Text

Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process
	ML072050385
Person / Time
Site:	Brunswick
Issue date:	07/17/2007
From:	Scarola J; Progress Energy Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BSEP 07-0058, TSC-2007-03
	Download: ML072050385 (61)
	v • d • e

James Scarola Vice President Brunswick Nuclear Plant Progress Energy Carolinas, Inc.

July 17, 2007 SERIAL: BSEP 07-0058 10 CFR 50.90 TSC-2007-03 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

References:

FederalRegister Notice of Availability of Technical Specification Improvement to Modify Requirements Regarding Control Room Envelope Habitability Using the Consolidated Line Item Improvement Process, published January 17, 2007 (72 FR 2022)

Ladies and Gentlemen:

In accordance with the provisions of the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., is submitting a request for an amendment to the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

The proposed amendments would modify TS requirements related to control room envelope habitability. The changes are in accordance with Nuclear Regulatory Commission approved Technical Specification Task Force (TSTF), Standard Technical Specifications (STS) change TSTF-448, Revision 3, "Control Room Habitability."

A notice announcing the availability of this proposed change using the Consolidated Line Item Improvement Process (CLIIP) was published in the FederalRegister on January 17, 2007 (72 FR 2022). In a letter dated December 9, 2003, "180-Day Response to Generic Letter 2003-01, Control Room Habitability," CP&L committed to submit a proposed control room habitability amendment request for BSEP, Unit Nos. 1 and 2, within six months of the CLIIP notice. This submittal fulfills that commitment.

P.O.Box 10429 Southport, NC 28461 4 1 2..

T> 910.457.3698 F> 910.457.2803

)ut:--g

Document Control Desk "

BSEP 07-0058 / Page 2 CP&L has evaluated the proposed change in accordance with 10 CFR 50.9 1(a)(1), using the criteria in 10 CFR 50.92(c), and determined that this change involves no significant hazards considerations. .

CP&L requests approval of the proposed License Amendment by July 31, 2008. Once approved, the amendment shall be implemented within 180 days.

In accordance with 10 CFR 50.9 1(b), CP&L is providing a copy of this application, with attachments, to the designated representative of the State of North Carolina. provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing Unit 1 TS pages marked-up to show the proposed changes. Since TS Section 3.7.3 is identical for Unit 1 and Unit 2, only the mark-up for Unit 1 is provided. Enclosures 3 and 4 provide typed versions of the Unit 1 and Unit 2 revised TS pages, respectively. These typed TS pages are to be used for issuance of the proposed amendments. Enclosure 5 provides existing Unit 1 TS Bases pages marked-up to show the proposed changes. These pages are being submitted for information only and do not require issuance by the NRC.

No regulatory commitments are contained in this submittal. Please refer any questions regarding this submittal to Mr. Randy C. Ivey, Manager - Support Services, at (910) 457-2447.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on July 17, 2007.

Sincerely, James Scarola LJ/lj g

Enclosures:

1. Evaluation of Proposed License Amendment Request

2. Marked-up Technical Specification Pages - Unit 1

3. Typed Technical Specification Pages - Unit 1

4. Typed Technical Specification Pages - Unit 2

5. Marked-up Technical Specification Bases Pages - Unit 1 (For Information Only)

Document Control Desk BSEP 07-0058 / Page 3 cc (with enclosures):

U. S. Nuclear Regulatory !Commission, Region II ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Mr. Stewart N. Bailey (Mail Stop OWFN 8B1) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

BSEP 07-0058 Enclosure 1 Page 1 of 3 Evaluation of Proposed License Amendment Request

Subject:

Request for License Amendment - Application to revise Technical Specifications regarding control room envelope habitability in accordance with TSTF-448, Revision 3, using the Consolidated Line Item Improvement Process 1.0 Description The proposed license amendments would modify Technical Specifications (TS) requirements regarding control room envelope habitability in TS 3.7.3, "Control Room Emergency Ventilation (CREV) System," and TS Section 5.5, "Programs and Manuals."

