PLA-6359, Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (CLIIP) PLA-6359
| ML090641019 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/20/2009 |
| From: | Spence W PPL Corp, Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-6359, TSTF-448 | |
| Download: ML090641019 (44) | |
Text
j 4F William H. Spence PPL Corporation Executive Vice President and Two North Ninth Street Chief Operating Officer/Chief Nuclear Officer Allentown, PA 18101-1179 *me%
Tel. 610.774.3683 Fax 610.774.5019 Tel. 610.774.5151 Whspence@pplweb.com www.pplweb.com rEB 2 0 2009 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OPI-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION AMENDMENT REQUEST NO. 302 TO UNIT 1 LICENSE NPF-14 AND AMENDMENT REQUEST NO. 272 TO UNIT 2 LICENSE NPF-22: APPLICATION TO REVISE TECHNICAL SPECIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448, REVISION 3, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP) Docket Nos. 50-387 PLA-6359 and 50-388 Reference. 1) PLA-5916, B. T McKinney (PPL)to Document Control Desk (NRC),
"FinalResolution to Generic Letter 2003-01 ControlRoom Habitability,"
datedJune 28, 2005.
In accordance with the provisions of 10 CFR 50.90, PPL Susquehanna, LLC is submitting a request for an amendment to the Technical Specifications (TS) for Susquehanna Steam Electric Station Units 1 and 2.
The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3 and satisfy the commitment made in Reference 1 to submit changes to the SSES Technical Specifications in accordance with TSTF-448.
These proposed changes have been reviewed by both the Plant Operations Review Committee and the Susquehanna Review Committee.
Attachment 1 provides a description of the proposed changes, the requested confirmation of applicability, and plant specific verifications. Attachment 2 provides the existing Technical Specification (TS) pages marked up to show the proposed changes.
Attachment 3 provides existing TS Bases pages marked up to show the proposed changes.
ý/-l 02, mg
Document Control Desk PLA-6359 PPL Susquehanna, LLC requests approval of the proposed license amendments no earlier than May 15, 2009 with the amendments being implemented within 180 days following approval.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the Commonwealth of Pennsylvania.
If you have any questions regarding this submittal, please contact Mr. Jason M. Welch at (570) 542-3251.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on:
W. H. Spence Attachments:
Attachment 1 - Description and Assessment Attachment 2 - Proposed Technical Specification Changes Units 1 & 2, (Mark-ups)
Attachment 3 - Proposed Technical Specification Bases Changes Units 1 & 2, (Mark-ups - For Information Only) cc: NRC Region I Mr. R. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. B. K. Vaidya, NRC Project Manager
Attachment 1 to PLA-6359 Description and Assessment
1.0 DESCRIPTION
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations 2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination 3.2 Commitments 4.0 ENVIRONMENTAL EVALUATION
Attachment 1 to PLA-6359 Page 1 of 3 I EVALUATION OF PROPOSED CHANGE
1.0 DESCRIPTION
The proposed amendment would modify Technical Specification (TS) requirements related to control room envelope habitability in TS 3.7.3, "Plant Systems Control Room Emergency Outside Air Supply (CREOAS) System" and TS Section 5.5, "Administrative Controls Programs and Manuals."
The changes are consistent with the Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-448, Revision 3.
The availability of this TS improvement was published in the Federal Register on January 17, 2007 (FR 72 2022) as part of the consolidated line item improvement process (CLIIP).
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation PPL Susquehanna, LLC has reviewed the safety evaluation dated January 17, 2007 as part of the CLIIP. This review included a review of the NRC staff s evaluation, as well as the supporting information provided to support TSTF-448, Revision 3. PPL Susquehanna, LLC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Susquehanna Steam Electric Station (SSES) Units 1 and 2 and justify this amendment for the incorporation of the changes to the SSES TS.
2.2 Optional Changes and Variations PPL Susquehanna, LLC is not proposing any significant variations or deviations from the TS changes described in the TSTF-448, Revision 3, or the applicable parts of the NRC staff s model safety evaluation dated January 17, 2007. Specifically, Evaluations 1, 5 and 6 of Section 3.3 of the model safety evaluation are applicable to Susquehanna Steam Electric Station Units 1 and 2. In order to establish standard terminology, "control room envelope" is used in place of "control room." Also the affected TS for SSES is "3.7.3, Control Room Emergency Outside Air Supply (CREOAS) System" instead of "3.7.4, Main Control Room Environmental Control (MCREC) System" referenced in the model SE.
Attachment 1 to PLA-6359 Page 2 of 3 2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements PPL Susquehanna, LLC proposes the following as a license condition to support implementation of the proposed TS changes. In subpart (a) of the license condition below, PPL Susquehanna, LLC provides a surveillance grace period as allowed by SR 3.0.2 of 18 months, which differs from the model application value of 15 months.
This discrepancy was noted in an NRC memorandum from C. Craig Harbuck to Timothy J. Kobetz, date February 2, 2007 (ADAMS Accession Number ML070330657).
Upon implementation of Amendment Nos. XXX for Susquehanna SES Unit 1 and YYY for Susquehanna SES Unit 2 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.14.c.(i), the assessment of CRE habitability as required by Specification 5.5.14.c.(ii), and the measurement of CRE pressure as required by Specification 5.5.14.d, shall be considered met. Following implementation:
(a) The first performance of SR 3.7.3.4 in accordance with Specification 5.5.14.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from December, 2004, the date of the most recent successful tracer gas test, as stated in PLA 5916, "Final Resolution to Generic Letter 2003-01, Control Room Habitability," dated June 28, 2005, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.14.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from December, 2004, the date of the most recent successful tracer gas test, as stated in PLA 5916, "Final Resolution to Generic Letter 2003-01, Control Room Habitability," dated June 28, 2005, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.14.d, shall be within 24 months, plus the 6 months allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test, or within 6 months if not performed previously.
