2CAN100702, License Amendment Request, Technical Specification Changes Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

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License Amendment Request, Technical Specification Changes Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process
ML073030547
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 10/22/2007
From: Mitchell T
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN100702, GL-03-001
Download: ML073030547 (33)
v • d • e


Text

Entergy Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Timothy G. Mitchell Vice President, Operations Arkansas Nuclear One 2CAN 100702 October 22, 2007 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request Technical Specification Changes Control Room Envelope Habitability in Accordance With TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

References:

1. Entergy letter to NRC dated February 14, 2007, Supplemental Response to GL 2003-01 Regarding Control Room Habitability, (OCAN020701)
2. Entergy letter to NRC dated October 22, 2007, Technical Specification Changes For Control Room Envelope Habitability in Accordance With TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (ANO-1) (1CAN100704)

Dear Sir or Madam:

In accordance with the provisions of 10 CFR 50.90, Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with Technical Specification Task Force (TSTF)-448, Revision 3, using the consolidated line item improvement process (CLIIP).

Entergy committed to submit a proposal to adopt TSTF-448 and retire current compensatory measures relating to control room habitability in letter dated February 14, 2007 (Reference 1). provides a description of the proposed changes, the requested confirmation of applicability, and plant specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides revised (clean) TS pages. provides a summary of the regulatory commitments made in this submittal. provides existing TS Bases pages marked up to show the proposed changes.

2CAN 100702 Page 2 of 3 Because the ANO-2 and Arkansas Nuclear One, Unit 1 (ANO-1) control rooms are supported by the same control room envelope and emergency ventilation systems, Entergy has submitted proposed TS changes adopting TSTF-448 for ANO-1 (Reference 2). NRC approval of TSTF-448, Revision 3, should therefore be coupled with NRC acceptance/approval of the ANO-1 TSTF-448 submittal.

The proposed change has been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that the change involves no significant hazards consideration. The bases for these determinations are included in Attachment 1.

Entergy requests approval of the proposed amendment by July 1, 2008, concurrent with NRC acceptance/approval of the proposed ANO-1 TSTF-448 application (Reference 2). Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review is requested.

If you have any questions or require additional information, please contact David Bice at 479-858-5338.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 22, 2007.

Sincerely, TGM/dbb Attachments:

1. Analysis of Proposed Technical Specification Change
2. Proposed Technical Specification Changes (mark-up)
3. Revised Technical Specification Pages
4. List of Regulatory Commitments
5. Proposed Technical Specification Bases Changes (mark-up)

2CAN100702 Page 3 of 3 cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV Office 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P. 0. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Alan B. Wang MS 0-7 D1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health & Human Services P.O. Box 1437 Slot, H-30 Little Rock, AR 72203-1437

Attachment 1 2CAN100702 Analysis of Proposed Technical Specification Change

Attachment to 2CAN100702 Page 1 of 3

1.0 DESCRIPTION

This letter is a request to amend Operating License NPF-6 for Arkansas Nuclear One, Unit 2 (ANO-2).

The proposed amendment would modify Technical Specification (TS) requirements related to control room envelope habitability (CREH) in TS 3.7.6.1, Control Room Emergency Ventilation and Air Condition System, and would establish a CREH program in TS Section 6.5, Administrative Controls - Programs and Manuals.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change 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).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy Operations, Inc. (Entergy) 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. Entergy has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to ANO-2 and justify this amendment for the incorporation of the changes to the ANO-2 TS.

2.2 Optional Chanqes and Variations Entergy is not proposing any variations or deviations from the TS changes described in the TSTF-448, Revision 3, or the applicable parts of the NRC staff's model safety evaluation (SE) dated January 17, 2007, except for a minor adjustment in the allowable time before performing the next surveillance tests. The previous tracer gas and pressure testing surveillances were performed on November 1, 2001. By the time TSTF-448 is approved for ANO-2, more than 6 years will have passed since the initial testing, but possibly not 6 years plus 15 months as noted in the NRC model application. In order to permit one starting date for all future testing and to avoid possibly having to test within weeks of TSTF-448 approval, Entergy requests that the next tracer gas test, periodic assessment, and pressurization test (see Section 2.3, Item 2 below) be performed within 15 months of the date in which TSTF-448 is approved by the NRC for ANO-2. Permitting this variation will have no significant impact on plant or public safety and will help to avoid potential human performance traps associated with tracking various due dates for related testing.

