ML072680852
| ML072680852 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/18/2007 |
| From: | Allen B FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PY-CEI/NRR-3059L | |
| Download: ML072680852 (28) | |
Text
FENOC Perry Nuclear Power Station
"""1%
10 Center Road FirstEnergy Nuclear Operating Company Perry, Ohio 44081 440-280-5382 Barry S. Allen Fax. 440-280-8029 Vice President 10 CFR 50.90 September 18, 2007 PY-CEI/NRR-3059L ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Perry Nuclear Power Plant Docket Number 50-440; License Number NPF-58
Subject:
License Amendment Request 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, a license amendment is requested for the Perry Nuclear Power Plant (PNPP). The proposed amendment would modify Technical Specification (TS) requirements related to control room envelope habitability in accordance with Technical Specification Task Force (TSTF) Traveler TSTF-448 Revision 3, and the Consolidated Line Item Improvement Process (CLIIP).
The Enclosure provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachments to the Enclosure provide markups of the existing TS pages, revised (clean) TS pages, and markups of the TS Bases pages (for information). Approval of the proposed license amendment is requested by March 31, 2008, with the amendment to be implemented within 120 days.
No new regulatory commitments are contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 761-6071.
I declare under penalty of perjury that the foregoing is true and correct. Executed on September /6
, 2007 Barry S. Allen
Enclosure:
Evaluation of the Proposed License Amendment cc:
NRC Project Manager NRC Resident Inspector NRC Region III State of Ohio
Enclosure PY-CEI/NRR-3059L Page 1 of 5 EVALUATION OF THE PROPOSED LICENSE AMENDMENT
Subject:
License Amendment Request to Modify the Perry Nuclear Power Plant Technical Specifications Related to Control Room Envelope Habitability in accordance with TSTF-448, Revision 3, using the Consolidated Line Item Improvement Process
- 1. DESCRIPTION
- 2. ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations 2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements
- 3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Determination 3.2 Commitments
- 4.
ENVIRONMENTAL EVALUATION Attachments:
- 1. Proposed Technical Specification Changes (Mark Up)
- 2. Proposed Technical Specification Changes (Re-typed)
- 3. Proposed Technical Specification Bases Pages (Mark Up)
Enclosure PY-CEI/NRR-3059L Page 2 of 5
1.0 DESCRIPTION
The proposed amendment would modify the Perry Nuclear Power Plant (PNPP) Technical Specification (TS) requirements related to control room envelope habitability in TS 3.7.3, Control Room Emergency Recirculation (CRER) System, and in TS Section 5.5, Administrative Controls - Programs and Manuals.
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Traveler TSTF-448, 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). to this Enclosure provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides retyped TS pages, for information only. provides existing TS Bases pages marked up to show proposed changes and is provided for information only. Technical Specification and Bases pages will be revised and repaginated as necessary to reflect the TS changes being proposed by this request.
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation The FirstEnergy Nuclear Operating Company (FENOC) has reviewed the NRC staff's model safety evaluation (SE) dated January 9, 2007, which was published in the Federal Register on January 17, 2007, as well as the supporting information provided to support TSTF-448.
FENOC has concluded that the justifications presented in the TSTF proposal and in the model SE prepared by the NRC staff are applicable to PNPP, and justify the amendment to incorporate these changes into the PNPP TS. With regard to Section 3.3 of the model SE, it has been determined that Evaluations No. 2, 5 and 6 are applicable to PNPP, with the following clarification for Evaluation 6.
Evaluation 6 in the model SE addresses relocation of the pressurization test of the overall Control Room Envelope (CRE) from Surveillance Requirement (SR) 3.7.3.4 into the Control Room Envelope Habitability Program (as sub-item d), and replacement of the CRE pressurization SR with an inleakage SR. At PNPP, the test required to be performed by SR 3.7.3.4 is different than the Standard Technical Specification SR 3.7.3.4, but the justification for relocating the PNPP test is consistent with the model SE's Evaluation 6. The PNPP SR requires a pressurization/leakage test of six CRER outside air intake and exhaust dampers. Because the PNPP CRER system is a neutral-pressure design rather than a pressurized design, this damper component test was substituted for the standard pressurization test when the original PNPP TS were developed. Relocating the PNPP damper pressurization/leakage test to the CRE Habitability Program as sub-item d (which will continue to require the damper test to be performed at least once per operating cycle) is considered to be enveloped by Evaluation 6 because of the similarity in the action being taken (relocation) and the reason for the relocation. Since the damper test only checks a portion of the CRE, meeting existing PNPP SR 3.7.3.4 is not necessarily a conclusive indication of CRE boundary leak tightness, i.e., CRE boundary OPERABILITY, similar to the discussion in Evaluation 6 for the standard pressurization test. Since the damper component test is not sufficient on its own to ensure ongoing OPERABILITY of the overall CRE envelope, the existing SR 3.7.3.4 test is
Enclosure PY-CEI/NRR-3059L Page 3 of 5 replaced with an ASTM E741 unfiltered air inleakage test of the entire envelope, coupled with the new CRE Habitability Program in TS Section 5.5, as also discussed in Evaluation 6.
