ML072330467
| ML072330467 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/21/2007 |
| From: | Schwarz C Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML072330467 (47) | |
Text
-^- Entery Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 August 21, 2007 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket 50-255 License No. DPR-20 Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process
Dear Sir or Madam:
Pursuant to 10 CFR 50. 90, Entergy Nuclear Operations, Inc. (ENO ) requests Nuclear Regulatory Commission (NRC) review and approval of a proposed license amendment to Renewed Facility Operating License DPR-20 for the Palisades Nuclear Plant (PNP).
ENO proposes to revise Technical Specification (TS) 3.7.10, "Control Room Ventilation (CRV) Filtration," and add a new administrative controls program as TS 5.5.16, "Control Room Envelope Habitability Program."
ENO proposes to incorporate changes based on NRC-approved Technical Specification Task Force (TSTF) TSTF-448-A,
" Control Room Habitability," revision 3. The availability of this TS improvement was noticed in the Federal Register on January 17, 2007 (72 FR 2022), as part of the consolidated line item improvement process. The proposed changes include deviations from the NRC-approved TSTF.
Deviations have been made to reflect the facility specific nomenclature, reference, or system description, and to establish consistency with the current PNP TS. provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. provides the existing TS pages marked up to show the proposed changes. provides the revised (clean) TS pages. provides existing TS Bases pages marked up to show the proposed changes, and is provided for information only.
ENO requests approval of this proposed license amendment by September 1, 2008, with a 120-day implementation period.
Document Control Desk Page 2 A copy of this request has been provided to the designated representative of the State of Michigan.
Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on August 21, 2007.
Ckrw'rs pher Schwa Site Vice President Palisades Nuclear Plant Enclosures (4)
CC Regional Administrator, Region III, USNRC Project Manager, Palisades, USNRC NRC Resident Inspector, Palisades USNRC
ENCLOSURE 1 DESC RIPTI ON OF REQUESTED CHANGES 1.0 DESCRIPTI ON Entergy Nuclear Operations, Inc. (ENO) proposes to modify Technical Specification (TS) requirements related to control room envelope habitability in TS 3.7.10, "Control Room Ventilation (CRV) Filtration," and TS Section 5.5, "Administrative Controls - Programs and Manuals."
The changes are consistent with Nuclear Regulatory Commission (NRC)-
approved Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-448-A, " Control Room Habitability,"
revision 3. 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).
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation ENO 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-A, revision 3. ENO has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Palisades Nuclear Plant (PNP) and justify this amendment for the incorporation of the changes to the PNP TS.
2.2 Optional Changes and Variations ENO is proposing minor variations and deviations from the TS changes described in TSTF-448-A, revision 3, or the applicable parts of the NRC staff's model safety evaluation dated January 17, 2007. The deviations are provided below. The proposed deviations reflect plant-specific design, current licensing basis, and plant-specific variations from NUREG-1432, "Standard Technical Specifications Combustion Engineering Plants."
Deviations have been made to reflect the facility specific nomenclature, reference, or system description.
"Control Room Ventilation Filtration" is used in lieu of "Control Room Emergency Air Cleanup System."
This change was made during the PNP conversion to the NUREG-1432 format TS, which the NRC approved on November 30, 1999.
Additionally, PNP does not have demisters. Accordingly, the reference to demisters in model safety evaluation Section 2.2 is not applicable to PNP.
Page 1 of 5
ENCLOSURE 1 DESCRIPTI ON O F REQUESTE D CHANGES A deviation was made to the wording of TS 3.7.10 Condition B, Required Action B.2, to reflect the PNP design. The design basis for the CRV Filtration does not include quantitative limits for exposure to chemical or smoke hazards. A hazardous chemical evaluation was performed in accordance with Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room during a Postulated Hazardous Chemical Release," dated December 2001. The evaluation did not credit CRV Filtration and showed that CRE occupants are protected from hazardous chemical releases. A habitability assessment for smoke was performed in accordance with Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," dated May 2003.
The assessment documented the qualitative assessment of smoke events at PNP. Smoke from a single credible onsite smoke event will not enter both the control room envelope (CRE) and alternate shut down panel area. Therefore, CRV Filtration is not required to demonstrate a habitable CRE following chemical or smoke releases.
PNP does not have a toxic gas initiation signal or equivalent.
Current PNP TS does not have the note above STS 3.7.10, Required Action D.1.
Therefore, the change to the note is not applicable.
Deviations have been made to establish consistency with the current PNP TS.
During the conversion to the STS format, references to Modes 5 and 6 were removed from TS 3.7.10, Conditions D and E. These conditions do not reference specific modes; however, the conditions are applicable during core alterations, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the spent fuel pool. ENO proposes to retain current licensing basis requirements. Therefore, the proposed revision to TS 3.7.10, Condition E, does not contain Mode references.
The proposed TS require moving information from the current pages to different pages. As shown in the proposed changes, TS 3.7.10, Condition C would move from page 3.7.10-1 to 3.7.10-2 to accommodate the additional text in Condition B.
Additionally, TS 3.7.10, Condition E would move from page 3.7.10-2 to 3.7.10-3 due to this addition.
Also, TS 3.7.10 Surveillance Requirements would move from page 3.7.10-3 to new 3.7.10-4.
Page numbering for TS Section 5.5 would be affected by the addition of TS 5.5.16, "Control Room Habitability Program."
Currently TS pages 5.0-14 to 5.0-16 are blank pages retained for page numbering. TS pages 5.0-17 to 5.0-23 would be renumbered to become pages 5.0-14 to 5.0-20.
