Text

Response for Additional Information Regarding Units 1, 2 and 3 - Technical Specifications Change 444 - Adoption of Changes to Standard Technical Specifications Under Technical Specification Task Force Change Number 448, Revision 3.
	ML083650227
Person / Time
Site:	Browns Ferry
Issue date:	12/19/2008
From:	Godwin F; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-448, Rev 3, TVA-BFN-TS-444
	Download: ML083650227 (78)
	v • d • e

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 December 19, 2008 TVA-BFN-TS-444 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - RESPONSE FOR ADDITIONAL INFORMATION REGARDING UNITS 1, 2, AND 3 - TECHNICAL SPECIFICATIONS (TS)

CHANGE 444 - ADOPTION OF CHANGES TO STANDARD TECHNICAL SPECIFICATIONS UNDER TECHNICAL SPECIFICATION TASK FORCE (TSTF) CHANGE NUMBER - 448, REVISION 3, REGARDING CONTROL ROOM ENVELOPE HABITABILITY By letter dated March 27, 2008 (Reference 1), TVA requested an amendment to the TSs consisting of a Consolidated Line Item Improvement that would modify the TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3. The proposed amendment adopts changes to TS Section 3.7.3 Control Room Emergency Ventilation (CREV) system and adds TS Section 5.5.13, Control Building Envelope Habitability Program, consistent with TSTF - 448, Revision 3.

This letter responds to the October 15, 2008, Request for Additional Information (RAI)

(Reference 2) regarding proposed TS - 444. provides TVA's reply to NRC's RAI questions. Enclosures 2 and 3 provide a revision to the Units 1, 2, and 3 TS and TS Bases pages marked-up to show the proposed change. The Bases pages in Enclosure 3 are included to aid the staff in their review and are for information only. Enclosure 4 revised the period for Commitment 1 in the March 27, 2008 letter, performing an assessment of the CRE Habitability.

U.S. Nuclear Regulatory Commission Page 2 December 19, 2008 Because of NRC's RAI questions, TVA has revised Enclosures 2 and 3 originally submitted in the March 27, 2008 letter. TVA's revised enclosures are similar to the TSs and TSs Bases approved for Duane Arnold on June 24, 2008 (Reference 3).

TVA is requesting approval of this TS change by April 1, 2009, and that the implementation of the revised TS be made within 60 days of NRC approval.

The revised pages provided in Enclosure 2 do not alter the original determination that there are no significant hazards considerations associated with the proposed changes, nor do they alter the originally submitted Environmental Assessment and Finding of No Significant Impact provided by the March 27, 2008 letter. Additionally, in accordance with 10 CFR 50.91(b)(1),

TVA is sending a copy of this letter and the Enclosures to the Alabama State Department of Public Health.

If you have any questions about this TS change, please contact me at (256) 729-2636.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 1 9 th 2008.

Sincerey/,I F. R. Godwin Manager of Licensing and Industry Affairs

Enclosures:

1. Reply to Request for Additional Information

2. Proposed Technical Specifications Changes (revised mark-up)

3. Proposed Changes to Technical Specifications Bases Pages (revised mark-up)

4. List of Regulatory Commitments (Revised)

U.S. Nuclear Regulatory Commission Page 3 December 19, 2008

References:

1. TVA letter to NRC dated March 27, 2008: Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - Technical Specifications (TS) Change 444 - Adoption of Changes to Standard Technical Specifications Under technical Specification Task Force (TSTF)

Change Number - 448, Revision 3, Regarding Control Room Envelope Habitability (ML080910360).

2. E-mail from NRC, Eva Brown, to TVA, Michael Brandon, Dated October 15, 2008:

Browns Ferry TSTF - 448.

3. NRC letter to Duane Arnold Energy Center Dated June 24, 2008: Duane Arnold Energy Center - Issuance of Amendment Regarding Adoption of Changes to TSTF -

448 Revision 3, "Control Room Envelope Habitability." (ML081690425).

U.S. Nuclear Regulatory Commission Page 4 December 19, 2008 cc (Enclosures):

State Health Officer Alabama State Department of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, Alabama 36130-3017 Ms. Eva Brown, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Eugene F. Guthrie, Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970

Enclosure 1 Browns Ferry Nuclear Plant (BFN)

Units 1,2, and 3 Technical Specifications (TS) Change 444 Adoption of Changes to Standard Technical Specifications Under Technical Specification Task Force (TSTF) Change Number - 448, Revision 3, Regarding Control Room Envelope Habitability Reply to Request for Additional Information NRC Request 1 The licensee stated that the Control Room Emergency Ventilation (CREV) system at BFN was not designed to protect the control room envelope (CRE) occupants from Chemical and Smoke hazards and therefore references to Chemical and Smoke hazards are not included in the proposed revisions to TS Sections 3.7.3 and 5.5.13, and TS Bases 3.7.3.

This resulted in significant deviations from the model safety evaluation for TSTF-448. While minor deviations to suit the licensee needs may be acceptable, entire removal of chemical and smoke hazards from control room habitability in Technical Specifications is not acceptable to staff. Even if quantitative requirements do not exist for smoke and chemical hazards, a qualitative discussion should at least be included in the control room habitability sections of the Technical Specifications with supporting basis provided in Technical Specification Bases section.

TVA Reply 1 TVA has revised the TS and TS Bases Section 3.7.3, CREV System, provided in the March 27, 2008 (Reference 1), proposed TSs change. Although the CREV System design does not include the protection of the CRE occupants from smoke and chemical hazards, TVA has included use of the CRE as a means to protect the CRE occupants from smoke and chemical hazards. TVA has included revised Enclosures 2 and 3 as part of this letter.

The revised enclosures are similar to the TSs and TSs Bases approved for Duane Arnold on June 24, 2008 (Reference 2).

NRC Reauest 2 In Enclosure 1 to your letter dated March 27, 2008, a reference was made to NEI 99-03, Revision 1. The same document was also referenced (as Reference 7) in the TS Bases 3.7.3. The NRC staff has neither formally endorsed NEI 99-03, Revision 1 nor has it reviewed this document. If exceptions or deviations to NEI 99-03, Revision 0 (June, 2001) are desired in support of this license amendment request, please indicate what they are and the supporting basis for the request.

E1-1

TVA Reply 2 TVA has revised the reference to NEI 99-03, Control Room habitability Assessment Guidance, from Revision 1 to Revision 0. This change is highlighted in the "References" Section of TS Bases 3.7.3, CREV System, included in Enclosure 3 of this letter.

References:

1. TVA letter to NRC Dated March 27, 2008: Browns Ferry Nuclear Plant (BFN) -

Units 1, 2, and 3 - Technical Specifications (TS) Change 444 - Adoption of Changes to Standard Technical Specifications Under technical Specification Task Force (TSTF) Change Number- 448, Revision 3, Regarding Control Room Envelope Habitability (ML080910360).

2. NRC letter to Duane Arnold Energy Center Dated June 24, 2008: Duane Arnold Energy Center - Issuance of Amendment Regarding Adoption of Changes to TSTF -

448 Revision 3, "Control Room Envelope Habitability." (ML081690425).

E1-2

Enclosure 2 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 444 Adoption of Changes to Standard Technical Specifications Under Technical Specification Task Force (TSTF) Change Number - 448, Revision 3, Regarding Control Room Envelope Habitability Proposed Technical Specifications Changes (Revised Mark-up)

TVA has revised the enclosed pages. A line is drawn through the deleted text and a double underline for new or revised text. TVA highlighted the text revised because of the NRC's RAI questions.