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-448, Revision 3. The availability of this TS improvement was published in the FederalRegister on January 17, 2007 (72 FR 2022) as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 Assessment 2.1 Applicability of Published Safety Evaluation Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., has reviewed the safety evaluation dated January 17, 2007, as part of the CLIIP. This included a review of the NRC's evaluation, as well as the supporting information provided to support TSTF-448. CP&L has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC are applicable to Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, and justify this amendment for the incorporation of the changes to the BSEP Unit 1 and Unit 2 TS.

2.2 Optional Changes and Variations The proposed changes are consistent with the intent of NRC-approved Technical Specifications Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-448, Revision 3, "Control Room Habitability." The changes to TS Section 3.7.3 add additional Conditions/Actions to distinguish between inoperability due to a degraded Control Room Envelope (CRE) boundary and inoperability for other reasons. Changes to the Surveillance Requirements for TS 3.7.3 replace the current surveillance to perform a positive pressure test with a more comprehensive Control Room Envelope Habitability Program. The requirements for this program are incorporated into new TS Section 5.5.13. This program will continue to require a positive pressure test, but augments that test with additional requirements such as a tracer gas

BSEP 07-0058 Enclosure 1 Page 2 of 3 inleakage test and a preventative maintenance program. These additional requirements will provide added confidence in the integrity of the CRE boundary.

Although the basic requirements and structure of TSTF-448 are captured in the proposed changes, there are some differences from the TSTF-448 wording. These differences are listed and justified as follows:

1. In TSTF-448, for the new Control Room Envelope Habitability Program (i.e., Section 5.5.15 in the BWR/4 STS), the lead-in paragraph states that the program "...shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE...." The BSEP proposed TS Section 5.5.13 for Unit Nos. 1 and 2 omits the words

"...access and...." The CRE boundary, and programs to maintain it, are only providing the necessary radiological protection for occupancy of the Control Room. The program is independent of any ability to access the Control Room. The regulatory guidance for performing control room dose analyses (e.g., Regulatory Guide 1.183, "Alternative Radioactive Source Term for Evaluating Design Basis Accidents at Nuclear Power Reactors") does not require the assessment of the access dose in assessing the ability of the control room habitability systems to meet the specified dose acceptance criteria. The reduced content of the lead-in paragraph does not impact the listed program requirements.

2. In line. item "d" for the new CRE habitability program requirements (Section 5.5.15 in the BWR/4 STS), the words "...all external areas adjacent to the CRE boundary..." are replaced with "...outside atmosphere..." in the proposed BSEP TS Section 5.5.13. The literal interpretation of the word "all" can cause implementation questions and the term adjacent areas is not as easily defined as stating outside atmosphere. This does not reduce the specified requirement in that the trending of the positive pressure test results will be performed for each required assessment.

The above variations also result in corresponding differences in the BSEP TS Bases wording.

2.3.1 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements In order to clarify the due date for the initial performance of the new and revised surveillance requirements, CP&L proposes the following as a license condition, for both BSEP Unit Nos. 1 and 2, to support implementation of the proposed TS changes:

Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.3, in accordance with TS 5.5.13.c.(i), the assessment of CRE habitability as required by Specification 5.5.13.c.(ii), and the measurement of CRE pressure as required by Specification 5.5.13.d, shall be considered met. Following implementation:

BSEP 07-0058 Enclosure 1 Page 3 of 3 (a) The first performance of SR 3.7.3.3, in accordance with Specification 5.5.13.c.(i),

shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from June 11, 2004, the date of the most recent successful tracer gas test.

(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.13.c.(ii), shall be within the next 9 months.

(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.13.d, shall be within 18 months, plus the 180 days allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test.

3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination CP&L has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the FederalRegister as part of the CLIIP. CP&L has concluded that the proposed NSHCD presented in the FederalRegister notice is applicable to BSEP, Unit Nos. 1 and 2, and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Commitments No regulatory commitments are contained in this submittal. Any other actions discussed in this submittal are provided for information purposes and are not considered regulatory commitments.