Section 2.2 of the model application requires the Licensee to identify which evaluation (of the six contained under Section 3.3 of the model SE) is applicable to the proposed adoption of TSTF-448, Revision 3. Entergy has determined that Evaluation 1 is applicable to ANO-2 because the ANO-2 TS include the Limiting Condition for Operation (LCO) Note associated with TSTF-287, Revision 5. In addition, Evaluation 6 is applicable to ANO-2, which permits

Attachment to 2CAN 100702 Page 2 of 3 deletion of pressurization test Surveillance Requirements (SR) from the TS. The outside makeup air flow limits currently described in SR 4.7.6.1.2.d and SR 4.7.6.1.2.e will be controlled henceforthin station procedures associated with the CREH Program under the requirements of 10 CFR 50.59.

The addition of the CREH Program to Section 6.5.12 of the TSs results in moving TS 6.5.13 requirements to the following page. This change is administrative only and is included in the markups and Attachment 3 revised (clean) TS pages. Because no change was made to TS 6.5.13, no revision bars are illustrated next to this TS.

Program TS 6.5.12.d wording in the TSTF requires 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 control room emergency ventilation system (CREVS), operating at the flow rate required by the VFTP, at a Frequency of 18 months on a Staggered Test Basis (emphasis added). ANO-2 TSs are custom vintage and have not yet been converted to the standard technical specifications (STS) for Combustion Engineering plants (NUREG-1432, Rev. 3.1). Under the STS, the aforementioned 18-month frequency on a staggered test basis means the pressure test must be completed every 18 months with one train of the CREVS in service during one 18-month test and the other train of CREVS in service during the next 18 month test. The ANO-2custom TS definition of "staggered test basis" is not the same as the STS. Therefore, the above statement is re-worded to "...at a Frequency of one train every 18 months." This is considered administrative in nature as it applies the same requirement to the ANO-2 custom TSs as is applied to the STS under TSTF-448.

Because ANO-2 has custom TSs, the TSTF was applied to TS 3.7.6.1 under custom TS usage rules and terminology. However, the TSTF intent for each change is maintained. Other minor changes made to the TS include the use of abbreviations and the addition of Action j. The current Action i requires suspension of the handling of irradiated fuel if one or more trains of CREVS or control room emergency air conditioning system (CREACS) were inoperable. The CREVS portion of this Action is split out to a new Action j in order to capture the CRE boundary aspects of CREVS inoperability. These changes are considered minor and administrative in nature, and do not result in a signification deviation or variation from the TSTF.

Due to space limitations, the TS 3.7.6.1 Actions associated with operation during the handling of irradiated fuel are shown on the following page (TS Page 3/4 7-17a) in the revised versions included in Attachment 3 of this submittal. Appropriate headings were included on this page to separate Actions from SRs. The LCO Note is maintained at the bottom of TS Page 3/4 7-18.

These chanfges are also administrative in nature.

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

Attachment to 2CAN 100702 Page 3 of 3

1. Upon implementation of TS amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.6.1.2.d, in accordance with TS 6.5.12.c.(i), the assessment of CRE habitability as required by Specification 6.5.12.c.(ii), and the measurement of CRE pressure as required by Specification 6.5.12.d, shall be considered met.
2. Following implementation:

(a) The first performance of SR 4.7.6.1.2.d, in accordance with Specification 6.5.12.c.(i),

shall be within 15 months of the approval of TSTF-448 for ANO-2. SR 3.0.2 will not be applicable to this first performance.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.5.12.c.(ii), shall be within 15 months of the approval of TSTF-448 for ANO-2.

SR 3.0.2 will not be applicable to this first performance.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.5.12.d, shall be within 15 months of the approval of TSTF-448 for ANO-2. SR 3.0.2 will not be applicable to this first performance.

3.0 REGULATORY ANALYSIS

3.1 No Siqnificant Hazards Consideration Entergy Operations, Inc. (Entergy) has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

Entergy has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Arkansas Nuclear One, Unit 2 (ANO-2) and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Commitments As included in Attachment 5 of this submittal, Entergy will establish the TS Bases for TS 3.7.6.1, consistent with TSTF 448, Revision 3, as adopted with the applicable license amendment. As a matter of administrative control, Entergy has also included the license conditions described in Section 2.3 above in Attachment 4.

4.0 ENVIRONMENTAL CONSIDERATION

S Entergy Operations, Inc. (Entergy) has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007, as part of the CLIIP. Entergy has concluded that the staffs findings presented in that evaluation are applicable to Arkansas Nuclear One, Unit 2 (ANO-2) and the evaluation is hereby incorporated by reference for this application.

