ML080250068
| ML080250068 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/17/2008 |
| From: | Mims D Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-05801-DCM/GAM | |
| Download: ML080250068 (31) | |
Text
10 CFR 5O.90 A M A subsidiary ofPinnacle West CapitalCorporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Vice President Tel. 623-393-5403 P. 0. Box 52034 Generating Station Regulatory Affairs and Plant Improvement Fax 623-393-6077 Phoenix, Arizona 85072-2034 102-05801-DCM/GAM January 17, 2008 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance With TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Arizona Public Service Company (APS) is submitting a request for an amendment to the technical specifications (TS) for PVNGS Units 1, 2, and 3. The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3. 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. Attachment 4 provides existing TS Bases pages marked up to show the proposed changes.
APS requests approval of the proposed license amendment by January 31, 2009, with the amendment to be implemented within 180 days of approval.
In accordance with the PVNGS Quality Assurance Program, the Plant Review Board and the Offsite Safety Review Committee have reviewed and concurred with this proposed amendment. By copy of this letter, this submittal is being forwarded to the Arizona Radiation Regulatory Agency (ARRA) pursuant to 10CFR 50.91(b)(1).
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Aa02A Callaway
- Comanche Peak
- Diablo Canyon 0 Palo Verde 0 South Texas Project
- Wolf Creek
NRC Document Control Desk Application to Revise Technical Specifications Regarding Control Room Envelope Habitability Page 2 This submittal satisfies the commitment made in APS letter no. 102-05609, dated December 8, 2006, to submit a TS amendment request to modify the requirements related to control room envelope habitability in accordance with TSTF-448, "Control Room Habitability," with any appropriate, justified site-specific deviations, within one year after the final approved CLIIP for TSTF-448 is published in the Federal Register.
No commitments are being made to the NRC by this letter. However, several license conditions are being proposed in Section 2.3 of Attachment 1 to support implementation of the proposed TS changes.
If there are any questions or if additional information is needed, please contact Glenn A.
Michael at (623) 393-5750.
I declare under penalt of perjury that the foregoing is true and correct.
Executed on (Date)
Sincerely, DCM/SAB/GAM/
Attachments:
- 1. Description and Assessment
- 2. Proposed Technical Specification Changes (Mark-Up)
- 3. Revised (clean) Technical Specification Pages.
- 4. Proposed Technical Specification Bases Changes (Mark-Up) cc: E. E. Collins Jr. NRC Region IV Regional Administrator M. T. Markley NRC NRR Project Manager G. G. Warnick NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA) aqodwin0ýazrra.qov)
T. Morales Arizona Radiation Regulatory Agency (ARRA) tmorales(bazrra..qov)
ATTACHMENT 1 DESCRIPTION AND ASSESSMENT
Subject:
Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance With TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process
1.0 DESCRIPTION
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Changes and Variations 2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination 4.0 ENVIRONMENTAL EVALUATION
Attachment 1 Description and Assessment
1.0 DESCRIPTION
The proposed amendment would modify technical specification (TS) requirements related to control room envelope habitability in TS 3.7.11, "Control Room Essential Filtration System (CREFS)" and TS Section 5.5, "Administrative Controls - Programs and Manuals." The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-448, Revision 3. The availability of this TS improvement was published in the Federal Register (72 FR 2022) on January 17, 2007 as part of the consolidated line item improvement process (CLIIP).
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Arizona Public Service Company (APS) 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. APS has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 and justify this amendment for the incorporation of the changes to the PVNGS TS.
2.2 Changes and Variations APS is proposing the following minor variations or deviations from the TS changes described in TSTF-448, Revision 3 or from the NRC staffs model safety evaluation, "Evaluation 2 - for facilities that have not yet adopted the CREFS TS LCO Note and Action B of TSTF-287, Rev. 5," dated January 17, 2007.