2.2 Optional Changes and Variations
- The term "CRER" has been utilized in place pf.the bracketed terms [CREEVS] and [CRFA]
throughout this amendment request, to be consistent with PNPP-specific terminology.
- The model safety evaluation, the model Control Room Envelope Habitability Program, and the TSTF-448 Bases markups contain bracketed phrases implying that the licensee should choose one of the following: [5 rem whole body dose or its equivalent to any part of the body] [5 rem total effective dose equivalent (TEDE)]. The PNPP TS and Bases markups utilize the second bracketed phrase, since as discussed in the PNPP response to Generic Letter 2003-01 dated May 30, 2006, control room dose analyses have only been docketed and approved by the NRC for the Loss Of Coolant Accident (LOCA) and the Fuel Handling Accidents, and these use the Alternative Source Term (AST) 5 rem TEDE acceptance criteria. As. also discussed in the letter dated May 30, 2006, analyses of a Main Steam Line Break Outside Containment, an Instrument Line Break, and a Control Rod Drop Accident were also performed to support the Generic Letter response, and the results were compared against the 5 rem TEDE criteria. The LOCA event was determined to be the most limiting event for determining PNPP control room inleakage criteria.
- The model safety evaluation, the TSTF-448 TS page markups, and the TSTF-448 Bases markups contain a bracketed phrase [primary or secondary containment]. The PNPP TS markups utilize the phrase "primary containment or fuel handling building" to be consistent with the PNPP plant design.
- The proposed PNPP TS 5.5.14 'Control Room Envelope Habitability Program,' sub-item d contains the relocated pressurization/leakage test of the outside air intake and exhaust dampers in place of the TSTF-448 version of sub-item d, which described the pressurization test of the overall envelope. This variation exists because the PNPP CRER system is a neutral-pressure system, and a periodic pressure measurement test of the overall envelope was never required by the PNPP TS. Sub-item f of the Program is also revised to be consistent with the wording of sub-item d.
Section 2.3 of this LAR proposes a License Condition specifying the schedule for initial performance of new surveillance and assessment requirements. Consistent with an NRC memorandum dated February 2, 2007 (ADAMS Accession No. ML070330657), the 15-month periods described in model License Condition sub-item (a) are corrected to be 18 months (25% of six years).
- Also, sub-item (c) in the proposed PNPP License Condition (see Section 2.3) is revised to include appropriate references to the 24-month damper test, in lieu of the 18 month pressure test.
- The TSTF-448 version of proposed Required Action (RA) B.2 includes words discussing smoke and chemical "limits," which are revised based on the following:
I ý :
I ý Enclosure PY-CEI/NRR-3059L Page 4 of 5 a) Smoke "limits": During development of Revision 3 to TSTF-448, it was agreed that smoke requirements were qualitative rather than quantitative, and the concept of smoke limits was therefore deleted from the Section 5.5 Habitability Program, item e.
In the NRC meeting minutes that agreed to this change to Section 5.5 (see ADAMS accession number ML061310293, page 2 of minutes dated May 12, 2006), it was noted that this was acceptable, because general qualitative requirements for protecting CRE occupants from smoke challenges are retained in the first paragraph of the proposed TS 5.5 Habitability Program, along with a licensing basis discussion in the proposed "Applicable Safety Analyses" section of the Bases for TS 3.7.3, which together adequately address the licensing basis requirements for protecting CRE occupants from smoke. To be consistent with this concept, the markup of RA B.2 in PNPP TS 3.7.3 retains a reference to limits for radiological hazards, but does not include a reference to limits for smoke. The proposed wording of RA B.2 with respect to smoke is consistent with the words used in Evaluation No. 2 of the NRC model safety evaluation; and with the words in the model Bases for RA B.2.
b) Chemical "limits": The explicit reference to limits on inleakage for chemical hazards has also been removed from RA B.2, although it is retained in the new Section 5.5.14.e Program discussion. The control room envelope hazard evaluations for hazardous chemicals stored or transported onsite or near PNPP performed per Regulatory Guide 1.78, Revision 0, do not require that isolation of the normal control room ventilation system be credited. The Applicable Safety Analysis section of the included Bases markup explains that the current PNPP licensing basis for hazardous chemicals does not require a limit on control room inleakage, and therefore, the limit on radiological inleakage is the limiting value for control room inleakage. The proposed wording of RA B.2 with respect to chemicals is consistent with the words used in the NRC model safety evaluation, Evaluation No. 2, and with the-words in the model Bases for RA B.2. In Section 5.5.14.e of the new Control Room Envelope Habitability Program, the reference to limits on inleakage for hazardous chemicals has been retained to require the establishment of quantitative limits if future licensing basis hazard evaluations determine that limits on chemical inleakage are necessary to protect control room envelope occupants.