The proposed addition of TS 5.5.16 is provided on page 5.0-21. TS Page 2 of 5
ENCLOSURE 1 D ESCRIPTI ON OF REQUESTED CHANGES pages 5.0-22 and 5.0-23 would be retained for numbering. The remaining pages in TS Section 5.5 would remain unaffected by these page numbering changes.
For the above page number changes, the corresponding Amendment numbers have been changed to reflect the Amendment numbers associated with the text.
ENO reviewed the TS Bases changes provided with TSTF-448-A.
ENO's proposed TS Bases changes meet the intent of the TSTF-448-A changes and are included in Enclosure 4 for information only.
The deviations provided above do not affect the no significant hazards consideration determination (NSHCD) or the environmental evaluation dated January 17, 2007, as part of the CLIIP. The proposed deviations reflect plant-specific design, current licensing basis, and plant-specific variations from NUREG-1432.
ENO proposes changes based upon Evaluation 1 of the model safety evaluation. These changes would revise the action requirements of TS 3.7.10 to acknowledge that an inoperable CRE boundary, depending upon the location of the associated degradation, could cause just one, instead of both CRV Filtration trains to be inoperable.
This is accomplished by revising Condition A to exclude Condition B, and revising Condition B to address one or more CRV Filtration trains, as follows:
Condition A: One CRV Filtration train inoperable for reasons other than Condition B.
Condition B: One or more CRV Filtration trains inoperable due to inoperable CRE boundary in MODE 1, 2, 3, or 4.
This change clarifies how to apply the action requirements in the event just one CRV Filtration train is unable to ensure CRE occupant safety within licensing basis limits because of an inoperable CRE boundary.
It enhances the usability of Conditions A and B with a presentation that is more consistent with the intent of the existing requirements. This change is an administrative change because it neither reduces nor increases the existing action requirements, and, therefore, is acceptable.
ENO proposes to replace existing Required Action B.1, "Restore control room boundary to OPERABLE status," which has a 24-hour Completion Time, with Required Action B.1, to immediately initiate action to implement mitigating actions; Required Action B.2, to verify, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that in the event of a design-basis accident (DBA), CRE occupant radiological Page 3 of 5
ENCLOSURE 1 DESC RIPTION OF REQUESTED CHANGES 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; and Required Action B.3, to restore CRE boundary to operable status within 90 days.
The 24-hour Completion Time of new Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions as directed by Required Action B.1. The 90-day Completion Time of new Required Action B.3 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. The 90-day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary.
Therefore, proposed Action B is acceptable.
2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements ENO proposes the following as a license condition to support implementation of the proposed TS changes:
Upon implementation of Amendment XXX adopting TSTF-448-A, revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7. 10.4, in accordance with TS 5.5.16.c.(i),
the assessment of CRE habitability as required by Specification 5.5.16.c.( ii), and the measurement of CRE pressure as required by Specification 5.5.16. d, shall be considered met.
Following implementation:
(a)
The first performance of SR 3.7.10.4, in accordance with Specification 5.5.16.c.(i), shall be within the specified Frequency of six years, plus the 18-month allowance of SR 3.0.2, as measured from June 26, 2007, the date of the most recent successful tracer gas test, as stated in the August 16, 2007, letter response to Generic Letter 2003-01.
(b)
The first performance of the periodic assessment of CRE habitability, Specification 5.5.16.c.(ii), shall be within three years, plus the nine-month allowance of SR 3.0.2, as measured from June 26, 2007, the date of the most recent Page 4 of 5
ENCLOSURE 1 DESCRIPTION R EQUESTE D CHANGES successful tracer gas test, as stated in the August 16, 2007, letter response to Generic Letter 2003-01.
(c)
The first performance of the periodic measurement of CRE pressure, Specification 5.5.16.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from July 16, 2007, the date of the most recent successful pressure measurement test.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination ENO has reviewed the proposed NSHCD published in the Federal Register as part of the CLIIP. ENO has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to PNP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
4.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007, as part of the CLIIP. ENO has concluded that the staff's findings presented in that evaluation are applicable to PNP and the evaluation is hereby incorporated by reference for this application.
Page 5 of 5
ENCLOSURE 2 LICENSE AMEN DMENT REQUEST : CONTROL ROOM HABITABILITY MARK-UP OF TECHNICAL SPECIFICATION PAGES 3.7.10.1
- 3.7.10-4, 5.0 5.0-23 (showing proposed changes)
(additions are highlighted; deletions are strikethrough) 14 Pages Follow
CRV Filtration 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Ventilation (CRV) Filtration LCO 3.7.10 Two CRV Filtration trains shall be OPERABLE.
NOTE --------------------------------------------
The control room envelope (CRE} boundary may be opened intermittently under administrative control.
APPLICABILITY:
MODES 1,2,3,4, During CORE ALTERATIONS, During movement of irradiated fuel assemblies, During movement of a fuel cask in or over the Spent Fuel Pool (SFP)
ACTIONS CONDITION REQUIRED ACTION I
COMPLETION TIME A.
One CRV Filtration train inoperable for reasons other than Condition B.
B.
TwoOne or more CRV Filtration trains inoperable due to inoperable GRE controlrreer-n boundary in MODE 1,2,3,or4.
A.1 Restore CRV Filtration I
7 days train to OPERABLE status.
B.1 Initiate prepped measures Act;,,n to implement mitigating actions.
AND ANlD estore GRE olroom 32 Restore,'
boundary to OPERABLE status.
,Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 90 dajrs24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Palisades Nuclear Plant 3.7.10-1 Amendment No. 44W-,l 97
CRV Filtration 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.
Required Action and C.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4.
C.2 Be in MODE 5.
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D.
Required Action and DA associated Completion Time of Condition A not met during CORE ALTERATIONS, during OR movement of irradiated Place OPERABLE CRV Filtration train in emergency mode.
