RC-08-0007, License Amendment Request - LAR 03-01931-20, Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

License Amendment Request - LAR 03-01931-20, Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

ML080220067
Person / Time
Site:	Summer  (NPF-012)
Issue date:	01/17/2008
From:	Archie J South Carolina Electric & Gas Co
To:	Martin R Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 03-01931-20, RC-08-0007, TSTF-448, Rev 3
Download: ML080220067 (42)

Text

Jeffrey B. Archie Vice President, Nuclear Operations 803.345.4214 A schNA cOMPANY *January 17, 2008 A SCANA COMPANY R

-80 0

RC-08-0007 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTN: R. E. Martin

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 LICENSE AMENDMENT REQUEST - LAR 03-01931-20 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448, REVISION 3, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS In accordance with 10 CFR 50.90, South Carolina Electric & Gas Company (SCE&G), acting for itself and as agent for South Carolina Public Service Authority, is submitting a request for an amendment to the Virgil C. Summer Nuclear Station (VCSNS) Technical Specifications (TS).

This proposed amendment will modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3.

Attachment I provides a description of the proposed changes, the requested confirmation of applicability, and plant specific verifications. Attachment II provides the existing TS pages marked up to show the proposed changes. Attachment III provides the revised TS pages incorporating the changes. The associated marked up TS Bases changes are provided in Attachment IV for information only and will be implemented in accordance with the VCSNS Technical Specification Bases Control Program and 10 CFR 50.59. Attachment V provides a summary of the regulatory commitments made in this submittal.

SCE&G requests approval of the proposed License Amendment by December 31, 2008, with the amendment being implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated South Carolina Official.

This proposed change has been reviewed and approved by both the Plant Safety Review Committee and the Nuclear Safety Review Committee.

If you should have any questions regarding this submittal, please contact Mr. Bruce L.

Thompson at (803) 931-5042.

SCE&G I Virgil C. Summer Nuclear Station - P. O. Box 88. Jenkinsville, South Carolina 29065.T (803) 345.5209 - www.sceg.com 4-ID2-

Document Control Desk LAR 03-01931-20 RC-08-0007 Page 2 of 2 I certify under penalty of perjury that the foregoing is true and correct.

Executed on 7/7Jeffrey B.Arjie JWT/JBA/dr Attachments: (5)

I Description and Assessment of Proposed Changes II Proposed Technical Specification Changes - Mark-up III Revised Technical Specification Pages IV Proposed Technical Specification Bases - Mark-up V

List of Regulatory Commitments c:

K. B. Marsh S. A. Byrne N. S. Cams J. H. Hamilton R. J. White V. M. McCree R. E. Martin NRC Resident Inspector P. Ledbetter K. M. Sutton T. P. O'Kelley NSRC CR (LAR 03-01931)

File (813.20)

PRSF (RC-08-0007)

Document Control Desk Attachment I LAR 03-01931-20 RC-08-0007 Page 1 of 3 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

LICENSE AMENDMENT REQUEST - LAR 03-01931-20 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448, REVISION 3, USING CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 1.0 Desciption The proposed license amendment would modify Technical Specifications (TS) requirements related to control room envelope habitability in TS 3.7.6, "Control Room Normal and Emergency Air Handling System" and TS Section 6.8, "Procedures and Programs."

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) 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 South Carolina Electric & Gas Company (SCE&G) 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, Revision 3.

SCE&G has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to VCSNS and justify this amendment for the incorporation of the changes to the VCSNS TS.

2.2 Optional Changes and Variations SCE&G is not proposing any significant variations or deviations from the TS changes described in the TSTF-448, Revision 3, or the applicable parts of the NRC staffs model safety evaluation (SE) dated January 17, 2007. Applicable parts of the SE, as determined by SCE&G, are 3.1, Proposed Changes, 3.2, Editorial Changes, 3.3, TS - Evaluations 1, 4, and 6, and 3.4, TS - CRE Habitability Program.

Minor variations and/or deviations from the TS terminology used in NUREG-1431, Standard Technical Specifications - Westinghouse Plants, and TSTF-448, Revision 3 are required because the VCSNS TS are based on NUREG-0452. Consequently, the VCSNS TS wording and format do not directly correspond to STS and TSTF-448, Revision 3 wording and format. Also, the VCSNS TS do not use the NUREG-1431 STS identified terms, such as CONDITION, REQUIRED ACTION, and COMPLETION TIME or their associated table format. However, the intent of the CLIIP wording has been maintained in the proposed TS change and has been used verbatim to the extent possible. In addition, the VCSNS TS format separates Limiting Conditions for Operation (LCOs) and Action Statements (ACTION) from Surveillance Requirements (SRs) by placing them in different TS sections (i.e., Sections 3 and 4, respectively).

Document Control Desk Attachment I LAR 03-01931-20 RC-08-0007 Page 2 of 3 The minor variations and/or deviations from the specific wording/format provided in the CLIIP do not change the meaning, intent, or applicability of the CLIIP.