2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements FENOC 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 SR 3.7.3.4 in accordance with TS 5.5.14.c(i), and the assessment of CRE habitability as required by Specification 5.5.14.c(ii), shall be considered met. Following implementation:
(a) The first performance of SR 3.7.3.4, in accordance with Specification 5.5.14.c(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from December 2004, the date of the most recent successful tracer gas test as stated in the response to Generic Letter 2003-01 dated May 30, 2006, or within the
Enclosure PY-CEI/NRR-3059L Page 5 of 5 next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.14.c(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from December 2004, the date of the most recent successful tracer gas test as stated in the response to Generic Letter 2003-01 dated May 30, 2006, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
(c) The first performance of the periodic measurement of outside air intake and exhaust damper leakage, Specification 5.5.14.d, shall be within 24 months, plus the 184 days allowed by SR 3.0.2, as measured from the date of the most recent successful damper leakage test.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination FENOC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the January 17, 2007 Federal Register as part of the CLIIP. FENOC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to PNPP, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
3.2 Commitments None
4.0 ENVIRONMENTAL CONSIDERATION
FENOC has reviewed the environmental consideration published in the January 17, 2007 Federal Register as part of the CLIIP. FENOC has concluded that the staff's findings presented in that evaluation are applicable to PNPP, and the evaluation is hereby incorporated by reference for this application.
Enclosure, Attachment 1 PY-CEI/NRR-3059L Page 1 of 7 PROPOSED TECHNICAL SPECIFICATION CHANGES MARK-UP
Enclosure, Attachment 1 PY-CEI/NRR-3059L Page 2 of 7 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Recirculation (CRER) System LCO 3.7.3 Two CRER subsystems shall be OPERABLE.
NOTE The Control Room Envelope (CRE) boundary may be opened intermittently under administrative control.
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, During operations with a potential for draining the reactor vessel (OPDRVs).
APPLICABILITY:
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRER subsystem A.1 Restore CRER 7 days inoperable for reasons subsystem to OPERABLE other than Condition B.
status.
B. One or more CRER B.1 Initiate action to implement Immediately subsystems inoperable mitigating actions.
due to inoperable CRE boundary in MODE 1, 2.
AND or 3.
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 (continued)
PERRY - UNIT 1 3.7-4 Amendment No.
Enclosure, Attachment 1 PY-CEI/NRR-3059L Page 3 of 7 CRER System 3.7.3 Actions (Continued)
B.3 Restore CRE boundary to 90 days OPERABLE status.
B-.
81 C. Required Action and C.1 Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or AND B not met in MODE 1, 2, or 3.
B.2 C.2 Be in MODE 4.
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />
NOTE ------------------
D. Required Action and LCO 3.0.3 is not applicable.
associated Completion Time of Condition A C.1 not met during D.1 Place OPERABLE CRER Immediately movement of recently subsystem in irradiated fuel emergency assemblies in the recirculation mode.
primary containment or fuel handling OR building, or during OPDRVs.
G.2.1 D.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in the primary containment and fuel handling building.
AND
- .2.2-D.2.2 Initiate action to suspend Immediately OPDRVs.
(continued)
PERRY - UNIT 1 3.7-5 Amendment No.
Enclosure, Attachment 1 PY-CEI/NRR-3059L Page 4 of 7 CRER System 3.7.3 Actions (Continued)
E. Two CRER subsystems E.1 Enter LCO 3.0.3.
Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.
.E-.--
E.1 F. Two CRER subsystems F.1 Suspend movement of Immediately inoperable during recently irradiated movement of recently fuel assemblies in irradiated fuel the primary assemblies in the containment and fuel primary containment or handling building.
fuel handling building, or during AND OPDRVs.
E.2 OR F.2 Initiate action to suspend Immediately OPDRVs.
One or more CRER subsystems inoperable due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, or during OPDRVs.
(continued)
PERRY - UNIT 1 3.7-6 Amendment No.
Enclosure, Attachment 1 PY-CEI/NRR-3059L Page 5 of 7 CRER System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CRER subsystem for 31 days
_> 10 continuous hours with the heaters operating.
SR 3.7.3.2 Perform required CRER filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).
SR 3.7.3.3 Verify each CRER subsystem actuates on an 24 months actual or simulated initiation signal.
SR 3.7.3.4 Verify leakago through the outside 24-mirths
, ntako and oxhaust damper is within In accordance knits. Perform required CRE unfiltered air with the Control inleaka~qe testing in accordance with the Control Room Envelope Room Envelope Habitability Program.