CREV System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

-NOTE ----------------------------------------

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

APPLICABILITY: MODES 1, 2, and 3, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREV subsystem A.1 Restore CREV subsystem 7 days inoperable for reasons to OPERABLE status.

other than Condition B.

B. Twe One or More CREV B.1 Initiate action to subsystems inoperable implement mitigating due to inoperable CRE actions.

"'"÷G-I .e.. boundary.

AND B.2 Verify mitigating actions ensure ORE occu:ant exposures to radiological 24 Hours hazards will not exceed limits, and verify by administrative means the CRE occupants are protected from smoke and chemical hazards.

AND 24 He.F, B.4-:.3 Restore ORE boundary to OPERABLE status.

BFN-UNIT 1 3.7-8 Amendment No.23A4,246, 251 September 27, 2004

CREV System 3.7.3 C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, or

3. C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

BFN-UNIT 1 3.7-9 Amendment No.234-246, 251 September 27, 2004

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Place OPERABLE CREV Immediately associated Completion subsystem in Time of Condition A not pressurization mode.

met during OPDRVs.

OR D.2 Initiate action to suspend Immediately OPDRVs.

E. Two CREV subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

(continued)

BFN-UNIT 1 3.7-10 Amendment No.24-246, 251 September 27, 2004

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.1 Two CREV subsystems F.1 Initiate action to suspend Immediately inoperable during OPDRVs.

OPDRVs for reasons other than Condition B.

OR AND F.2 Required actions and F.2 Initiate Actions to suspend Immediately Completion times of OPDRVS Condition B not met during OPDRVS.

BFN-UNIT 1 3.7-11 Amendment No.24, 246, 251 September 27, 2004

CREV System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for __10 31 days continuous hours with the heaters operating.

SR 3.7.3.2 Perform required CREV filter testing in In accordance accordance with the Ventilation Filter Testing with the VFTP Program (VFTP).

SR 3.7.3.3 Verify each CREV subsystem actuates on an 24 months actual or simulated initiation signal.

SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope Habitabilit Verify oa.h REVsubyt.m can mitn a Proaram positive proSSUro of Ž!0.125 inchoc water gauge rolativo to the outdoors during the 214..MonA.ths on;0 a

prsswuization mo*do of

,pcatin ,Gn at a flow 2TA GGERE.

rate of ! 2700 cFm andil 3300 Gcfm. T-EST -AVl BFN-UNIT 1 3.7-12 Amendment No.234,-246, 251 September 27, 2004

CREV System 3.7.3 5.5.12 Primary Containment Leakaae Rate Testing Pro-gram (continued)

Leakage Rate acceptance criteria are:

a. The primary containment leakage rate acceptance criteria is < 1.0 La. During the first unit startup following the testing performed 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 the Type A test; and

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate < 0.05 La when tested at > Pa.

2) Air lock door seals leakage rate is < 0.02 La when the overall air lock is pressurized to > 2.5 psig for at least 15 minutes.

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

5.5.13 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Proaram shall be established and implemented to ensure that CRE habitabilit is maintained such that, with an OPERABLE Control Room Emergency Ventilation (CREV) System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The proaram shall ensure that adeauate radiation protection is provided to permit access and occupancv of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

The program shall include the following elements:

a. The definition of CRE and the CRE boundary.

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

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room (continued)

BFN-UNIT 1 5.0-22 Amendment No. 2-44-,269 March 06, 2007

CREV System 3.7.3 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 adiacent to the CRE boundary during the pressurization mode of operation by one subsystem of the CREV System, operating at the flow rate required by the VFTP, at a frequency of 24 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 leakage into the GRE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakaae measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenaes is the inleakaqe 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.

(continued)

BFN-UNIT 1 5.0-23 Amendment No. 2,-34,269 March 06, 2007

CREV System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

-NO T E ----------------------------------------

The main control room boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREV subsystem A.1 Restore CREV subsystem 7 days inoperable for reasons to OPERABLE status.

other than Condition B.

B. Two One or more CREV B.1 Initiate actions to Immediately subsystems inoperable implement mitigating due to inoperable control actions.

room boundary in MODES 1, 2, and 3. AND 24 Hours B.2 Verify mitigating actions ensure CRE occupant exposures will not exceed limits, and verify by administrative means CRE occupants are protected from smoke and chemical hazards.

AND B.4-3 Restore-CRE boundary to 24 h... 0dy OPERABLE status.

BFN-UNIT 2 3.7-9 Amendment No. 264- 2-8, 290 September 27, 2004

CREV System 3.7.3 C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, or

3. C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

BFN-UNIT 2 3.7-10 Amendment No. 264- 2-8, 290 September 27, 2004

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Place OPERABLE CREV Immediately associated Completion subsystem in Time of Condition A not pressurization mode.

met during OPDRVs.

OR D.2 Initiate action to suspend Immediately OPDRVs.

E. Two CREV subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

(continued)

BFN-UNIT 2 3.7-11 Amendment No. 254- 2-8., 290 September 27, 2004

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.1 Two CREV subsystems F.1 Initiate action to suspend Immediately inoperable during OPDRVs.

OPDRVs for reasons other than Condition B AND OR F.2 Initiate actions to suspend Immediately and F.2 Required actions Completion times of Condition B not met during OPDRVs.

BFN-UNIT 2 3.7-12 Amendment No. 264-, 2-8, 290 September 27, 2004

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for __10 31 days continuous hours with the heaters operating.

SR 3.7.3.2 Perform required CREV filter testing in In accordance accordance with the Ventilation Filter Testing with the VFTP Program (VFTP).

SR 3.7.3.3 Verify each CREV subsystem actuates on an 24 months actual or simulated initiation signal.

SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope habitability

,, ..... ch r,',- ,, .... .,.. . . 'Program pesitivc prcczurc of Ž!0. 126 inchoc wator gauge rolativo to the eutdeerzs during tho 24 moneths on a prossurizatioRnemdo of oporatin -At -aflo-w I V LIV* v *VV LV LI V V* II

LIIV1 STAGGEREID Fate of Ž-27010- c-fm and :- 33200-4fm, TEm2-1ORA 254 BFN-UNIT 2 3.7-13 Amendment No. 254 September 08, 1998

5.5.12 Primary Containment Leakage Rate Testing Program (continued)

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 50.6 psig. The maximum allowable primary containment leakage rate, La, shall be 2% of primary containment air weight per day at Pa.

Leakage Rate acceptance criteria are:

a. The primary containment leakage rate acceptance criteria is < 1.0 La. During the first unit startup following the testing performed 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 the Type A test; and

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate

0.05 La when tested at > Pa.

2) Air lock door seals leakage rate is < 0.02 La when the overall air lock is pressurized to > 2.5 psig for at least 15 minutes.

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

5.5.13 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that., with an OPERABLE Control Room Emergency Ventilation (CREV) System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radioloaical 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 desian basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

The program shall include the following elements:

a. The definition of CRE and the CRE boundary.

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

BFN-UNIT 2 5.0-21 Amendment No. 266 November 21, 2000

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 Intearity 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 Reaulatory Guide 1.197. Revision 0.

