1,2002, November 4,2002, and December 2,2002, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

Q. As discussed in the footnote to Technical Specifications 3.23.C.2.a.l and 3.23.C.2.b.1, the use of temporary 45-day and 14-day allowed outage times to permit replacement of the Main Control Room and Emergency Switchgear Room Air Conditioning System chilled water piping shall be in accordance with the basis, risk evaluation, equipment unavailability restrictions, and compensatory actions provided in the licensee's submittal dated February 26, 2007 (Serial No. 07-01 09).

R. Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of Main Control RoomIEmergency Switchgear Room (MCRIESGR) envelope unfiltered air inleakage as required by TS SR 4.18 in accordance with TS 6.4.R.3.a, the assessment of MCRIESGR envelope habitability as required by Specification 6.4.R.3.b, and the measurement of MCRIESGR envelope pressure as required by Specification 6.4.R.4, shall be considered met. Following implementation:

(1) The first performance of SR 4.18, in accordance with Specification 6.4.R.3.a, shall be within the specified frequency of 6 years plus the 18-month allowance of SR 4.0.2, as measured from January 18, 2004, the date of the most recent successful tracer gas test, as stated in the April 22, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(2) The first performance of the periodic assessment of MCRIESGR envelope habitability, Specification 6.4.R.3.b, shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from January 18, 2004, the date of the most recent successful tracer gas test, as stated in the April 22, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

SURRY - UNIT 2

(3) The first performance of the periodic measurement of MCRIESGR envelope pressure, Specification 6.4.R.4, shall be within 18 months, plus the I38 days allowed by SR 4.0.2, as measured from January 19, 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

4. This renewed license is effective as of the date of issuance, and shall expire at midnight on January 29, 2033.

FOR THE NUCLEAR REGULATORY COMMISSION Samuel J. Collins, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A, Technical Specifications Date of Issuance: March 20, 2003 SURRY - UNIT 2

TECHNICAL SPECIFICATION TABLE OF CONTENTS SECTION 3.15 3.16 3.17 3.18 3.19 3.20 3.2 1 3.22 3.23 TITLE DELETED EMERGENCY POWER SYSTEM LOOP STOP VALVE OPERATION MOVABLE INCORE INSTRUMENTATION MAIN CONTROL ROOM BOTTLED AIR SYSTEM SHOCK SUPPRESSORS (SNUBBERS)

MAIN CONTROL ROOMIEMERGENCY SWITCHGEAR ROOM (MCRIESGR) EMERGENCY VENTILATION SYSTEM (EVS)

AUXILIARY VENTILATION EXHAUST FILTER TRAINS PAGE TS 3.16-1 TS 3.17-1 TS 3.18-1 TS 3.19-1 TS 3.20-1 TS 3.21-1 TS 3.22-1 MAIN CONTROL ROOM AND EMERGENCY SWITCHGEAR ROOM TS 3.23-1 AIR CONDITIONING SYSTEM 4.0 SURVEILLANCE REQUIREMENTS TS 4.0-1 OPERATIONAL SAFETY REVIEW TS 4.1-1 AUGMENTED INSPECTIONS TS 4.2-1 DELETED CONTAINMENT TESTS TS 4.4-1 SPRAY SYSTEMS TESTS TS 4.5-1 EMERGENCY POWER SYSTEM PERIODIC TESTING TS 4.6-1 MAIN STEAM LINE TRIP VALVES TS 4.7-1 AUXILIARY FEEDWATER SYSTEM TS 4.8-1 RADIOACTIVE GAS STORAGE MONITORING SYSTEM TS 4.9-1 REACTIVITY ANOMALIES TS 4.10-1 SAFETY INJECTION SYSTEM TESTS TS 4.1 1-1 VENTILATION FILTER TESTS TS 4.12-1 RCS OPERATIONAL LEAKAGE TS 4.13-1 DELETED Amendment Nos.

TS iii TECHNICAL SPECIFICATION TABLE OF CONTENTS SECTION 4.15 4.16 4.17 4.18 4.19 4.20 TITLE AUGMENTED INSERVICE INSPECTION PROGRAM FOR HIGH ENERGY LINES OUTSIDE OF CONTAINMENT LEAKAGE TESTING OF MISCELLANEOUS RADIOACTIVE MATERIALS SOURCES SHOCK SUPPRESSORS (SNUBBERS)

MAIN CONTROL ROOMIEMERGENCY SWITCHGEAR ROOM (MCRIESGR) EMERGENCY VENTILATION SYSTEM (EVS) TESTING STEAM GENERATOR (SG) TUBE INTEGRITY CONTROL ROOM AIR FILTRATION SYSTEM 5.0 DESIGN FEATURES 5.1 SITE 5.2 CONTAINMENT 5.3 REACTOR 5.4 FUEL STORAGE 6.0 ADMINISTRATIVE CONTROLS 6.1 ORGANIZATION, SAFETY AND OPERATION REVIEW 6.2 GENERAL NOTIFICATION AND REPORTING REQUIREMENTS 6.3 ACTION TO BE TAKEN IF A SAFETY LIMIT IS EXCEEDED 6.4 UNIT OPERATING PROCEDURES AND PROGRAMS 6.5 STATION OPERATING RECORDS 6.6 STATION REPORTING REQUIREMENTS 6.7 ENVIRONMENTAL QUALIFICATIONS 6.8 PROCESS CONTROL PROGRAM AND OFFSITE DOSE CALCULATION MANUAL PAGE TS 4.15-1 TS 4.16-1 TS 4.17-1 TS 4.18-1 TS 4.19-1 TS 4.20-1 TS 5.1-1 TS 5.1-1 TS 5.2-1 TS 5.3-1 TS 5.4-1 TS 6.1-1 TS 6.1-1 TS 6.2-1 TS 6.3-1 TS 6.4-1 TS 6.5-1 TS 6.6-1 TS 6.7-1 TS 6.8-1 Amendment Nos.