Habitability Program.
PERRY - UNIT 1 3.7-7 Amendment No.
Enclosure, Att~chmerit 1 PY-CEI/NRR-3059L Page 6 of 7 Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.13.1 Configuration Risk Management Program The Configuration Risk Management Program (CRMP) provides a risk-informed assessment to manage the risk associated with equipment maintenance activities. The program applies to those structures, systems, or components for which a Technical Specification risk-informed Completion Time has been granted. Specifically, this program applies to:
Required Action B.4 of LCO 3.8.1, "AC Sources-Operating" from > 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after entering Condition B.
The program shall include the following:
- a.
Provisions for the control and implementation of the Probabilistic Safety Assessment (PSA) model and methodology.
The PSA model shall be capable of performing assessments evaluating the applicable plant configurations.
- b.
Provisions for performing assessments for preplanned risk-informed activities prior to entering the risk-informed Completion Time.
- c.
Provisions for performing an assessment after entering the risk-informed Completion Time for an unplanned entry into the risk-informed Completion Time.
- d.
Provisions for assessing the need for additional actions after the discovery of subsequent equipment out of service conditions while in the risk-informed Completion Time.
- e.
Provisions for considering other applicable risk significant contributors external to the preplanned activity such as weather conditions, qualitatively or quantitatively.
5.5.14 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Recirculation (CRER) 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 Total Effective Dose Equivalent (TEDE) for the duration of the accident. The program shall include the following elements:
continued PERRY - UNIT 1 5.0-15b Amendment No.
Encl6sure"Attachment 1 PY-CEI/NRR-3059L Page 7 of 7 Programs and Manuals 5.5 5.5 Programs and Manuals (continued)
- a.
The definition of the CRE and the CRE boundary.
- b.
Requirements for maintaining the CRE boundary in its desiqn 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 of leakage through the outside air intake and exhaust dampers at a Frequency of 24 months. The results shall be trended and used as part of the periodic 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 outside air intake and exhaust damper leakage, as required by paragraphs c and d, respectively.
PERRY - UNIT 1 5.0-15c Amendment No.
Enclosure, Attachment 2 PY-CEI/NRR-3059L Page 1 of 7 PROPOSED TECHNICAL SPECIFICATION CHANGES RETYPED (PROVIDED FOR INFORMATION)
Enclosure, Attachment 2 PY-CEI/NRR-3059L Page 2 of 7 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Recirculation (CRER) System LCO 3.7.3 Two CRER subsystems shall be OPERABLE.
NOTE -----------------------------------------
The Control Room Envelope (CRE) boundary may be opened intermittently under administrative control.
APPLICABILITY:
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRER subsystem A.1 Restore CRER 7 days inoperable for reasons subsystem to OPERABLE other than Condition B.
status.
B. One or more CRER B.1 Initiate action to implement Immediately subsystems inoperable mitigating actions.
due to inoperable CRE boundary in MODE 1, 2, AND or 3.
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 (continued)
PERRY - UNIT 1 3.7-4 Amendment No.
Enclosure, -Attachment 2 PY-CEI/NRR-3059L Page 3 of 7 CRER System 3.7.3 Actions (Continued)
B.3 Restore CRE boundary to 90 days OPERABLE status.
C. Required Action and C.1 Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or AND B not met in MODE 1, 2, or 3.
C.2 Be in MODE 4.
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Required Action and
NOTE associated Completion LCO 3.0.3 is not applicable.
Time of Condition A not met during D.1 Place OPERABLE CRER Immediately movement of recently subsystem in irradiated fuel emergency assemblies in the recirculation mode.
primary containment or fuel handling OR building, or during OPDRVs.
D.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in the primary containment and fuel handling building.
AND D.2.2 Initiate action to suspend Immediately OPDRVs.
(continued)
PERRY - UNIT 1 3.7-5 Amendment No.
Enclosure, Attachment 2 PY-CEI/NRR-3059L Page 4 of 7 CRER System 3.7.3 Actions (Continued)
E. Two CRER subsystems E.1 Enter LCO 3.0.3.
Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.
F. Two CRER subsystems F.1 Suspend movement of Immediately inoperable during recently irradiated movement of recently fuel assemblies in irradiated fuel the primary assemblies in the containment and fuel primary containment or handling building.
fuel handling building, or during AND OPDRVs.
F.2 Initiate action to suspend Immediately OR OPDRVs.
One or more CRER subsystems inoperable
'due to inoperable CRE boundary during movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, or during OPDRVs.
(continued)
PERRY - UNIT 1 3.7-6 Amendment No.
Enclosure, Attachment 2 PY-CEI/NRR-3059L Page 5 of 7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CRER subsystem for 31 days
> 10 continuous hours with the heaters operating.