Attachment 2 2CAN100702 Proposed Technical Specification Changes (mark-up)

'~1

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent control room emergency ventilation and air conditioning systems shall be OPERABLE. (Note 1)

APPLICABILITY: MODES 1, 2, 3, 4, or during handling of irradiated fuel.

ACTION:

MODES 1, 2, 3, and 4

a. With one control room emergency air conditioning system (CREACS) inoperable, restore the inoperable system to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With one control room emergency ventilation system (CREVS) inoperable for reasons other than ACTION d, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
c. With one CREVScontrol room emergency air conRditioning system inoperable for reasons other than ACTION d and one CREACScontrol rooem emergency ventilatio*n system inoperable, restore the inoperable CREVScontro, room emer..gency Vcntilation syst to OPERABLE status within 7 days and restore the inoperable CREACSenRtFeI FeeI, o,,rgo,.3

.ir conditioning system to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

d. With one or moretwo CREVScontro! room emergency ventilat!on systems inoperable due to an inoperable CREcen4trcFer, boundary-
1. Immediately initiate action to implement miticqating actions, and
2. Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and
3. R-estore the CREenRtreI Feem boundary to OPERABLE status within 90 davs24 hG...

Otherwise,-ea be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

e. With two CREVScontro room, em.r.gency

. VeRtilation systems inoperable for reasons other than ACTION d or with two CREACScentrl roo,,m emergency air conditioning systems inoperable, enter Specification 3.0.3.

ARKANSAS - UNIT 2 3/4 7-17 Amendment No. 20-6,24-,2-5,

3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION During Handling of Irradiated Fuel

f. With one CREACSGcontrl room- cm...gen.y air conditioning .Y.t..m inoperable, restore the inoperable system to OPERABLE status within 30 days or immediately place the OPERABLE system in operation; otherwise, suspend all activities involving the handling of irradiated fuel. The provisions of Specification 3.0.4 are not applicable.
g. With one CREVSco)nRtol room. em..rgncy ventilation .ytm inoperable, restore the inoperable system to OPERABLE status within 7 days or immediately place the control room in the emergency recirc mode'of operation; otherwise, suspend all activities involving the handling of irradiated fuel. The provisions of Specification 3.0.4 are not applicable.

Note 1: The control room envelope (CRE) boundary may be open intermittently under administrative controls.

ARKANSAS - UNIT 2 3/4 7-17 Amendment No. 206,24-,2-55,

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION

h. With one CREVScontGo* .. omeqergency "air ,.nditioning system inoperable for reasons other than ACTION d and one CREACScontrol room om.ergncy Ventilation System inoperable:
1. restore the inoperable CREVScontrol room emergency 'e-ntilatin system to OPERABLE status within 7 days or immediately place the CREceRetrl reem in the emergency recirc mode of operation, and
2. restore the inoperable CREACScontrtFo, room emergency aiFr conditiRin*g system to OPERABLE status within 30 days or immediately place the OPERABLE system in operation;
3. otherwise, suspend all activities involving the handling of irradiated fuel.
4. The provisions of Specification 3.0.4 are not applicable.
i. With both CREACScontrFO room emergency air conditioning systems or bo-th contrFol room em.ergency ventilatio systems inoperable, immediately suspend all activities involving the handling of irradiated fuel.

With both CREVS inoperable or with one or more CREVS inoperable due to an inoperable CRE boundary, immediately suspend all activities involvinq the handling of irradiated fuel.

ARKANSAS - UNIT 2 3/4 7-17a Amendment No. 2-g6,2-4-9,255,

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS 4.7.6 .1.1 Each control room emergency air conditioning system shall be demonstrated OPERABLE:

a. At least once per 31 days by:
1. Starting each unit from the control room, and
2. Verifying that each unit operates for at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and maintains the control room air temperature _ 84°F D.B.
b. At least once per 18 months by verifying a system flow rate of 9900 cfm +/- 10%.

