ML072050474

Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

ML072050474
Person / Time
Site:	Nine Mile Point
Issue date:	07/12/2007
From:	Polson K Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TSTF-448, Rev 3
Download: ML072050474 (23)

Text

Keith J. Poison P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax 0 Constellation Energy*

Nine Mile Point Nuclear Station July 12, 2007 U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attention: Document Control Desk

Subject:

Nine Mile Point Nuclear Station Unit No. 1; Docket No. 50-220 Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Nine Mile Point Nuclear Station, LLC (NMPNS) is submitting a request for an amendment to the technical specifications (TS) for Nine Mile Point, Unit 1, renewed operating license No. DPR-63. The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3.

Attachment (1) provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment (2) provides the existing TS pages marked up to show the proposed changes. Attachment (3) provides the existing TS Bases pages marked up to show the proposed changes.

NMPNS requests approval of the proposed License Amendment by July 31, 2008, with the amendment being implemented within the subsequent 60 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated New York state official.

Sko;

Document Control Desk July 12, 2007 Page 2 Should you have any questions regarding this submittal, please contact T. F. Syrell, Licensing Director, at (315) 349-5219.

Very truly yours, STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, Keith J. Polson, being duly sworn, state that I am Vice President-Nine Mile Point, and that I am duly authorized to execute and file this request on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice .and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public, in and for the State of New York and County of this Z 'day of A ,2007.

WITNESS my Hand and Notarial Seal:

Notary Public My Commission Expires:

Z D e SANDRA A. OSWALD Notary Public, State of New York No. 01OS6032276 Qualified In Oswego County/

KJP/JJD Commission Expires I I Attachments: (1) Description and Assessment (2) Proposed License and Technical Specification Changes (Mark-Up)

(3) Proposed Technical Specification Bases Changes (Mark-Up) cc: M. J. David, NRC S. J. Collins, NRC Resident Inspector, NRC J. P. Spath, NYSERDA

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT Nine Mile Point Nuclear Station, LLC July 12, 2007

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed amendment would modify technical specification (TS) requirements related to control room envelope habitability in TS 3.4.5, "Control Room Air Treatment System," and TS Section 6.5, "Programs and Manuals."

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification change TSTF-448, Revision 3. The availability of this TS improvement was published in the FederalRegister on January 17, 2007, as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Nine Mile Point Nuclear Station, LLC (NMPNS) has reviewed the safety evaluation (SE) dated January 17, 2007, as part of the CLIIP. This review included a review of the NRC staff's safety evaluation, as well as the information provided to support TSTF-448. NMPNS has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Nine Mile Point Nuclear Station, Unit I (NMP 1) and justify this amendment for the incorporation of the changes to the NMP1 TSs.

2.2 Optional Changes and Variations NMPNS is proposing the following variations or deviations from the TS changes described in TSTF-448, Revision 3, or the applicable parts of the NRC staff s model safety evaluation dated January 17, 2007:

The NMP1 TSs have a custom format and content. The changes proposed by TSTF-448 are incorporated into the NMP1 TSs to the extent practical within the existing TS and Bases structure.

The NMP 1 control room air treatment system does not have redundant filtration trains. Therefore, the TSs associated with this system are written to reflect a single train. As a result, the proposed TS changes do not include any of the TSTF-448 changes for two trains being inoperable.

The conditions of applicability for operability of the control room air treatment system are revised to better incorporate the TSTF-448 changes. Operability requirements have been added during core alterations and during operations With a potential for draining the reactor vessel. Operability during the refueling condition has been deleted since the specific activities occurring during this condition for which the control room air treatment system is required to be operable have been individually added to the applicability e.g., core alterations.

The following parts of Section 3.0 of the model SE are applicable to NMPl: 3.1, 3.2, 3.3 Evaluation 2, 3.3 Evaluation 5, 3.3 Evaluation 6, and 3.4.