SR 3.7.3.2 Perform required CRER filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).
SR 3.7.3.3 Verify each CRER subsystem actuates on an 24 months actual or simulated initiation signal.
SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program.
Room Envelope Habitability Program.
PERRY - UNIT 1 3.7-7 Amendment No.
Enclosure, Attachment 2 PY-CEI/NRR-3059L Page 6 of 7 Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.13.1 Configuration Risk Management Program The Configuration Risk Management Program (CRMP) provides a risk-informed assessment to manage the risk associated with equipment maintenance activities. The program applies to those structures, systems, or components for which a Technical Specification risk-informed Completion Time has been granted. Specifically, this program applies to:
Required Action B.4 of LCO 3.8.1, "AC Sources-Operating" from _Ž 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after entering Condition B.
The program shall include the following:
- a.
Provisions for the control and implementation of the Probabilistic Safety Assessment (PSA) model and methodology.
The PSA model shall be capable of performing assessments evaluating the applicable plant configurations.
- b.
Provisions for performing assessments for preplanned risk-informed activities prior to entering the risk-informed Completion Time.
- c.
Provisions for performing an assessment after entering the risk-informed Completion Time for an unplanned entry into the risk-informed Completion Time.
- d.
Provisions for assessing the need for additional actions after the discovery of subsequent equipment out of service conditions while in the risk-informed Completion Time.
- e.
Provisions for considering other applicable risk significant contributors external to the preplanned activity such as weather conditions, qualitatively or quantitatively.
5.5.14 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Recirculation (CRER) 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 Total Effective Dose Equivalent (TEDE) for the duration of the accident. The program shall include the following elements:
continued PERRY - UNIT 1 5.0-15b Amendment No.
Enclosure, Attachment 2 PY-CEI/NRR-3059L Page 7 of 7 Programs and Manuals 5.5 5.5 Programs and Manuals (continued)
- 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 of leakage through the outside air intake and exhaust dampers at a Frequency of 24 months. The results shall be trended and used as part of the periodic 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 outside air intake and exhaust damper leakage, as required by paragraphs c and d, respectively.
PERRY - UNIT 1 5.0-15c Amendment No.
Enclosure, Attachment 3 PY-CEI/NRR-3059L
.Page 1 of 10 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES MARK-UP (PROVIDED FOR INFORMATION)
Enclosure, Attachment 3 PY-CEI/NRR-3)59L Page 2 of 10 CRER System B 3.7.3 B 3.7 PLANT SYSTEMS B 3.7.3 Control Room Emergency Recirculati BASES C
- eCR
+ER
) S y s t e m&
~.. £.t,C -
BACKGROUND The CRER System provides atradi44lgi4&.G4 n,-'irwnment from which thc u-nit cn bc h
- l a.-.
~ -,,
^ -"J The safety related function of the CRER System used to control radiation exposure consists of two independent and redundant high efficienc filtratio subsystems for treatment o-recirculated ai Each h
tem consists of a o
demister, an electric heater, a alter' a high efficiency particulate air (HEPA) filte an activated mk" of charcoal adsorber sectioz-a second HEPAfilter, a fan, and the associated ductwor a!)
dampersj The demister is g-0, _**', provided to remove ent"aT1hed water in the air, while th electric heater reduces the relative hum*li;b of the W
airstream to less than 70%.
The F-@4.fq L*'+M Tter removes TheRistheareEawithinthe" large particulate matter, while the EPA filter is confines of the CRE provided to remove fine particulate ter and protect the conaines ofthe sCRE boundary that charcoal from fouling.
The charcoal ads es room occupants inhabit to control gaseous elemental iodine and organic iodide, and the HEPA the unit during normal and after filter is rovided to collect any car n fi accident conditions. This area exhausted from t charcoal adsorber.
(
ck M k"'
encompasses the control room, and may encompass other non-In addition-to t af e at stan y emergency critical areas to which frequent filtration u
i parts of e CRER System are operated personnel access or continuous occupancy is not necessary in the to maintai h
m environment during normal event ofan accident. The CRE is operatio on receipt of the initiation signal (s) protected for normal operation, (indicaye of conditions that could result in radiatio a,".,J-sý natural events, and accident exposu t
conditions. The CRE boundary is autom ic lly switches the emergency recirculation mode the combination of walls, floor, of op ra ion ton"-fiTraion of conaminate air
-nlr
'I" ceiling, ducting, doors, I
penetrations and equipment that int he physically form the CRE. The
, and a
r flow is recirculated and OPERABILITY of the GRE processed through either o o fi s
t boundary must be maintained to orb A
ensure that the inleakage of The CRER System is desi gnec oma i nta i nF unfiltered air into the CRE will not e9#i for a 30 day continuous occupancy after a DBA, exceed the inleakage assumed inCRER System in the licensing basis analysis of the operation in design basis accident (DBA) maintaining th habitability is discussed in consequences to CRE occupants.
the USAR, Sections 6.5 and 6.4.1 (Refs. 1 and 2, The CRE and its boundary are respectively).
defined in the Control Room Envelope Habitability (continued)
Program.