Immediately fuel assemblies, or D.2. 1 Suspend CORE Immediately during movement of a ALTERATIONS.
fuel cask in or over the SFP.
AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.
AND D.2.3 Suspend movement of a Immediately fuel cask in or over the SFP.
Palisades Nuclear Plant 3.7.10-2 Amendment No.
1 89, 197
CRV Filtration 3.7.10 CONDITION REQUIRED ACTION COMPLETION TIME E.
Two CRV Filtration trains E.1 inoperable during CORE ALTERATIONS, during movement of irradiated AND fuel assemblies, or during movement of a E.2 fuel cask in or over the SFP.
AND OR E.3 Suspend CORE Immediately ALTERATIONS.
Suspend movement of Immediately irradiated fuel assemblies.
Suspend movement of a Immediately fuel cask in or over the SFP.
F.
Two CRV Filtration trains F.1 inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.
Enter LCO 3.0.3.
1 Immediately Palisades Nuclear Plant 3.7.10-3 Amendment No. 449-,197
CRV Filtration 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRV Filtration train for 31 days
>- 10 continuous hours with associated heater (VHX-26A or VHX-26B) operating.
SR 3.7.10.2 Perform required CRV Filtration filter testing in In accordance with accordance with tEe Ventilation Filter Testing the Ventilation Filter Program.
Testing Program SR 3.7.10.3
NOTE-----------------------------
Only required to be met in MODES 1, 2, 3, and 4, and during movement of irradiated fuel assemblies in containment.
Verify each CRV Filtration train actuates on an 18 months actual or simulated actuation signal.
SR 3.7.10.4 Pef orm required; CRE unfiltered air infea(cage l
accordant with testing to accordance with the Control Room the Control Room Envelope Habitability PrograrmVerify ^ne CRV Envelope Habitability Filtration train can m intain a positive pressure of 0 125 inches water gauge, relative to the adjacent area di uring the emergency mode of operati^n at an emergency ventilation flew rate of 3040 nfm and 9 3520 nfm Pro rarn-t-E7' hs Palisades Nuclear Plant 3 7.10-4 Amendment No.
189
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Secondary Water Chemistry Program A program shall be established, implemented and maintained for monitoring of secondary water chemistry to inhibit steam generator tube degradation and shall include:
a.
Identification of a sampling schedule for the critical variables and control points for these variables, b.
Identification of the procedures used to measure the values of the critical variables, c.
Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in-
- leakage, d.
Procedures for the recording and management of data, e.
Procedures defining corrective actions for all off-control point chemistry conditions, and A procedure identifying (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective actions.
5.5.10 Ventilation Filter Testing Program A program shall be established to implement the following required testing of Control Room Ventilation (CRV) and Fuel Handling Area Ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2 (RG 1.52), and in accordance with RG 1.52 and ASME N510-1989, at the system flowrates and tolerances specified below*:
a.
Demonstrate for each of the ventilation systems that an inplace test of the High Efficiency Particulate Air (HEPA) filters shows a penetration and system bypass < 0.05% for the CRV and < 1.00% for the Fuel Handling Area Ventilation System when tested in accordance with RG 1.52 and ASME IN510-1989:
Ventilation System V-8A or V-8B V-8A and V-8B V-95 or V-96 Flowrate (CFM) 7300 +/- 20%
10,000 +/- 20%
12,500 +/- 10%
Palisades Nuclear Plant 5. 0-,
Amendment No. 189
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Ventilation Filter Testing Program (continued) b.
Demonstrate for each of the ventilation systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.05% for the CRV and < 1.00% for the Fuel Handling Area Ventilation System when tested in accordance with RG 1.52 and ASME N510-1989.
Ventilation System Flowrate (CFM)
V-8A and V-8B 10,000 +/- 20%
V-26A and V-26B 3200 +10% -5%
c.
Demonstrate for each of the ventilation systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in RG 1.52 shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of
<_ 30°C and equal to the relative humidity specified as follows:
Ventilation System Penetration Relative Humidity VF-66 6.00%
95%
VFC-26A and VFC-26B 0.157%
70%
d.
For each of the ventilation systems, demonstrate the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with RG 1.52 and ASME N510-1989:
Ventilation System Delta P (In H20)
Flowrate (CFM)
V-8A and V-8B 6.0 10,000 +/- 20%
VF-26A and VF-26B 8.0 3200 +10% -5%
e.
Demonstrate that the heaters for the CRV system dissipates the following specified value +/- 20% when tested in accordance with ASME N510-1989:
Ventilation System Wattage VHX-26A and VHX-26B 15 kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Ventilation Filter Testing Program frequencies.
Should the 720-hour limitation on charcoal adsorber operation occur during a plant operation requiring the use of the charcoal adsorber - such as refueling - testing may be delayed until the completion of the plant operation or up to 1,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of filter operation; whichever occurs first.
Palisades Nuclear Plant 5.0-`j'-,,"$4-9 Amendment No.
189
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Fuel Oil Testing Program A fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling requirements, testing requirements, and acceptance criteria, based on the diesel manufacturer's specifications and applicable ASTM Standards. The program shall establish the following:
a.
Acceptability of new fuel oil prior to addition to the Fuel Oil Storage Tank, and acceptability of fuel oil stored in the Fuel Oil Storage Tank, by determining that the fuel oil has the following properties within limits:
API gravity or an absolute specific gravity, 2.
Kinematic viscosity, and 3.
Water and sediment content.
b.
Other properties of fuel oil stored in the Fuel Oil Storage Tank, specified by the diesel manufacturers or specified for grade 2D fuel oil in ASTM D 975, are within limits.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Fuel Oil Testing Program.
5.5.12 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.
a.
Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
b.
Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:
A change in the TS incorporated in the license; or 2.
A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
Palisades Nuclear Plant 5 0 115 Amendment No. 4-89, 204
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Technical Specifications (TS) Bases Control Program (continued) c.
The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.
d.
Proposed changes that meet the criteria of Specification 5.5.12.b. above shall be reviewed and approved by the NRC prior to implementation.
Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).
5.5.13 Safety Functions Determination Program (SFDP)
This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists.
Additionally, other appropriate limitations and remedial or compensatory actions may be identified to be taken as a result of the support system inoperability and corresponding exception to entering supported system Condition and Required Actions. This program implements the requirements of LCO 3.0.6. The SFDP shall contain the following:
a.
Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected; b.
Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists; c.
Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and d.
Other appropriate limitations and remedial or compensatory actions.
A loss of safety function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be performed.
For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:
a.
A required system redundant to system(s) supported by the inoperable support system is also inoperable; or b.
A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable; or Palisades Nuclear Plant 5.0-1"7`28 Amendment No. 189
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Safety Functions Determination Program (SFDP)
(continued)
A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable.
The SFDP identifies where a loss of safety function exists.
If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
5.5.14 Containment Leak Rate Testing Program a.
A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines of Regulatory Guide 1.163, "Performance-Based Containment Leakage-Test Program," dated September 1995, as modified by the following exceptions:
Leakage rate testing is not necessary after opening the Emergency Escape Air Lock doors for post-test restoration or post-test adjustment of the air lock door seals. However, a seal contact check shall be performed instead.
Emergency Escape Airlock door opening, solely for the purpose of strongback removal and performance of the seal contact check, does not necessitate additional pressure testing.
2.
Leakage rate testing at Pa is not necessary after adjustment of the Personnel Air Lock door seals.
However, a between-the-seals test shall be performed at >_10 psig instead.
3.
Leakage rate testing frequency for the Containment 4 inch purge exhaust valves, the 8 inch purge exhaust valves, and the 12 inch air room supply valves may be extended up to 60 months based on component performance.
b.
The calculated peak containment internal pressure for the design basis loss of coolant accident, Pa, is 53 psig. The containment design pressure is 55 psig.
c.
The maximum allowable containment leakage rate, La, at Pa, shall be 0.1 % of containment air weight per day.
Palisades Nuclear Plant 5.0 1841-Amendment No. 4-89,194
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Containment Leak Rate Testing Program (continued) d.
Leakage rate acceptance criteria are:
Containment leakage rate acceptance criteria is <_ 1.0 La.
During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and Type C tests and < 0.75 La for Type A tests.
2.
Air lock testing acceptance criteria are:
a)
Overall air lock leakage is <_ 1.0 La when tested at >_ Pa and combined with all penetrations and valves subjected to Type B and C tests. However, during the first unit startup following testing performed in accordance with this program, the leakage rate acceptance criteria is < 0.6 La when combined with all penetrations and valves subjected to Type B and C tests.
b)
For each Personnel Air Lock door, leakage is < 0.023 La when pressurized to >_ 10 psig.
c)
For each Emergency Escape Air Lock door, a seal contact check
, consisting of a verification of continuous contact between the seals and the sealing surfaces, is acceptable.
e.
"Containment OPERABILITY" is equivalent to "Containment Integrity" for the purposes of the testing requirements.
The provisions of SR 3.0.3 are applicable to the Containment Leak Rate Testing Program requirements.
Nothing in these Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J.
Palisades Nuclear Plant 5.0-1922 Amendment No. 4-99,194
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Process Control Program a.
The Process Control Program shall contain the current formula, sampling, analyses, tests, and determinations to be made to ensure that the processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR 20, 10 CFR 71, Federal and State regulations, and other requirements governing the disposal of the radioactive waste.
b.
Changes to the Process Control Program:
Shall be documented and records of reviews performed shall be retained as required by the Quality Program, CPC-2A. This documentation shall contain:
a)
Sufficient information to support the change together with the appropriate analyses or evaluation justifying the change(s) and b)
A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of Federal, State, or other applicable regulations.
2.
Shall become effective after approval by the plant superintendent.
Palisades Nuclear Plant 5 0=2023 Amendment No.
, 194
Programs and Manuals 5.5 5.5 Programs and Manuals Palisades Nuclear Plant 5.0-21 Amendment No.
Programs and Manuals 5.5 5.5 Programs and Manuals This page retained for page numbering Palisades Nuclear Plant 5.0-22 Amendment No.
Programs and Manuals 5.5 5.5 Programs and Manuals This page retained for page numbering Palisades Nuclear Plant 5.0-23 Amendment No.
ENCLOSURE 3 LICENSE AMEN DMENT REQUEST: CONTROL ROOM HABITABILITY REVISED TECHNICAL SPECIFICATION PAGES 3.7.10.1
- 3.7.10-4, 5.0 5.0-23 14 Pages Follow
CRV Filtration 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Ventilation (CRV) Filtration LCO 3.7.10 Two CRV Filtration trains shall be OPERABLE.
NOTE --------------------------------------------
The control room envelope (CRE) boundary may be opened intermittently under administrative control.
APPLICABILITY :
MODES 1,2,3,4, During CORE ALTERATIONS, During movement of irradiated fuel assemblies, During movement of a fuel cask in or over the Spent Fuel Pool (SFP)
ACTIONS CONDITION I
REQUIRED ACTION COMPLETION TIME A.
One CRV Filtration train A.1 Restore CRV Filtration 7 days inoperable for reasons train to OPERABLE status.
other than Condition B.
B.
One or more CRV B.1 Initiate action to implement Immediately Filtration trains mitigating actions.
inoperable due to inoperable CRE AND boundary in MODE 1, 2, 3, or 4.