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adiacent to the CRE boundary during the pressurization mode of operation by one subsystem of the CREV System, operating at the flow rate required by the VFTP, at a frequency of 24 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 leakage into the CRE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.

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.

BFN-UNIT 2 5.0-22 Amendment No. 266 November 21, 2000

CREV System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

-NO T E ----------------------------------------

The main control room boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREV subsystem A.1 Restore CREV subsystem 7 days inoperable for reasons to OPERABLE status.

other than Condition B.

B. Two One or more CREV B.1 Initiate actions to Immediately subsystems inoperable implement mitigating due to inoperable Ge49e actions.

Foon CRE boundary in MODES 1, 2, and 3. AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B.2 Verify mitigating actins ensure CRE occupant exposures to radiological hazards will not exceed limits, and verify by administrative means the CRE occupants are protected form smoke and chemical hazards.

AND B.4-3 Restore CRE boundary to OPERABLE status.

BFN-UNIT 3 3.7-9 Amendment No. 2!4, 24!, 249 September 27, 2004

CREV System 3.7.3 C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B AND not

3. met in MODE 1, 2, or C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

BFN-UNIT 3 3.7-10 Amendment No. 214,-244, 249 September 27, 2004

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Place OPERABLE CREV Immediately associated Completion subsystem in Time of Condition A not pressurization mode.

met during OPDRVs.

OR D.2 Initiate action to suspend Immediately OPDRVs.

E. Two CREV subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1,2, or 3 for reasons other than Condition B.

(continued)

BFN-UNIT 3 3.7-11 Amendment No. 214-241-, 249 September 27, 2004

CREV System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.1 Two CREV subsystems F.1 Initiate action to suspend Immediately inoperable during OPDRVs.

OPDRVs for reasons other than Condition B.

OR AND F.2 Required actions and F.2 Initiate actions suspend Completion times of OPDRVs.

Condition B not met during OPDRVs.

BFN-UNIT 3 3.7-12 Amendment No. 244,-241, 249 September 27, 2004

CREV System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for __10 31 days continuous hours with the heaters operating.

SR 3.7.3.2 Perform required CREV filter testing in In accordance accordance with the Ventilation Filter Testing with the VFTP Program (VFTP).

SR 3.7.3.3 Verify each CREV subsystem actuates on an 24 months actual or simulated initiation signal.

SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope Habitability

\1,..*.- I.. .,,,. ,-,.. +.. .. . "**""* Program positive prcssurc of Ž!0.125 inhswater gauge r.latk', to the outdoors during -h, 24 months on a pressui zation,*mde of operation at a flow STAGGERED rate of 2700 cfm,- and, ,r 3300 TEST BASIS BFN-UNIT 3 3.7-13 Amendment No. 214 September 08, 1998

5.5.12 Primary Containment Leakage Rate Testing Program (continued)

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 50.6 psig. The maximum allowable primary containment leakage rate, La, shall be 2% of primary containment air weight per day at Pa.

Leakage Rate acceptance criteria are:

a. The primary containment leakage rate acceptance criteria is < 1.0 La. During the first unit startup following the testing performed 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 the Type A test; and

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate < 0.05 La when tested at _>Pa.

2) Air lock door seals leakage rate is < 0.02 La when the overall air lock is pressurized to > 2.5 psig for at least 15 minutes.

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

5.5.13 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Proaram shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation (CREV) System. CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release.

or a smoke challenae. The proaram shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

The program shall include the following elements:

a. The definition of CRE and the CRE boundary.

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

BFN-UNIT 3 5.0-14 Amendment No. 226 November 21, 2000

c. Requirements for (i) determining the unfiltered air inleakaqe past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies s.ecified in Sections C. 1 and C.2 of Reaulatory Guide 1.197. "Demonstratina Control Room Envelope Intearity 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 adiacent to the GRE boundary during the pressurization mode of operation by one subsystem of the CREV System. operating at the flow rate required by the VFTP. at a frequency of 24 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 leakage 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 paraaraph c. The unfiltered air inleakage limit for radiological challenaes is the inleakaae 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 paragraohs c and d. respectively.

BFN-UNIT 3 5.0-15 Amendment No. 226 November 21, 2000

Enclosure 3 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 444 Adoption of Changes to Standard Technical Specifications Under Technical Specification Task Force (TSTF) Change Number - 448, Revision 3, Regarding Control Room Envelope Habitability Proposed Changes to Technical Specifications Bases Pages (Revised Mark-up)

TVA has revised the enclosed pages. A line was drawn through the deleted text and a double underline for new or revised text. TVA highlighted the text revised because of the NRC's RAI questions.

CREV System B 3.7.3 B 3.7 PLANT SYSTEMS B 3.7.3 Control Room Emergency Ventilation (CREV) System BASES BACKGROUND The CREV System provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity. *adiele, iGa.l, contro9llod onironmnit from which the unit can be safely oporatod following a DnsigRn Bavi Acnidont (DBA).

The safety related function of the CREV System includes two independent and redundant high efficiency air filtration subsystems for emergency treatment of outside supply air and a CRE boundary that limits the inleakapge of unfiltered air. The CREV Seystem has a high efficiency particulate air (HEPA) filter bank in the portion of the inlet piping common to both subsystems. Each CREV subsystem consists of a motor-driven fan, an electric duct air heater, an activated charcoal adsorber section, an electric charcoal heater, and the associated ductwork, valves or and dampers, doors, barriers, and instrumentation. The HEPA filter bank removes particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay; however, no credit is taken in the analyses for the charcoal adsorbers.

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 event 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 inleakaae of unfiltered air (continued)

BFN-UNIT 1 B 3.7-17 Revision Q-, 29 January 25, 2005

CREV System B 3.7.3 into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The GRE and its boundary are defined in the Control Room Envelope Habitability Program.

Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to GCRE occupants contro ..... p.....nl), the CREV System automatically switches to the pressurization mode of operation to minimize pevent infiltration of contaminated air into the CREcGfroroomI FG. A system of dampers isolates the CRE G9otfro roOM. Outside air is taken in through the CREV System ventilation intake and is passed through one of the charcoal adsorber filter subsystems for removal of airborne radioactive particles.

(continued)

BFN-UNIT 1 B 3.7-18 Revision Q, 29 January 25, 2005

CREV System B 3.7.3 BASES BACKGROUND The CREV System is designed to maintain a habitable environment in the CRE controlF9, room ,. emv,,

(continued) for a 30 day continuous occupancy after a DBA without exceeding 5 rem total effective dose equivalent (TEDE). A single CREV subsystem oDeratina at a flow rate of 3000 cfm

+/-10 percent will pressurize the .e-FG-,

,REvFe,, to about 0.125 inches water gauge to minimize pieven infiltration of air from all surrounding areas adiacent to CRE boundary bildig-,s and the outdoors. CREV System operation in maintaining CRE GnoetFe F0m -habitability is discussed in the FSAR, Section 10.12 (Ref. 1).

APPLICABLE The ability of the CREV System to maintain the habitability SAFETY ANALYSES of the CRE GGetrc FMrc is an explicit assumption for the safety analyses presented in the FSAR, Chapters 10 and 14 (Refs. 2 and 3, respectively). The pressurization mode of the CREV System is assumed to operate following a DBA, les of coolant a.*idcnt, main steam line break, and *ontrol rod drop accidont If-t------------~r r +k----- ------...

n r-. rk ir^ ~rl."