-r(cn.ne 1b~i-Ld ~-E&Lc*'iQ., ~
~-~'
~-). I PERRY - UNIT 1 B 3.7-10 Revision No. 0 INFON nATiON ONLY
Enclosure, Attachment 3 PY-CEI/NRR-3059L Page 3 of 10 BASES (continued)
/
CRER System B 3.7.3
)
APPLICABLE The ability of the RER System to maintain the SAFETY ANALYSES habitabili t/y of the t
r is an explicit assumption Illp for the saf.ty analyses presented in the USAR, Chapters 6 and 15 (Ref3. 3 and 4, respectively).
The emergency e
n pro v
recirculati bn mode of the CRER System is assumed to operate from smoke and hazardous followlnga__l___"
chemicals to CRE occupaunts.
following abloss of coolant naccidnt, meains m 11 an bre&ak, cwhevral a
f and Controaul-rnl r
OPn Aaa-dct. The radiological doses to chemical hazards from onsite, as a result of the various DBAs are H
w ver an evalua tion o..
offsite, and transportation sources summarized in Reference 4.
No single active or passive has determined that the probability failure will cause the__joss of ability to recirculate air in of a hazardous chemical spill the resulting in unacceptable0 exposures is less than NRC The CRER System satisfies Criterion 3 of the NRC Policy licensing basis criteria. Asa Statement in MODES 1, 2 or 3.
During MODES 4 and 5a there result, the plant licensing basis does notpostulatehazardous are no accident analyses that credit the CRER System.
chemical release events (Refs. 2 However, it was determined that Specifications should remain and 5). Therefore, no quantitative in place per Criterion 4 to address OPDRVs and fuel handling limits on inleakage of hazardous accidents.
Criterion 3 would apply if dose calculations are chemicals into the CRE have been revised to credit the CRER System during handling of established. The evaluation of a recently irradiated fuel, i.e., fuel that has occupied part smoke challenge demonstrates of a critical reactor core withinri, e.nrevious 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
that it will not result in theInability LCO of the CRE occupants to control the reactor either from the control room or from the remote shutdown controls (Ref. 6). Therefore, no quantitative limits on inleakage of smoke into the CRE have been
- established. Because inleakage limits for hazardous chemicals and smoke are not necessary to protect CRE occupants, the limit established for radiological events is the limiting value for CRE m
eJ suc a foma oss of both*
ventilation subsystems or from an inoperable CRE boundary, n Two independent and rdundant ubsystems of the CRER System are required to be OrERABLE t ensure that at least one is available,--- *w+ý ia singleailure disables the other subsystem_
Totalysv~tpm failurCcould result in a failure to meet the dose requirements o GDC 19 in the event of DBA (for the design-basis Alternative Source Term LOCI and fuel handling accident analyses, the lic ns*
Jb Control Room dose limit is 5 Rem ED aRef-nd T-htR.onsi*
OPERABE when the individual components necessary to--
ert or sure are OPERABLE*,n both subsyztc5m.
A CRER subsystem is considered OPERABLE when its associated:
1 Fan$ a-p.
OPERABLE:
a.
- b.
HEPA filter and charcoal adsorber are not excessively restricting flow and are capable of performing their filtration functions; and (continued)
INFORMATION O LY PERRY
- UNIT 1 B 3.7-11 Revision No. 4
CRER System Enclosure, Attachment 3 B 3.7.3 PY-CEI/NRR-3059L Page 4 of 10 BASES LCO
- c.
Heater, demister, ductwork, valves, and dampers are (continued)
OPERABLE, and air circulation can be maintained.
InA add44to, th@ c-o-ntr-ol room bhndar*y mist b@ mainta' inHd 41inlulding1 the in9tegrijty o~f the W8116l, floor2S, ceilings, ductwork, and acccss doors.
APPLICABILITY In MODES 1, 2. and 3, the CRER System must be OPERABLE to Q
ol r.,s e*PAs ---...
during and following a DBA. sin(
the DBA coudale~ad to Ission product release.(cniu In order for the CRER subsystems e
i.r.-
+....
c-..-E.
,)4I1 to be considered OPERABLE, the k*3o i-&,.IL.
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.
I
'e d)
The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls. This Note 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 aa need for CRE isolation is Lindicated.