4.7.6 .1.2 Each control room emergency air filtration system shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that the system operates for at least 15 minutes.
b. At least once per 18 months by verifying that on a control room high.radiation signal, either actual or simulated, the system automatically isolates the control room and switches into a recirculation mode of operation.
c. By performing the required Control Room Emergency Ventilation filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
d. Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.At loast once Per 18 mon*thS* .eify VSF 9 makeup flow rate isŽ300 and !*366 cfm Whon su1pplying the conRtrol room with A-L t. r-. m.v rd -All lll llAl v*

t6t At. once pr 18 mn..th. veri , 9 makeup flow rate is 44 18.5 and

!* 511 .5 cfm when SUPPlying the control room with outside afir.-

ARKANSAS - UNIT 2 3/4 7-18 Amendment No. 14-,206,249,255, Next Page is 3/4 7-22

ADMINISTRATIVE CONTROLS 6.5.12 Late Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), 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 adeguate- 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 CREVS, operating at the flow rate reguired by the VFTP, at a Frequency of one train every 18 months. 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 testinqgdescribed 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 Specification 4.0.2 are applicable to the Frequencies for.

assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

6.5.13 Diesel Fuel Oil Testing Pro.gram A diesel 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 and testing requirements, and acceptance criteria, -all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

ARKANSAS - UNIT 2 &-16 Amendment No. 2-55,

a. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:
1. an API gravity or an absolute specific gravity within limits,
2. a flash point and kinematic viscosity, within limits for ASTM 2D fuel oil, and
3. water and sediment within limits;
b. Within 31 days following addition of new fuel oil to storage tanks, verify that the properties of the new fuel oil, other than those addressed in a. above, are within limits for ASTM 2D fuel oil;
c. Total particulate concentration of the fuel oil is < 10 mg/I when tested every 31 days based on ASTM D-2276, Method A-2 or A-3; and
d. The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Diesel Fuel Oil Testing Program surveillance frequencies.

ARKANSAS - UNIT 2 6-16 Amendment No. 2-55,

Attachment 3 2CAN100702 Revised Technical Specification Pages

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent control room emergency ventilation and air conditioning systems shall be OPERABLE. (Note 1)

APPLICABILITY: MODES 1, 2, 3, 4, or during handling of irradiated fuel.

ACTION:

MODES 1, 2, 3, and 4

a. With one control room emergency air conditioning system (CREACS) inoperable, restore the inoperable system to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With one control room emergency ventilation system (CREVS) inoperable for reasons other than ACTION d, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
c. With one CREVS inoperable for reasons other than ACTION d and one CREACS inoperable, restore the inoperable CREVS to OPERABLE status within 7 days and restore the inoperable CREACS to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
d. With one or more CREVS inoperable due to an inoperable CRE boundary:
1. Immediately initiate action to implement mitigating actions, and
2. Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and
3. Restore the CRE boundary to OPERABLE status within 90 days Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
e. With two CREVS inoperable for reasons other than ACTION d or with two CREACS inoperable, enter Specification. 3.0.3.

Note 1: The control room envelope (CRE) boundary may be open intermittently under administrative controls.

ARKANSAS - UNIT 2 3/4 7-17 Amendment No. 296,2-1-9,255,

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION During Handling of Irradiated Fuel

f. With one CREACS inoperable, restore the inoperable system to OPERABLE status within 30 days or immediately place the OPERABLE system in operation; otherwise, suspend all activities involving the handling of irradiated fuel. The provisions of Specification 3.0.4 are not applicable.
g. With one CREVS inoperable, restore the inoperable system to OPERABLE status within 7 days or immediately place the control room in the emergency recirc mode of operation; otherwise, suspend all activities involving the handling of irradiated fuel. The provisions of Specification 3.0.4 are not applicable.
h. With one CREVS inoperable for reasons other than ACTION d and one CREACS inoperable:

S1. restore the inoperable CREVS to OPERABLE status within 7 days or immediately place the CRE in the emergency recirc mode of operation, and

2. restore the inoperable CREACS to OPERABLE status within 30 days or immediately place the OPERABLE system in operation;
3. otherwise, suspend all activities involving the handling of irradiated fuel.
4. The provisions of Specification 3.0.4 are not applicable.
i. With both CREACS inoperable, immediately suspend all activities involving the handling of irradiated fuel.
j. With both CREVS inoperable or with one or more CREVS inoperable due to an inoperable CRE boundary, immediately suspend all activities involving the handling of irradiated fuel.

ARKANSAS - UNIT 2 3/4 7-18 Amendment No. 206,24-9,2Z5,

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS 4.7.6 .1.1 Each control room emergency air conditioning system shall be demonstrated OPERABLE:

a. At least once per 31 days by:
1. Starting each unit from the control room, and
2. Verifying that each unit operates for at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and maintains the control room air temperature < 84°F D.B.
b. At least once per 18 months by verifying a system flow rate of 9900 cfm +/- 10%.