In addition, since TSTF-448, Revision 3 refers to a Ventilation Filter Testing Program (VFTP), SCE&G is including a VFTP in Section 6.8.4. The VFTP description is consistent with NUREG-1431, Revision

3. SCE&G is also submitting changes to the Containment Systems Particulate Iodine Cleanup System 3/4.6.3 and the Spent Fuel Pool Ventilation System 3/4.7.11 to align their surveillance requirements to the VFTP.

2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements SCE&G 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 Surveillance Requirement SR 4.7.6.e. in accordance with TS 6.8.4.m.3.(i), the assessment of CRE habitability as required by Specification 6.8.4.m.3.(ii), and the measurement of CRE pressure as required by Specification 6.8.4.m.4, shall be considered met. Following implementation:

(a) The first performance of SR 4.7.6, in accordance with Specification 6.8.4.m.3.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from March 25, 2005, the date of the most recent successful tracer gas test, as stated in the November 18, 2005 letter response to Generic Letter 2003-01, or within the 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 6.8.4.m.3.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from March 25, 2005, the date of the most recent successful tracer gas test, as stated in the November 18, 2005 letter response to Generic Letter 2003-01, 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 CRE pressure, specification 6.8.4.m.4, shall be within 18 months, plus the 138 days allowance of SR 4.0.2, as measured from September 28, 2006, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination SCE&G has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

SCE&G has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to VCSNS and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

Document Control Desk Attachment I LAR 03-01931-20 RC-08-0007 Page 3 of 3 3.2 Commitments There are no regulatory commitments created due to this License Amendment Request.

4.0 Environmental Evaluation SCE&G has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007, as part of the CLIIP. SCE&G has concluded that the staff's findings presented in that evaluation are applicable to VCSNS and the evaluation is hereby incorporated by reference for this application.

Document Control Desk Attachment II LAR 03-01931-20 RC-08-0007 Page 1 of 15 ATTACHMENT II PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Attachment to License Amendment No. XXX To Facility Operating License No. NPF-12 Docket No. 50-395 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages.

The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages VllI Vlll XIV XIV 3/46-15 3/46-15 3/46-16 3/46-16 3/47-14 3/47-14 3/4 7-15 3/4 7-15 3/4 7-40 3/4 7-40 3/47-41 3/47-41 6-12f 6-12f N/A 6/12g N/A 6-12h

Document Control Desk Attachment II LAR 03-01931-20 RC-08-0007 Page 2 of 15 SCE&G -- EXPLANATION OF CHANGES Page Affected Bar Description of Change Reason for Change Section VIII 3/4.7.6 1

Change Section 3/4.7.6 title.

Adopt standard Westinghouse terminology (NUREG-1431) as addressed by CLIIP for TSTF-448, Rev.3.

XIV B 3/4.7.6 1

Change Section 3/4.7.6 title.

Adopt standard Westinghouse (NUREG-1431) terminology as addressed by CLIIP for TSTF-448, Rev.3.

3/4 6-15 4.6.3.b 1

Change to refer filter testing to Adopt standard Westinghouse Ventilation Filter Testing (NUREG-1431) terminology and Program (VFTP).

preclude duplication of surveillance requirements.

4.6.3.c 2

Revise and renumber Revised to refer filter testing to surveillance requirements.

the VFTP as described in 6.8.4.1. (Note: moved to page 3/4 6-15 due to repagination.)

3/4 6-16 4.6.3.d Remove surveillance Removed filter testing to the requirements.

VFTP as described in 6.8.4.1 as referred to in new 4.6.3.b.

3/4 7-14 3/4.7.6 1

Change Section 3/4.7.6 title Adopt standard Westinghouse (NUREG-1431) terminology as addressed by CLIIP for TSTF-448, Rev.3.

3.7.6 2

Change description of Control For consistency with NUREG-Room Normal and Emergency 1431 terminology.

Air Handling System to CREFS trains.

3.7.6.a 3

Insert new Action a.

To incorporate TSTF-448, Rev.3.

3.7.6.b 4

Insert new Action b.

To incorporate TSTF-448, Rev.3.

4.7.6 5

Change description of Control For consistency with NUREG-Room Normal and Emergency 1431 terminology.

Air Handling System to CREFS trains.

4.7.6.b 6

Change description of Control For consistency with NUREG-Room Normal and Emergency 1431 terminology.

Air Handling System to CREFS trains and modify frequency statement.

4.7.6.c 7

Insert new surveillance To incorporate TSTF-448, requirements.

Rev.3.

Document Control Desk Attachment II LAR 03-01931-20 RC-08-0007 Page 3 of 15 Paae Affected Bar Description of Change Reason for Change Section

__on_#

3/4 7-14 8

Reword footnote.

To incorporate TSTF-448, cont.

Rev.3.

3/4 7-15 4.7.6.d 1

Insert new surveillance To incorporate TSTF-448, 4.7.6.e requirements.

Rev.3.

3/4 7-40 4.7.11.a 1

Reworded surveillance For consistency with NUREG-requirements.