3.10 REFUELING Applicability Applies to operating limitations during REFUELING OPERATIONS or recently I

irradiated fuel movement in the Fuel Building.

Objective To assure that no accident could occur during REFUELING OPERATIONS or recently I

irradiated fuel movement in the Fuel Building that would affect public health and safety.

Specification A. During REFUELING OPERATIONS the following conditions are satisfied:

1. The equipment access hatch and at least one door in the personnel airlock shall be capable of being closed. For those penetrations which provide a direct path from containment atmosphere to the outside atmosphere, the containment isolation valves shall be OPERABLE or the penetration shall be closed by a valve, blind flange, or equivalent or the penetration shall be capable of being closed.

Amendment Nos.

10. A spent fuel cask or heavy loads exceeding 110 percent of the weight of a fuel assembly (not including fuel handling tool) shall not be moved over spent fuel, and only one spent fuel assembly will be handled at one time over the reactor or the spent fuel pit.

This restriction does not apply to the movement of the transfer canal door.

11. Two Main Control RoornIEmergency Switchgear Room (MCRIESGR)

Emergency Ventilation System (EVS) trains shall be OPERABLE.

a.

With one required train inoperable for reasons other than an inoperable MCWESGR envelope boundary, restore the inoperable train to OPERABLE status within 7 days. If the inoperable train is not returned to OPERABLE status within 7 days, comply with Specification 3.10.C.

b.

If two required trains are inoperable or one or more required trains are inoperable due to an inoperable MCRIESGR envelope boundary, comply with Specification 3.10.C.

12. Two Main Control Room Bottled Air System trains shall be OPERABLE.

a.

With one train inoperable for reasons other than an inoperable MCRIESGR envelope boundary, restore the inoperable train to OPERABLE status within 7 days. If the inoperable train is not returned to OPERABLE status within 7 days, comply with Specification 3.10.C.

b.

If two trains are inoperable or one or more trains are inoperable due to an inoperable MCWESGR envelope boundary, comply with Specification 3.10.C.

13. Three chillers shall be OPERABLE in accordance with the power supply requirements of Specification 3.23.C. With one of the required OPERABLE chillers inoperable or not powered as required by Specification 3.23.C. 1, return the inoperable chiller to OPERABLE status within 7 days or comply with Specification 3.10.C. With two of the required OPERABLE chillers inoperable or not powered as required by Specification 3.23.C.1, comply with Specification 3.10.C.

14. Eight air handling units (AHUs) shall be OPERABLE in accordance with the operability requirements of Specification 3.23.C. With two AHUs inoperable on the shutdown unit, ensure that one AHU is OPERABLE in each unit's main control room and emergency switchgear room, and restore an inoperable AHU to OPERABLE status within 7 days, or comply with Specification 3.10.C. With more than two AHUs inoperable, comply with Specification 3.10.C.

Amendment Nos.

B. During recently irradiated fuel movement in the Fuel Building the following conditions are satisfied:

1. The fuel pit bridge area monitor and the ventilation vent stack 2 particulate and gas monitors shall be OPERABLE and continuously monitored to identify the occurrence of a fuel handling accident.

2. A spent fuel cask or heavy loads exceeding 110 percent of the weight of a fuel assembly (not including fuel handling tool) shall not be moved over spent fuel, and only one spent fuel assembly will be handled at one time over the reactor or the spent fuel pit.

This restriction does not apply to the movement of the transfer canal door.

3. A spent fuel cask shall not be moved into the Fuel Building unless the Cask Impact Pads are in place on the bottom of the spent fuel pool.

4.

Two MCWESGR EVS trains shall be OPERABLE.

a.

With one required train inoperable for reasons other than an inoperable MCWESGR envelope boundary, restore the inoperable train to OPERABLE status within 7 days. If the inoperable train is not returned to OPERABLE status within 7 days, comply with Specification 3.10.C.

b.

If two required trains are inoperable or one or more required trains are inoperable due to an inoperable MCWESGR envelope boundary, comply with Specification 3.10.C.

5. Two Main Control Room Bottled Air System trains shall be OPERABLE.

a.

With one train inoperable for reasons other than an inoperable MCWESGR envelope boundary, restore the inoperable train to OPERABLE status within 7 days. If the inoperable train is not returned to OPERABLE status within 7 days, comply with Specification 3.10.C.

b. If two trains are inoperable or one or more trains are inoperable due to an inoperable MCWESGR envelope boundary, comply with Specification 3.10.C.

6. Three chillers shall be OPERABLE in accordance with the power supply requirements of Specification 3.23.C. With one of the required OPERABLE chillers inoperable or not powered as required by Specification 3.23.C. 1, return the inoperable chiller to OPERABLE status within 7 days or comply with Specification 3.10.C. With two of the required OPERABLE chillers inoperable or not powered as required by Specification 3.23.C. 1, comply with Specification 3.10.C.

Amendment Nos.

7. Eight air handling units (AHUs) shall be OPERABLE in accordance with the operability requirements of Specification 3.23.C. With two AHUs inoperable on either unit, ensure that one AHU is OPERABLE in each unit's main control room and emergency switchgear room, and restore an inoperable AHU to OPERABLE status within 7 days, or comply with Specification 3.10.C. With more than two AHUs inoperable on a unit, comply with Specification 3.10.C.

C. If any one of the specified limiting conditions for refueling is not met, REFUELING OPERATIONS or recently irradiated fuel movement in the Fuel Building shall cease and recently irradiated fuel shall be placed in a safe position, work shall be initiated to correct the conditions so that the specified limit is met, and no operations which increase the reactivity of the core shall be made.

D. After initial fuel loading and after each core refueling operation and prior to reactor operation at greater than 75% of rated power, the movable incore detector system shall be utilized to verify proper power distribution.