NMPNS is proposing the following changes from the new license condition described in the model license amendment request:

Items (a) and (b) of the license condition discuss performing actions within specific time periods after the last "successful" tracer gas test. NMPNS is proposing to delete the word "successful" from these 1 of 3

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT items. A tracer gas test was performed in February 2004, but the results of the test were not within the current licensing basis inleakage assumptions for NMP1 at the time of the test. An operability determination was completed demonstrating that the control room doses with the measured inleakage were acceptable, although margin was reduced. No credit was taken in the operability determination for the use of any compensatory measures, e.g., KI tablets. As part of the resolution of Generic Letter 2003-01, "Control Room Habitability," NMPNS committed to submit a license amendment request to revise the current licensing bases to utilize AST methodologies. The AST license amendment request was submitted on December 14, 2006. Once the AST methodologies are incorporated into the current licensing basis, the February 2004 tracer gas test would be considered "successful." As such, a new tracer gas test would not be required until February 2010, plus the allowance permitted by TS 4.0.2.

The AST license amendment is expected to be implemented prior to the end of the six year period from the performance of the last tracer gas test. With this change to the proposed license condition, the revised TS 4.4.5.g addressing tracer gas testing will be considered met upon implementation of the license amendment.

2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements NMPNS 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 control room envelope (CRE) unfiltered air inleakage as required by TS 4.4.5.g, in accordance with TS 6.5.8.c.(i), the assessment of CRE habitability as required by Specification 6.5.8.c.(ii),

and the measurement of CRE pressure as required by Specification 6.5.8.d, shall be considered met. Following implementation:

(a) The first performance of TS 4.4.5.g, in accordance with Specification 6.5.8.c.(i), shall be within the specified Frequency of 6 years plus the 18-month allowance of TS 4.0.2, as measured from February 19, 2004, the date of the most recent tracer gas test, as stated in the January 31, 2005 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.5.8.c.(ii), shall be within 3 years, plus the 9-month allowance of TS 4.0.2, as measured from February 19, 2004, the date of the most recent tracer gas test, as stated in the January 31, 2005 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.5.8.d, shall be within 24 months, plus the 182 days allowed by TS 4.0.2, as measured from March 1, 2007, the date of the most recent successful pressure measurement test, or within the next 182 days if not performed previously.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination NMPNS has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the FederalRegister as part of the CLIIP. NMPNS has concluded that the proposed NSHCD 2 of 3

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT presented in the FederalRegister notice is applicable to NMP 1 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Commitments There are no regulatory commitments made in conjunction with this application.

4.0 ENVIRONMENTAL EVALUATION NMPNS has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007 as part of the CLUP. NMPNS has concluded that the staff's findings presented in that evaluation are applicable to NMP1 and the evaluation is hereby incorporated by reference for this application.

3 of 3

ATTACHMENT (2)

NINE MILE POINT UNIT 1 PROPOSED LICENSE AND TECHNICAL SPECIFICATION CHANGES (MARK-UP)

License Page

'8 TS Pages 178 179 356 Nine Mile Point Nuclear Station, LLC July 12, 2007

H. All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of the most recent NRC-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP)

Integrated Surveillance Program (ISP) appropriate for the configuration of the specimens in the capsule. All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements m'ust be approved by the NRC, as required by 10 CFR Part 50, Appendix H.

FOR THE NUCLEAR REGULATORY COMMISSION J. E. Dyer, Director Office of Nuclear Reactor Regulation

Enclosure:

Appendix A - Technical Specifications Date of Issuance: October 31, 2006

--- r~new~ea Licfense i'Ju. DPR-03-2

INSERT 1

1. Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by TS 4.4.5.g, in accordance with TS 6.5.8.c.(i), the assessment of CRE habitability as required by Specification 6.5.8.c.(ii),

and the measurement of CRE pressure as required by Specification 6.5.8.d, shall be considered met. Following implementation:

(a) The first performance of TS 4.4.5.g, in accordance with Specification 6.5.8.c.(i), shall be within the specified Frequency of 6 years plus the 18-month allowance of TS 4.0.2, as measured from February 19, 2004, the date of the most recent tracer gas test, as stated in the January 31, 2005 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.5.8.c.(ii), shall be within 3 years, plus the 9-month allowance of TS 4.0.2, as measured from February 19, 2004, the date of the most recent tracer gas test, as stated in the January 31, 2005 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.5.8.d, shall be within 24 months, plus the 182 days allowed by TS 4.0.2, as measured from March 1, 2007, the date of the most recent successful pressure measurement test, or within the next 182 days if not performed previously.