1431 terminology and to be consistent with surveillance requirements of 4.6.3 and 4.7.6.

4.7.11.b 2

Revise surveillance Revised to refer filter testing to requirements.

the VFTP as described in 6.8.4.1.

4.7.11.c 3

Revise surveillance Removed filter testing to the requirements and renumber VFTP as described in 6.8.4.1 as steps.

referred to in new 4.7.11.b.

(Note: moved to page 3/4 6-15 due to repagination.)

3/4 7-41 1

This page has been deleted due This page has been deleted due to repagination.

to repagination.

6-12f 6.8.4 1

Insert new programs I and m.

To incorporate TSTF-448, 6-12g Rev.3.

6-12h

uWOING cOITIONS FOR OPERATION AND SUVEMIANCE REQUInEMETS 314.7 PL.ANT SYT 314.7.1 TUASINE CYCLE 34 7-1 8orgency Feoodwa Sysm.......--

W47-4 COWdmn Trek..

X4 7-6 3147.4 Main Stesm Lkw t V*.._

3/4"-0 keelwa ft I***Vi.

3/4 7-ft 314.7.2 STEAM GENERATOR PREBSUtRETmRTURtE UMITATION....

3/47-10 314.7.3 COMPONENT COOLJNG WATE] SYST'E,................

3/47-11 3W4.7.4 SERVICE WATER SYSTEM 3/4 7-42 3/4.7.5 ULTIMATE HEAT SNK__

7--.3 3(4.7.8 SEALED SOURCE CONTAP4NATION.

3147-4 3%4.7.9 AREA TIWPERATURE MON4TOAIU.

3/4 7-7 3(4.7.10 WATER LEVEL-SPENT FUEL POOl.

3/4 7-U 3X4.7.11 SPEW FUEL POOL VEN4TILATION 3(4 7-40 314.7.13 SPENT FUEL POOL BOFRONC ENTRATION X4 7-"

CI SUMMER - UN*IT I Vil Amandment No. 2-2,M 160

INDEX BASES SECTION 3/4.7 PLANT SYSTEMS 3/4.7.1 TU R BIN E CYC LE..................................................................................

3/4.7.2 STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION.....

3/4.7.3 COMPONENT COOLING WATER SYSTEM........................................

3/4.7.4 SERVICE W ATER SYSTEM..................................................................

3/4.7.5 ULTIMATE HEAT SINK.........................................................................

3/4.7.6 1CONTROL ROOM.O...L...

(EMERGENCY.RIINLN SYSTEM..(.e. )............

3/4.7.7 SNUBBERS..............

3/4.7.8 SEALED SOURCE CONTAMINATION.................................................

3/4.7.9 AREA TEMPERATURE MONITORING.................................................

3/4.7.10 WATER LEVEL - SPENT FUEL POOL..................................................

3/4.7.11 SPENT FUEL POOL VENTILATION SYSTEM......................................

3/4.7.12 SPENT FUEL ASSEMBLY STORAGE..................................................

3/4.7.13 SPENT FUEL POOL BORON CONCENTRATION...............................

3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1, 3/4.8.2 and 3/4.8.3 A.C. SOURCES, D.C. SOURCES AND ONSITE POW ER DISTRIBUTION SYSTEMS....................................................

3/4.8.4 ELECTRICAL EQUIPMENT PROTECTION DEVICES.........................

PAGE B 3/4 7-1 B 3/4 7-3 B 3/4 7-3 B 3/4 7-3 B 3/4 7-3 B 3/4 7-4 B 3/4 7-4-P B 3/4 7-6 B 3/4 7-6 B 3/4 7-6 B 3/4 7-6 B 3/4 7-7 B 3/4 7-7 B 3/4 8-1 B 3/4 8-4 I

SUMMER - UNIT 1 XlV Amendment No. 38, 63, 79,160, 178

[F7T k, i F!4,Ill P-woAvmTE IONELNP SYSTEM

-j. z"'

LIfTING CONDMON FOR OPERATION 3.6.3 Tw kxdpendm g*us of HEPA fier bands (aMcstas d wbh tgo OPERABLE maar bn oolM wil of Spocllca*lo 3.6.3) wt* at eW ona Vtr balk In e*h gum. m"a b OPER*B4LE.

Wk oray ona groeup HEPA liftr barnk OPERABL, restore one m te Iopeamble banks in ft ohr gmup to OPERABLE ofsuI wffM 7 pays or be In at Wast-HOT STANDBY wfeh the nexm 6 hum and in COLD SHUTDOWN wilin a* klawing 30 homu.

suRVELLAWNE REQUIREMENTS 4.o.3 The two goups of HEPA fiftr banke shal be demon fte OPERA.BLE

a.