E. The requirements of 3.0.1 are not applicable.

Detailed instructions, the above specified precautions, and the design of the fuel handling equipment, which incorporates built-in interlocks and safety features, provide assurance that an accident, which would result in a hazard to public health and safety, will not occur during unit REFUELING OPERATIONS or recently irradiated fuel movement in the Fuel I

Building. When no change is being made in core geometry, one neutron detector is sufficient to monitor the core and permits maintenance of the out-of-function instrumentation. Continuous monitoring of radiation levels and neutron flux provides immediate indication of an unsafe condition.

Potential escape paths for fission product radioactivity within containment are required to be closed or capable of closure to prevent the release to the environment. However, since there is no potential for significant containment pressurization during refueling, the Appendix J leakage criteria and tests are not applicable.

The containment equipment access hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of the containment. During REFUELING OPERATIONS, the equipment hatch must be capable of being closed.

Amendment Nos.

The containment airlocks, which are also part of the containment pressure boundary, provide a means for personnel access during periods when CONTAINMENT INTEGRITY is required. Each airlock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening. During periods of unit shutdown when containment closure is not required, the door interlock mechanism may be disabled, allowing both doors to remain open for extended periods when frequent containment entry is necessary. During REFUELING OPERATIONS, containment closure does not have to be maintained, but airlock doors may need to be closed to establish containment closure.

Therefore, the door interlock mechanism may remain disabled, but one airlock door must be capable of being closed.

Containment penetrations that terminate in the Auxiliary Building or Safeguards and provide direct access from containment atmosphere to outside atmosphere must be isolated or capable of being closed by at least one barrier during REFUELING OPERATIONS. The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated by at least one barrier during REFUELING OPERATIONS. Isolation may be achieved by an OPERABLE isolation valve, a closed valve, a blind flange, or by an equivalent isolation method.

Equivalent isolation methods must be evaluated and may include use of a material that can provide a temporary, atmospheric pressure ventilation barrier.

For the personnel airlock, equipment access hatch, and other penetrations, 'capable of being closed' means the openings are able to be closed; they do not have to be sealed or meet the leakage criteria of TS 4.4. Station procedures exist that ensure in the event of a fuel handling accident, that the open personnel airlock and other penetrations can and will be closed. Closure of the equipment hatch will be accomplished in accordance with station procedures and as allowed by dose rates in containment. The radiological analysis of the fuel handling accident does not take credit for closure of the personnel airlock, equipment access hatch or other penetrations.

The fuel building ventilation exhaust and containment ventilation purge exhaust may be diverted through charcoal filters whenever refueling is in progress. However, there is no requirement for filtration since the Fuel Handling Accident analysis takes no credit for these filters. At least one flow path is required for cooling and mixing the coolant contained in the reactor vessel so as to maintain a uniform boron concentration and to remove residual heat.

Amendment Nos.

The requirements in this specification for the Main Control RoomIEmergency Switchgear Room (MCWESGR) Emergency Ventilation System (EVS), Main Control Room (MCR)

Bottled Air System, and the MCR and ESGR Air Conditioning System (chillers and air handling units) apply to the shutdown unit. If any of the specified limiting conditions is not met, the requirements appropriately suspend activities that could result in a release of radioactivity that might require isolation of the MCWESGR envelope and place recently irradiated fuel in a safe position without delay and in a controlled manner. The requirements applicable to the operating unit are contained in Specifications 3.19, 3.21, and 3.23.

During REFUELING OPERATIONS and during the movement of recently irradiated fuel assemblies, the MCWESGR EVS and the MCR Bottled Air System must be operable to ensure that the MCWESGR envelope will remain habitable during and following a Design Basis Accident.

Specifically, during REFUELING OPERATIONS and during movement of recently irradiated fuel assemblies, the MCWESGR EVS and the MCR Bottled Air System must be OPERABLE to respond to the release from a fuel handling accident involving recently irradiated fuel. The MCRIESGR EVS and the MCR Bottled Air System are only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e.,

fuel that has occupied part of a critical reactor core within a time frame established by analysis), due to radioactive decay. The term recently is defined as all irradiated fuel assemblies, until analysis is performed to determine a specific time.

3.10.A.7 and 8 During refueling, the reactor refueling water cavity is filled with approximately 220,000 gal of water borated to at least 2,300 ppm boron. The boron concentration of this water, established by Specification 3.10.A.7, is sufficient to maintain the reactor subcritical by at least 5% Aklk in the COLD SHUTDOWN condition with all control rod assemblies inserted. This includes a 1% Ak/k and a 50 ppm boron concentration allowance for uncertainty. This concentration is also sufficient to maintain the core subcritical with no control rod assemblies inserted into the reactor. Checks are performed during the reload design and safety analysis process to ensure the K-effective is equal to or less than 0.95 for each core. Periodic checks of refbeling water boron concentration assure the proper shutdown margin. Specification 3.10.A.8 allows the Control Room Operator to inform the manipulator operator of any impending unsafe condition detected from the main control board indicators during fuel movement.

Amendment Nos.

3.10.A.11 and 12 and 3.10.B.4 and 5 When one MCWESGR EVS or MCR Bottled Air System train is inoperable, for reasons other than an inoperable MCWESGR envelope boundary, action must be taken to restore OPERABLE status within 7 days. In this condition, the remaining required OPERABLE MCRIESGR EVS or MCR Bottled Air System train is adequate to perform the MCRIESGR envelope occupant protection function. However, the overall reliability is reduced because a failure in the OPERABLE MCRIESGR EVS or MCR Bottled Air System train could result in loss of MCRIESGR EVS or MCR Bottled Air System function. The 7 day Allowed Outage 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.