4.7.6 .1.2 Each control room emergency air filtration system shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that the system operates for at least 15 minutes.
b. At least once per 18 months by verifying that on a control room high radiation signal, either actual or simulated, the system automatically isolates the control room and switches into a recirculation mode of operation.
c. By performing the required Control Room Emergency Ventilation filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
d. Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

ARKANSAS - UNIT 2 3/4 7-18 Amendment No. 4-94,2-G6,2-1-,2-5, Next Page is 3/4 7-22

ADMINISTRATIVE CONTROLS 6.5.12 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), 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 CREVS, operating at the flow rate required by the VFTP, at a Frequency of one train every 18 months. 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 Specification 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

ARKANSAS - UNIT 2 6-16 Amendment No. 2-55,

ADMINISTRATIVE CONTROLS 6.5.13 Diesel Fuel Oil Testing Program A diesel 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 and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

a. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:
1. an API gravity or an absolute specific gravity within limits,
2. a flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and
3. water and sediment within limits;
b. Within 31 days following addition of new fuel oil to storage tanks, verify that the properties of the new fuel oil, other than those addressed in a. above, are within limits for ASTM 2D fuel oil;
c. Total particulate concentration of the fuel oil is < 10 mg/I when tested every 31 days based on ASTM D-2276, Method A-2 or A-3; and
d. The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Diesel Fuel Oil Testing Program surveillance frequencies.

6.5.14 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:
1. A change in the TS incorporated in the license or
2. A change to the updated SAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the SAR.
d. Proposed changes that do not meet the criteria of 6.5.14b 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).

6.5.15 not used ARKANSAS - UNIT 2 6-17 Amendment No. 2-&5,

Attachment 4 2CAN100702 List of Regulatory Commitments

Attachment 4 to 2CAN 100702 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED COMPLETION COMMITMENT DATE (If Required)

ONE-TIME CONTINUING ACTION COMPLIANCE Entergy will establish the Technical X To be Specification (TS) Bases for TS 3.7.6.1, implemented consistent with TSTF 448, Revision 3, as with adopted with the applicable license amendment amendment.

The first performance of SR 4.7.6.1.2.d, in X Within accordance with Specification 6.5.12.c.(i), 15 months shall be within 15 months of the approval of following TSTF-448 for ANO-2. SR 3.0.2 will not be amendment applicable to this first performance. approval The first performance of the periodic X Within assessment of CRE habitability, Specification 15 months 6.5.12.c.(ii), shall be within 15 months of the following approval of TSTF-448 for ANO-2. SR 3.0.2 amendment will not be applicable to this first performance. approval The first performance of the periodic X Within measurement of CRE pressure, Specification 15 months 6.5.12.d, shall be within 15 months of the following approval of TSTF-448 for ANO-2. SR 3.0.2 amendment

,will not be applicable to this first performance. approval

Attachment 5 2CAN100702 Proposed Technical Specification Bases Changes (mark-up)

PLANT SYSTEMS BASES 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION (CREVS) AND AIR CONDITIONING SYSTEM (CREACS)

BACKGROUND CREVS The CREVS is a shared system which provides a protected environment from which occupantsGpe-ater-s can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The CREVS consists of two independent filter and fan trains, a control room envelope (CRE) boundary.that limits the inleakage of unfiltered air, two independent actuation channels, and the Control Room isolation dampers. The CREVS is an emergency system. Upon receipt of a unit specific high radiation signal, the control room .nvolopeCRE

. is isolated, the associated unit's normal control room ventilation system is shutdown, and the associated unit's CREVS is started.

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

The CREVS is discussed in the SAR, Section 9.4.

CREACS The control room emergency air conditioning system (CREACS) provides temperature control for the control room following isolation of the control room. It is manually started from the Unit 2 Control Room.

The CREACS consists of two independent and redundant trains that provide cooling of recirculated control room air. A cooling coil and a water cooled condensing unit are provided for each system to provide suitable temperature conditions in the control -room for operating personnel and safety related control equipment. During operation, the CREACS maintains the temperature in a range consistent with personnel comfort and long term equipment operation.

APPLICABLE SAFETY ANALYSES The shared CREVS components are arranged in two safety related ventilation trains, which ensure an adequate supply of filtered air to all areas requiring access. The CREVS provides ARKANSAS - UNIT 2 B 3/4 7-5 Amo.-m.M.(-;

,t No. 62,129,206,219 Rovised by leoor dated 9/8/95 Rev. 41-, ,

airborne radiological protection for the control room occupantspe.atei-, for the design basis loss of coolant accident fission product release and for a fuel handling accident.