At MW oace per 31 days by kli&alng. onm *e contlMroom, flowlluth=

HEPA fem and vedlying #a te t

yotmn oporam for at lert b

15 Mnt 9

SUMMER - UNIT I 3/46-15 Armenmn No.159

4 SURNVBU.AAE REOUREMSM M.

Alongta osP ISr 1.onthsby:

VerO t)59hat fti Owb byvpef damper can be opw-ed by VperWo adkwL Verylng OWa "i ftff bypmss dampar a~i n a Safaty Injection Tog

.1 I

0 SUMMER - UNIT 1 3Y4 s-16s Amenarnent No. 159

3/4-7.6 COITRO NORM~~AL ANY EMERGENCY AIRl 1 ANOLIIJSYSTEM(CES LIMITING CONDITION FOR OPERATION APPLICABILIY:

ALL MODES ACTION:

8.

MODESI1. 23and4:

ST DOY Wn next 6 hinC SHUUT N I the lo 30

b. MO0DES 5 and 6:

I.

ih contr ad araNd igs

,res the In e

to ERA E status lhfr7 or

" o alrnan of remaihi OPE LE ro)Mi air nup Wys in 16 the rria mode.

e stnsi ml it E

contro ancy rcdean nbrqu to be In SURVEILLANCE REQUIREMENTS OPERALE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is less than or equal to 85T.

b.

A least once per 31 days en a ST.AGGED*R TE-T BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers an ved*yM~ that th* eyl rtsfor at least 15 mninutes.

o. rt per mon or1 t

d

'th 6~~ii 1

hus*

or ln ha

'is con n*ocaty with syotey:

The contrI room boundary may be open ntemfittently under administrative control.

Amendment No. -$W4., 171

0 SUMMER - UMT I 3V4 7-15 44% 159

Document Control Desk Attachment II LAR 03-01931-20 RC-08-0007 Page 10 of 15 INSERT 3.7.6 (a)

1. With one CREFS train inoperable for reasons other than ACTION 3.7.6.a.2, restore the inoperable train 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 />.

2. With one or more CREFS trains inoperable due to an inoperable control room envelope (CRE) boundary, immediately initiate action to implement mitigating actions and verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits and restore 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 />.

3. With both CREFS trains inoperable for reasons other than ACTION 3.7.6.a.2, immediately enter LCO 3.0.3.

INSERT 3.7.6 (b)

1. With one CREFS train inoperable for reasons other than an inoperable CRE boundary, restore the inoperable train to OPERABLE status within 7 days, or immediately place the OPERABLE CREFS train in the emergency mode of operation or immediately suspend movement of recently irradiated fuel assemblies.

2. With both CREFS trains inoperable or one or more CREFS trains inoperable due to an inoperable CRE boundary, immediately suspend movement of recently irradiated fuel assemblies.

INSERT 4.7.6

c. By performing required CREFS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

d. At least once per 18 months by verifying that on a simulated SI or high radiation test signal, each CREFS train automatically switches into an emergency mode of operation with flow through the HEPA filters and charcoal adsorber banks.

e. By performing required CRE unfiltered air inleakage testing in accordance with the Control Room Habitability Program.

0 PLANTSYTM 3W4.7.11 sPENT FUEL POOL VENTLATION SYSTEM UMmNG CONDITION FOR OPERATION 3.7.11 Two m odpwidan aWow fuel Podl i'wdllun ajub4Yutes eAl ks..P L with aSleast one anub n in oqeamoL A

.PLC.M : Whenewr frdited flul Ib e moved In the spen fuel pool and duwng a"n ope*

tn oads obd r the pooL

a.

Wml one e"rt fuel pod vefnadon a--eyst knperabbe fuel movmert

%Mo ew spent fuel pool or ae operation wto h lool am Vie spent fe pool ma r ce provided th OPERAB.

spent fo'pod Melaon in ozpable of being powre from an OPERABLE emergeny pwm scums and is in CwraOlo endr dihar gln thruAi~ at beatoe tamib of KE:PA firmsi and duutcod adorbem

b.

Wit no apart fuel po vwenilon &64"alm OPERABLE. suspen &I opeauimw krtwoving movmerd of fue wMi thinR spent fuel padl or caune

-pau wati loads over the spert hael pood.

c.The provisions of Specifcation 3.0.4 are not appkodWle SURVEILLANCE REQUREMENTS 4.7.11 The above required SPent fuel Pool V01elot SUbf.**Mt atm be denXoSUMMald OPERAE:

I At.

W once per 31i S

byiMalbng *am t*% c*eil mwn-SAW-aua M*i vsrVyf that each ub-sA tw e

qoetes for t ewst 15 minzti.

SUMMER - UNIT I Amendment No. 42,*45G7 160

SURVEILLANCE REQUIREMENTS (Cortinumd) f'A~J Verffybig th at n a I=*s of ollaho pomwe toisnt u MilDe systm mkau~lo ay

( 3 Veltfying that the s rtem tinuaf he sOwpu fuel pod am* eta negagOv presum gmrat than or equal to 1/8 kichas Waar Smuga.rlmve to the outside atfmophere dirg syom umia p

SUMMER - UNIT I 3147-41 Amencknet No. 42i$

440.469,160

ADMINISTRATIVE CONTROLS location of flaws to which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.

a)

Inspect 100% of the tubes in each SG during the first refueling outage following SG replacement.

b)

Inspect 100% of the tubes at sequential periods of 144, 108, 72 and thereafter, 60 effective full power months. The first sequential period shall be considered to begin after the first inservice inspection of the SGs. In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outage nearest the end of the period. No SG shall operate for more than 72 effective full power months or three refueling outages (whichever is less) without being inspected.

c)

If crack indications are found In any SG tube, then the next Inspection for each SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever is less). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation

(

indicates that a crack-like indication Is not associated with a crack(s), then the indication need not be treated as a crack.