B.2 Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant radiological exposures will not exceed limits, and CRE occupants are protected from chemical and smoke hazards.
AND B.3 Restore CRE boundary to 90 days OPERABLE status.
Palisades Nuclear Plant 3.7.10-1 Amendment No.
- 497,
CRV Filtration 3.7.10 ACTIONS CONDITION REQUIRED ACTION I COMPLETION TIME C.
Required Action and C.1 associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or4.
C.2 D.
Required Action and D.1 Place OPERABLE CRV Immediately associated Completion Filtration train in Time of Condition A not emergency mode.
met during CORE ALTERATIONS, during OR movement of irradiated fuel assemblies, or D.2.1 Suspend CORE Immediately during movement of a ALTERATIONS.
fuel cask in or over the SFP.
AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.
AND D.2.3 Suspend movement of a Immediately fuel cask in or over the SFP.
Be in MODE 3.
( 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Be in MODE 5.
1 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Palisades Nuclear Plant 3.7.10-2 Amendment No. 499, 497,
CRV Filtration 3.7.10 CONDITION REQUIRED ACTION COMPLETION TIME E.
Two CRV Filtration trains E.1 inoperable during CORE ALTERATIONS, during movement of irradiated AND fuel assemblies, or during movement of a E.2 fuel cask in or over the SFP.
AND OR E.3 One or more CRV Filtration trains inoperable due to an inoperable CRE boundary during CORE ALTERATIONS, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the SFP.
F.
Two CRV Filtration trains F.1 inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.
Suspend CORE I
Immediately ALTERATIONS.
Suspend movement of I Immediately irradiated fuel assemblies.
Suspend movement of a Immediately fuel cask in or over the SFP.
Enter LCO 3.0.3.
1 Immediately Palisades Nuclear Plant 3.7.10-3 Amendment No. 4-N, 4
CRV Filtration 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRV Filtration train for 31 days
>_ 10 continuous hours with associated heater (VHX-26A or VHX-26B) operating.
SR 3.7.10.2 Perform required CRV Filtration filter testing in In accordance with accordance with the Ventilation Filter Testing the Ventilation Filter Program.
Testing Program SR 3.7.10.3
NOTE-----------------------------
Only required to be met in MODES 1, 2, 3, and 4, and during movement of irradiated fuel assemblies in containment.
Verify each CRV Filtration train actuates on an 18 months actual or simulated actuation signal.
SR 3.7.10.4 Perform required CRE unfiltered air inleakage In accordance with testing in accordance with the Control Room the Control Room Envelope Habitability Program.
Envelope Habitability Program Palisades Nuclear Plant 3.7.10-4 Amendment No.
4-89,
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Secondary Water Chemistry Program A program shall be established, implemented and maintained for monitoring of secondary water chemistry to inhibit steam generator tube degradation and shall include:
a.
Identification of a sampling schedule for the critical variables and control points for these variables, b.
Identification of the procedures used to measure the values of the critical variables, Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in-
- leakage, 5.5.10 d.
Procedures for the recording and management of data, e.
Procedures defining corrective actions for all off-control point chemistry conditions, and f.
A procedure identifying (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective actions.
Ventilation Filter Testing Program A program shall be established to implement the following required testing of Control Room Ventilation (CRV) and Fuel Handling Area Ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2 (RG 1.52), and in accordance with RG 1.52 and ASME N510-1989, at the system flowrates and tolerances specified below*:
a.
Demonstrate for each of the ventilation systems that an inplace test of the High Efficiency Particulate Air (HEPA) filters shows a penetration and system bypass < 0.05% for the CRV and < 1.00% for the Fuel Handling Area Ventilation System when tested in accordance with RG 1.52 and ASME N510-1989:
Ventilation System V-8A or V-8B V-8A and V-8B V-95 or V-96 Flowrate (CFM) 7300 +/- 20%
10,000 +/- 20%
12,500 +/- 10%
Palisades Nuclear Plant 5.0-14 Amendment No. 4-99,
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Ventilation Filter Testing Program (continued) b.
Demonstrate for each of the ventilation systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.05% for the CRV and < 1.00% for the Fuel Handling Area Ventilation System when tested in accordance with RG 1.52 and ASME N510-1989.
Ventilation System Flowrate (CFM)
V-8A and V-8B 10,000 +/- 20%
V-26A and V-26B 3200 +10% -5%
c.
Demonstrate for each of the ventilation systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in RG 1.52 shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 5 30°C and equal to the relative humidity specified as follows:
Ventilation System Penetration Relative Humidity VF-66 6.00%
95%
VFC-26A and VFC-26B 0.157%
70%
d.
For each of the ventilation systems, demonstrate the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with RG 1.52 and ASME N510-1989:
Ventilation System Delta P (In HQ Flowrate (CFM)
V-8A and V-8B 6.0 10,000 +/- 20%
VF-26A and VF-26B 8.0 3200 +10% -5%
e.
Demonstrate that the heaters for the CRV system dissipates the following specified value +/- 20% when tested in accordance with ASME N510-1989:
Ventilation System Wattage VHX-26A and VHX-26B 15 kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Ventilation Filter Testing Program frequencies.
Should the 720-hour limitation on charcoal adsorber operation occur during a plant operation requiring the use of the charcoal adsorber - such as refueling - testing may be delayed until the completion of the plant operation or up to 1,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of filter operation; whichever occurs first.
Palisades Nuclear Plant 5.0-15 Amendment No. 489,
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Fuel Oil Testing Program A fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling requirements, testing requirements, and acceptance criteria, based on the diesel manufacturer's specifications and applicable ASTM Standards. The program shall establish the following:
a.