The CREVS provides protection from smoke and hazardous chemicals to the CRE occupants.

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

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

The design basis for the CREACS is to maintain control room temperature for 30 days of continuous occupancy.

The CREACS components are arranged in redundant, safety related trains. A single active failure of a CREACS component does not impair the ability of the system to perform as designed. The CREACS is designed in accordance with Seismic Category I requirements. The CREACS is capable of removing sensible and latent heat loads from the control room; including consideration of equipment heat loads and personnel occupancy requirements, to ensure a habitable environment and equipment OPERABILITY.

ARKANSAS - UNIT 2 B 3/4 7-5 Amodmont No. 62,129,206,219 Rov;irco9d by loer dated W1&195 Rev. 41,44, 7f

PLANT SYSTEMS BASES In MODES 1 and 2 and during movement of irradiated fuel assemblies, the CREVS and CREACS satisfy Criterion 3 of 10 CFR 50.36. In MODES 3 and 4, the CREVS and CREACS satisfy Criterion 4 of 10 CFR 50.36.

LCO The OPERABILITY of the control room emergency ventilation and air conditioning system ensures that 1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for oporations personnel during and following all credible accident conditions.

Two CREVS trains are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other train. Total system failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem whole body or its equivalent to CRE occupantstho control room operators in the event of a large radioactive release. This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A", 10 CFR 50.

For a CREVS train to be considered OPERABLE, the CREVS train must include the associated:

a. OPERABLE fan;
b. OPERABLE HEPA filter and charcoal adsorber; and
c. OPERABLE ductwork and dampers sufficient to maintain air circulation and provide adequate makeup air flow.

In order for the CREACS 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..n addition, the control room onVelopo, including the integrity of the walls, floors, ceilings, ductwork, and accGss doors, must' be maint-ained wti the a~ssumptions Of the design analysis-.

Automatic actuation is required for both trains of ventilation fans and dampers. When one or both actuation systems are inoperable, the design function of the system to limit the dose consequences to control room operators to within GDC-19 limits is maintained by placing the control room in the emergency recirculation mode of operation as required by TS 3.3.3.1. Once the control room has been placed in the emergency recirculation mode of operation, the standby emergency fan unit handswitch may be placed in the "STOP" position to preclude inadvertent start and/or subsequent dual fan operation while in this configuration. Because this action maintains the design basis of the system, the secured fan may be considered OPERABLE while in the emergency recirculation mode of operation.

Two independent and redundant trains of the CREACS are required to be OPERABLE to ensure that at least one is available, assuming a single failure disables the other train. Total system failure could result in the control room temperature exceeding limits in the event of an accident.

For a CREACS train to be considered OPERABLE, the individual components that are necessary to maintain control room temperature must be OPERABLE. These components include the cooling coils, condensing units, and associated temperature control instrumentation.

In addition, the CREACS must be capable of maintaining air circulation.

ARKANSAS - UNIT 2 B 3/4 7-,a6 Rev. 44,

PLANT SYSTEMS BASES The LCO is modified by Note 1 that allows the CREcGGtrI rFom 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, conduits, cable penetrations, 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 CREeentrFerom. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CREcEnRtFeI Foem isolation is indicated.

Due to the unique situation of the shared emergency ventilation and air conditioning equipment, the components may be cross fed from the opposite unit per predetermined contingency actions/procedures. Unit 1 may take credit for operability of these systems when configured to achieve separation and independence regardless of normal power and/or service water configuration. This will be in accordance with pre-determined contingency actions/procedures.

APPLICABILITY In MODES 1, 2, 3, and 4, the CREVS and CREACS must be OPERABLE to ensure that the CREGcRtrGI-FG!nr will remain habitable during and following a DBA.

During movement of irradiated fuel assemblies, the CREVS must be OPERABLE to cope with a release due to a fuel handling accident.

Unit 1 and Unit 2 control rooms are a single environment for emergency ventilation and air conditioning concerns. Since the control room emergency ventilation and air conditioning equipment is shared between units, the plant status of both units must be considered when determining applicability of the specification.

ACTIONS a.

With one CREACS train inoperable, action must be taken to restore OPERABLE status within 30 days. In this ACTION, the remaining OPERABLE CREACS train is adequate to maintain the control room temperature within limits. However, the overall reliability is reduced because a failure in the OPERABLE CREACS train could result in a loss of CREACS function. The 30 day ACTION statement is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining train can provide the required capabilities, and alternate non-safety related cooling means that are available.

b.