.rodititako for any filtration by the RV I-cct.o1 iVim) as discussed in the FSAR, Section 14.6 (Ref. 4). The analyses for radiological doses to CRE occupants control room pcr..nne. as a result of the various DBAs are summarized in Reference 3.

No single active failure will cause the loss of filtered outside air from the CRE centr4e! eFr.

There are no offsite or onsite hazardous chemicals that would pose a credible threat to CRE habitability (Ref 9).

Consequently, engineering controls for the CRE are not required to ensure habitability against chemical threat.

The evaluation of a smoke challenae demonstrated that smoke will not result in the inability of the CRE occupants to control the reactor either from the control room or remote shutdown system (Ref 9). The assessment verified that a fire or smoke event anywhere with the plant should not simultaneously render the remote shutdown system and the CRE uninhabitable, nor would it prevent access from the CRE to the remote shutdown system in the event remote shutdown is required. No automatic CREV (continued)

BFN-UNIT 1 B 3.7-19 Revision 0-, 29 January 25, 2005

CREV System B 3.7.3 actuation is required for hazardous chemical releases orLmoke and no Surveillance Requirements are required to verify OPERABILITY in cases of hazardous chemicals or smoke.

The CREV System satisfies Criterion 3 of the NRC Policy Statement (Ref. 6).

(continued)

BFN-UNIT 1 B 3.7-20 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 BASES (continued)

LCO Two redundant subsystems of the CREV System are required to be OPERABLE to ensure that at least one is available, assum,,g if a single active failure disables the other subsystem.

Total CREV Zaystem failure, such as from a loss of both ventilation subsystems or from an inoperable CRE boundary.

could result in exceeding a TEDE of 5 rem to the GRE occupants contr ro .patorsin the event of a DBA.

T49 Each CREV yste ubytm is considered OPERABLE when the individual components necessary to limit CRE ocuA "-RGI+"'.. exposure are OPERABLE in *both subsystems. A subsystem is considered OPERABLE when its associated:

a. Fan is OPERABLE;

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

c. The electric duct heater, ductwork, and dampers are OPERABLE.

in additi*n, tho -ontro! room boundary must bo marntaip+ad, including the integr of the wal*s, floors,- ilinngs, ductWork, and access doors-.

In order for the CREV subsystems to be considered OPERABLE, the GRE 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 consequences analyses for DBAs. and that the CRE occupants are protected from hazardous chemicals and smoke.

BFN does not have automatic CREV actuations for hazardous chemicals or smoke. Current practices at BFN do not utilize chemicals of sufficient quantity to present a chemical hazard to the CRE. Smoke is not considered in the current BFN safety (continued)

BFN-UNIT 1 B 3.7-21 Revision 0-, 29 Amon dmel t No. 246 January 25, 2005

CREV System B 3.7.3 analysis. Therefore, BFN has no specific limits on chemical hazards or smoke.

The LCO is modified by a Note allowing the CRE manoRtfre F9R9m boundary to be opened intermittently under administrative controls. This Note only apolies 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 main control room. 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 ORE main control room isolation is indicated.

(continued)

BFN-UNIT 1 B 3.7-22 Revision 0, 29 AmWn*d-mo,-nR No. 2216 January 25, 2005

CREV System

. B 3.7.3 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, the CREV System must be OPERABLE to ensure that the CRE will remain habitable Rt-- e...e eXpesUIe during and following a DBA, since the DBA could lead to a fission product release.

In MODES 4 and 5, the probability and consequences of a DBA are reduced because of the pressure and temperature limitations in these MODES. Therefore, maintaining the CREV System OPERABLE is not required in MODE 4 or 5, except for during operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS A.1 With one CREV subsystem inoperable, for reasons other than an inoperable CRE boundary, the inoperable CREV subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE CREV subsystem is adequate to perform the CRE occupant GGctrGI ro-m radiation protection function. However, the overall reliability is reduced because a-si4& failure in the OPERABLE subsystem could result in loss of the -FedUGedCREV System function Gapabili,... The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities.

(continued)

BFN-UNIT 1 B 3.7-23 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 BASES ACTIONS B. 1, B.2 and B.3 (continued)

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in a CRE occupant radiological dose Greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 REM TEDE) the CRE boundary is inoperable.

As discussed in the Applicable Safety Analysis Section. the BFN licensing bases notes that CRE inleakaae limits for hazardous chemicals and smoke are not needed to protect the CRE occupants. Since the limit established for radiological events is limiting, verification of smoke and chemical hazards by administrative means is acceotable for an inoperable CRE boundary. Verification that the periodic check of onsite and offsite hazardous chemical sources has been performed within the time limit defined by the Control Room Habitability Proaram is an acceptable means to ensure the CRE occupants are protected from chemical hazards and smoke.

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 challenae from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that GRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences and that CRE occuoants are orotected from hazardous chemicals and smoke. These mitiaatina 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time (continued)

BFN-UNIT 1 B 3.7-24 Revision G, 29 Amondmont No. 216 January 25, 2005

CREV System B 3.7.3 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 within the CRE boundary.

If the mai;n oRntr*l room bounRdar, i- onoporblo in MODES 1, 2, and 3, the trai..cnno po.Vorm Itheir,h i*todod function.-,,

Actions must be taken to Fe toir ain OPER-ABLE m nain conrol1 room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . DuFrig the period that the main control room boundar is inoorblo, appropriate componsatery moasures (consistent6Awl wt~h t~h. in51.t.en.t. o-f GDC 19) sho9ul1d be utilized to protect control room operators from potential hazards such as radioactive contam~ination, toXic chemicals, smok~e, temperature and rolative humidity, and physical security.-

Proplannod mneasures should be available to address ths concerns for intentional and unintentional entry into the condition. The 21 hour2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months Completion Time is reasonable based on the low probability of a DB3A occurring duFrig this time period, and the use Of compensator,' measures. The 21 hour2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months Completion Time is, a typically reasonable time to diagnose, control room boundary.

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREV subsystem or the CRE Gcontee re.m boundary cannot be restored to OPERABLE status within the required assoclated Completion Time, 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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

(continued)

BFN-UNIT 1 B 3.7-25 Revision 0-, 29 Amendmert No. 246 January 25, 2005

CREV System B 3.7.3 BASES ACTIONS D.1 and D.2 (continued)

During OPDRVs, if the inoperable CREV subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREV subsystem may be placed in the pressurization mode. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action D.1 is to immediately initiate actions to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

(continued)

BFN-UNIT 1 B 3.7-26 Revision 0, 29 Amendmnent No. 246 January 25, 2005

CREV System B 3.7.3 BASES ACTIONS E.1 (continued)

If both CREV subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable CRE.control room boundaFy (i.e., Condition B), the CREV System may not be capable of performing the intended function and the unit is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

F.1 and F.2 During OPDRVs, with two CREV subsystems inoperable for reasons other than Condition C or with the Required Actions and associated Completion Times of B not met, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

(continued)

BFN-UNIT 1 B 3.7-27 Revision 0-, 29 AMeRondmot We. -216 January 25, 2005

CREV System B 3.7.3 BASES (continued)

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts on demand and continues to operate. Standby systems should be checked periodically to ensure that they start and function properly. As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system.