During REFUELING OPERATIONS or during movement of recently irradiated fuel assemblies, if the required inoperable MCRIESGR EVS or MCR Bottled Air System train cannot be restored to OPERABLE status within the required Allowed Outage Time, or two required MCWESGR EVS or MCR Bottled Air System trains are inoperable or with one or more required MCWESGR EVS or MCR Bottled Air System trains inoperable due to an inoperable MCRIESGR envelope boundary, action must be taken to suspend activities that could result in a release of radioactivity that might require isolation of the MCWESGR envelope. This places the unit in a condition that minimizes the accident risk.

This does not preclude the movement of fuel to a safe position.

In addition to the above safeguards, interlocks are used during refueling to assure safe handling of the he1 assemblies. An excess weight interlock is provided on the lifting hoist to prevent movement of more than one fuel assembly at a time. The spent fuel transfer mechanism can accommodate only one fuel assembly at a time.

Upon each completion of core loading and installation of the reactor vessel head, specific mechanical and electrical tests will be performed prior to initial criticality.

The fuel handling accident has been analyzed based on the methodology outlined in Regulatory Guide 1.183. The analysis assumes 100% release of the gap activity from the assembly with maximum gap activity after a 100-hour decay period following operation at 2605 MWt.

Detailed procedures and checks insure that fuel assemblies are loaded in the proper locations in the core. As an additional check, the movable incore detector system will be used to verify proper power distribution. This system is capable of revealing any assembly enrichment error or loading error which could cause power shapes to be peaked in excess of design value.

Amendment Nos.

References UFSAR Section 5.2 UFSAR Section 6.3 UFSAR Section 9.12 UFSAR Section 9.13 UFSAR Section 1 1.3 UFSAR Section 13.3 UFSAR Section 14.4.1 FSAR Supplement:

Containment Isolation Consequence Limiting Safeguards Fuel Handling System Auxiliary Ventilation Systems Radiation Protection Table 13.3-1 Fuel Handling Accidents Volume I: Question 3.2 Amendment Nos.

3.19 MAIN CONTROL ROOM BOTTLED AIR SYSTEM Applicability The following Specifications are applicable whenever either unit is above COLD SHUTDOWN.

Objective To specify fimctional requirements for the main control room bottled air system.

Specification A. Requirements Two trains of bottled air shall be OPERABLE and each shall be capable of pressurizing the Main Control RoomIEmergency Switchgear Room (MCWESGR) envelope to a positive differential pressure with respect to adjoining areas of the auxiliary, turbine, and service buildings for one hour. A minimum positive differential pressure of 0.05 inches of water must be maintained when the MCWESGR envelope 1

is isolated under accident conditions. This capability shall be demonstrated by the testing requirements delineated in Technical Specification 4.1.

Note: The MCWESGR envelope boundary may be opened intermittently under administrative control.

B. Remedial Action

1. With one train of the bottled air system inoperable for reasons other than Specification 3.19.B.3, restore the inoperable train to OPERABLE status within 7 days or both units shall be placed in at least HOT SHUTDOWN within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

2. With both trains of the bottled air system inoperable for reasons other than Specification 3.19.B.3, restore one train to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or both units shall be placed in at least HOT SHUTDOWN within the same 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3. If one or more trains of the bottled air system are inoperable due to an inoperable MCWESGR envelope boundary, then perform the following:

a. Immediately initiate action to implement mitigating actions; I

b. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , verify mitigating actions ensure MCWESGR envelope occu-pant exposures to radiological, chemical, and smoke hazards will not exceed limits; and

c. Within 90 days, restore MCRIESGR envelope boundary to OPERABLE status.

I Amendment Nos.

4. If the requirements of Specification 3.19.B.1 or 3.19.B.2 are not met within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after achieving HOT SHUTDOWN, both units shall be placed in COLD SHUTDOWN within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

5. If the requirements of Specification 3.19.B.3 are not met, both units shall be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Basis The Main Control RoomIEmergency Switchgear Room (MCRIESGR) Emergency Habitability System (EHS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The MCWESGR EHS consists of the Main Control Room (MCR) Bottled Air System and the MCIUESGR Emergency Ventilation System (EVS) (TS 3.21).

Following a Design Basis Accident (DBA), the containment will be depressurized to 0.5 psig (Unit I), 1.0 psig (Unit 2) in less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and to subatmospheric pressure within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The radiological consequences analysis demonstrates acceptable results provided the containment pressure does not exceed 0.5 psig (Unit 1) and 1.0 psig (Unit 2) for the interval from 1 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following the DBA. Beyond 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , containment pressure is assumed to be less than 0.0 psig, terminating leakage from containment. The MCWESGR envelope is maintained at a positive differential pressure using bottled air during the first hour, when the containment leakrate is greatest.

The MCWESGR envelope is the area within the confines of the MCIUESGR envelope boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the common Main Control Room and the Emergency Switchgear Rooms, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The MCWESGR envelope is protected during normal operation, natural events, and accident conditions. The MCRJESGR envelope boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the MCWESGR envelope. The OPERABILITY of the MCWESGR envelope boundary must be maintained to ensure that the inleakage of unfiltered air into the MCWESGR envelope will not exceed the inleakage assumed in the licensing basis analysis of DBA consequences to MCRIESGR envelope occupants. The MCWESGR envelope and its boundary are defined in the MCRIESGR Envelope Habitability Program (TS 6.4.R).

Amendment Nos.

Upon receipt of the actuating signal(s), normal air supply to and exhaust from the MCRIESGR envelope is isolated, and airflow from the MCR Bottled Air System maintains a positive pressure in the MCWESGR envelope. Two dampers in series in both the MCRIESGR envelope supply and exhaust ducts close to isolate the MCRIESGR envelope. Approximately 60 minutes after the actuation of the MCR Bottled Air System, the MCWESGR EVS is manually actuated. Each MCWESGR EVS train provides filtered air from the Turbine Building to the MCWESGR envelope through HEPA filters and charcoal adsorbers. Prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers.