Acceptability of new fuel oil prior to addition to the Fuel Oil Storage Tank, and acceptability of fuel oil stored in the Fuel Oil Storage Tank, by determining that the fuel oil has the following properties within limits:
1.
API gravity or an absolute specific gravity, 2.
Kinematic viscosity, and 3.
Water and sediment content.
5.5.12 b.
Other properties of fuel oil stored in the Fuel Oil Storage Tank, specified by the diesel manufacturers or specified for grade 2D fuel oil in ASTM D 975, are within limits.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Fuel Oil Testing Program.
Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.
a.
Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
b.
Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:
A change in the TS incorporated in the license; or 2.
A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
Palisades Nuclear Plant 5.0-16 Amendment No. 4-99, 204,
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Technical Specifications (TS) Bases Control Program (continued)
The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.
d.
Proposed changes that meet the criteria of Specification 5.5.12.b. above shall be reviewed and approved by the NRC prior to implementation.
Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).
5.5.13 Safety Functions Determination Program (SFDP)
This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists.
Additionally, other appropriate limitations and remedial or compensatory actions may be identified to be taken as a result of the support system inoperability and corresponding exception to entering supported system Condition and Required Actions. This program implements the requirements of LCO 3.0.6. The SFDP shall contain the following:
a.
Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected; b.
Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists; c.
Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and d.
Other appropriate limitations and remedial or compensatory actions.
A loss of safety function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be performed.
For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:
a.
A required system redundant to system(s) supported by the inoperable support system is also inoperable; or b.
A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable; or Palisades Nuclear Plant 5.0-17 Amendment No.
4-99,
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Safety Functions Determination Program (SFDP)
(continued)
A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable.
5.5.14 The SFDP identifies where a loss of safety function exists.
If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
Containment Leak Rate Testing Program a.
A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines of Regulatory Guide 1.163, "Performance-Based Containment Leakage-Test Program," dated September 1995, as modified by the following exceptions:
Leakage rate testing is not necessary after opening the Emergency Escape Air Lock doors for post-test restoration or post-test adjustment of the air lock door seals. However, a seal contact check shall be performed instead.
Emergency Escape Airlock door opening, solely for the purpose of strongback removal and performance of the seal contact check, does not necessitate additional pressure testing.
2.
Leakage rate testing at Pa is not necessary after adjustment of the Personnel Air Lock door seals.
However, a between-the-seals test shall be performed at >_10 psig instead.
3.
Leakage rate testing frequency for the Containment 4 inch purge exhaust valves, the 8 inch purge exhaust valves, and the 12 inch air room supply valves may be extended up to 60 months based on component performance.
b.
The calculated peak containment internal pressure for the design basis loss of coolant accident, Pa, is 53 psig. The containment design pressure is 55 psig.
c.
The maximum allowable containment leakage rate, La, at Pa, shall be 0.1 % of containment air weight per day.
Palisades Nuclear Plant 5.0-18 Amendment No. 4189, 4-94,
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Containment Leak Rate Testing Program (continued) d.
Leakage rate acceptance criteria are:
1.
Containment leakage rate acceptance criteria is <_ 1.0 La.
During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and Type C tests and _< 0.75 La for Type A tests.
2.
Air lock testing acceptance criteria are:
a)
Overall air lock leakage is <_ 1.0 La when tested at >_ Pa and combined with all penetrations and valves subjected to Type B and C tests. However, during the first unit startup following testing performed in accordance with this program, the leakage rate acceptance criteria is < 0.6 La when combined with all penetrations and valves subjected to Type B and C tests.
b)
For each Personnel Air Lock door, leakage is _< 0.023 La when pressurized to >_ 10 psig.
c)
For each Emergency Escape Air Lock door, a seal contact check
, consisting of a verification of continuous contact between the seals and the sealing surfaces, is acceptable.
e.
"Containment OPERABILITY" is equivalent to "Containment Integrity" for the purposes of the testing requirements.
The provisions of SR 3.0.3 are applicable to the Containment Leak Rate Testing Program requirements.
g.
Nothing in these Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J.
Palisades Nuclear Plant 5.0-19 Amendment No. 489,1-94,
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Process Control Program a.
The Process Control Program shall contain the current formula, sampling, analyses, tests, and determinations to be made to ensure that the processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR 20, 10 CFR 71, Federal and State regulations, and other requirements governing the disposal of the radioactive waste.
b.
Changes to the Process Control Program:
1.
Shall be documented and records of reviews performed shall be retained as required by the Quality Program, CPC-2A. This documentation shall contain:
a)
Sufficient information to support the change together with the appropriate analyses or evaluation justifying the change(s) and b)
A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of Federal, State, or other applicable regulations.
2.
Shall become effective after approval by the plant superintendent.
Palisades Nuclear Plant 5.0-20 Amendment No.
9,.1-94,
Programs and Manuals 5.5 5.5 Prog rams and Manuals 5.5.16 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 Ventilation (CRV) Filtration, 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 by one train of the CRV Filtration, operating at the flow rate required by the Ventilation Filter Testing Program, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 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 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.
Palisades Nuclear Plant 5.0-21 Amendment No.
Programs and Manuals 5.5 5.5 Programs and Manuals This page retained for page numbering Palisades Nuclear Plant 5.0-22 Amendment No.
Programs and Manuals 5.5 5.5 Programs and Manuals This page retained for page numbering Palisades Nuclear Plant 5.0-23 Amendment No.