INFORMATION ONLY PERRY - UNIT 1 B 3.7-11a Revision No. 4
CRER System B 3.7.3 Enclosure, Attachment 3 PY-CEI/NRR-3059L Page 5 of 10 BASES APPLICABILITY In MODES 4 and 5, the probability and consequences of a DBA (continued) are reduced due to the pressure and temperature limitations in these MODES.
Therefore, maintaining the CRER System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:
- a.
During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building: and
- b.
During operations with a potential for draining the reactor vessel (OPDRVs).
Due to radioactive decay, handling of fuel only requires OPERABILITY of the Control Room Emergency Recirculation System when the fuel being handled is recently irradiated, i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Although this Function retains APPLICABILITY during "movement of recently irradiated fuel", which could be interpreted to permit fuel handling before 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of radiological decay if certain buildings and filtration systems are OPERABLE, this is not the case.
Fuel handling during that period is prohibited since no dose calculations exist to address a fuel handling accident within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the reactor core is sub-critical (Ref. 4).
OPDRVs assume that one or more fuel assemblies are loaded into the core.
Therefore, if the fuel is fully off-loaded from the reactor vessel, the CRER System is not required to be OPERABLE.
A 1
- ~kr
,*,o E-ý:" -1***-*
With one C R subsystem inoperable, the inoperable CRER subsystem ust be restored to OPERABLE status within 7 days.
With the u it in this condition, the remaining OPERABLE R
subsystem s adequate to perform een,, u!
,adimfL'F protection However, the overall reliability is reucd cc because a t failure in the OPERABLE CRER subsystem could result in loss of CRER System function.
The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining CRER subsystem can provide the required capabilities.
(continued)
IFOR ATION ONLY PERRY - UNIT 1 B 3.7-12 Revision No. 4
CRER System B 3.7.3 Enclosure, Attachment 3 PY-CEI/NRR-3059L Page 6 of 10 BASES o r it-t-c-P. E ACTIONS C/.
1 and
.2) 6ot;L&X (continued)
In MODE 1, 2, or 3, if the inoperable CRER subsystem cannot be restored to OPERABLE status within the associated Completion-Time, the unit must be placed in a MODE that minimizes r-Cr To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
(continued)
B.1, B.2, and B.3 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 5 Rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. As discussed in the Applicable Safety Analyses section, the current PNPP licensing basis identifies that CRE inleakage limits for hazardous chemicals and smoke are not necessary to protect CRE occupants; therefore the limit established for radiological events is the limiting value for determining entry into Condition B for an inoperable CRE boundary. 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. These mitigating actions are outlined in the PNPP Control Room Habitability Program.
The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time 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 Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.
I J
I INFORMATION ONLY PERRY - UNIT 1 B 3.7-12a Revision No. 4
CRER System B 3.7.3 Enclosure,.Attachment 3 PY-CEI/NRR-3059L Page 7 of 10 BASES ACTIONS (continued)
'K.1, r.2.1 and E.2,J2 The Required Actions of Condition are modified by a Note indicating that LCO 3.0.3 does notapply.
If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3. the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.
During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, or during OPDRVs. if the inoperable CRER subsystem cannot be restored to OPERABLE status within the required Completion Time of Condition A. the OPERABLE CRER subsystem may be placed in the emergency recirculation mode.
This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.
An alternative to Required Action is to immediately suspend activities that present a lt'ential for releasing significant amounts of radioactivity that might require isolation of the 49pt-el--9Rk*
This places the unit in a condition that mini ris i
If applicable, movement-OT recently irradiated fuel assemblies in the primary containment and fuel handling building must be suspended immediately.
Suspension of these activities shall not preclude completion of movement of a component to a safe position.
Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release.
Actions must continue until the OPDRVs are suspended.
If both CRER subsystems are inoperable in MODE 1. 2. or 36A the CRER System may not be capable of performing the intended function and the unit is in a condition outside of the accident analyses.
Therefore, LCO 3.0.3 must be entered 1--.L,&A
-*5 immediately.
(M (continued)
INFORMATION ONLY PERRY - UNIT 1 R 3.7-13 Revision No. 2
CRER System Enclosure, Attachment 3 B 3.7.3 PY-CEI/NRR-3059L Page 8 of 10 BASES ACTIONS
.1and.2 (continued)
During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building, or during
- OPDRVs, with two CRER subsystems inoperablp action must be taken immediately to suspend activities that present a potential for releasing significant amounts of radioactivity
- or OK,* CC e
that might require isolation of the ! !ntH,
I-;,_
his places the unit in a condition that minimizes risk.
L/
AJ f,9J*JLAP If applicable, movement of recently irradiatedu assemblies in the primary containment and fuel handling jl'io
&N
- '""o building must be suspended immediately.
Suspension of these C,'-e-Lk activities shall not preclude completion of movement of a component to a safe position.
Also if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release.
Actions must continue until the OPDRVs are suspended.