Section Variation or Deviation Justification TS 3.7.11 - Required The requirement to verify There are no quantitative limits for Action B.2, and mitigating actions to ensure CRE smoke or hazardous chemicals.
associated TS Bases. occupant exposures will not Additionally, per the PVNGS exceed smoke and hazardous licensing basis, hazardous chemical limits is replaced with chemicals are not stored or used the requirement to protect the onsite in quantities sufficient to CRE occupants from smoke and necessitate CRE protection, as hazardous chemicals, required by Regulatory Guide 1.78.
Nearby industrial, military, and transportation facilities present no hazard to the operation of PVNGS, and there are no site-related design basis events due to accidents at these facilities.
1
Attachment 1 Description and Assessment Section Variation or Deviation Justification TS 3.7.11 - Condition Proposed Condition D addresses The Condition "during movement of D, and associated TS Mode 5 and Mode 6 only, rather irradiated fuel assemblies" is Bases. than Mode 5, Mode 6 and "during addressed in a separate Condition E movement of irradiated fuel in the Palo Verde TS 3.7.11 assemblies." because the appropriate Required Action for "during movement of irradiated fuel assemblies" is different from the Required Action for Mode 5 or 6.
TS 3.7.11 - Required The change to the Note on "toxic The note on "toxic gas protection Action D.1, and gas protection mode" in Required mode" is not in the PVNGS TS associated TS Bases. Action D.1 of TSTF-448 is not 3.7.11. Toxic Gas Protection is not proposed. a mode of CREFS operation at PVNGS.
TS 5.5.17.d When referring to the trending of The assessment is described as a CRE pressure relative to periodic assessment in NEI 99-03, adjacent areas, "[18] month Revision 1. The periodicity is shown assessment" has been replaced in Figure 1 of RG 1.197, May 2003, with "periodic assessment" to "Periodic Testing and Assessment describe the assessment interval. Schedule," and in Figure 1 in NEI 99-03, Revision 1, as every 6 years.
TS 5.5.17.e The last sentence regarding There are no quantitative limits for unfiltered air inleakage limits for hazardous chemicals. Additionally, hazardous chemicals meeting per the PVNGS licensing basis, the assumptions of the licensing hazardous chemicals are not stored basis has not been included in or used onsite in quantities sufficient TS 5.5.17.e. to necessitate CRE protection, as required by Regulatory Guide 1.78.
Nearby industrial, military, and transportation facilities present no hazard to the operation of PVNGS, and there are no site-related design basis events due to accidents at these facilities.
TS Bases B 3.7.11, The description of outside air This is an editorial enhancement Background entering the CRE was revised to that does not impact the TSTF-448 clarify that it combines with changes.
recirculated air from the CRE prior to being filtered.
TS Bases B 3.7.11, The description of "normally open This is an editorial enhancement Background isolation dampers" has been that does not impact the TSTF-448 enhanced to clarify that these changes.
dampers are components of the normal Control Room HVAC System.
2
Attachment 1 Description and Assessment Section Variation or Deviation Justification TS Bases B 3.7.11, A reference to Regulatory Guide Regulatory Guide 1.52, Revision 2 References (RG) 1.52, Revision 2 is being continues to be referenced in TS maintained. Bases for SR 3.7.11.2, which is not affected by TSTF-448, to reflect the current licensing bases. The reference to RG 1.52 is being deleted from the Bases for SR 3.7.11.3, consistent with TSTS-448..
2.3 License Conditions Regarding Initial Performance of New Surveillance and Assessment Requirements APS proposes the PVNGS Units 1, 2, and 3 license conditions described below to support implementation of the proposed TS changes. It is anticipated that these proposed license conditions would be imposed consistent with Section 4.4 of NRC Office Instruction LIC-101, Revision 3, "License Amendment Review Procedures"; i.e.,
"along with other legally binding aspects of the amendment (e.g., when the amendment is effective and when the amendment must be implemented) on the amendment page (usually listed as item 3) that is signed by an authorized member of the NRR staff.