LIMITING CONDITION FOR OPERATION SURVEILLANCE REUIRMEN SUVEILANE REQUIREMENT FO OPEATIN LIMIINGCONDTIO 3.4.5 CONTROL ROOM AIR TREATMENT SYSTEM 4.4.5 CONTROL ROOM AIR TREATMENT SYSTEM Applicability: Applicability:

Applies to the operating status of the control room air Applies to the testing of the control room air treatment treatment systemr , . systemny/ , (

Obiective: Obiecbve:

To assure the capability of the control room air treatment To assure the operability of the control room air treatment system to minimize the amount of radioactivity or other system.

gases entering the control room inthe event of an incident.

Specification: Specification:

a. Except as specifie.i ecIif-o .4 below, a. At least once per operating cycle, or once every the control room air treatmentsalste al Te be . 24 months, whichever occurs first, the pressure operable durin owr.operatng drop across the combined HEPA filters and conditio a henever irradiated fuel ori <k i-, charcoal adsorber banks shall be demonstrated to be irradiated fuel cask is being handled inthe reactor less than 1.5 inches of water at system design flow rate (+/- 10%).

b. The results of the in-place cold DOP and halo- b. The tests and sample analysis of Specification genated hydrocarbon tests at design flows on 3.4.5b, c and d shall be performed at least once per HEPA filters and charcoal adsorber banks shall operating cycle or once every 24 months, or after 720 show > 99% DOP removal and > 99% halogen- hours of system operation, whichever occurs first or ated hydrocarbon removal when tested in following significant painting, fire or chemical release in accordance with ANSI N.510-1980. any ventilation zone communicating with the system.

AMENDMENT NO. 442, 7-T0, 4-74,4q1 178

INSERT 2 and Control Room Envelope (CRE) boundary.

---

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

The CRE boundary may be opened intermittently under administrative control.

INSERT 3 during core alterations, and during operations with a potential for draining the reactor vessel (OPDRVs).

INSERT 4 and CRE boundary.

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT LIMITING CONDITION FOR OPERATION -t SURVEILLANCE REQUIREMENT

c. The results of laboratory carbon sample analysis c. Cold DOP testing shall be performed after each shall show z!_95% radioactive methyl iodine complete or partial replacement of the HEPA removal when tested in accordance with ASTM filter bank or after any structural maintenance on D3803-1989 at 301C and 95% R.H. the system housing.

d. Fans shall be shown to operate within +/- 10% d. Halogenated hydrocarbon testing shall be design flow. performed after each complete or partial replacement of the charcoal absorber bank or

e. From and after the date that the control room air after any structural maintenance on the system treatment system is made or found housing.

shnouerable *-s-isreasonit for any eactd r operatioa

• rmiss46le only d .ng.s or rrr,*uelin operati

e. The system shall be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> he su ceeding/ even/ tays Li. less the s /tem i every month.

[sonr made .npera.b.,ly

~r4~

7 P f. At least'once per operating. cycle, not to exceed it.[MIf caitgo cannot be metrreactor 24 months, automatic initiation of the control.

3- sh~utdown shall -be initiated and the reactor shall room air treatment system shall be demon-be in cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for r ctor strated.

o ateions re u ng o s shal e teofminate within hour . g. e _t on per oper ing cycl , not to exce-d 2month , the con ol room a' treatment stem anl be s wn to ma tain a. posi*K/e

-- "iO10 pressu within e control boom of grevaer than AMFNDMENT NO. W' -'=7T'7 179

INSERT 5 except for an inoperable CRE boundary during the power operating condition, restore the system to operable within the succeeding seven days.

INSERT 6

f. If the control room air treatment system is made or found to be inoperable due to an inoperable CRE boundary during the power operating condition: immediately initiate action to implement mitigating actions; within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits; and within 90 days, restore the CRE boundary to operable status.

INSERT 7 Specifications 3.4.5.e or 3.4.5.f INSERT 8 during the power operating condition INSERT 9

h. If Specification 3.4.5.e cannot be met whenever irradiated fuel or an irradiated fuel cask is being handled in the reactor building, during core alterations, or during OPDRVs: immediately suspend handling of irradiated fuel or the irradiated fuel cask in the reactor building; immediately suspend core alterations; and immediately initiate action to suspend OPDRVs.

INSERT 10 In accordance with the frequency and specifications of the Control Room Envelope Habitability Program, perform required CRE unfiltered air inleakage testing.