4.0 Environmental Evaluation CP&L has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007, as part of the CLIIP. CP&L has concluded that the NRC's findings presented in that evaluation are applicable to BSEP, Unit Nos. 1 and 2, and the evaluation is hereby incorporated by reference for this application.

BSEP 07-0058 Enclosure 2 Brunswick Steam Electric Plant Unit Nos. 1 and 2 Marked-up Technical Specification Pages - Unit 1 Strikeout/Shadowed Format Stfikeout Tex Indicates Deleted Text I-T Indicates Added.Text

CREV System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREV subsystem A. 1 Restore CREV subsystem 7 days Uinoe~rable f-orre-asons _other to OPERABLE status.

thnCondition-Bý B neormoe-RE ~ j~ n~fiate action'J -o Imm-e-d-iawtwerf inoerbl du 6impement mni ti gai na to-inoperable fRE Bounda9 actio-ns'ý inMdl r M2 "ies VrfEitgtn 2 or B~3 estoe R, E-bo0 C d to day ePpe~raesstoatus, i~l (continued)

Brunswick Unit 1 3.7-11 Amendment No 2-W.

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

. Required Action and B".1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Compltion Time of Condition A or not met AND in MODE 1, 2, or 3.

8*.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two CREV subsystems inoperable in MODE 1, 2, or 3 for, reasons otiher thi'n-h P"on-diltjln B.

CID. Required Action and ----------------- NOTE -----------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A not met during movement of irradiated fuel assemblies in Gr.1 Place OPERABLE CREV Immediately the secondary containment, subsystem in during CORE radiation/smoke protection ALTERATIONS, or during mode.

OPDRVs.

OR GM.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND 2.2 Suspend CORE Immediately ALTERATIONS.

AND GJ.2.3 Initiate action to suspend Immediately OPDRVs.

(continued)

Brunswick Unit 1 3.7-12 Amendment No. 203

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

9. Two CREV subsystems --------------- NOTE -----------

inoperable during movement LCO 3.0.3 is not applicable.

of irradiated fuel assemblies ----------------

in the secondary containment, during CORE 91.1 Suspend movement of Immediately ALTERATIONS, or during irradiated fuel assemblies in OPDRVs. the secondary containment.

__ AND bne ot ejRc',1REf 9.2 Suspend CORE Immediately subsystems inoperab ~ALTERATIONS.

toan inprbl_ R boUndydýihng movement AND Of' i rraiaated fuel assem~bles seend.. QT13 Initiate action to suspend Immediately ndOPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for 15 continuous 31 days minutes.

SR 3.7.3.2 Perform required CREV filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP (continued)

Brunswick Unit 1 3.7-13 Amendment No. 203

CREV System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.3.3 peorm.equid Rufilter,'ed air inleakg-e testin n accordance-with in.4accordancic with the Conro Room Enop he etrobl!Roomý,

HaL6ýi~fb itabitability SR 3.7.3.4 Verify each CREV subsystem actuates on an actual or 24 months simulated initiation signal.

Brunswick Unit 1 3.7-14 Amendment No. 203

Programs and Manuals 5.5 5.5 Programs and Manuals Primary Containment Leakage Rate Testing Pro-gram (continued)

2) For each air lock door, leakage rate is < 5 scfh when the gap between the door seals is pressurized to > 10 psig.

The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program frequencies.

5.5.13 Cot~rol Room Enve'p [ itlitV Iro rami

a. hedefirnition of the CRanth CRE boundiar.

~continued Brunswick Unit 1 5.0-17 Amendment No. 24-6 1

Programs and Manuals 5.5 5.5 Programs and Manuals Gýontrol Roomrnvip HaiaiiVPorm-q Brunswick Unit 1 5.0-18 Amendment No.