These conditions are generally not added to the operating license (i.e., Section 2.C)."
Proposed license conditions:
Upon implementation of TS Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.11.4, in accordance with TS 5.5.17.c.(i), the assessment of CRE habitability as required by Specification 5.5.17.c.(ii), and the measurement of CRE pressure as required by Specification 5.5.17.d, shall be considered met.
Following implementation of TS Amendment No. xxx adopting TSTF-448, Revision 3:
(a) The first performance of SR 3.7.11.4, in accordance with Specification 5.5.17.c.(i), shall be as follows for each unit:
Unit 1: Within the specified Frequency of 6 years plus-the 18-month allowance of SR 3.0.2, as measured from August 9, 2005, the date of the most recent successful tracer gas test on Unit 1.
Unit 2: Within the first 18 months of implementation, because the time period since the most recent successful tracer gas test on Unit 2 (April 26, 2001) is greater than 6years.
3
Attachment 1 Description and Assessment Unit 3: Within the specified Frequency of 6 years plus the 18-month allowance of SR 3.0.2, as measured from August 15, 2005, the date of the most recent successful tracer gas test on Unit 3.
(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.17.c.(ii), shall be as follows for each unit:
Unit 1: Within 3 years plus the 9-month allowance of SR 3.0.2, as measured from August 9, 2005, the date of the most recent successful tracer gas test on Unit 1, or within the first 9 months of implementation, which ever is later.
Unit 2: Within the first 9 months of implementation, because the time period since the date of the most recent successful tracer gas test on Unit 2 (April 26, 2001) is greater than 3 years.
Unit 3: Within 3 years plus the 9-month allowance of SR 3.0.2, as measured from August 15, 2005, the date of the most recent successful tracer gas test on Unit 3, or within the first 9 months of implementation, which ever is later.
(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.17.d, shall be as follows for each unit:
Unit 1: Within 18 months plus the 138 days allowed by SR 3.0.2, as measured from May 16, 2007, the date of the most recent successful pressure measurement test on Unit 1, or within the first 138 days of implementation, which ever is later.
Unit 2: Within 18 months plus the 138 days allowed by SR 3.0.2, as measured from September 18, 2006, the date of the most recent successful pressure measurement test on Unit 2, or within the first 138 days of implementation, which ever is later.
Unit 3: Within 18 months plus the 138 days allowed by SR 3.0.2, as measured from November 23, 2007, the date of the most recent successful pressure measurement test on Unit 3, or within the first 138 days of implementation, which ever is later.
3.0 REGULATORY ANALYSIS
3.1 No Siqnificant Hazards Consideration Determination APS has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. APS has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to 4
Attachment 1 Description and Assessment PVNGS Units 1, 2 and 3 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
4.0 ENVIRONMENTAL EVALUATION APS has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007 as part of the CLIIP. APS has concluded that the staffs findings presented in that evaluation are applicable to PVNGS Units 1, 2 and 3 and the evaluation is hereby incorporated by reference for this application.
5
Attachment 2 Proposed Technical Specification Changes (Mark-Up)
Pages:
3.7.11-1 3.7.11-2 3.7.11-3 5.5-16 5.5-17
CREFS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Essential Filtration System (CREFS)
LCO 3.7.11 Two CREFS trains shall be OPERABLE.
NOTE ---------------
The Control Room Envelope (CRE) boundary may be opened intermittently under administrative control.
APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREFS train A.1 Restore CREFS train 7 days inoperable for reasons to OPERABLE status.
other than Condition B.
B. One or more CREFS B.1 Initiate action to Immediately trains inoperable due implement mitigating to inopera le CRE actions boundary in MOE1, 2, AND 3, or 4.
B.2 Verify mitigating 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions ensure CRE occupant exposures will not exceed radiological limits and that CRE occupants are protecte from smoke and potential chemical hazards.