6.5.7 10 CFR 50 Appendix J Testing Program Plan

a. A program shall be established to implement thetleakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, entitled "Performance-Based Containment Leak-Test Program," dated September 1995 with the following exceptions:

1. Type A tests will be conducted in accordance with ANSI/ANS 56.8-1 994 and/or Bechtel Topical Report BN-TOP-1, and

2. The first Type A test following approval of this Specification will be a full pressure test conducted approximately 70, rather than 48, months since the last low pressure Type A test.

b. The peak calculated containment internal pressure (Pac) for the design basis loss of coolant accident is 35 psig.

c. The maximum allowable primary containment leakage rate (La) at Pac shall be 1.5% of primary containment air weight per day.

d. Leakage Rate Surveillance Test acceptance criteria are: .-M

1. The as-found Primary Containment Integrated Leak Rate Test (Type A Test) acceptance criteria is less than 1.0 La.

2. The as-left Primary Containment Integrated Leak Rate Test (Type A Test) acceptance criteria is less than,_- _...

or equal to 0.75 La, prior to entering a mode of operation where containment integrity is required.

3. The combined Local Leak Rate Test (Type B & C Tests including airlocks) acceptance criteria is less than 0.6 La, calculated on a maximum pathway basis, prior to entering a mode of operation where containment integrity is required.

4. The combined Local Leak Rate Test (Type B & C Tests including airlocks) acceptance criteria is less than 0.6 La, calculated on a minimum pathway basis, at all times when containment integrity is required.

e. The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the 10 CFR 50 Appendix J Testing Program Plan.

The provisions of Specification 4.0.3 are applicable to the 10 CFR 50 Appendix J Testing Program Plan.

AMENDMENT NO. 142, 157, 162, 181, 182 355

6.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

6.6.1 Deleted 6.6.2 Annual Radiological Environmental Operating Report*

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 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 T.

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 the table 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.

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

Amendment No. 442, 444, 46f 35 356

INSERT 11 6.5.8 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 Air Treatment (CRAT) 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 access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body 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 all external areas adjacent to the CRE boundary during the pressurization mode of operation of the CRAT System, operating at a flow rate of 2025-2475 cfm, at a Frequency of 24 months.

The results shall be trended and used as part of the 24 month assessment of the CRE boundary.

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 TS 4.0.2 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.

ATTACHMENT (3)

PROPOSED TECHNICAL SPECIFICATION BASES CHANGES

.(MARK-UP)

The current versions of the following Technical Specifications Bases pages have been marked-up by hand to reflect the proposed changes. These Bases pages are provided for information only and do not require NRC approval.

180 181 Nine Mile Point Nuclear Station, LLC July 12, 2007

BASES FOR 3.4.5 AND 4.4.5 CONTROL ROOM AIR TREATMENT SYSTEM The control room air treatment system is designed to filter the control room atmosphere for intake air. A roughing filter is u ed for recirculation flow during normal control room air treatment operation. The control room air treatment system :is des~igned t maintain the control room pressure to the design positive pressure (one-sixteenth inch water) a shoulde ou lea e. The control room air treatment system starts automatically upon receipt of a LOCA (high drywell pressure or low-low reactor water level) or Main Steam Line Break (MSLB) (high steam flow main-steam line or high temperature main-steam line tunnel) signal. The system can also be manually initiated.

High efficiency particulate absolute (HEPA) filters are installed before the charcoal adsorbers to prevent clogging of the iodine adsorber.

The charcoal adsorbers are installed to reduce the potential intake of radioiodine to the control room. The in-place test results should indicate a system leak tightness of less than 1 percent bypass leakage for the charcoal adsorbers and a HEPA efficiency of at least 99 percent removal of DOP particulates. The laboratory carbon sample test results should indicate a radioactive methyl iodide removal efficiency of at least 95 percent, which is derived from applying a safety factor of 2 to the charcoal filter efficiency of 90 percent assumed in analyses of design basis accidents. If the efficiencies of the HEPA filter and charcoal adsorbers are as specified, adequate radiation -

protection will be provided such that resulting doses will be less than the allowable levels stated in Criterion -

19 of the General Design Criteria for Nuclear Power Plants, Appendix A to 10CFR Part 50. Operation of the fans significantly different-frombh :,.