Pressurization of the MCWESGR envelope limits infiltration of unfiltered air from the surrounding areas adjacent to the MCWESGR envelope.

A single train of the MCR Bottled Air System will pressurize the MCRIESGR envelope to 2 0.05 inches water gauge for at least 60 minutes. The MCRIESGR EHS operation in maintaining the MCWESGR envelope habitable is discussed in the UFSAR, Section 9.13 (Ref. 3).

The MCWESGR EHS is designed to maintain a habitable environment in the MCWESGR envelope for 30 days of continuous occupancy after a DBA without exceeding a 5 rem total effective dose equivalent (TEDE).

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

TS 3.19.B.3 and 5 If the unfiltered inleakage of potentially contaminated air past the MCWESGR envelope boundary and into the MCWESGR envelope can result in MCWESGR envelope occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of MCWESGR envelope occupants from hazardous chemicals or smoke, the MCRIESGR envelope boundary is inoperable. Actions must be taken to restore an OPERABLE MCWESGR envelope boundary within 90 days.

Amendment Nos.

During the period that the MCNESGR envelope boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on MCWESGR envelope occupants fiom the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that MCRIESGR envelope occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that MCRIESGR envelope occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable MCWESGR envelope boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Allowed Outage Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Allowed Outage Time is reasonable based on the determination that the mitigating actions will ensure protection of MCWESGR envelope occupants within analyzed limits while limiting the probability that MCWESGR envelope occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Allowed Outage Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the MCRIESGR envelope boundary.

REFERENCES

1. UFSAR, Section 2.1, Geography, Demography And Potential External Hazards

2.

UFSAR, Section 9.10, Fire Protection

3.

UFSAR, Section 9.13, Auxiliary Ventilation Systems

4.

UFSAR, Chapter 14, Safety Analysis

5.

Letters from B. R. Sylvia (VEPCO) to Harold R. Denton (NRC) dated January 19 and June 30, 1981, Response to Item III.D.3.4, Control Room Habitability Requirements of NUREG-0737 for Surry Power Station.

6.

Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors"

7.

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

8.

Letter from Eric J. Leeds (NRC) to James W. Davis (NET) dated January 30,2004, "NEI Draft White Paper, Use of Generic Letter 91-1 8 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694)

Amendment Nos.

3.21 MAIN CONTROL ROOM/EMERGENCY SWITCHGEAR ROOM (MCWESGR)

EMERGENCY VENTILATION SYSTEM (EVS)

Applicability The following specifications are applicable whenever either unit is above COLD SHUTDOWN.

Objective To specify the hnctional requirements for the MCWESGR EVS.

Specifications A. Two MCWESGR EVS trains shall be OPERABLE whenever the unit is above COLD SHUTDOWN.

Note: The MCWESGR envelope boundary may be opened intermittently under administrative control.

B. If one required MCWESGR EVS train is inoperable for reasons other than Specification 3.21.C, restore the MCRIESGR EVS train to OPERABLE status within 7 days.

C. If one or more required MCRIESGR EVS trains are inoperable due to an inoperable MCWESGR envelope boundary, then perform the following:

1. Immediately initiate action to implement mitigating actions.

2. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , verify mitigating actions ensure MCFUESGR envelope occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

3. Within 90 days, restore MCWESGR envelope boundary to OPERABLE status.

D. If the requirements of Specifications 3.21.B or 3.21.C are not met, the unit shall be placed in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

E. If two required MCWESGR EVS trains are inoperable for reasons other than TS 3.21.C, the unit shall be placed in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Amendment Nos.

TS 3.21-2 BASES BACKGROUND - The MCWESGR Emergency Habitability System (EHS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The MCWESGR EHS consists of the Main Control Room Bottled Air System (TS 3.19) and the MCWESGR EVS.

The MCRIESGR EVS consists of four full capacity trains that supply filtered air to the MCRIESGR envelope and a MCRIESGR envelope boundary that limits the inleakage of unfiltered air. Each MCWESGR EVS train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves, dampers, doors, barriers, and instrumentation also form part of the system. One EVS train is capable of performing the safety function of providing outside filtered air for pressurization. Two independently powered EVS trains are required for independence and redundancy.

The MCWESGR envelope is the area within the confines of the MCWESGR envelope boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the common Main Control Room and the Emergency Switchgear Rooms, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The MCRIESGR envelope is protected during normal operation, natural events, and accident conditions. The MCRlESGR envelope boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the MCWESGR envelope. The OPERABILITY of the MCRIESGR envelope boundary must be maintained to ensure that the inleakage of unfiltered air into the MCRIESGR envelope will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to MCWESGR envelope occupants. The MCWESGR envelope and its boundary are defined in the MCWESGR Envelope Habitability Program (TS 6.4.R).

Upon receipt of the actuating signal(s), normal air supply to and exhaust from the MCWESGR envelope is isolated, and airflow from the MCR Bottled Air System maintains a positive pressure in the MCRIESGR envelope. Two dampers in series in both the MCRIESGR envelope supply and exhaust ducts close to isolate the MCWESGR envelope. Approximately 60 minutes after the isolation of the MCRIESGR envelope and actuation of the MCR Bottled Air System, the MCWESGR EVS is manually actuated. Each MCWESGR EVS train provides filtered air from the Turbine Building to the MCWESGR envelope through HEPA filters and charcoal adsorbers.

Prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers.

Amendment Nos.

Pressurization of the MCRIESGR envelope limits infiltration of unfiltered air from the surrounding areas adjacent to the MCWESGR envelope.

A single train of the MCRIESGR EVS will pressurize the MCRIESGR envelope to about 0.05 inches water gauge relative to external areas adjacent to the MCWESGR envelope boundary.

The MCWESGR EHS operation in maintaining the MCWESGR envelope habitable is discussed in the UFSAR, Section 9.13 (Ref. 3).