With one CREVS train inoperable for reasonsdue-te other than the loss of capability for automatic actuation on a high radiation signalT or for reasons other than an inoperable CRE boundary, action must be taken to restore the OPERABLE status within 7 days. In this ACTION, the remaining OPERABLE CREVS train is adequate to perform the CREon~trec r*eIe radiation protection function. However, the overall reliability is reduced because a failure in the OPERABLE CREVS train could result in loss of CREVS function. The 7 day ACTION statement is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability. If automatic actuation on high radiation is lost, the ACTIONS of LOC 3.3.3.1 provide sufficient actions to ensure continued safe operation.

ARKANSAS - UNIT 2 B 3/4 7-5b7 Rev. 44,

PLANT SYSTEMS BASES C.

With one CREVS train inoperable for reasons other than ACTION d and one CREACS train inoperable, actions must be taken to restore the CREVS to an OPERABLE status within 7 days and to restore the CREACS train to an OPERABLE status within 30 days.

d.

If the unfiltered inleakage of botentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the -

licensing basis analyses of DBA consequences (allowed to be up to 5 rem whole body or its equivalent to any part of the body), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.If the control room beound..,' i, inoel. hin i MODE 1, 2, 3, and 4, the GREVS trains cannot pe1:orM their intended-func-tions.-- Actioens6 mnust be takceI t1tJt1tFkJ1 FA-A.M. -A-'-'P-aFy WRHIR e-4 URAg tHe PeFIGG Mat T.

control room boundr is inoperble, appropriate comFpensator,' mneasur~e (con6Sitent With th eV inRtent of GOC 19) shoul-d beA utilized to protect conRtrol room operators fromA potential hazards suc~h as radioactivity, to)Xic chcmicals, smoke, tomporaturo and relative humidity, and physical security. PrpnlannHed mcasures should be available to addrcss these concerns for intenRtionl and unintentGional Po-tr int* the ACTION. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AGTION statlme÷nnt is renable based 9n the low probability of a IDBA occurring during this time period, and the use of cempons~ator, measures. The 24 hourF ACTION statement is a typically reasonable timne to) diagnose, plan and pessibly repair, and test onest problems with the control room bon ndary.

Durinq the period that the CRE boundary is considered inoperable, action must be initiated to implement mitiqating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenqe 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 mitiqatingq 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 mitiqating actions (i.eý, actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurrinq 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.

e.

With both trains of CREVS for reasons other than ACTION d and/or both trains of the CREACS inoperable, the function of the systems has been lost, requiring immediate action to place the unit in a MODE where the specification does not apply. To achieve this status, the unit 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 the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed outage 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.

ARKANSAS - UNIT 2 B 3/4 7-&G8 Rev. 44,

f.

If during handling of irradiated fuel, the system cannot be restored within 30 days, then either the OPERABLE CREACS train must be immediately placed in service or all activities involving the handling of irradiated fuel must be suspended. Placing the OPERABLE CREACS train in service ensures any active failure will be readily detected. The alternative to immediately suspend movement of irradiated fuel assemblies is acceptable since handling of irradiated fuel could release radioactivity that might require isolation of the CREonrGFeI FeOm. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

g.

If during handling of irradiated fuel, the system cannot be restored within 7 days, then either the OPERABLE CREVS train must be immediately placed in emergency recirculation mode or all activities involving the handling of irradiate fuel must be suspended. Placing the OPERABLE CREVS train in emergency recirculation mode ensures that no failures preventing automatic actuation will occur, and that any active failure will be readily detected. The alternative to immediately suspend movement of irradiated fuel assemblies is acceptable since handling of irradiated fuel could release radioactivity that might require isolation of the CREentr4 roeeom.

This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

ARKANSAS - UNIT 2 B 3/4 7-5G8 Rev. 44,

PLANT SYSTEMS BASES h.

If during handling of irradiated fuel, one CREVS train is inoperable for reasons other than ACTION d and one CREACS train are inoperable,_actions must be taken to restore the CREVS to an OPERABLE status within 7 days or immediately place the OPERABLE CREVS in the emergency recirculation mode and actions must be taken to restore the CREACS train to an OPERABLE status within 30 days or immediately place the OPERABLE CREACS train in service. If these actions cannot be accomplished, then all activities involving the handling of irradiated fuel must be suspended. This does not preclude movement of fuel to a safe position.

i.