AND B.3 Restore CRE boundary 90 days to OPERABLE status.
PALO VERDE UNITS 1,2,3 3.7.11-1 AMENDMENT NO. 117
CREFS 3.7.11 CONDITION REQUIRED ACTION COMPLETION TIME 9C, Required Action and BC.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion AND Time of Condition A or B not met in MODE 1, 9C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 2, 3, or 4. C GD. Required Action and GD.1 Place OPERABLE CREFS Immediately associated Completion train in operation.
Time of Condition A not met in MODES 5 4 or 6.
DE. Required Action and DE.1 Place OPERABLE CREFS Immediately associated Completion Train in operation.
Time of Condition A OR not met during Immediatel movement of irradiated DE.2 Suspend movement of fuel assemblies. irradiated fuel assemblies.
- F. Two CREFS trains *EF.1 Suspend CORE Immediately inoperable in MODES 5 ALTERATIONS.
44 or 6, or during movement of irradiated AND fuel assemblies.
OR One or more CREFS EF.2 - Suspend irradiated fuel of movement Immediately trains ino perable due as ies.
to inopera le CRE assemblies.
boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies.
-G. Two CREFS trains -PG.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.
PALO VERDE UNITS 1,2,3 3.7.11-2 AMENDMENT NO. 117
CREFS 3.7.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Operate each CREFS train for >_15 minutes. 31 days SR 3.7.11.2 Perform required CREFS filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program -VFTP).
SR 3.7.11.3 Verify each CREFS train actuates on an 18 months.
actual or simulated actuation signal.
SR 3.7.11.4 Perform required CRE unfiltered air In accordance inleakage testing in accordance with the with the Control Control
\I* ....~ Room(' Envelope
[-rr
', pe= Habitability
... Program.
Habitabilit Room Envelope veri1y onRe- C.1REF train can maintain a Habitability posi*tve pressure of*, 0.125 inches Water-r Program. -18 gauge, relative to the adjacent area during m~h operation at a ventilat-io flow rate of STA416ERDITI TEST
<1000 cfm BASIS PALO VERDE UNITS 1,2,3 3.7.11-3 AMENDMENT NO. 117
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.16 Containment Leakage Rate Testing Program (continued)
- b. The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 52.0 psig for Unit 1 through operating cycle 12 and Unit 3 through operating cycle 13, and 58.0 psig for Unit 1 after operating cycle 12, Unit 2, and Unit 3 after operating cycle 13. The containment design pressure is 60 psig.
- c. The maximum allowable containment leakage rate, La, at Pa, shall be 0.1 % of containment air weight per day.
- d. Leakage Rate acceptance criteria are:
- 1. Containment leakage rate acceptance criterion is
- 1.0 La.
During the first unit startup following testing in accordance with this program, the leakage rate acceptance are < 0.60 La for the Type B and C tests and
- 0.75 La for Type A tests.
- 2. Air lock testing acceptance criteria are:
a) 'Overall air lock leakage rate is
- 0.05 La when tested at Ž Pa.
b) For each door, leakage rate is
- 0.01 La when pressurized to Ž 14.5 psig.
- e. The provisions of SR 3.0.2 do not apply to the test frequencies in the Containment Leakage Rate Testing Program.
- f. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.
[Relocate page-end line to the bottom of the page and add "(continued)"1 PALO VERDE UNITS 1,2,3 5.5-16 AMENDMENT NO. 4-5-7,161
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.17 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 Essential 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 e]ements:
- 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 in accordance with the testing methods and 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 GRE habitability at the Frequencies specified in in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.
- d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation of one train of the CREFS, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the periodic assessment of the CRE boundary.
- e. The quantitative limits on unfiltered air inleakage into the CRE 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.
- f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing GRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.