SURVEILLANCE SR 3.7.3.1 REQUIREMENTS Operating each CRER subsystem for Ž 10 continuous hours after initiating from the control room and ensuring flow through the HEPA filters and charcoal adsorbers ensures that both subsystems are OPERABLE and that all associated controls are functioning properly.
It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action.
Operation with the heaters on for Ž 10 continuous hours every 31 days eliminates moisture on the adsorbers and HEPA filters.
The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.
SR 3.7.3.2 This SR verifies that the required CRER testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).
-The RER filtcr te^ts are in accordance with fa Regulatory Guide 1.52 (Ref.
- 5)
The VFTP includes testing HEPA filter efficiency, charcoal adsorber efficiency and bypass leakage, system flow rate, and general operating (continued)
INFORMATION ONLY PERRY - UNIT 1 SB 3.7-14 Revision No. 3
CRER System B 3.7.3 Enclosure, Attachment 3 PY-CEI/NRR-3059L BASES Page 9 of 10 SURVEILLANCE REQUIREMENTS SR 3.7.3.2 (continued) parameters of the filtration system.
(Note: Values identified in 1-6-VFTP are Surveillance Requirement values.)
Specific test quencies and additional information are discussed in dfail in t TP.
+
This SR verifies that each CRER subsystem starts an operates on an ac ua or simulated initiation signa ) nd the isolation dampers ose within 10 seconds.
The LOG SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.5 overlaps thi rovide comple testing oftesafety function.ffhe 24 mo
/-r-e-quency IS basea on theneed-to*
pý the surveillance tests whichý sa jz,-f-*)issa under the conditions that a dring a plant outage, and the lpotentiaLý nunplanned transient if t~hose pa 1&set*-s-Vre performed with the reactor at power.
Th 24 mon Frequency is Dased on operating experience, and is consistent with a typical i dustry refueling cycle.
SR 3.7.3.4 his SR verifies the integrity of the control room enclos and the assumed inleakage rates of potentially contami:
ed air.
The Control Room HVAC System is designed so ti
. when operating in the normal mode, the system automati ally maintains a positive differential pressure b een the
&a-eZ XV1 &er+
control room and the outside environment.
uring an emergency, when the CRER System is ope ing, the supply (M25-FO10A and M25-FO20B for one trn and M25-FO10B and M25-FO20A for the other train) exhaust (M25-F130A and M25-F130B) dampers of the C rol Room HVAC System are closed (no design admit e of outside air).
When in the emergency recirculat' mode of o eration no attempt is made to pressurize the ntrol room.
hs the leakage through the intake a as apr ste prlmary source of-leakage i ecnro tut Frequency of k* dampers is not expected over this perrioddoode.Z.
/
(continued)
INFORMATION ONLY j
PERRY - UNIT 1 B 3.7-15 Revision No. 5
CRER System B 3.7.3 Enclosure, Attachment 3 PY-CEI/NRR-3059L Page 10 of 10 BASES (continued)
REFERENCES
(
- 1.
USAR, Section 6.5.1.
- 5. FSAR, Section 2.2
- 2.
USAR Section 6.4.1.
- 6. Letter from L. W. Pearce (FENOC) to Document SControl Desk (NRC) dated May 30, 2006, "Perry Nuclear Power Plant Final Response to Generic
- 3.
USAR. Chapter 6.
Letter 2003-01, 'Control Room Habitability' (TAC No. MB9839)."
- 4.
USAR, Chapter 15.
. Regulatory Guide1.52,.1 Amendment No. 103 to Facility Operating License No.
NPF-58, Perry Nuclear Power Plant, Unit 1; and Letter, D. Pickett (NRC) to L. Myers (FENOC).
"Issuance of Exemption from 10 CFR Part 50, Appendix A, General Design Criterion 19", dated March 26, 1999.
Amendment No. 122 to Facility Operating License No.
NPF-58, Perry Nuclear Power Plant, Unit 1.
.. 1j,SPe~rA5vAt",
),P a,-OO,(.,c A)
S 'S R 3.7.3.4-_
This SR 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 H abitability P rogram.,
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 TEDE and the CRE occupants are protected from hazardous chemicals and smoke. This SR 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, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to'OPERABLE status provided mitigating actions can
.i'n accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 7),
which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 10). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 11).
OTheCEios onsidredshbitblenge the raioogca dousar to OPEABL sttuciclupant chalcuateng the licensingbaiDB consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon Pre hazarRof hemicals and UIeT 1 Revrscve rionn Nao 4he scp e
inleakage inothe cess no ActinB3ab l lsh t
imhatrstr the CRE boundary h sb e etoredt o
OPERABLE status
.po ie iiatn cin a
me sue maR y
als beI use as mitiatin Revision ao re urdb e urdAcinB 2 e p rr INFORMATiON ONLY