5.

Provisions for monitoring operational primary-to-secondary leakage.

1#51W a.P lL SUMMER - UNIT I 6.,12f Amendment No. 179

Document Control Desk Attachment II LAR 03-01931-20 RC-08-0007 Page 14 of 15 INSERT 6.8.4.1

1. Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in accordance with Regulatory Guide 1.52, Revision 2 and ASME N510-1989.

1. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flowrate specified below +

10%.

ESF Ventilation System Flowrate Control Room Emergency Filtration System 21,270 SCFM Spent Fuel Pool Ventilation System 30,000 ACFM Reactor Building Cooling Units 60,270 ACFM

2. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flowrate specified below +/- 10%.

ESF Ventilation System Flowrate Control Room Emergency Filtration System 21,270 SCFM Spent Fuel Pool Ventilation System 30,000 ACFM

3. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.

ESF Ventilation System Penetration RH Face Velocity (fps)

Control Room

<2.5%

70%

0.667 Spent Fuel Pool

<2.5%

95%

0.667

4. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flowrate specified below +/- 10%.

ESF Ventilation System Delta P Flowrate Control Room

<6 in. W.G.

21,270 SCFM Spent Fuel Pool

<6 in. W.G.

30,000 ACFM Reactor Building Cooling Units

<3 in. W.G.

60,270 ACFM The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the VFTP test frequencies.

Document Control Desk Attachment II LAR 03-01931-20 RC-08-0007 Page 15 of 15 INSERT 6.8.4.m

m. 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 Filtration System (CREFS), 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:

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

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

3. 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.

4. 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 CREFS, operating at the flow rate required by the Ventilation Filter Testing Program (VFTP), at a Frequency of 36 months on a STAGGERED TEST BASIS such that one train is tested every 18 months. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.

5. 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 6.8.4.m.3. 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.

6. The provisions of SR 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 6.8.4.m.3 and 6.8.4.m.4, respectively.

Document Control Desk Attachment III LAR 03-01931-20 RC-08-0007 Page 1 of 12 ATTACHMENT III REVISED TECHNICAL SPECIFICATION PAGES

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE Safety V alves.........................................................................................

3/4 7-1 Emergency Feedwater System..............................................................

3/4 7-4 Condensate Storage Tank.....................................................................

3/4 7-6 A ctivity....................................................................................................

3/4 7-7 Main Steam Line Isolation Valves..........................................................

3/4 7-9 Feedwater Isolation Valves....................................................................

314 7-9a 3/4.7.2 STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION.....

3/4 7-10 3/4.7.3 COMPONENT COOLING WATER SYSTEM........................................

3/4 7-11 3/4.7.4 SERVICE WATER SYSTEM..................................................................

3/4 7-12 3/4.7.5 ULTIMATE HEAT SINK.........................................................................

3/4 7-13 3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM (CREFS)....

3/4 7-14 3/4.7.7 SN UBBERS...........................................................................................

3/4 7-16 3/4.7.8 SEALED SOURCE CONTAMINATION.................................................

3/4 7-23 3/4.7.9 AREA TEMPERATURE MONITORING.................................................

3/4 7-37 3/4.7.10 WATER LEVEL - SPENT FUEL POOL..................................................

3/4 7-39 3/4.7.11 SPENT FUEL POOL VENTILATION SYSTEM......................................

3/4 7-40 3/4.7.12 SPENT FUEL ASSEMBLY STORAGE..................................................

3/4 7-42 3/4.7.13 SPENT FUEL POOL BORON CONCENTRATION...............................

3/47-44 SUMMER - UNIT 1 Vill Amendment No. 2 3,7 -,

6 9,

INDEX BASES SECTION 3/4.7 PLANT SYSTEMS 3/4.7.1 TU R BIN E CYC LE..................................................................................

3/4.7.2 STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION.....

3/4.7.3 COMPONENT COOLING WATER SYSTEM........................................

3/4.7.4 SERVICE W ATER SYSTEM..................................................................

3/4.7.5 ULTIMATE HEAT SINK.........................................................................

3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM (CREFS)....

3/4.7.7 S N U B BE R S...........................................................................................

3/4.7.8 SEALED SOURCE CONTAMINATION.................................................

3/4.7.9 AREA TEMPERATURE MONITORING.................................................

3/4.7.10 WATER LEVEL - SPENT FUEL POOL..................................................

3/4.7.11 SPENT FUEL POOL VENTILATION SYSTEM......................................

3/4.7.12 SPENT FUEL ASSEMBLY STORAGE..................................................