the design flow will change the removal efficiency of the HEPA filters and charcoal adsorbers.

ifEthsystem found to be/inoperable, th e is no im" iate threat tot he control roo nd reac*r*-operationor vfueling operatj,'i may'r co/rtinue foa limited pe(rd of time whyii6 repairs aro/eing made. Ifte makeup sys m cannobe repaired wj.fiin seven days he reactor Sshutdown and brou t to cold shutdown withinA 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or refweling operation g-r-term ted Pressure drop across the combined HEPA filters and charcoal adsorbers of less than 1.5 inches of water at the-system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter. Pressure drop should be determined at leasta once per operating cycle to show system performance capability.

The frequency of tests and sample analysis are necessary to show the HEPA filters and charcoal adsorbers can perform as evaluated.

The charcoal adsorber efficiency test should allow for charcoal sampling to be conducted using an ASTM D3803-1989 approved method.

If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent meeting the physical property specification of Table 5-1 of ANSI 509-1980. -The replacement charcoal for the adsorber tray removed for the test should meet the same adsorbent quality. Any HEPA filters found defective shall be replaced with filters qualified pursuant to ANSI 509-1980.

AMENDMENT NO. A, 7, .2 180

INSERT B I to minimize inleakage of unfiltered air.

INSERT B2 The Control Room Envelope (CRE) is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to- control the unit during normal and accident conditions. The CRE is protected for normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The operability of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

The control room air treatment system provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release (Ref. 1). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Ref. 1).

A periodic offsite chemical survey and procedures for controlling onsite chemicals are essential elements of CRE protection against hazardous chemicals. Changes in offsite, mobile, and onsite hazardous chemical types or quantities are assessed in accordance with the Control Room Envelope Habitability Program. The assessments provide the necessary justification for not installing a toxic gas monitoring automatic isolation system.

In order for the control room air treatment system to be considered operable, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The CRE boundary may be opened intermittently under administrative controls. This only applies to openings in the CRE 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 CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.

INSERT B2 (cont)

If the control room air treatment system is found to be inoperable for any reason other than an inoperable CRE during the power operating condition, there is no immediate threat to the CRE occupants and reactor operation may continue for a limited period of time while repairs are being made. If the system cannot be repaired within seven days, the reactor is shutdown and brought to a cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If the control room air treatment system is found to be inoperable for any reason whenever irradiated fuel or an irradiated fuel cask is being handled in the reactor building, during core alterations, or during operations with a potential for draining the reactor vessel (OPDRVs), there is no immediate threat to the CRE occupants and these activities may continue for a limited period of time while repairs are being made. - If the system cannot be repaired within seven days, these activities must be immediately suspended.

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem whole body or its equivalent to any part of the body), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. If in the power operating condition, actions must be taken to restore an operable CRE boundary within 90 days. During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period allowed is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day period is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE 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 period is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

INSERT B2 (cont)

The testing performed for TS 4.4.5.g verifies the operability of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary- and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program. The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem whole body or its equivalent to any part of the body and the CRE occupants are protected from hazardous chemicals and smoke. This surveillance requirement verifies that the unfiltered air inleakage into the CRE 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 during the power operating condition, TS 3.4.5.f must be entered. The actions allow time to restore the CRE boundary to operable status provided mitigating actions can ensure that the CRE 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.

2) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 3). These compensatory measures may also be used as mitigating actions as required by TS-3.4.5.f. Temporary analytical methods may also be used as compensatory measures to restore operability (Ref. 4). Options for restoring the CRE boundary to operable status include changing the licensing basis DBA consequence analysis, repairing the CRE 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 CRE boundary has been restored to operable status.

BASES FOR 3.4.5 AND 4.4.5 CONTROL ROOM AIR TREATMENT SYSTEM Operation of the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month will demonstrate operability of the filters and adsorber system and remove excessive moisture built up on the adsorber.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign materials, the same tests and sample analysis shall be performed as required for operational use. The determination of significant shall be made by the operator on duty at the time of the incident. Knowledgeable staff members should be consulted prior to making this determination.

AMENDMENT NO. 44-18 181

.J

INSERT B3

References:

1. UFSAR,Section III.B.

2. Regulatory Guide 1.196.

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

4. 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).