ML080520008

Revised Technical Specifications, Regarding Control Room Envelope Habitability in Accordance with Technical Specification Task Force-448, (TSTF-448), Revision 3, Using the Consolidated Line Item Improvement Process

ML080520008
Person / Time
Site:	Palisades
Issue date:	02/20/2008
From:	Mahesh Chawla NRC/NRR/ADRO/DORL/LPLIII-1
To:	Balduzzi M Entergy Nuclear Operations
Chawla, ML, NRR/DLPM/LPD III-2, 415-8371
Shared Package
ML080510175	List: ML080520008
References
TAC MD6554
Download: ML080520008 (14)

Text

CRV Filtration 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Ventilation .(CRV) Filtration LCO 3.7.10 Two CRV Filtration trains shall be OPERABLE.

-NOTE The control room envelope (CRE) boundary may be opened intermittently under administrative control APPLICABILITY: MODES 1, 2, 3, 4, During CORE ALTERATIONS, During movement of irradiated fuel assemblies, During movement of a fuel cask in or over the Spent Fuel Pool (SFP).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRV Filtration train A.1 Restore CRV Filtration 7 days inoperable for reasons train to OPERABLE status.

other than Condition B.

B. One or more CRV B.1 Initiate action to implement Immediately Filtration trains mitigating actions.

inoperable due to inoperable CRE AND boundary in MODE 1, 2, 3, or 4. B.2 Verify mitigating actions 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> ensure CRE occupant radiological exposures will not exceed limits, and CRE occupants are protected from chemical and smoke hazards.

AND B.3 Restore CRE boundary to 90 days OPERABLE status.

Palisades Nuclear Plant 3.7.10-1 Amendment No. 44-9, 1-9W-, 230

CRV Filtration

• 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1,2, 3, or4. C.2 Be in MODE 5. 36 hours1.5 days <br />0.214 weeks <br />0.0493 months <br /> D. Required Action and D.1 Place OPERABLE CRV Immediately associated Completion Filtration train in Time of Condition A not emergency mode.

met during CORE ALTERATIONS, during OR movement of irradiated fuel assemblies, or D.2.1 Suspend CORE Immediately during movement of a ALTERATIONS.

fuel cask in or over the SFP. AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND D.2.3 Suspend movement of a Immediately fuel cask in or over the SFP.

Palisades Nuclear Plant 3.7.10-2 Amendment No. 489, 4-9-7, 230

CRV Filtration 3.7.10

ACTIONS, CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRV Filtration E.1 Suspend CORE Immediately trains inoperable during ALTERATIONS.

CORE ALTERATIONS, during movement of AND irradiated fuel assemblies, or during E.2 Suspend movement of Immediately movement of a fuel cask irradiated fuel assemblies.

in or over the SFP.

AND OR E.3 Suspend movement of a Immediately One or more CRV fuel cask in or over the Filtration trains SFP.

inoperable due to an inoperable CRE boundary during CORE ALTERATIONS, during movement of irradiated fuel assemblies, or during movement of a fuel cask in or over the SFP.

F. Two CRV Filtration F.1 Enter LCO 3.0.3. Immediately trains inoperable in MODE 1, 2, 3, or4 for reasons other than Condition B.

Palisades Nuclear Plant 3.7.10-3 Amendment No. 489, 1-9-7 230

CRV Filtration 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRV Filtration train for 31 days

> 10 continuous.hours with associated heater (VHX-26A or VHX-26B) operating.

SR 3.7.10.2 Perform required CRV Filtration filter testing in In accordance with accordance with the Ventilation Filter Testing the Ventilation Filter Program. .. Testing Program SR 3.7.10.3 - - ------ NOTE ----------- -----------------

Only required to be met in MODES 1, 2, 3, and 4, and during movement of irradiated fuel assemblies in containment.

Verify each CRV Filtration train actuates on an 18 months actual or simulated actuation signal.

SR 3.7.10.4 Perform required CRE unfiltered air inleakage In accordance with testing in accordance with the Control Room the Control Room Envelope Habitability Program.. Envelope Habitability Program Palisades Nuclear Plant 3.7.10-4 Amendment No. 4-1-9, 230

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Secondary Water Chemistry Program A program shall be established, implemented and maintained for monitoring of secondary water chemistry to inhibit steam generator tube degradation and shall include:

a. Identification of a sampling schedule for the critical variables and control.

points for these variables,

b. Identification of the procedures used to measure the values of the critical variables,

c. Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in-leakage,

d. Procedures for the recording and management of data,

e. Procedures defining corrective actions for all off-control point chemistry conditions, and

f. A procedure identifying (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective actions.