Redundant MCWESGR EVS supply trains provide the required pressurization and filtration should one train fail to start or should an excessive pressure drop develop across the operating filter train. 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 MCWESGR EVS is designed in accordance with Seismic Category I requirements.

The MCRIESGR EHS is designed to maintain a habitable environment in the MCRIESGR envelope for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem total effective dose equivalent (TEDE).

APPLICABLE SAFETY ANALYSES - The MCWESGR EVS components are arranged in redundant, safety related ventilation trains. The MCWESGR EHS provides airborne radiological protection for the MCWESGR envelope occupants, as demonstrated by the MCWESGR envelope occupant dose analyses for the most limiting design basis accident fission product release presented in the UFSAR, Chapter 14 (Ref. 4).

The MCRIESGR EHS provides protection from smoke and hazardous chemicals to the MCWESGR envelope occupants. An evaluation of hazardous chemical releases demonstrates that the toxicity limits for chemicals are not exceeded in the MCWESGR envelope following a hazardous chemical release (Refs. 1 and 5) or that ample time is available for MCRIESGR envelope occupants to isolate the MCWESGR envelope. The evaluation of a smoke challenge demonstrates that it will not result in the inability of the MCWESGR envelope occupants to control the reactor either from the MCR or from the remote shutdown panel (Ref. 2).

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

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

LIMITING CONDITIONS FOR OPERATION (LCO) - Two independent and redundant MCWESGR EVS trains are required to be OPERABLE to ensure that at least one is available to pressurize and to provide filtered air to the MCWESGR envelope assuming a single active failure disables one of the two required trains. Due to electrical power considerations, one train must be from the other unit. Total system failure, such as from a loss of both ventilation trains or from an inoperable MCWESGR envelope boundary, could result in exceeding a dose of 5 rem TEDE to the MCWESGR envelope occupants in the event of a large radioactive release.

Amendment Nos.

Each MCRJESGR EVS train is considered OPERABLE when the individual components necessary to limit MCWESGR envelope occupant exposure are OPERABLE in the two required trains of the MCWESGR EVS, one train of which is from the other unit. A MCWESGR EVS train is OPERABLE when the associated:

a. Fan is OPERABLE;

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

c. Ductwork, valves, and dampers are OPERABLE, and air flow can be maintained.

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

The LC0 is modified by a Note allowing the MCRJESGR envelope boundary to be opened intermittently under administrative controls. This Note only applies to openings in the MCWESGR envelope boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the MCRJESGR envelope. This individual will have a method to rapidly close the opening and to restore the MCWESGR envelope boundary to a condition equivalent to the design condition when a need for MCWESGR envelope isolation is indicated.

APPLICABILITY - In REACTOR OPERATION conditions above COLD SHUTDOWN, the MCWESGR EVS must be OPERABLE to ensure that the MCWESGR envelope will remain habitable during and following a DBA.

ACTIONS When one required MCRIESGR EVS train is inoperable, for reasons other than an inoperable MCRJESGR envelope boundary, action must be taken to restore OPERABLE status within 7 days. In this condition, the remaining required OPERABLE MCWESGR EVS train is adequate to perform the MCRJESGR envelope occupant protection function. However, the overall reliability is reduced because a failure in the OPERABLE MCWESGR EVS train could result in loss of MCRIESGR EVS function. The 7 day Allowed Outage 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.

Amendment Nos.

3.21.C If the unfiltered inleakage of potentially contaminated air past the MCRIESGR envelope boundary and into the MCRIESGR envelope can result in MCRIESGR envelope occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of MCRIESGR envelope occupants from hazardous chemicals or smoke, the MCRIESGR envelope boundary is inoperable. Actions must be taken to restore an OPERABLE MCRIESGR envelope boundary within 90 days.

During the period that the MCWESGR envelope boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on MCRIESGR envelope occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that MCWESGR envelope occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that MCRIESGR envelope occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable MCWESGR envelope boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Allowed Outage Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Allowed Outage Time is reasonable based on the determination that the mitigating actions will ensure protection of MCWESGR envelope occupants within analyzed limits while limiting the probability that MCWESGR envelope occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Allowed Outage Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the MCWESGR envelope boundary.

3.21.D In REACTOR OPERATION conditions above COLD SHUTDOWN, if the inoperable MCWESGR EVS train or the MCWESGR envelope boundary cannot be restored to OPERABLE status within the Allowed Outage Time, the unit must be placed in a REACTOR OPERATION condition that minimizes accident risk. To achieve this status, the unit must be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-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.

Amendment Nos.

3.21.E If both MCRIESGR EVS trains are inoperable in REACTOR OPERATION conditions above COLD SHUTDOWN for reasons other than an inoperable MCWESGR envelope boundary (i.e.,

TS 3.21.C), the MCWESGR EVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, the unit must be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

REFERENCES

1. UFSAR, Section 2.1, Geography, Demography and Potential External Hazards

2.

UFSAR, Section 9.10, Fire Protection

3.

UFSAR, Section 9.13, Auxiliary Ventilation Systems

4.

UFSAR, Chapter 14, Safety Analysis

5. Letters from B. R. Sylvia (VEPCO) to Harold R. Denton (NRC) dated January 19 and June 30, 1981, Response to Item III.D.3.4, Control Room Habitability Requirements of NUREG-0737 for Suny Power Station

6.

Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors"

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

8.

Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 9 1 - 18 Process and Alternative Source Terms in the Context of Control Room Habitability" (ADAMS Accession No. ML040300694)

Amendment Nos.

3.23 MAIN CONTROL ROOM AND EMERGENCY SWITCHGEAR ROOM AIR CONDITIONING SYSTEM 1

Applicability Applies to the Main Control Room (MCR) and Emergency Switchgear Room (ESGR) Air Conditioning System.

I Obiective To specify requirements to ensure the proper function of the Main Control Room and Emergency Switchgear Room Air Conditioning System.