PALO VERDE UNITS 1,2,3 5.5-17 AMENDMENT NO. 4-4-7, 161
Attachment 2 Revised (clean) Technical Specification Pages Pages:
3.7.11-1 3.7.11-2 3.7.11-3 5.5-16 5.5-17
CREFS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Essential Filtration System (CREFS)
LCO 3.7.11 Two CREFS trains shall be OPERABLE.
--------- - -NOTE- ---------------------
The Control Room Envelope (CRE) boundary may be opened intermittently under administrative control.
APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies, ACTIONS CONDITION. REQUIRED ACTION COMPLETION TIME A. One CREFS train A.1 Restore CREFS train 7 days inoperable for reasons to OPERABLE status.
other than Condition B.
B. One or more CREFS B.1 Initiate action to Immediately trains inoperable due implement to inoperable CRE mitigating actions.
boundary in MODE 1, 2, 3, or 4. AND B.2 Verify mitigating 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions ensure CRE occupant exposures will not exceed radiological limits and that CRE occupants are protected from smoke and potential chemical hazards.
AND B.3 Restore CRE 90 days boundary to OPERABLE status.
(continued)
PALO VERDE UNITS 1,2,3 3.7.11-1 AMENDMENT NO. 4,
CREFS 3.7.11 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Compl eti on Time of Condition A or AND B not met in MODE 1, 2, C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 3, or 4.
D Required Action and D.1 Place OPERABLE Immediately associated Completion CREFS train in Time of Condition A not operation.
met in MODE 5 or 6.
E. Required Action and E.1 Place OPERABLE Immediately associated Completion CREFS Train in Time of Condition A not operation.
met during movement of irradiated fuel OR assemblies.
E.2 Suspend movement or Immediately irradiated fuel assemblies.
F. Two CREFS trains F.1 Suspend CORE Immediately inoperable in MODE 5 or ALTERATIONS.
6, or during movement of irradiated fuel AND assemblies.
OR One or more CREFS trains F.2 'Suspend movement of Immediately inoperable due to irradiated fuel inoperable CRE boundary assemblies.
in MODE 5 or 6, or during movement of irradiated fuel assemblies.
G. Two CREFS trains G.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4, for reasons other than Condition B.
(continued)
PALO VERDE UNITS 1,2,3 3.7.11-2 AMENDMENT NO. 44-ý,
CREFS 3.7.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Operate each CREFS train for Ž 15 minutes. 31 days SR 3.7.11.2 Perform required CREFS filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).
SR 3.7.11.3 Verify each CREFS train actuates on an 18 months actual or simulated actuation signal.
SR 3.7.11.4 Perform required CRE unfiltered air In accordance inleakage testing in accordance with the with the Control Control Room Envelope.Habitability Program. Room Envelope Habitability Program.
PALO VERDE UNITS 1,2,3 3.7.11-3 AMENDMENT NO. 44-ý,
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.16 Containment Leakage Rate Testing Program (continued)
- b. The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 52.0 psig for Unit 1 through operating cycle 12 and Unit 3 through operating cycle 13, and 58.0 psig for Unit 1 after operating cycle 12, Unit 2, and Unit 3 after operating cycle 13. The containment design pressure is 60 psig.
- c. The maximum allowable containment leakage rate, La, at Pa, shall be 0.1 % of containment air weight per day.
- d. Leakage Rate acceptance criteria are:
- 1. Containment leakage rate acceptance criterion is
- 1.0 La.
During the first unit startup following testing in accordance with this program, the leakage rate acceptance are < 0.60 L, for the Type B and C tests and ! 0.75 La for Type A tests.
- 2. Air lock testing acceptance criteria are:
a) Overall air lock leakage rate is
- 0.05 La when tested at Ž Pa.
b) For each door, leakage rate is
- 0.01 La when pressurized to Ž 14.5 psig.
- e. The provisions of SR 3.0.2 do not apply to the test frequencies in the Containment Leakage Rate Testing Program.
- f. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.