5.5.10 Ventilation Filter Testing Program A program shall be established to implement the following required testing of Control Room Ventilation (CRV) and Fuel Handling Area Ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2 (RG 1.52), and in accordance with RG 1.52 and ASME N510-1989, at the system flowrates and tolerances specified below*':

a. Demonstrate for each of the ventilation systems that an inplace test of the High EfficiencyParticulate Air (HEPA) filters shows a penetration and system bypass, < 0.05% for the CRV and < 1.00% for the Fuel Handling Area Ventilation System when tested in accordance with RG 1.52 and ASME N510-1989:

Ventilation System Flowrate (CFM)

V-8A or V-8B 7300+ 20%

V-8A and V-8B 10,000 +20%

V-95 or V-96 12,500 +10%

Palisades Nuclear Plant 5.0-14 Amendment No. 4-8W, 230

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Ventilation Filter Testing Program (continued)

b. Demonstrate for each of the ventilation systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.05% for the CRV and < 1.00% for the Fuel Handling Area Ventilation System when tested in accordance with RG 1.52 and ASME N510-1989.

Ventilation System. Flowrate (CFM)

V-8A and V-8B 10,000 +/- 20%

V-26A and V-26B 3200 +10% -5%

c. Demonstrate for each of the ventilation systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in RG 1.52 shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of

!< 30°C and equal to the relative humidity specified as follows:

Ventilation System Penetration Relative Humidity VF-66 6.00% 95%

VFC-26A and VFC-26B 0.157% 70%

d. For each of the ventilation systems, demonstrate the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with RG 1.52 and ASME N510-1989:

Ventilation System Delta P (In Hz0) Flowrate (CFM)

V-8A and V-8B 6.0 10,000 + 20%

VF-26A and VF-26B 8.0 3200 +10% -5%

e. Demonstratethat the heaters for the CRV system dissipates the following specified value +/- 20% when tested in accordance with ASME N510-1989:

Ventilation System Wattage VHX-26A and VHX-26B 15 kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Ventilation Filter

'Testing Program frequencies.

Should the 720-hour limitation on charcoal adsorber operation occur during a plant operation requiring the use of the charcoal adsorber - such as refueling - testing may be delayed until the completion of the plant operation or up to 1,500 hours20.833 days <br />2.976 weeks <br />0.685 months <br /> of filter operation; whichever occurs first.

Palisades Nuclear Plant 5.0-15 Amendment No. 41-8, 230 1

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Fuel Oil Testing Program A fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling requirements, testing requirements, and acceptance criteria, based on the diesel manufacturer's specifications and applicable ASTM Standards. The program shall establish the following:

a. Acceptability of new fuel oil prior to addition to the Fuel Oil Storage Tank, and acceptability of fuel oil stored in the Fuel Oil Storage Tank, by determining that the fuel oil has the following properties within limits:

1. API gravity or an absolute specific gravity,

2. Kinematic viscosity, and

3. Water and sediment content.

b. Other properties of fuel oil stored in the Fuel Oil Storage Tank, specified by the diesel manufacturers or specified for grade 2D fuel oil in ASTM D 975, are within limits.

The provisions of SR 3.0.2 and SR3.0.3 are applicable to the Fuel. Oil Testing Program.

5.5.12 Technical Specifications (TS) BasesControl Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative c6ntrols and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided theý changes do not require either of the following:

1. A change in the TS incorporated in the license; or

2. A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

Palisades Nuclear Plant 5.0-16 Amendment No. 4-9, 2094, 230

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12, Technical Specifications (TS) Bases Control Program (continued)

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

d. Proposed changes that meet the criteria of Specification 5.5.12.b. above shall be reviewed and approved by the NRC prior to implementation.

Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

5.5.13 Safety Functions Determination Program (SFDP)

This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate limitations and remedial or compensatory actions may be identified to be taken as a result of the support system inoperability and corresponding exception to entering supported system Condition and Required Actions. This program implements the requirements of LCO 3.0.6. The SFDP shall contain the following:

a. Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accidentanalysis does not go undetected;

b. Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists;

c. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and

d. Other appropriate limitations and remedial or compensatory actions.,

A loss of safety function exists when, assuming no concurrentsingle failure, a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to system(s) supported by the inoperable support system is also inoperable; or

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable; or Palisades Nuclear Plant 5.0-17 Amendment No. 4-8, 230 I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Safety Functions Determination Program (SFDP) (continued)

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFD.P identifies wherea loss of safety fUnction exists. If a loss of safety function is determined toexist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

5.5.14 Containment Leak Rate Testing Program

a. A programshall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions.. This program shall be in accordance with the guidelines of Regulatory Guide. 1.163, "Performance-Based Containment Leakage-Test Program," dated September 1995, as modified by the following exceptions:

1. Leakage rate testing is not necessary after opening the Emergency Escape Air Lock doors for post-test restoration or post-test adjustment of the air lock door seals. However, a seal contact check shall be performed instead..

Emergency Escape Airlock door opening, solely for the purpose of strongback removal and performance of the seal contact check, does not necessitate additional pressure testing.

2. Leakage rate testing at Pa is not necessary after adjustment of the Personnel Air Lock door seals. However, a between-the-seals test shall be performed at Ž10 psig instead.

3. Leakage rate testing frequency for the Containment 4 inch purge exhaust valves, the 8 inch purge exhaust valves, and the 12 inch air room supply valves may be extended up to 60 months based on component performance.

b. The calculated peak containment internal pressure for the design basis loss of coolant accident, Pa, is 53 psig. The containment design pressure is 55 psig.

c. The maximum allowable containment leakage rate, La, at Pa, shall be 0.1% of containment air weight per day.

Palisades Nuclear Plant 5.0-18 Amendment No. 499, 4-94, 230 1

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Containment Leak Rate Testing Program (continued)

d. Leakage rate acceptance criteria are:

1. Containment leakage rate acceptance, criteria is < 1.0 La. During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and Type C tests and < 0.75 La for Type'A tests.

2. Air lock testing acceptance criteria are:

a) Overall air lock leakage is

• 1.0 La when tested at Ž Pa and combined with all penetrations and valves subjected to Type B and C tests. However, during the first unit startup(

following testing performed in accordance with this program, the leakage rate acceptance criteria is < 0.6 La when combined with all penetrations and valves subjected to Type B and C tests.

b) For each Personnel Air Lock door, leakage is < 0.023 La when pressurized to > 10 psig.

c) For each Emergency Escape Air Lock door, a seal contact check , consisting of a verification of continuous contact between the seals and the sealing surfaces, is acceptable.

e. "Containment OPERABILITY" is equivalent to "Containment Integrity" for the purposes of the testing requirements.

f. The provisions of S.R 3.0.3 are applicable to the Containment Leak Rate Testing Program requirem.ents.

g. Nothing in these Technical Specifications shall be construed to. modify the testing Frequencies required by 10 CFR 50, Appendix J.

Palisades Nuclear Plant 5.0-19 Amendment No. -8&9, 4-94, 230

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 ProcessControl Program

a. The Process Control Program shall contain the current formula; sampling, analyses, tests, and determinations to be made to ensure that the processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10. CFR 20, 10 CFR 71, Federal and State regulations, and other requirements governing the disposal of the radioactive waste.

b. Changes to the Process Control Program:

1. Shall be documented and records of reviews performed shall be retained as required by the Quality Program, CPC-2A. This documentation shall contain:

a) Sufficient information to support the change together with the appropriate analyses or evaluation justifying the change(s) and b) A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of Federal, State, or other applicable regulations,

2. Shall become effective after approval by the plant superintendent.

Palisades Nuclear Plant 5.0-20 Amendment No. 4-4R9, 1-94, 230

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CR.E habitability is maintained such that, with an OPERABLE Control Room Ventilation (CRV) Filtration, CRE occupants can control the reactor safely under normal conditions and. maintain it in a safe*

condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the.body for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the.ORE boundary.

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

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE.

habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

d. Measurement, at designated locations, of the CRE.pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CRV Filtration, operating at the flow rate required by the Ventilation Filter Testing Program, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.

into the CRE. These

e. The quantitative limits on unfiltered air inleakage limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

Palisades Nuclear Plant 5.0-21 Amendment No. 230

Programs and Manuals 5.5 5.5 Programs and Manuals This page retained for page numbering Palisades Nuclear Plant 5.0-22 Amendment No. 230

Programs and Manuals 5.5 5.5 Programs and Manuals Prga I. san aul This page retained for page numbering Palisades Nuclear Plant 5.0-23 Amendment No. 230