3/4.7.13 SPENT FUEL POOL BORON CONCENTRATION...............................

3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1, 3/4.8.2 and 3/4.8.3 A.C. SOURCES, D.C. SOURCES AND ONSITE PAGE B 3/4 7-1 B 3/4 7-3 B 3/4 7-3 B 3/4 7-3 B 3/4 7-3 B 3/4 7-4 B 3/4 7-4f B 3/4 7-6 B 3/4 7-6 B 3/4 7-6 B 3/4 7-6 B 3/4 7-7 B 3/4 7-7 POW ER DISTRIBUTION SYSTEMS....................................................

B 3/4 8-1 ELECTRICAL EQUIPMENT PROTECTION DEVICES.........................

B 3/4 8-4 3/4.8.4 SUMMER - UNIT 1 XlV Amendment No. 38, 63,79,160,

CONTAINMENT SYSTEMS 3/4.6.3 PARTICULATE IODINE CLEANUP SYSTEM LIMITING CONDITION FOR OPERATION 3.6.3 Two independent groups of HEPA filter banks (associated with the OPERABLE reactor building cooling units of Specification 3.6.2.3) with at least one filter bank in each group, shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

With only one group of HEPA filter banks OPERABLE, restore one of the inoperable banks in the other group 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 />.

SURVEILLANCE REQUIREMENTS 4.6.3 The two groups of HEPA filter banks shall be demonstrated OPERABLE:

a.

At least once per 31 days by initiating, from the control room, flow through the HEPA filters and verifying that the system operates for at least 15 minutes.

b.

By performing required filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

c.

At least once per 18 months by:

1.

Verifying that the filter bypass damper can be opened by operator action.

2.

Verifying that the filter bypass damper closes on a Safety Injection Test Signal.

SUMMER - UNIT 1 3/4 6-15 Amendment No. 46Q-

THIS PAGE INTENTIONALLY LEFT BLANK SUMMER - UNIT 1 3/4 6-16 Amendment No. 459 -

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM (CREFS)

LIMITING CONDITION FOR OPERATION 3.7.6 Two CREFS trains shall be OPERABLE.*

APPLICABILITY:

ALL MODES ACTION:

a.

MODES 1, 2, 3 and 4:

1.

With one CREFS train inoperable for reasons other than ACTION 3.7.6.a.2, restore the inoperable train 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 />.

2.

With one or more CREFS trains inoperable due to an inoperable control room envelope (CRE) boundary, immediately initiate action to implement mitigating actions and verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits and restore 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 />.

3.

With both CREFS trains inoperable for reasons other than ACTION 3.7.6.a.2, immediately enter LCO 3.0.3.

b.

MODES 5 and 6:

1.

With one CREFS train inoperable for reasons other than an inoperable CRE boundary, restore the inoperable train to OPERABLE status within 7 days, or immediately place the OPERABLE CREFS train in the emergency mode of operation or immediately suspend movement of recently irradiated fuel assemblies.

2.

With both CREFS trains inoperable or one or more CREFS trains inoperable due to an inoperable CRE boundary, immediately suspend movement of recently irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS 4.7.6 Each CREFS train shall be demonstrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is less than or equal to 850F.

b.

At least once per 31 days by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the CREFS train operates for at least 15 minutes.

c.

By performing required CREFS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

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

SUMMER - UNIT 1 3/4 7-14 Amendment No.

6 1!, ! 71,

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

d.

At least once per 18 months by verifying that on a simulated SI or high radiation test signal, each CREFS train automatically switches into an emergency mode of operation with flow through the HEPA filters and charcoal adsorber banks.

e.

By performing required CRE unfiltered air inleakage testing in accordance with the Control Room Habitability Program.

SUMMER - UNIT 1 3/4 7-15 Amendment No. 24,,

34,,

PLANT SYSTEMS 3/4.7.11 SPENT FUEL POOL VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.11 Two independent spent fuel pool ventilation sub-systems shall be OPERABLE with at least one sub-system in operation.

APPLICABILITY: Whenever irradiated fuel is being moved in the spent fuel pool and during crane operation with loads over the pool.

ACTION:

a.

With one spent fuel pool ventilation sub-system inoperable, fuel movement within the spent fuel pool or crane operation with loads over the spent fuel pool may proceed provided the OPERABLE spent fuel pool ventilation sub-system is capable of being powered from an OPERABLE emergency power source and is in operation and discharging through at least one train of HEPA filters and charcoal adsorbers.

b.

With no spent fuel pool ventilation sub-system OPERABLE, suspend all operations involving movement of fuel within the spent fuel pool or crane operation with loads over the spent fuel pool.

c.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.7.11 The above required spent fuel pool ventilation sub-systems shall be demonstrated OPERABLE:

a.

At least once per 31 days by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that each sub-system operates for at least 15 minutes.

b.

By performing required filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

c.

At least once per 18 months by:

1.

Verifying that on a loss of offsite power test signal, the system automatically starts.

2.