Monthly heater operation dries out any moisture that has accumulated in the charcoal as a result of humidity in the ambient air. The CREV System must be operated for > 10 continuous hours with the heaters energized to dry out any moisture and to demonstrate the function of the system.

Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available.

SR 3.7.3.2 This SR verifies that the required CREV testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test Ffrequencies and additional information are discussed in detail in the VFTP.

(continued)

BFN-UNIT 1 B 3.7-28 Revision 0

CREV System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.3 REQUIREMENTS (continued) This SR verifies that on an actual or simulated initiation signal, each CREV subsystem starts and operates. This SR includes verification that dampers necessary for proper CREV operation function as required. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.4 and SR 3.3.7.1.6 overlaps this SR to provide complete testing of the safety function. The Freauencv of 24 months is based on BFN's normal operatina cycle.

SR 3.7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope 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 that 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke.

There is no automatic CREV actuation for hazardous chemical releases or smoke and there are no Surveillance Requirements to verify the OPERABILITY in cases of hazardous chemicals or smoke. This SR verifies that the unfiltered air inleakage into the CRE is no areater than the flow rate assumed in the licensing basis analysis of DBA conseguences. When unfiltered air inleakage is areater 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 occupants following an accident.

Compensatory measures are discussed in Reaulatory 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 reguired by Required 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 (continued)

BFN-UNIT 1 B 3.7-29 Revision Q, 29 January 25, 2005

CREV System B 3.7.3 changing the licensing basis DBA consequences analysis.

repairing the CRE boundary, or a combination of these actions.

(continued)

BFN-UNIT 1 B 3.7-30 Revision Q-, 29 January 25, 2005

CREV System B 3.7.3 SURVEILLANCE SR 3.7.3.4 REQUIREMENTS (continued) Dependina 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.

This SRA vo fifio the int.grity of the control room onnn osur and the assumed inlnakago Fates of potentially cn,,taminatod air. The Gontrol room, p prFssuro,

-sitivo with rospoct to outdoorS is periedlcally te stcd to Yerify pnopon funct*io of the System. During th nREV omor~gency mode of opeation, vstemthG E Sm designed to Slightly p*mem*m izc the contro -rom> 0.125 inc~hoc water gauge positivo pressure with respect to the outdoors to prevent unfiltorod inleakage. Tho GREV Systom is designed to maintain this positive pressure a flow rate of Žm2700 cfm and 3300 fonmto tho conrol room; in the prsurtion moede. The FrFequency of 24 months on a STAGGERcED TEST BAS*2ISisconsistent With idtr'practice and other filtration systems SRS.

BFN-UNIT 1 B 3.7-31 Revision 0, 29 January 25, 2005

CREV System B 3.

7.3 REFERENCES

1. FSAR, Section 10.12.

2. FSAR, Chapter 10.

3. FSAR, Chapter 14.

4. FSAR, Section 14.6.

5. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.

6. NRC Reaulatorv Guide 1.196. "Control Room Habitability At Light-Water Power Reactors". January 2007.

7. NEI 99-03, "Control Room Habitability Assessment."

June 2001.

8. 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)

9. FSAR, Chanter 10.12.5.3, Toxic Gas Protection BFN-UNIT 1 B 3.7-32 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 B 3.7 PLANT SYSTEMS B 3.7.3 Control Room Emergency Ventilation (CREV) System BASES BACKGROUND The CREV System provides a protected environment from which occupants can control the unit following an uncontrolled release of radoactivi ra. oogcal cont.o... d............

froM which the unit can be safely oporatod following a Desig Basis Accidont (DBA).-

The safety related function of the CREV System includes two independent and redundant high efficiency air filtration subsystems for emergency treatment of outside supply air and a CRE boundary that limits the inleakage of unfiltered air. The CREV Ssystem has a high efficiency particulate air (HEPA) filter bank in the portion of the inlet piping common to both subsystems. Each CREV subsystem consists of a motor-driven fan, an electric duct air heater, an activated charcoal adsorber section, an electric charcoal heater, and the associated ductwork, valves or and dampers, doors, barriers and instrumentation. The HEPA filter bank removes particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay; however, no credit is taken in the analyses for the charcoal adsorbers.

The CRE is the areas 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 or an accident. The CRE is protected during normal operation, natural event and accident conditions. The CRE boundary is the combination of wall, 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 in the CRE will not (continued)

BFN-UNIT 2 B 3.7-17 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 exceed the inleakage assumed in the licensing basis analysis of design basis accident (CBA) consequences to CRE occupants.

The CRE and idS boundary are defined in the Control Room Envelope Habitability Program.

Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to CRE occuoants eeit-eI

,v .. pe-sG.Rne4

., the CREV System automatically switches to the pressurization mode of operation to minimizer..e~..,.4 infiltration of contaminated air into the CRE contrieI-tom. A system of dampers isolates the CRE emtre-' reem. Outside air is taken in through the CREV System ventilation intake and is passed through one of the charcoal adsorber filter subsystems for removal of airborne radioactive particles.

(continued)

BFN-UNIT 2 B 3.7-18 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 BASES BACKGROUND The CREV System is designed to maintain a habitable environment in the GRE the control room (continued) environment-for a 30 day continuous occupancy after a DBA without exceeding 5 rem total effective dose equivalent (TEDE).

A single CREV subsystem operating at a flow rate of 3000 GEM

_+10 percent will pressurize theGRE ceR#eI room to about 0.125 inches water gauge to minimize -,-- , infiltration of air from all surrounding areas adjacent to CRE boundary *4';ii'e and the outdoors. CREV System operation in maintaining CRE GntrGIFFroo habitability is discussed in the FSAR, Section 10.12 (Ref. 1).

APPLICABLE The ability of the CREV System to maintain the habitability SAFETY ANALYSES of the CRE Gectrc-fco,," is an explicit assumption for the safety analyses presented in the FSAR, Chapters 10 and 14 (Refs. 2 and 3, respectively). The pressurization mode of the CREV System is assumed to operate following a DBA loss of coolant accident, main steam line break, and contro orpacdn

-H1d UldHtFfdl F "H+ MH HICHH tiftletW HHW Idi"WOK, Htf I .. . . I f co-,t is taon ,or . any itraton by the -,,LV system), as discussed in the FSAR, Section 14.6 (Ref. 4). The analyses for radiological doses to CRE oCCupants contro roo.m personno! as a result of the various DBAs are summarized in Reference 3.

No single active failure will cause the loss of filtered outside air from the CRE GOetMooMMG.

There are no offsite or onsite hazardous chemicals that would pose a credible threat to CRE habitability (Ref 9).

Consequently. engineering controls for the CRE are not required to ensure habitability against chemical threat.

The evaluation of a smoke challenge demonstrated that smoke will not result in the inability of the CRE occupants to control the reactor either from the control room or remote shutdown system (Ref 9). The assessment verified that a fire or smoke event anywhere with the Dlant should not simultaneously render the remote shutdown system and the CRE uninhabitable, nor would (continued)

BFN-UNIT 2 B 3.7-19 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 it prevent access from the CRE to the remote shutdown system in the event remote shutdown is required. No automatic CREV actuation is required for hazardous chemical releases or smoke and no Surveillance Requirements are required to verify OPERABILITY in cases of hazardous chemicals or smoke.

The CREV System satisfies Criterion 3 of the NRC Policy Statement (Ref. 6).