ENCLOSURE 4 LICENSE AMEN DMENT REQUEST: CONTROL ROOM HABITABILITY MARK-UP OF TECHNICAL SPECIFICATION BASES PAGES 3.7.10-1
- 3.7.10-9 (showing proposed changes)
(additions are highlighted; deletions are strikethrough)
(proposed changes are provided for information only) 9 Pages Follow
CRV Filtration B 3.7.10 B 3.7 PLANT SYSTEMS B 3.7.10 Control Room Ventilation (CRV) Filtration BASES BACKGROUND The CRV Filtration provides a protected environment from which hers occupants can control the plant following an uncontrolled release of radioactivity.
The CRV Filtration consists of a common emergency intake which splits into two independent, redundant trains that recirculate and filter 11 the air in the control room envelope (GRE} air and a CRE boundary thaf limits fhe m[eakage of unfiltered air. The exhaust of each train exhausts into a common supply plenum.
Each train consists of a prefilter, a heater, a High Efficiency Particulate Air (HEPA) filter, two banks of activated charcoal adsorbers for removal of gaseous activity (principally iodines), a second HEPA filter, and a fan.
- Ductwork, valves or dampers, doors, barriers;' and instrumentation also form part of the system. A second bank of HEPA filters follows the adsorber section to collect carbon fines, and provides to--back up in case of fa lure o the main HEPA filter bank-4
- ails.
The CRV Filtration is an emergency system, part of which may also operate during normal plant operations in the standby mode of operation.
Upon manual initiation or receipt of a containment high pressure or containment high radiation signal, normal air supply to the CRE control room is isolated, and the stream of ventilation air is recirculated through the filter trains of the system. The prefilters remove any large particles in the air.
Continuous operation of each train for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month;, with the heaters on reduces moisture buildup on the HEPA filters and adsorbers. The heater is important to the effectiveness of the charcoal adsorbers.
Palisades Nuclear Plant B 3.7.10-1 Revised xx/xx/200x
CRV Filtration B 3.7.10 BASES BACKGROUND Actuation of the system to the emergency mode of operation closes the normal (continued) unfiltered outside air intake and unfiltered exhaust dampers, opens the emergency air intake, and aligns the system for recirculation of the air within the R
through the redundant trains of HEPA and charcoal filters.
The emergency mode aisoxinitiates pressurization and filtered ventilation of the air supply to the EGORtFOI Outside air is filtered, and then added to the air being recirculated from the, RE control ream.
Pressurization of the CRE 4
GGn#G14-G^
prevents infiltration of unfiltered air through the CRE boundary from all the surrounding boundary^f + ie buil ing areas adjacent to W,, RF A single train will pressurize the CRE sentrelrester to at least 0 125 inches water gauge relative to external areas adjacent to the CREboundary hallway outside the Gentrel Reern Viewing
, and provides an air exchange rate in excess of 25% per hour. The CRV Filtration operation in maintaining the CRC= con trol roo habitable is discussed in the FSAR, Section 9.8 (Ref. 1).
Redundant supply and recirculation trains provide the required filtration should an excessive pressure drop develop across one filter train.
Normally open isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The CRV Filtration is designed in accordance with Seismic Category I requirements.
The CRV Filtration is designed to maintain a habitable environment art the CRE the control room enviro Rent for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem whole body dose or its equivalent to any part of the body.
APPLICABLE The CRV Filtration components are arranged in redundant safety SAFETY ANALYSES related ventilation trains. The location of components and ducting within the CF ensures an adequate supply of filtered air to all areas requiring access.
Palisades Nuclear Plant B 3.7.10-2 Revised xx/xx/200x The CRV Filtration provides airborne radiological protection for the GRE occupants as demonstrated by the ORE occupant dose analyses for the most limiting design basis events discussed in the FSAR, Chapter 14 (Ref. 2).
CRV Filtration B 3.7.10 BASES APPLICABLE SAFETY ANALYSES (continued)
The worst case single active failure of a component of the CRV Filtration, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.
The CRV Filtration satisfies Criterion 3 of 10 CFR 50.36(c)(2).
LCO Two independent and redundant trains of the CRV Filtration are required to be OPERABLE to ensure that at least one is available, ass g if that a single acf ve failure disables the other train. Total system failuresuch as from Ioss ble:GRE boundary,, could result in a a dose in eXGeSe of 5 reri : iihole
!y5-rem in the event of a large radioactive release.
EachT-he CRV Filtration trai is considered OPERABLE when the individual components necessary to grater limit CRE occupant exposure are OPERABLE in both trains. A CRV Filtration train is considered OPERABLE when the associated:
a.
Main recirculation fan and emergency filter fan are OPERABLE; b.
HEPA filters and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functions; and Required heater, ductwork, valves, and dampers are OPERABLE, ad "air circulation canybe maintained" In order for the CRV Filtration trains 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.
125 inches w 0
ater e positive p au ressure can be maintained in the emergency mo g
g de.
This LCO is modified by a Note allowing the' tse si room boundary to be opened intermittently under administrative control This Note only applies to condition, such as doors, hatches, floor plugs, artd access panels ; Since this Note modifies the LCO, no Condition entry is required when the control room boundary is opened under its provisions.
For entry and exit through doors, the Palisades Nuclear Plant B 3. 7.10-3 Revised xx/xx/200x
CRV Filtration B 3.7.10 BASES nsurethat APPLICABILITY In MODES 1, 2, 3, and 4, the CRV Filtration must be OPERABLE to th'e C_RE will remain habitabl expesure during and following a DBA.
In MODES 5 and 6, the probability and consequences of a Design Basis Accident are reduced due to the pressure and temperature limitations in these MODES.
Therefore, maintaining CRV Filtration OPERABLE is not required in MODE 5 or 6, except for the following situations under which significant radioactive releases can be postulated:
a.
During CORE ALTERATIONS; b.
During movement of irradiated fuel assemblies; and During movement of a fuel cask in or over the SFP.