I Specification A. The Main Control Room and Emergency Switchgear Room Air Conditioning System 1

shall be OPERABLE as delineated in the following:

1. Chiller Refrigeration Units

a. Three main control room and emergency switchgear room chillers must be OPERABLE whenever either unit is above COLD SHUTDOWN.

b. The three OPERABLE chillers are required to be powered from three of the four emergency buses with one of those chillers capable of being powered from the fourth emergency bus.

c. If one of the OPERABLE chillers becomes inoperable or is not powered as required by Specification 3.23.A. I.b, return an inoperable chiller to I

OPERABLE status within seven (7) days or bring both units to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

d. If two of the OPERABLE chillers become inoperable or are not powered as required by Specification 3.23.A. I.b, return an inoperable chiller to I

OPERABLE status within one (1) hour or bring both units to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Amendment Nos.

2. If two Unit 2 AHUs on different chilled water loops and in different air conditioning zones (2-VS-AC-7 and 2-VS-AC-8 or 2-VS-AC-6 and 2-VS-AC-9) become inoperable, restore operability of the two inoperable AHUs within seven (7) days or bring Unit 2 to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

3. If two Unit 2 AHUs in the same air conditioning zone (2-VS-AC-8 and 2-VS-AC-9 or 2-VS-AC-6 and 2-VS-AC-7) become inoperable, restore operability of at least one Unit 2 AHU in each air conditioning zone (2-VS-AC-8 or 2-VS-AC-9 and 2-VS-AC-6 or 2-VS-AC-7) within one (1) hour or bring Unit 2 to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

4. If more than two Unit 2 AHUs become inoperable, restore operability of at least one Unit 2 AHU in each air conditioning zone (2-VS-AC-8 or 2-VS-AC-9 and 2-VS-AC-6 or 2-VS-AC-7) within one (1) hour or bring Unit 2 to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. Both Unit 1 AHUs or both Unit 2 AHUs powered from the respective H buses (1-VS-AC-I and 1-VS-AC-7 or 2-VS-AC-6 and 2-VS-AC-8) must be OPERABLE whenever both units are above COLD SHUTDOWN.

1. If one or two AHUs on each unit powered from an H bus is inoperable, restore operability of the inoperable AHU(s) on one unit within one (1) hour or bring both units to HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Amendment Nos.

Basis The MCR and ESGR Air Conditioning System (ACS) cools the MCRIESGR envelope.

From an ACS perspective, the envelope consists of four zones: 1) the Unit 1 side of the control room (including the Unit I air conditioning equipment and computer rooms),

2) the Unit 2 side of the control room (including the annex area, the Unit 2 air conditioning equipment and computer rooms), 3) the Unit 1 ESGR and relay room (referred to as the Unit 1 ESGR), and 4) the Unit 2 ESGR and relay room (including MER-3), referred to as the Unit 2 ESGR. The design basis of the MCR and ESGR ACS is to maintain the MCRIESGR envelope temperature within the equipment design limits for 30 days of continuous occupancy after a design basis accident (DBA). The ACS includes five chillers (1-VS-E-4A, 4B, 4C, 4D, and 4E). Chillers 4A, 4B, and 4C are located in MER-3, in the Unit 2 ESGR. Chillers 4D and 4E are located in MER-5, in the Unit 2 Turbine Building. The chillers supply chilled water to eight air handling units (AHUs),

arranged in two independent and redundant chilled water loops. Each chilled water loop provides redundant 100% heat removal capacity per unit. Each loop contains four AHUs (one AHU in each unit's air conditioning zones), the necessary power supplies, the associated valves, piping (from the supply header to return header), instrumentation, and controls. Each AHU has 100% capacity for cooling its zone.

The combination of five chillers and two chilled water loops affords considerable flexibility in meeting the cooling requirements. Two chillers are powered from single emergency buses (1-VS-E-4C from 2H, 1-VS-E-4E from 1H). The remaining three chillers can be powered from either of two emergency buses (1-VS-E-4A from 1J or 25, 1-VS-E-4B from 1J or 2H, and 1-VS-E-4D from 1H or 25). The AHUs are powered from the four emergency buses in pairs. For example, the Unit 1 MCR and ESGR AHUs 1-VS-AC-1 and 1-VS-AC-7 are powered from the 1H bus; the redundant Unit 1 MCR and ESGR AHUs 1-VS-AC-2 and 1-VS-AC-6 are powered from the 1J bus. Control of the ACS is by manual action.

The chillers are procedurally aligned by power supply to meet TS 3.23.A. 1.b, and the AHU pairs are normally aligned to match the power supplies of the OPERABLE chillers.

For example, chiller 1-VS-E-4E and AHUs 1-VS-AC-1 and 1-VS-AC-7 are powered from the 1H emergency bus. However, due to the number of emergency diesel generators (EDGs) and the chiller/AHU piping layout, only one chiller and AHU pair can be powered from each emergency bus at a time. Also, if chilled water is needed in both chilled water loops, two chillers must be operated. Only one chiller can be operated on each chilled water loop at a time, and the 4D and 4E chillers cannot be operated simultaneously. The combinations of OPERABLE chillers1AHUs allowed by procedure ensure that sufficient cooling capacity is available during a DBA with a coincident loss of offsite power (LOOP) and single failure of an EDG, a chiller, or an AHU.

Amendment Nos.

4.18 MAIN CONTROL ROOMIEMERGENCY SWITCHGEAR ROOM (MCWESGR)

EMERGENCY VENTILATION SYSTEM (EVS) TESTING A. Operate each MCWESGR EVS train for 2 15 minutes once every 3 1 days.

B. Perform required Control Room Air Filtration System Testing in accordance with TS 4.20.

C. Perform required MCWESGR envelope unfiltered air inleakage testing in accordance with the MCWESGR Envelope Habitability Program.