(continued)

BFN-UNIT 2 B 3.7-20 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 BASES (continued)

LCO Two redundant subsystems of the CREV System are required to be OPERABLE to ensure that at least one is available, assumiILfa single active failure, such as from a loss of both ventilation subsystems or from an inoperable CRE boundary.

disables the other subsystem. Total system failure could result in exceeding a TEDE of 5 rem to the CRE OCCuantsG

...... peFaf*. in the event of a DBA.

The Each CREV subsystem "ystemis considered OPERABLE when the individual components necessary to limit CRE occupant ,,,I-,,t .pe4..-e exposure are OPERABLE in both subsystems. A subsystem is considered OPERABLE when its associated:

a. Fan is OPERABLE;

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

c. The electric duct heater, ductwork, and dampers are OPERABLE.

In order for the CREV subsystems 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 consequences analyses for DBAs, and that the CRE occupants are protected from hazardous chemicals and smoke.

BFN does not have automatic CREV actuations for hazardous chemicals or smoke. Current practices at BEN do not utilize chemicals of sufficient quantity to present a chemical hazard to the ORE. Smoke is not considered in the current BEN safety analysis. Therefore, BFN has no specific limits on chemical hazards or smoke.

(continued)

BFN-UNIT 2 B 3.7-21 Revision 0, 29 Amondmert No. 283 January 25, 2005

CREV System B 3.7.3 In addition, the control room boun~dary must bc maintained-,

includi*g the inrtegrity f the walls, floFrs, ceIln*eg, , ,rk, W, aRd accoss doors..

The LCO is modified by a Note allowing the CRE-ma4;*i-Gcont Feem 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 and CRE main control room. 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 main control room isolation is indicated.

(continued)

BFN-UNIT 2 B 3.7-22 Revision 0, 29 Amcndmont No. 283 January 25, 2005

CREV System B 3.7.3 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, the CREV System must be OPERABLE to ensure that the CRE will remain habitable GGR.UGI-,pG. ,

expeseeduring and following a DBA, since the DBA could lead to a fission product release.

In MODES 4 and 5, the probability and consequences of a DBA are reduced because of the pressure and temperature limitations in these MODES. Therefore, maintaining the CREV System OPERABLE is not required in MODE 4 or 5, except for during operations with potential for draining the reactor vessel (OPDRVs).

ACTIONS A.1 With one CREV subsystem inoperable, for reasons other than in inoperable CRE boundary, the inoperable CREV subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE CREV subsystem is adequate to perform the CRE occupant GOR40e room radi*aton protection function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of the redu'ed CREV System function isanailil. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities.

(continued)

BFN-UNIT 2 B 3.7-23 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 BASES ACTIONS B.1, B.2, and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in a CRE occupant radiological dose areater than the calculated dose of the licensing basis analyses of DBA conseauences (allowed to be up to 5 REM TEDE) the CRE boundary is inoperable.

As discussed in the Applicable Safety Analysis Section. the BFN licensina bases notes that CRE inleakaae limits for hazardous chemicals and smoke are not needed to protect the CRE occupants. Since the limit established for radiological events is limiting, verification of smoke and chemical hazards by administrative means is acceotable for an inoperable GRE boundary. Verification that the periodic check of onsite and offsite hazardous chemical sources has been performed within the time limit defined by the Control Room Habitability Proaram is an acceotable means to ensure the CRE occupants are protected from chemical hazards and smoke.

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 radioloaical or chemical event or a challenae from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that GRE 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time (continued)

BFN-UNIT 2 B 3.7-24 Revision 0, 29 mo.,.n,-,dmont No. 283 January 25, 2005

CREV System B 3.7.3 perod, 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 eRE 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 within the CRE boundary.

if the main control iii room bouidai Wa MODES 1, 2, anRd 3, the -RE=\' train- cnnot perform their ntenRded functiGo&n*

ActionS must bo takon to restoeF an OPERABLE mnain control room; boundar,' within 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months . During the poriod that the main contro lroom boundar' i* in appropriate iopeble, iOMpcnsator measures (csitent ith tho nent

. f GD 19) sh u1d bo utilized to prVVett co*n*toI room operators from potential hazrdsI such as rad*ioa*ctive co1entaminatiRn, tox chm*-Ials, smoke, temnperature and rolative humidity, and physical secUrity.-

concerns for intentional and unintentionaI eF;t*y into the on;dition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time ;is r-easonablhbased on the loW probability of a -DBAoccurring duFrig this time period, anmd the use ofcompsatoy mIeasiures The 21 hour2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months Completion Time is a typically reasonarble time to-diagnose, plan and possibly repair, and test most problems with the main coentro-l roo-m.budr' C. 1 and C.2 In MODE 1, 2, or 3, if the inoperable CREV subsystem or the CRE centrel .een boundary cannot be restored to OPERABLE status within the required asseGiated-Completion Time, 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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power (continued)

BFN-UNIT 2 B 3.7-25 Revision 0, 29 Amendmert No. 283 January 25, 2005

CREV System B 3.7.3 conditions in an orderly manner and without challenging unit systems.

(continued)

BFN-UNIT 2 B 3.7-26 Revision 0, 29 Amendment No. 283 January 25, 2005

CREV System B 3.7.3 BASES ACTIONS D.1 and D.2 (continued)

During OPDRVs, if the inoperable CREV subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREV subsystem may be placed in the pressurization mode. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action D.1 is to immediately initiate actions to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

(continued)

BFN-UNIT 2 B 3.7-27 Revision 0, 29 Amonudamt 2o. 283 January 25, 2005

CREV System B 3.7.3 BASES ACTIONS E. 1 (continued)

If both CREV subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable CRE l

.room,, .,boundar*

(i.e., Condition B), the CREV System 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.

F. 1 During OPDRVs, with two CREV subsystems inoperable for reasons other than Condition C or with the Required Actions and associated Completion times of B not met, actions must be initiated immediately to suspend OPDVRs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

(continued)

BFN-UNIT 2 B 3.7-28 Revision Q, 29 Amondment No. 283 January 25, 2005

CREV System B 3.7.3 BASES (continued)

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts on demand and continues to operate. Standby systems should be checked periodically to ensure that they start and function properly. As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system.

Monthly heater operation dries out any moisture that has accumulated in the charcoal as a result of humidity in the ambient air. The CREV System must be operated for > 10 continuous hours with the heaters energized to dry out any moisture and to demonstrate the function of the system.

Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available.

SR 3.7.3.2 This SR verifies that the required CREV testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

(continued)

BFN-UNIT 2 B 3.7-29 Revision 0

CREV System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.3 REQUIREMENTS (continued) This SR verifies that on an actual or simulated initiation signal, each CREV subsystem starts and operates. This SR includes verification that dampers necessary for proper CREV operation function as required. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.4 and SR 3.3.7.1.6 overlaps this SR to provide complete testing of the safety function. The frequencv of 24 months is based on BFN's normal operating time.

SR 3.7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testina 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 that 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke.

There is no automatic CREV actuation for hazardous chemical releases or smoke and there are no Surveillance Requirements to verify the OPERABILITY in cases of hazardous chemicals or smoke. This SR verifies that the unfiltered air inleakage into the CRE is no areater than the flow rate assumed in the licensing basis analysis of DBA consequences. When unfiltered air inleakaae is areater 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 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 Required 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 (continued)

BFN-UNIT 2 B 3.7-30 Amendment 255 November, 1998

CREV System B 3.7.3 changing the licensing basis DBA consequences analysis.

repairing the CRE boundary, or a combination of these actions.