(continued)
PALO VERDE UNITS 1,2,3 5.5-16 AMENDMENT NO. 441,
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.17 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 Essential 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:
- 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 in accordance with the testing methods and the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Determining 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 andC.2 of Regulatory Guide 1.197, Revision 0.
- d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation of one train of the CREFS, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the periodic assessment of the CRE boundary.
,e. The quantitative limits on unfiltered air inleakage into the CRE 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.
- f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.
PALO VERDE UNITS 1,2,3 5.5-17 AMENDMENT NO. 4-4,
Attachment 3 Proposed Changes to Technical Specification Bases Pages (Mark-Up)
Pages:
B 3.7.11-1 B 3.7.11-2 B 3.7.11-3 B 3.7.11-4 B 3.7.11-5 B 3.7.11-6 B 3.7.11-7 B.3.7.11-8 B 3.7.11-9 B 3.7.11-10
CREFS B 3.7.11 B 3.7 PLANT SYSTEMS B 3.7.11 Control Room Essential Filtration System (CREFS)
BASES BACKGROUND The CREFS provides a protected environment from which opeptatps 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) a-a and a CRE boundary that limits the inleakage o unfiTTtered air. Each CREFS train consists of a prefilter, a High Efficiency Particu-late Air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodine), 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 back-up 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. Upon receipt of the actuating signal(s), normal HVAC to the eontrpl rpeoCRE is isolated, and the stream of ventilation air is mixed w-fh outside air and recirculated through the filter trains of the system. The prefilters remove any large particles in the air, to prevent excessive loading of the HEPA filters and charcoal adsorbers.
PALO VERDE UNITS 1,2,3 B 3.7.11 -1 REVISION 10
CREFS B 3.7.11 BACKGROUND (continued) Actuation of CREFS aligns the system for recirculation of control room air mixed Iw'ith outside the air within the CRE through the redundant trains of HEPA and charcoal filters.
Actuation of fthe CREFS also initiates pressurization and filtered ventilation of th air supply to the ontrel roo CRE.
Outside air is combined and filtered, and then added to with the air being recirculated from the controloom CRE.
Pr-essurization of the contprlroomGCRE ppeve4ts minimizes infiltration of unfiltered air from-Tl the surrounding areas adjacent to ef the -bH,4,44- the-CRE boundary.
The air entering the cotrol room CRE is continuously monitored by radiation detectors. Me detector output above the setpoint will cause actuation of the CREFS trains.
A single CREFS train operating at a flow rate of : 1000 cfm is designed to pressurize the cnr CRE to Ž0.125 inches water gauge relative to external areas adjacent to the CRE boundary. The CREFS operation in maintaining the CRE e habitable is discussed in the UFSAR, Sec--tion 6.4 (Ref. 1).
Redundant recirculation trains provide the required filtration. Normally open isolation dampers in the normal Control Room HVAC System 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 the control room environment 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 to the CRE occupants in the event of a large radioactive release.
APPLICABLE SAFETY ANALYSES The CREFS components are arranged in redundant, safety related ventilation trains. The location of components and ducting within the control room envelope GRE ensures an adequate supply of filtered air to all areas requiring access.
PALO VERDE UNITS 1,2,3 B 3.7.11-2 REVISION 10
CREFS B 3.7.11 APPLICABLE SAFETY ANALYSES (continued) The CREFS provides airborne radiological protection for the
,,,*t ........
eI, PA CRE occu ants, as demonstrated by the CRE occupant Gcotr room 2c5-4 dose analyses for the most limiting design basis loss of coolant accident fission product release presented in the UFSAR Chapter 15 (Ref. 2).
The CREFS provides protection from smoke and hazardous chemicals to the CRE occupants; 1'e-J--, se& however, hazardous chemicals are not stored or used onsite in quantities sufficient to necessitate CRE cotrol room protection, as required by RegulatoryTuide 1.78 (Ref. 1).