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Not used 5.6.2 Annual Radioloclical Environmental Operatina Report

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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with (continued)

Brunswick Unit 1 5.0-4-&F1L9 Amendment No. 2-51

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued) the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of Table 3 in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Effluent Release Report

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

A single submittal may be made for a multiple unit station. The submittal shall combine sections common to all units at the station.

The Radioactive Effluent Release Report covering the operation of the unit during the previous year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and the Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.

5.6.4 Not used (continued)

Brunswick Unit 1 5.0-4-C29-0, Amendment No. 2-35 I

J* tj, .,

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1. The AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) for Specification 3.2.1;

2. The MINIMUM CRITICAL POWER RATIO (MCPR) for Specification 3.2.2;

3. The period based detection algorithm (PBDA) setpoint for Function 2.f, Oscillation Power Range Monitor (OPRM) Upscale, for Specification 3.3.1.1; and

4. The Allowable Values and power range setpoints for Rod Block Monitor Upscale Functions for Specification 3.3.2.1.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. NEDE-24011 -P-A, "General Electric Standard Application for Reactor Fuel" (latest approved version).

2. NEDE-32906P-A, "TRACG Application for Anticipated Operational Occurrences (AOO) Transient Analyses," approved version as specified in the COLR.

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

(continued)

Brunswick Unit 1 5.0-2-Ggý Amendment No. 2 I

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.6 Post Accident Monitoring (PAM) Instrumentation Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

Brunswick Unit 1 5.0-940", Amendment No. 24-7 I

High Radiation Area 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area As provided in paragraph 20.1601 (c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601 (a) and (b) of 10 CFR Part 20:

5.7.1 High Radiation Areas with Dose Rates not exceeding 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface Penetrated by the radiation)

a. Each accessible entryway to such an area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.

b. Access to, and activities in, each such area shall be controlled by means of a Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.

d. Each individual or group entering such an area shall:

1. Possess a radiation monitoring device that continuously displays radiation dose rates in the area ("radiation monitoring and indicating device"); or

2. Possess a radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached ("alarming dosimeter"), with an appropriate alarm setpoint; or

3. Possess a radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area; or (continued)

Brunswick Unit 1 Amendment No. 225

High Radiation Area 5.7 5.7 High Radiation Area 5.7.1 High Radiation Areas with Dose Rates not exceeding 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated by the radiation) (continued)

4. Possess a self-reading dosimeter and be under the surveillance, as specified in the RWP or equivalent, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area; or

5. Be under the surveillance, as specified in the RWP or equivalent, of an individual at the work site, qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel radiation exposure within the area.

e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.

5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation)

a. Each accessible entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked door, gate, or guard that prevents unauthorized entry, and in addition:

1. All such door and gate keys shall be maintained under the administrative control of the shift superintendent or the radiation control supervisor or designated representative; and

2. Doors and gates shall remain locked or guarded except during periods of personnel or equipment entry or exit.

(continued)

Brunswick Unit 1 5.0-2 C24 Amendment No. 22

High Radiation Area 5.7 5.7 High Radiation Area 5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) (continued)

b. Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.

d. Each individual or group entering such an area shall:

1. Possess an alarming dosimeter with an appropriate alarm setpoint; or

2. Possess a radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area with the means to communicate with and control every individual in the area; or

3. Possess a direct-reading dosimeter and be under the surveillance, as specified in the RWP or equivalent, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individual in the area; or

4. Be under the surveillance, as specified in the RWP or equivalent, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel exposure within the area; or (continued)

Brunswick Unit 1 5. 0 -2C25- Amendment No. 225 I

High Radiation Area 5.7 5.7 High Radiation Area 5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) (continued)

5. Possess a radiation monitoring and indicating device in those cases where the options of Specifications 5.7.2.d.2, 5.7.2.d.3, and 5.7.2.d.4. above, are impractical or determined to be inconsistent with the "As Low As is Reasonably Achievable" principle.

e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.

f. Such individual areas that are within a larger area that is controlled as a high radiation area, where no enclosure exists for purpose of locking and where no enclosure can reasonably be constructed around the individual area need not be controlled by a locked door or gate, but shall be barricaded and conspicuously posted as a high radiation area, and a conspicuous, clearly visible flashing light shall be activated at the area as a warning device.