Verifying that the system maintains the spent fuel pool area at a negative pressure greater than or equal to 1/8 inches Water Gauge relative to the outside atmosphere during system operation.

SUMMER - UNIT 1 3/4 7-40 Amendment No. 42,159, 460-,

THIS PAGE INTENTIONALLY LEFT BLANK SUMMER - UNIT 1 3/4 7-41 Amendment No. 42 4 31,

140, 159,160,

ADMINISTRATIVE CONTROLS location of flaws to which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.

a)

Inspect 100% of the tubes in each SG during the first refueling outage following SG replacement.

b)

Inspect 100% of the tubes at sequential periods of 144, 108, 72 and thereafter, 60 effective full power months. The first sequential period shall be considered to begin after the first inservice inspection of the SGs. In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outage nearest the end of the period. No SG shall operate for more than 72 effective full power months or three refueling outages (whichever is less) without being inspected.

c)

If crack indications are found in any SG tube, then the next inspection for each SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever is less). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

5.

Provisions for monitoring operational primary-to-secondary leakage.

Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in accordance with Regulatory Guide 1.52, Revision 2 and ASME N510-1989.

1.

Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass

< 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flowrate specified below +/- 10%.

ESF Ventilation System Flowrate Control Room Emergency Filtration System 21,270 SCFM Spent Fuel Pool Ventilation System 30,000 ACFM Reactor Building Cooling Units 60,270 ACFM SUMMER - UNIT 1 6-12f Amendment No. 4-9-,

ADMINISTRATIVE CONTROLS

2.

Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flowrate specified below +/- 10%.

ESF Ventilation System Flowrate Control Room Emergency Filtration System 21,270 SCFM Spent Fuel Pool Ventilation System 30,000 ACFM

3.

Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30 0C (860F) and the relative humidity specified below.

ESF Ventilation System Penetration RH Face Velocity (fps)

Control Room

<2.5%

70%

0.667 Spent Fuel Pool

<2.5%

95%

0.667

4.

Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flowrate specified below

+ 10%.

ESF Ventilation System Delta P Flowrate Control Room

<6 in. W.G.

21,270 SCFM Spent Fuel Pool

<6 in. W.G.

30,000 ACFM Reactor Building Cooling Units

<3 in. W.G.

60,270 ACFM The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the VFTP test frequencies.

m.

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 Filtration System (CREFS), 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:

SUMMER - UNIT 1 6-12g Amendment No.

ADMINISTRATIVE CONTROLS 1

The definition of the CRE and the CRE boundary.

2.

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

3.

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.

4.

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 CREFS, operating at the flow rate required by the Ventilation Filter Testing Program (VFTP), at a Frequency of 36 months on a STAGGERED TEST BASIS such that one train is tested every 18 months. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.

5.

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 6.8.4.m.3. 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.

6.

The provisions of SR 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 6.8.4.m.3 and 6.8.4.m.4, respectively.

SUMMER - UNIT 1 6-12h Amendment No.

Document Control Desk Attachment IV LAR 03-01931-20 RC-08-0007 Page 1 of 9 ATTACHMENT IV PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP)

PLANT SYSTEMS BASES ULTIMATE HEAT SINK rContinued)

The imitations on minimum water level and maximum temperature are based on providing a 30 day ooling water supply to safety related equiment without exceeding their design basis Itmperature and Is consistent with the recommendallons of Regulatory Guide 1.27. "Ultmate Heat Sink for Nuclear Plants. March 1974.

I AN snubbers on systems required for safe shutdown/accident miUtigation shall be OPERABLE. This Includes safety and non-safety related siubbers on systems used to protect the code boundary and to ensure the structural integrity of these systems under dynamic loads.

SUMMER - UNIT I B03147-4 Amendment No. 4 37-103. 171

Document Control Desk Attachment IV LAR 03-01931-20 RC-08-0007 Page 3 of 9 INSERT B 3 / 4.7.6 Control Room Emergency Filtration System (CREFS)

BASES BACKGROUND The CREFS provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The CREFS consists of two independent, redundant trains that recirculate and filter the air in the control room envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air. Each CREFS train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system. A second bank of HEPA filters follows the adsorber section to collect carbon fines and provides backup in case of failure of the main HEPA filter bank.

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 CREFS is an emergency system, parts of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of the actuating signal(s), normal air supply to the CRE is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers.

Actuation of the CREFS to the emergency mode of operation aligns the system for recirculation air within the CRE through the redundant trains of HEPA and the charcoal filters. The emergency mode of operation maintains pressurization and filtered ventilation of the air supply to the CRE.

Document Control Desk Attachment IV LAR 03-01931-20 RC-08-0007 Page 4 of 9 Outside air is filtered and added to the air being recirculated from the CRE.

Pressurization of the CRE minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas adjacent to the CRE boundary.

The air entering the CRE is continuously monitored by radiation detectors. Detector output above the setpoint will cause actuation of the emergency mode of operation.