(continued)

BFN-UNIT 2 B 3.7-31 Amendment 255 November, 1998

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m miaintaintiui~pesiive preSU~r at aT19W Fate of 2-2-2-0-0 rm and r 3300 cfn n to the conro n 9l roomr in the pro/urization moedm. The Froguo1cY of 24 months On a STIAGGERAD TEST RBASSil conictntwith induistr: oractico and-othorF filtration sVcteoms J r- -- j .......

REFERENCES 1. FSAR, Section 10.12.

2. FSAR, Chapter 10.

3. FSAR, Chapter 14.

4. FSAR, Section 14.6.

5. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.

6. NRC Reaulatory Guide 1.196, "Control Room Habitability At Liaht-Water Power Reactors". January 2007.

7. NEI 99-03. "Control Room Habitability Assessment." June 20Q1.

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NElI 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)

9. FSAR, Chapter 10.12.5.3. Toxic Gas Protection BFN-UNIT 2 B 3.7-32 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 B 3.7 PLANT SYSTEMS B 3.7.3 Control Room Emergency Ventilation (CREV) System BASES BACKGROUND The CREV System provides a protected environment from which occupants cab control the unit following an uncontrolled release of radioactivityradiologicall controlled enVirnme.t.t fro-m.whic"*h the unit a*n b,* *-afh pr- atod following a, D,I-n, Bai*i Accident (DBA.

The safety related function of the CREV System includes two independent and redundant high efficiency air filtration subsystems for emergency treatment of outside supply air and a CRE boundary that limits the inleakage of unfiltered air. The CREV Seystem has a high efficiency particulate air (HEPA) filter bank in the portion of the inlet piping common to both subsystems. Each CREV subsystem consists of a motor-driven fan, an electric duct air heater, an activated charcoal adsorber section, an electric charcoal heater, and the associated ductwork, valves or aei dampers, doors, barriers, and instrumentation. The HEPA filter bank removes particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay; however, no credit is taken in the analyses for the charcoal adsorbers.

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 event 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 (continued)

BFN-UNIT 3 B 3.7-17 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 design basis accident (DBA) consequences to CRE occupants.

The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to CRE occupants GGRtIFG Fe-, peFseR-e-. , the CREV System automatically switches to the pressurization mode of operation to minimize pievef infiltration of contaminated air into the CRE GentOeI-reem. A system of dampers isolates the CRE Gcntre .1I-Ie Outside air is taken in through the CREV System ventilation intake and is passed through one of the charcoal adsorber filter subsystems for removal of airborne radioactive particles.

(continued)

BFN-UNIT 3 B 3.7-18 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 BASES BACKGROUND The CREV System is designed to maintain the control room (continued) ea habitable environment in the CRE for a 30 day continuous occupancy after a DBA without exceeding 5 rem total effective dose equivalent (TEDE). A single CREV subsystem operating at a flow rate of 3000 cfm _ 10 percent will pressurize the CRE GeRtro! Foom to about 0.125 inches water gauge to minimize pFer,e. t infiltration of air from all surrounding areas adjacent to CRE boundary ';"*"i".in,, and the outdoors.

CREV System operation in maintaining CRE GORtroI-o.M habitability is discussed in the FSAR, Section 10.12 (Ref. 1).

APPLICABLE The ability of the CREV System to maintain the habitability SAFETY ANALYSES of the CRE GO.tr4o reGo is an explicit assumption for the safety analyses presented in the FSAR, Chapters 10 and 14 (Refs. 2 and 3, respectively). The pressurization mode of the CREV System is assumed to operate following DBA, lecs of coolant accidont, mnain steam line break, and conrolI rod drop accident (for thc conrol rod drop accidont and main steam line break, no credit istaken for an" filtration by the CRE=V system) as discussed in the FSAR, Section 14.6 (Ref. 4). The analyses for radiological doses to CRE occupants as a result of the various DBAs are summarized in Reference 3. No single active failure will cause the loss of filtered outside air from the GREGGR#9e FGIA.

There are no offsite or onsite hazardous chemicals that would pose a credible threat to GRE habitability (Ref 9).

Consequently, engineering controls for the GRE are not required to ensure habitability against chemical threat.

The evaluation of a smoke challenae demonstrated that smoke will not result in the inability of the CRE occupants to control the reactor either from the control room or remote shutdown system (Ref 9). The assessment verified that a fire or smoke event anywhere with the plant should not simultaneously render the remote shutdown system and the CRE uninhabitable, nor would it prevent access from the CRE to the remote shutdown system (continued)

BFN-UNIT 3 B 3.7-19 Revision Q, 29 January 25, 2005

CREV System B 3.7.3 in the event remote shutdown is required. No automatic CREV actuation is required for hazardous chemical releases or smoke and no Surveillance Requirements are required to verify OPERABILITY in cases of hazardous chemicals or smoke.

The CREV System satisfies Criterion 3 of the NRC Policy Statement (Ref. 6).

(continued)

BFN-UNIT 3 B 3.7-20 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 BASES (continued)

LCO Two redundant subsystems of the CREV System are required to be OPERABLE to ensure that at least one is available, assuminggif a single active failure, such as from a loss of both ventilation subsystems or form an inoperable CRE boundary.;

disables the other subsystem. Total system failure could result in exceeding a TEDE of 5 rem to the CRE occuoantss e#

........ G.- in the event of a DBA.

The Each CREV -*,,",- ystem is considered OPERABLE when the individual components necessary to limit GRE occupant contr-oloeýr..or exposure are OPERABLE in-bet-,

subsystems. A subsystem is considered OPERABLE when its associated:

a. Fan is OPERABLE;

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

c. The electric duct heater, ductwork, and dampers are OPERABLE.

inaddition, the control room boundar', must be maintained-,

inc~luding the integrity of the walls, floors, ceilings, dUcF.W~rk, and access6 doorS-.

In order for the CREV subsystems to be considered OPERABLE, thegRE 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 consequences analyses for DBAs, and that the CRE occupants are protected from hazardous chemicals and smoke.

BFN does not have automatic CREV actuations for hazardous chemicals or smoke. Current Dractices at BFN do not utilize chemicals of sufficient quantity to present a chemical hazard to (continued)

BFN-UNIT 3 B 3.7-21 Revision 0, 29 Amonidmont N*. 211 January 25, 2005

CREV System B 3.7.3 the CRE. Smoke is not considered in the current BFN safetv analysis. Therefore. BFN has no soecific limits on chemical hazards or smoke.

The LCO is modified by a Note allowing the CRE F'aia GiAr4I Feem 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 and to restore the CRE boundary who is in continuous communication with the ooerators 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 main cotrol room isolation is indicated.

(continued)

BFN-UNIT 3 B 3.7-22 Revision 0, 29 Amendment No. 2115 January 25, 2005

CREV System B 3.7.3 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, the CREV System must be OPERABLE to ensure that the CRE will remain habitable GE"Rt' .epe.ae e*PGSUwe during and following a DBA, since the DBA could lead to a fission product release.

In MODES 4 and 5, the probability and consequences of a DBA are reduced because of the pressure and temperature limitations in these MODES. Therefore, maintaining the CREV System OPERABLE is not required in MODE 4 or 5, except for during operations with potential for draining the reactor vessel (OPDRVs).