In addition, nearby industrial, military, and transportation facilities present no hazard to the operation of PVNGS, and there are no site-related design basis events due to accidents at these facilities (Ref. 61 and 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 panel (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 (c)(2)(ii).
LCO Two independent and redundant trains of the CREFS are required to be OPERABLE to ensure that at least one is available, asing if %44,at a single active failure disables the other train. Tot-al system failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in 8 roo..m operatorrecei.in.
exceeding a dose #R-eSS 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.
T-he Each CREFS train is considered OPERABLE when the individual components necessary to ctrolll operator limit CRE occupant exposure are OPERABLE in both trains. -TR-FS train is considered OPERABLE when the associated:
- a. Fan is OPERABLE;
- b. HEPA filters and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functions; and
PALO VERDE UNITS 1,2,3 B 3.7.11-3 REVISION 10
CREFS B 3.7.11 LCO (continued) 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 the CRE occupants are protected from hazardous chemicals and smoke.
including the integrty o the walls, feilins, Ai irt.,cyd ~nH -rnc-c Acr~nc-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 integrity to the design condition when a need for CRE isolation is indicated.
APPLICABILITY In MODES 1, 2, 3, 4P4 4, and during movement of irradiated fuel assemblies, the CREFS must be OPERABLE to ensure that the CRE will remain habitable limit operator exposure during and following a DBA.
In MODES 5 and 6, the CREFS is required to cope with the release from a rupture of a waste gas tank.
Movement of spent fuel casks containing irradiated fuel assemblies is not within the scope of the Applicability of this technical specification. The movement of dry casks containing irradiated fuel assemblies will be done with a single-failure-proof handling system and with transport equipment that would prevent any credible accident that could result in a release of radioactivity.
During movement of irradiated fuel assemblies, the CREFS must be OPERABLE to cope with the release from a fuel handling accident.
PALO VERDE UNITS 1,2,3 B 3.7.11-4 REVISION 10
CREFS B 3.7.11 ACTIONS A.1 (continued)
With one CREFS train inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREFS s.bs e train is adequate to perform the CRE occupant control roo radiation protection function. However, the overall reliability is reduced because a -- gle failure in the OPERABLE CREFS train could result in loss of CREFS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and the ability of the remaining train to provide the required capability.
B.1, and B.2, and B.3 If the unfiltered air leakage of potentially contaminated air past the CRE boundary and into the GRE 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 GRE 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 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 upon the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair and test most problems with the CRE boundary.
PALO VERDE UNITS 1,2,3 B 3.7.11-5 REVISION 10
CREFS B 3.7.11 ACTIONS (continued) C.1 and C.2 In MODE 1, 2, 3, or 4, if 4-f the inoperable CREFS or the CRE boundary cannot be restored to OPERABLE status wIthIn the required Completion Time in MODE 1, 2, 3, or 4, the unit must be placed in a MODE that minimizes the 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 allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit-systems.
GD.1 In MODE 5 or 6, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CREFS train must be immediately placed in the emergency mode of operation (i.e., fan running, valves/dampers aligned to the post-CREFAS mode. etc.). This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure will be readily detected.
DE.1 and DE.2 During movement of irradiated fuel assemblies, if required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CREFS train must be immediately placed in the emergency mode of operation (i.e., fan running, valves/dampers aligned to the post-CREFAS mode, etc.) or movement of irradiated fuel assemblies must be suspended immediately. The first action ensures that the remaining train is OPERABLE, that no undetected failures preventing system operation will occur, and that any active failure will be readily detected.
An alternative to Required Action E.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. If t*e system Is
- d i te emergency m of operation, thi actin r ires of the movement of 9o iatdfe assemb]ees in.d*e r to minimize the riGk oGfa relea of radioa vity, that might requ..ire the actuation of G This does not preclude the movement of fuel to a safe position.