BASES SURVElLLANCE REQUIREMENTS (SR)

Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. Systems without heaters need only be operated for 2 15 minutes to demonstrate the function of the system. The 3 1 day frequency is based on the reliability of the equipment and the two train redundancy. Operation of the MCRIESGR EVS trains shall be initiated manually from the MCR.

This SR verifies that the required Control Room Air Filtration System testing is performed in accordance with Specification 4.20. Specification 4.20 includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test frequencies and additional information are discussed in detail in TS 4.20.

This SR verifies the OPERABILITY of the MCRIESGR envelope boundary by testing for unfiltered air inleakage past the MCR/ESGR envelope boundary and into the MCWESGR envelope. The details of the testing are specified in the MCWESGR Envelope Habitability Program (TS 6.4.R).

Amendment Nos.

The MCWESGR envelope is considered habitable when the radiological dose to MCWESGR envelope occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE, and the MCRIESGR envelope occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the MCWESGR envelope is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Specification 3.2 1.C must be entered. Specification 3.2 1.C.3 allows time to restore the MCWESGR envelope boundary to OPERABLE status provided mitigating actions can ensure that the MCWESGR envelope remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 1) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 2). These compensatory measures may also be used as mitigating actions as required by Specification 3.21.C.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 3). Options for restoring the MCRIESGR envelope boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the MCWESGR envelope boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the MCWESGR envelope boundary has been restored to OPERABLE status.

REFERENCES

1. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors"

2.

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

3.

Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30,2004, "NEI Draft White Paper, Use of Generic Letter 9 1-1 8 Process and Alternative Source Terms in the Context of Control Room Habitability" (ADAMS Accession No. ML040300694)

Amendment Nos.

8. The procedure for iodine removal efficiency tests shall follow ASTM D3803. The test conditions shall be in accordance with those listed in Specification 4.20.B.4.

9. The pressure drop across the HEPA filter and adsorber banks shall be checked:

a. Initially;

b. Once per 18 months; and

c. After each complete or partial replacement of filters or adsorbers.

I B. Acceptance Criteria

1. Fan flow tube test shall show a flow rate through any single filter train of 1000

10 percent cfm.

2. In-place cold DOP tests on HEPA filters shall show greater than or equal to 99.5 percent DOP removal. Leaking sources shall be identified, repaired and retested. Any HEPA filter found defective shall be replaced.

3. In-place halogenated hydrocarbon leakage tests on charcoal adsorber banks shal show greater than or equal to 99 percent halogenated hydrocarbon removal Leakage sources shall be identified, repaired and retested.

Amendment Nos.

4. Laboratory analysis on new charcoal adsorbent shall show the methyl iodide penetration less than or equal to 14 percent, when tested in accordance with ASTM D3803-1989 (with the exception of face velocity which is to be at 24.4 Mlmin), with the relative humidity equal to 95 percent, and the temperature equal to 30°C (86°F).

5. The pressure drop across filter cells and adsorbers shall not exceed 5.0 inches W.G. at design flow rate. If this condition cannot be met, new filter cells shall be installed.

I Basis Ventilation system filter components are not subject to rapid deterioration, having lifetimes of many years. The tests outlined above provide assurance of filter reliability and will ensure timely detection of conditions which could cause filter degradation.

A pressure drop across the combined HEPA filters and charcoal adsorbers of less than 5 inches of water will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter.

I Amendment Nos.

R. Main Control Room/Emergency Switchgear Room (MCWESGR) Envelope Habitability Program A Main Control Room/Emergency Switchgear Room (MCRIESGR) Envelope Habitability Program shall be established and implemented to ensure that MCWESGR envelope habitability is maintained such that, with an OPERABLE Emergency Habitability System [i.e., the MCWESGR Emergency Ventilation System (EVS) and the Main Control Room Bottled Air System], MCRIESGR envelope occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the MCRIESGR envelope under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

1. The definition of the MCWESGR envelope and the MCWESGR envelope boundary.

2. Requirements for maintaining the MCWESGR envelope boundary in its design condition including configuration control and preventive maintenance.

3. Requirements for (a) determining the unfiltered air inleakage past the MCWESGR envelope boundary into the MCWESGR envelope in accordance with the testing methods and at the Frequencies specified in Sections C. 1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (b) assessing MCRIESGR envelope habitability at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197, Revision 0.

The following is an exception to Sections C. 1 and C.2 of Regulatory Guide 1.197, Revision 0:

2.C. 1 Licensing Bases - Vulnerability assessments for radiological, hazardous chemical and smoke, and emergency ventilation system testing were completed as documented in the UFSAR. The exceptions to the Regulatory Guides (RGs) referenced in RG 1.196 (i.e., RG 1 S2, RG 1.78 and RG l.l83), which were considered in completing the vulnerability assessments, are documented in the UFSAWcurrent licensing basis. Compliance with these RGs is consistent with the current licensing basis as described in the UFSAR.

Amendment Nos.

Measurement, at designated locations, of the MCWESGR envelope pressure relative to all external areas adjacent to the MCWESGR envelope boundary during the pressurization mode of operation by one train of the MCRIESGR EVS, operating at the flow rate required by TS 4.20, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the assessment of the MCWESGR envelope boundary.

The quantitative limits on unfiltered air inleakage into the MCRIESGR envelope.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph 3. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of MCRIESGR envelope occupants to these hazards will be within the assumptions in the licensing basis.

The provisions of SR4.0.2 are applicable to the Frequencies for assessing MCWESGR envelope habitability, determining MCRJESGR envelope unfiltered inleakage, and measuring MCRIESGR envelope pressure and assessing the MCWESGR envelope boundary as required by paragraphs 3 and 4, respectively.

Amendment Nos.

ML071970301

Text

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

Attachment:

Attachment:

Attachment:

Attachment:

Navigation menu

Search