If during handling of irradiated fuel, both CREVS trains or both CREACS trains are inoperable, actions must be taken immediately to suspend movement of irradiated fuel assemblies since this is an activity that could release radioactivity that could enter the CREcoRtFol Foem. This places the unit in a condition that minimizes the accident risk. This does not preclude movement of fuel-to a safe position.

If durinq the handlinq of irradiated fuel both CREVS trains are inoperable or with one or more CREVS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position. This does not preclude the movement of fuel to a safe position.

SURVEILLANCE REQUIREMENTS SR 4.7.6.1.1 a. and b.

These SRs, in conjunction with periodic preventative maintenance activities, provide verification that the CREACS will maintain the control room temperature within acceptable bound.

SR 4.7.6.1.1 .a is performed on a STAGGERED TEST BASIS with one train being tested every two weeks. The frequencies (31 days and 18 months) are appropriate as periodic preventative maintenance activities are routinely performed and significant degradation of the CREACS is not expected over these time periods.

SR 4.7.6.1.2.a Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every month adequately checks this system. This test is conducted on alternating trains on a STAGGERED TEST BASIS with one train being tested every two weeks by starting the system from the control room and initiating flow through the HEPA filters and charcoal adsorbers. The CREVS is designed without heaters and need only be operated at least 15 minutes to demonstrate the function of the system. The 31 day frequency is based on the known reliability of the equipment and two train redundancy available.

ARKANSAS - UNIT 2 B 3/4 7-5d9 Rev. 44,

.SR 4.7.6.1.2.b This SR. verifies that upon injection of an actual or simulated control room high radiation test signal the Control Room automatically isolates within 10 seconds and the CREVS switches into arecirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks. The frequency of 18 months is based on industry operating experience and is consistent with the typical refuelinq cycleconsistnt ,Withthe guida*ce provided in Rcgulatory' Guide 1.52.

ARKANSAS - UNIT 2 B 3/4 7-,5t9 Rev.-144,

PLANT SYSTEMS BASES SR 4.7.6.1.2.c This SR verifies that the required CREVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal. Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 4.7.6.1.2.d and SR 4.7.6.1.2.e This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the ORE boundary and into the eRE. The details of the testing are specified in the Control Room Envelope Habitability Program.Thoso .e...' SR. the ability of the CREVS to prvid outeido air at a flow rat.8. Gonsistt with their safoty fuction t*o protot th o*perator f4rom r-dol-ogical- o"xpure by minimiifrg uAnfiltered air iR leakagen the vnt o.f an accr.ident. Many facto~r, mu-st bcp tapkc~n into acco)unt to dbtormine the overall xcco doso cosqG61 ens for conRtrol room personnel during various Off nrGmal events. The CREVS makeup airflow a4nd filtper efficiency are two of the factors that must be considered. Makeup airflow, which is filtered outsido air, is drawn into)thFonrl o mrecircuated airflow to pressur~ize the control room in, order to reduc~e the potential for un1fileed in leakage. The flow verification ensures that an assumned amount of makeup air is available to account for bEoUnda~' leak paths. The flowrate verfiaton s onistent With SRP SecG-tion 6.4 (Reference 4) forF those conPtrol roomIrs having a design makeup rate Of Ž! 0.5 volumne changes per hour. Duo to design variations between the ffilter trains, the acceptance criteria forF each train are different. SR 3.7.9.4 verifies VSF= 9 makeup air flew accounting for a separate mnakeup air filter in the acceptance criteria. SR 3.7.9.5 verifies 2VSF= 9 makeup air flew which is based en expected fleW rates through the filew path. The Frequency Of 18 moneths is conRsidered adequate to detect an" degradation of the outeidoq air flew rate befor it is,reduced te a point at which sufficient pressurizatiPon will not 9GGGUF The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem whole body or its equivalent to any part of the body and the CRE occupants are protected from hazardous chemicals and smoke. This 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, ACTION d must be entered. ACTION d allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 3) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 4). These compensatory measures may also be used as mitigating actions. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 5). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA conseguence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

ARKANSAS - UNIT 2 B 3/4 7-106 Rev. ,--,

REFERENCES

1. SAR. Section 6.4 and 9.4.
2. SAR, Chapter 15.
3. Reaulatorv Guide 1.196.
4. NEI 99-03, "Control Room Habitability Assessment," June 2001
5. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694)

ARKANSAS - UNIT 2 B 3/4 7-106 AmendMent Noe. 132,206

-Rev. 4,44,,

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