Brunswick Unit 1 5.04C6**_ Amendment No. 22- I

BSEP 07-0058 Enclosure 3 Brunswick Steam Electric Plant Unit Nos. 1 and 2 Typed Technical Specification Pages - Unit 1

CREV System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

NOTE.

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

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREV subsystem A.1 Restore CREV subsystem 7 days inoperable for reasons other to OPERABLE status.

than Condition B.

B. One or more CREV B.1 Initiate action to Immediately subsystems inoperable due implement mitigating to inoperable CRE Boundary actions.

in Mode 1, 2, or 3.

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

AND B.3 Restore CRE boundary to 90 days Operable status.

(continued)

Brunswick Unit 1 3.7-11 Amendment No.

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met AND in MODE 1, 2, or 3.

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

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

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A not met during movement of irradiated fuel assemblies in D.1 Place OPERABLE CREV Immediately the secondary containment, subsystem in during CORE radiation/smoke protection ALTERATIONS, or during mode.

OPDRVs.

OR D.2.1 Suspend movement of Immediately I irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately I ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately I OPDRVs.

(continued)

Brunswick Unit 1 3.7-12 Amendment No.

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CREV subsystems ------------- NOTE -----------

inoperable during movement LCO 3.0.3 is not applicable.

of irradiated fuel assemblies ---------------------------

in the secondary containment, during CORE E.1 Suspend movement of Immediately ALTERATIONS, or during irradiated fuel assemblies in OPDRVs. the secondary containment.

OR AND One or more CREV E.2 Suspend CORE Immediately subsystems inoperable due ALTERATIONS.

to an inoperable CRE boundary during movement AND of irradiated fuel assemblies in the secondary E.3 Initiate action to suspend Immediately containment, during CORE OPDRVs.

ALTERATIONS, or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for > 15 continuous 31 days minutes.

SR 3.7.3.2 Perform required CREV filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP (continued)

Brunswick Unit 1 3.7-13 Amendment No.

CREV System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.3.3 Perform required CRE unfiltered air inleakage testing In accordance with in accordance with the Control Room Envelope the Control Room Habitability Program. Envelope Habitability Program SR 3.7.3.4 Verify each CREV subsystem actuates on an actual or 24 months I

simulated initiation signal.

Brunswick Unit 1 3.7-14 Amendment No.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued)

2) For each air lock door, leakage rate is < 5 scfh when the gap between the door seals is pressurized to _>10 psig.

The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program frequencies.

5.5.13 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation (CREV) System, CRE 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 occupancy of the CRE 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:

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

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

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE 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 (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

d. Measurement, at designated locations, of the CRE pressure relative to outside atmosphere during the pressurization mode of operation by one subsystem of the CREV System, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS.

The results shall be trended and used as part of the 72 month assessment of the CRE boundary.

(continued)

Brunswick Unit 1 5.0-17 Amendment No.

Programs and Manuals 5.5 5.5 Programs and Manuals Control Room Envelope Habitability Program (continued)

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. 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 CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

Brunswick Unit 1 5.0-18 Amendment No.

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Not used 5.6.2 Annual Radiological Environmental Operating Report

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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with (continued)

Brunswick Unit 1 5.0-19 Amendment No. I

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued) the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of Table 3 in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Effluent Release Report

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

A single submittal may be made for a multiple unit station. The submittal shall combine sections common to all units at the station.

The Radioactive Effluent Release Report covering the operation of the unit during the previous year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and the Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.

5.6.4 Not used (continued)

Brunswick Unit 1 5.0-20 Amendment No. I