A single CREFS train operating at a nominal flow rate of < 21,270 scfm will pressurize the CRE to approximately 0.125 inches water gauge relative to external areas adjacent to the CRE boundary. The CREFS operation in maintaining the CRE habitable is discussed in the FSAR, Section 9.4 (Ref. 1).

Redundant supply and recirculation trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally open isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The CREFS is designed in accordance with Seismic Category I requirements.

The CREFS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem whole body dose or its equivalent to any part of the body.

APPLICABLE SAFETY ANALYSES The CREFS components are arranged in redundant, safety related ventilation trains.

The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. The CREFS provides airborne radiological protection for the CRE occupants as demonstrated by the CRE occupant dose analyses for the most limiting design basis loss of coolant accident, fission product release presented in the FSAR, Chapter 15 (Ref. 2).

The CREFS 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. 3).

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. 4).

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

The CREFS satisfies Criterion 3 of 10 CFR 50.36(d)(2)(ii).

Document Control Desk Attachment IV LAR 03-01931-20 RC-08-0007 Page 5 of 9 LCO Two independent and redundant CREFS 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 any part of the body to the CRE occupants in the event of a large radioactive release.

Each CREFS train is considered OPERABLE when the individual components necessary to limit CRE occupant exposure are OPERABLE. A CREFS train is OPERABLE when the associated:

a. Fan is OPERABLE,

b. HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions, and

c. Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In order for the CREFS 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.

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 a need for CRE isolation is indicated.

APPLICABILITY In MODES 1, 2, 3, and 4, and during movement of recently irradiated fuel assemblies, the CREFS must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

In MODES 5 and 6, the CREFS is required to cope with the release from the rupture of an outside waste gas tank.

During movement of recently irradiated fuel assemblies, the CREFS must be OPERABLE to cope with the release from a fuel handling accident.

Document Control Desk Attachment IV LAR 03-01931-20 RC-08-0007 Page 6 of 9 ACTIONS 3.7.6.a.1 When one CREFS train is inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 7 days. In this LCO, the remaining OPERABLE CREFS train is adequate to perform the CRE occupant protection function. However, the overall reliability is reduced because a failure in the OPERABLE CREFS train could result in loss of CREFS function. The 7 day Allowed Outage Time (AOT) 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.

In MODE 1, 2, 3, or 4, if the inoperable CREFS train or the CRE cannot be restored to OPERABLE status within the required AOT; the unit must be placed in a MODE that minimizes accident risk. 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 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The AOTs 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.

3.7.6.a.2 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem whole body or its equivalent to any part of the body), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable.

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 LCO, 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 /> AOT is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day AOT 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 AOT is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

Document Control Desk Attachment IV LAR 03-01931-20 RC-08-0007 Page 7 of 9 3.7.6.a.3 If both CREFS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e., LCO ACTION 3.7.6.a.2), the CREFS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

3.7.6.b. 1 In MODE 5 or 6, or during movement of recently irradiated fuel assemblies, if the inoperable CREFS train cannot be restored to OPERABLE status within the required AOT, action must be taken to immediately place the OPERABLE CREFS train in the emergency mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative to Required Action 3.7.6.b.1 is to immediately 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.

3.7.6.b.2 In MODE 5 or 6, or during movement of recently irradiated fuel assemblies, with two CREFS trains inoperable or with one or more CREFS 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.

SURVEILLANCE REQUIREMENTS SR 4.7.6.a The control room temperature should be checked periodically to ensure that the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by the CREFS and that the control room will remain habitable for operations personnel during and following all credible accident conditions.

Document Control Desk Attachment IV LAR 03-01931-20 RC-08-0007 Page 8 of 9 SR 4.7.6.b Standby systems should be checked periodically to ensure that they function properly.

As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. The VCSNS CREFS does not have heaters and each train need only be operated for a minimum of 15 minutes to demonstrate the function of the system. The 31 day Frequency is based on the reliability of the equipment and the two train redundancy.

SR 4.7.6.c This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP implementing procedures.

SR 4.7.6.d This SR verifies that each CREFS train starts and operates on an actual or simulated actuation signal. The Frequency of 18 months is based on industry operating experience and is consistent with the typical refueling cycle.

SR 4.7.6.e 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 Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem whole body or its equivalent to any part of the body and the CRE occupants are protected from hazardous chemicals and smoke. This 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 3.7.6.a.2 must be entered. Action 3.7.6.a.2 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. 5) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 6). These compensatory measures may also be used as mitigating actions as required by Action 3.7.6.a.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 7). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis

Document Control Desk Attachment IV LAR 03-01931-20 RC-08-0007 Page 9 of 9 DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

REFERENCES

1. FSAR, Section 9.4.

2. FSAR, Chapter 15.

3. FSAR, Section 6.4.

4. FSAR, Section 9.5.

5. Regulatory Guide 1.196.

6. NEI 99-03, "Control Room Habitability Assessment," March 2003.

7. 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).

Document Control Desk Attachment V LAR 03-01931-20 RC-08-0007 Page 1 of I ATTACHMENT V LIST OF REGULATORY COMMITMENTS There are no regulatory commitments created due to this License Amendment Request.