ACTIONS A.1 With one CREV subsystem inoperable, for reasons other than an inoperable CRE boundary., the inoperable CREV subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE CREV subsystem is adequate to perform the CRE occupant e9,t-el room radimatio protection function. However, the overall reliability is reduced because a-si*Ke failure in the OPERABLE subsystem could result in a loss of the ' UGed CREV System functiona,*,i*,ity. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities.

(continued)

BFN-UNIT 3 B 3.7-23 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 BASES ACTIONS B.1, B.2 and B.3 (continued)

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in a CRE occupant radiological dose areater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 REM TEDE) the CRE boundary is inoperable.

As discussed in the Applicable Safety Analysis Section. the BFN licensing bases notes that CRE inleakage limits for hazardous chemicals and smoke are not needed to protect the CRE occupants. Since the limit established for radiological events is limiting, verification of smoke and chemical hazards by administrative means is acceptable for an inoperable GRE boundary. Verification that the periodic check of onsite and offsite hazardous chemical sources has been performed within the time limit defined by the Control Room Habitability Program is an acce)table means to ensure the CRE occupants are protected from chemical hazards and smoke.

Actions must be taken to restore an OPERABLE CRE boundar 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA. the mitiaatina 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 conseauences 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time (continued)

BFN-UNIT 3 B 3.7-24 Revision 0, 29 Amendment No. 24*11 January 25, 2005

CREV System B 3.7.3 period, and the use of miligatina actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of eRE 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 within the CRE bounda.ry.

Itthe main contro room boundar-h o eab in MODISE 1, 2, and 3, the CREYV trafinscnoRefr their intended functions.-

Actions must be takon to Fe toro -;A OERA-LE main control room; boundary within 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months . During the period that the main contro rom mbounda i iorble, appropriate compensato moasuros (csitentwth th intent o-f GDG 19) rhould be utilized to protect Gontrol room operators from potential hazards such as radioactive contamination, toxi chemicals, smoeke, temperature and relative humidity, and physical security.

conc"ers for intentional and unintentional entry in+to the condition. The 21 hour2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months Completion Time isq reasonable based on the low probability of a DB Anemyl vtnnn v l oatl ocurngdrn this time period, and the u-se of compensator; 1measure The 2P4 hr Completion Timois a tYpially reasona le time to diagnose, plan and possibly repair, and test moest problems with the main control room boundary.

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREV subsystem or the CRE control room boun.da.ry cannot be restored to OPERABLE status within the uredasseeiatei Completion Time, 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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

(continued)

BFN-UNIT 3 B 3.7-25 Revision 0, 29 Amendment No. 2115 January 25, 2005

CREV System B 3.7.3 BASES ACTIONS D.1 and D.2 (continued)

During OPDRVs, if the inoperable CREV subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREV subsystem may be placed in the pressurization mode. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action D.1 is to immediately initiate actions to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

(continued)

BFN-UNIT 3 B 3.7-26 Revision 0, 29 Amcndmnrt No. 2001 January 25, 2005

CREV System B 3.7.3 BASES ACTIONS E.1 (continued)

If both CREV subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable CRE control room boundar, (i.e., Condition B), the CREV System 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.

F. 1 During OPDRVs, with two CREV subsystems inoperable for reasons other than Condition C or with the Reauired Actions and associated Completion Times of B not met, actions must be initiated immediately to suspend OPDVRs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

(continued)

BFN-UNIT 3 B 3.7-27 Revision 0, 29 Amendment No. 211*

January 25, 2005

CREV System B 3.7.3 BASES (continued)

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts on demand and continues to operate. Standby systems should be checked periodically to ensure that they start and function properly. As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system.

Monthly heater operation dries out any moisture that has accumulated in the charcoal as a result of humidity in the ambient air. The CREV System must be operated for > 10 continuous hours with the heaters energized to dry out any moisture and to demonstrate the function of the system.

Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available.

SR 3.7.3.2 This SR verifies that the required CREV testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

(continued)

BFN-UNIT 3 B 3.7-28 Revision 0

CREV System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.3 REQUIREMENTS (continued) This SR verifies that on an actual or simulated initiation signal, each CREV subsystem starts and operates. This SR includes verification that dampers necessary for proper CREV operation function as required. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.4 and SR 3.3.7.1.6 overlaps this SR to provide complete testing of the safety function. The frequency of 24 months is based on BFN's normal overatina cycle.

SR 3.7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the GRE boundary and into the CRE. The details of the testing are secified 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 that 5 rem TEDE and the GRE occupants are protected from hazardous chemicals and smoke.

There is no automatic CREV actuation for hazardous chemical releases or smoke and there are no Surveillance Requirements to verify the OPERABILITY in cases of hazardous chemicals or smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analysis of DBA consegquences. When unfiltered air inleakaae is areater 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 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 Required Action B.2. Temorary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 8). Options for restoring the CRE boundary to OPERABLE status include (continued)

BFN-UNIT 1 B 3.7-29 Revision O, 29 January 25, 2005

CREV System B 3.7.3 changing the licensing basis DBA consequences analysis, repairing the CRE boundary, or a combination of these actions.

(continued)

BFN-UNIT 1 B 3.7-30 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.4 REQUIREMENTS (continued) 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.

This SR vorifios the integrity of the control ro m oncloSUro and the assumed inleakage rates of potentialy contaminated air. The conrol room pesitivc presur~e, With respect to outdoors is periodicalaly te sted to verify proper fu*ction of the CREV System. Durng th-emergeRcY mode of .p..atien, thc CREV Sytem is designed to slightly pressurize the control room Ž 0. 12 inc~hes water gauge positive pressure With respect to the outdoor Wto prevent unfiltered inleakago. The CREV System is designed to mnaintain this positive pressure a floW Fate of Ž!2700 cfmn and!!* 3300 cfmn to the conrol1 roomR OR the prsuiation mode. The Frequency of 24 months on *onA STAGGERED TEST BASIS is istent with industI' practice and other filtration systems SRs.

REFERENCES 1. FSAR, Section 10.12.

2. FSAR, Chapter 10.

3. FSAR, Chapter 14.

4. FSAR, Section 14.6.

5. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.

6. NRC Regulatory Guide 1.196, "Control Room Habitability At Light-Water Power Reactors". January 2007.

BFN-UNIT 3 B 3.7-31 Revision Q, 29 January 25, 2005

CREV System B 3.7.3 BASES

7. NEI 99-03. "Control Room Habitability Assessment."

June 2001.

8. 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)

9. FSAR; Chapter 10.12.5.3. Toxic Gas Protection BFN-UNIT 3 B 3.7-32 Revision 0, 29 January 25, 2005

Enclosure 4 Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3 Technical Specifications (TS) Change 444 Adoption of Changes to Standard Technical Specifications Under Technical Specification Task Force (TSTF) Change Number - 448, Revision 3, Regarding Control Room Envelope Habitability Regulatory Commitments (Revised)

1. The first performance of the periodic assessment of the Control Room Envelope (CRE) Habitability, Technical Specification 5.5.13.c.(ii), shall be within 9 months following the initial implementation of the TS Change. The next performance of the periodic assessment will be in a period specified by the specified by the Control Room Envelope Habitability Program. That is 3 years from the last successful performance of the Technical Specification 5.5.13.c.(ii) tracer gas test.

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