PALO VERDE UNITS 1,2,3 B 3.7.11-6 REVISION 10
CREFS B 3.7.11 ACTIONS EF.1 and EF.2 (continued)
Whenq inMODES 5 and 6, or durin moeet of irradiatedi fuel asscm ....With two C trains inoperabl o mut h This a reeaseof the.
plae rdioativity that mfightthat t in a condition uni.. entrminimizes teotrlrom the ccient isk.This does not preclude the moGvement of fuel If two CREFS trains become inoperable for reasons other than an inoperable CRE boundary or one or more CREFS trains become inoperable due to an inoperable CRE boundary, during Mode 5 or 6, or during the movement of irradiated fuel assemblies, immediate action must be taken to suspend activities that could release radioactivity that might enter the CRE. The Required Actions place the unit in a condition that minimizes accident risk. These actions do not preclude movement of fuel assemblies to safe positions.
-G.1 If both CREFS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e.,
Condition B), 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.
SURVEILLANCE SR 3.7.11.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system.
Monthly operations for > 15 minutes to demonstrate the function of the system is required. The 31 day Frequency is based on the known rel iability of th e equipment, and the two train redundancy avail able.
PALO VERDE UNITS 1,2,3 B 3.7.11-7 REVISION 10
CREFS B 3.7.11 SURVEILLANCE REQUIREMENTS (continued) SR 3.7.11.2 This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREFS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 35). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test fFrequencies and additional information are discussed in detail in the VFTP.
SR 3.7.11.3 This SR verifies that each CREFS train starts and operates on an actual or simula-ted actuation signal. This includes verification that the system is automatically placed into a filtration 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 18 mnGA-thc jIS the typical Witc*+,.*h refueling cycle. The that ScnG44e =e9we*y
!R ,l Referenc SR 3.7.11.4 This SR verifies the operability of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.
PALO VERDE UNITS 1,2,3 B 3.7.11-8 REVISION 10
CREFS B 3.7.11 SURVEILLANCE REQUIREMENTS (continued) 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, Condition B must be entered. Required Action B.3 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. 6) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 7). These compensatory measures may also be used as mitigating actions as required by Action B.2.
Temporary analytical methods may also be used as compensatory measures to restore operability (Ref. 8).
Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending on 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.
This SR verifies the intcgrity of the conrol1 room enclosure and theassumedim nleakage r-ates of poten*týi1y contaminated air. Th control ...room potve prc.ssu.e.. w#h r.espet to potntillyconaminated adjacent areas, is periodically tested to verify proPer fcti-oAn' f t-he CREPS. 6uring operation, the CREFS is designed to pressurize the control room Ž! 0.125 inches water gauge positive pressure with respect to adjacent area in order to prevent unfiltered inleakage. The 94CRES is designed tonmantain this pos*tve pressue with one t rin a t a vent*i*a I
I7Rflow n r te o)f *10 cfm. The ventilation flowr-ate is the outside maken air flo',,'ate. The Frequ1ency'%' of 18 mnhonaSGERDTEST BASIS is consistent with the guidance provieinURG00 An 4 CR ttf 4 WA REFERENCES 1. UFSAR, Section 6.4.
- 2. UFSAR, Chapter 15.
PALO VERDE UNITS 1,2,3 B 3.7.11-9 REVISION l10
CREFS B 3.7.11 SURVEILLANCE REQUIREMENTS (continued) 3. Regquatory Guide 1.52 (Rev. 2) UFSAR, Section 2.2.3 A. NUREG 080, SeGtiHon 6.1, Rev. 2, Ju!y 1981. UFSAR, Section 9.4
- 5. UFSAR, Section 9.4. Regulatory Guide 1.52 (Rev. 2)
- 6. UFSAR, Section 2.2. Regulatory Guide 1.196
- 7. NEI 99-03, "Control Room Envelope Habitability Assessment," March 2003.
- 8. Letter from Eric (NEI) dated J. Leeds (NRC) to James W. Davis 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).
PALO VERDE UNITS 1,2,3 B 3.7.11 -10 REVISION 10