ACTIONS A_1 With one CRV Filtration train inoperable,
, or reasonstiother than an tnoperab[e CRE boundary, action must be taken to restore OPERABLE status within 7 days.
In this Condition, the remaining OPERABLE CRV Filtration subsystem train is adequate to perform the GR occupant control roo rad iatieR protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CRV Filtration train could result in loss of CRV Filtration function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and the ability of the remaining train to provide the required capability.
Palisades Nuclear Plant B 3.7.10-4 Revised xx/xx/200x B1,B2; andB.23
CRV Filtration B 3.7.10 BASES ACTIONS (continued) i o r t h e n f re n^ h et^nd Ee+^tr i s i r^o n^a ble inn MODE 1 s-or A th 3
e CRV my a
o^
erfor Filtration trains Gannet p
TT^Tw-^
m their functions Actions m ust btaken to p
PERABLE contr restere an ol roombeyndary within 21 heu rs D u the rin O
g compensatory measures (con sistent With the intent of Ge neral Des ign Criterion 19 ) shall be utilized to protect control room opera tors from potential hazards such as rad ioactive contamination toxin chemica ls nr and to ensure control smoke roomhyiral securit Rr ed e
measures shall be available t y.
e address these GE)nGerns fG F"Rtentie nal and intotheC unintentional ent ondition The224 hn GGM
!eti E)R Tim e is ry P
aRd the use of com measures Th ensator 7
e 24 hourCom letion TiReis a reaso nable y
p time to diagnose and repair m p
T ost problems occurring with the cont rol room beti C.1 and C.2 In BODE 1, 2,:3, or 4, f-I4 the inoperable CRV Filtration train or the CRE controlreem boundary cannot be restored to OPERABLE status within the required Completion Time of Condition A or B inMODET23, e r the plant must be placed in a MODE that minimizes the accident risk. To achieve this status, the plant must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times Palisades Nuclear Plant B 3.7.10-5 Revised xx/xx/200x
CRV Filtration B 3.7.10 BASES ACTIONS are reasonable, based on operating experience, to reach the required plant (continued )
conditions from full power conditions in an orderly manner and without challenging plant systems.
D.1. D.2.1. D.2.2. and D.2.3 During CORE ALTERATIONS, during movement of irradiated fuel assemblies, during movement of a fuel cask in or over the SFP, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CRV Filtration train must be immediately placed in the emergency mode of operation. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure will be readily detected.
An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE This places the plant in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies or a fuel cask to a safe position.
E.1, E.2, and E.3 During CORE ALTERATIONS, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the SFP, with two CRV Filtration trans inoperable',
r with one or mare GRV Filtration trams inoperable adue to an m©perable GRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the' REco t el-Keep. This places the plant in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies or a fuel cask to a safe position.
F.1 If both CRV Filtration trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CREeer m boundary (i.e.,
Condition B), the CRV Filtration may not be capable of performing the intended function and the plant is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.
Palisades Nuclear Plant B 3.7.10-6 Revised xx/xx/200x
CRV Filtration B 3.7.10 BASES SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system.
Monthly heater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air. Each train must be operated for
>_ 10 continuous hours with the associated heater, VHX-26A or VHX-26B, energized. The 31 day Frequency is based on the known reliability of the equipment, and the two train redundancy available.
SR 3.7.10.2 This SR verifies that the required CRV Filtration testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CRV Filtration filter tests are in accordance with Regulator Gu ide 1
.52 (Ref. 3) as d'^robed the VFTP. The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).
Specific test, requencies and additional information are discussed in detail in the VFTP.
SR 3.7.10.3 This SR verifies that each CRV Filtration train starts and operates on an actual or simulated actuation signal.
Specific signals (e.g., containment high pressure, containment high radiation) are tested under Section 3.3, "Instrumentation."
This SR is modified by a Note which states this SR is only required to be met in MODES 1, 2, 3 and 4 and during movement of irradiated fuel assemblies in containment. The instrumentation providing the input signal is not required in othere plant conditions, therefore, to keep consistency with Section 3. 3, "Instrumentation," the SR is not required F
w to be met. Tk e. Freuuencu of 18,months; is based on` industru operating Palisades Nuclear Plant B 3.7.10-7 Revised xx/xx/200x
CRV Filtration B 3.7.10 BASES SURVEILLANCE REQUIREMENTS (Continued)
SIR 3.7.10.4 SR verifie s the integrity o Thi f the con trol room enclosure and the s
e rates of umed leaka s
otentiallv contam inated air The control p
g a
s
^9 r as,
a e mods D
rin the emer enc of operati on the GRV Filtration is desi ned u
g g
y rize the control room to press
^ 0 125 g
inches water gau e
ositive u
ect to adjac with res r
r ent area g
p s
in order to prevent unfiltered p
p essu e k
The CRV Filtration a
Rl is desig ned to maintain this ositive age.
ea ss
^rewn ith one train at an c r emer enc p
ventilation flow rate of ^ 3040 e
nfm The FTe nd
^ 3520 f R; g
n o
FeR y
the f
1 8 months is consistent with the with p
E
!^
a EG guirdaTceprovided in NU R EG y
q
-08v0, S
-08 00, vi i a
^rcr rrv ection 6.4(Ref.
4).
Palisades Nuclear Plant B 3.7.10-8 Revised xx/xx/200x
CRV Filtration B 3.7.10 BASES REFERENCES 1.
FSAR, Section 9.8 2.
FSAR, Chapter 14 3.
Reaulatorv Gui 4.
NUREG-0800,Sectien 6.4, Rev. 2, July 1981 Palisades Nuclear Plant B 3.7.10-9 Revised xx/xx/200x 4
NEI :99 03, "control Room Habitability Assessment,"June 2001.