Attachment 1 to PLA-6359 Page 3 of 3
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination PPL Susquehanna, LLC has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Register on January 17, 2007 (FR 72 2022) as part of the CLIIP. PPL Susquehanna, LLC has concluded that the proposed NSHCD presented in the Federal Register notice (FR 72 2022) is applicable to Susquehanna Steam Electric Station Units 1 and 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
3.2 Commitments There are no new regulatory commitments contained in this request.
4.0 ENVIRONMENTAL EVALUATION PPL Susquehanna, LLC has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007 as part of the CLIIP. PPL Susquehanna, LLC has concluded that the staff's findings presented in that evaluation are applicable to SSES Units 1 and 2 and the evaluation is hereby incorporated by reference for this application.
Attachment 2 to PLA-6359 Proposed Technical Specification Changes Units 1 & 2 (Mark-ups)
PPL Rev. 0 CREOAS System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Outside Air Supply (CREOAS) System LCO 3.7.3 Two CREOAS subsystems shall be OPERABLE.
.----- .........------------------------------ NOTE ---------------------------------------------
The control room habitability envelope (CREI boundary may be opened I intermittently under administrative control.
APPLICABILITY: MODES 1,2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREOAS subsystem A.1 Restore CREOAS subsystem 7 days inoperable for reasons other to OPERABLE status.
than Condition B; B. TweOne or more CREOAS B.1 Initiate action to implement Immediately subsystems inoperable due mitigating actions to inoperable controe rooM habitability o ,,NolopeCQRE AND boundary in MODES 1, 2, and 3. B.2 Verify mitigating actions ensure 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CRE occupant exbosures to radiolo.qical, chemical, and smoke hazards will not-exceed limits.
AND B.341- Restore contFrI room 90 days2"4-hours habitability onvelopoCRE boundary to OPERABLE status.
(continued)
SUSQUEHANNA - UNIT 1 TS / 3.7-6 Amendment 203,
PPL Rev. 0 CREOAS System 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or B not met AND in MODE 1, 2, or 3.
C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Required Action and -------------------- NOTE ---------------------
associated Completion Time LCO 3.0.3 is not applicable.
of Condition A not met during -------------------------------------------------
movement of irradiated fuel assemblies in the secondary D.1 Place OPERABLE CREOAS Immediately containment, during CORE subsystem in pressurization/
ALTERATIONS, or during filtration mode.
OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.
AND D.2.2 Suspend CORE Immediately ALTERATIONS.
AND D.2.3 Initiate action to suspend Immediately OPDRVs.
E. Two CREOAS subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.
(continued)
SUSQUEHANNA - UNIT 1 TS / 3.7-7 Amendment 2-03,
PPL Rev. 0 CREOAS System 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREOAS subsystems - NOTE --------------
inoperable during movement LCO 3.0.3 is not applicable.
of irradiated fuel assem blies ------ -
in the secondary containment, during CORE F.1 Suspend movement of Immediately ALTERATIONS, or during irradiated fuel assemblies in OPDRVs. the secondary containment.
OR AND One or more CREOAS F.2 Suspend CORE Immediately subsystems ,inoperable due ALTERATIONS.
to an inoperable CRE boundary during movement AND of irradiated fuel assemblies, in the secondary F.3 Initiate action to suspend Immediately containment, during CORE OPDRVs.
ALTERATIONS, or during OPDRVs SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREOAS filter train for _ 10 31 days continuous hours with the. heaters operable.
SR 3.7.3.2 Perform required CREOAS filter testing in In accordance with the VFTP accordance with the Ventilation Filter Testing Program (VFTP).
SR 3.7.3.3 Verify each CREOAS subsystem actuates on an 24 months actual or simulated initiation signal.
(continued)
SUSQUEHANNA - UNIT 1 TS / 3.7-8 Amendment 203,.
PPL Rev. 0 CREOAS System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.3.4 Perform required CRE unfiltered air inleakaqe In accordance with the testina in accordance with the Control Room Control Room Envelope Envelope Habitability Proqram.VrFify-eaeh Habitability Pro-gram 24 CREOAS subsystemr can main tain,a positive months on a ST.AGGERED proscuro of Ž! 0.1425 inches wator gaugo relative to TEST- BASIS tho outside atmosphren duurig the pr-ur,,izatin-*filir-ation moRde of opeFation at a flow I rato of 9 5810 ,fM.
SUSQUEHANNA - UNIT 1 TS,/ 3.7-9 Amendment 44!9-, 1
PPL Rev. 3 Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.14 Control Room Envelope Habitability Program A ControlfRoom Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Outside Air Supply (CREOAS) 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 challenqe. The proqram shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under desiqin basis accident (DBA).conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its eauivalent to any Dart of the body for the duration of the accident.
The program shall include the followin6- elements:
- b. Reguirements for maintaining the CRE boundary in its design condition including, configuration control and preventive maintenance.
- c. Requirements for (i) determining the unfiltered air inleakaqe past the CRE boundary into the CRE in accordance with theltesting methods and at the Frequencies specified in Section C1A and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Inteqrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessingq RE habitability at the Frequencies specified in Sections C.1 and C.2 of Requlatory 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 CREOAS 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 24 month assessment of the CRE boundarv.
SUSQUEHANNA - UNIT 1 TS / 5.0-1813 Amendment
PPL Rev. ,
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued)
- e. The quantitative limits on unfiltered air inleakaqe 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 inleakaqe limit for radiological challenges is the inleakaqe flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within-the assumptions in the licensing basis.
- f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paraqraphs c and d, respectively.
SUSQUEHANNA - UNIT 1 TS / 5.0-18C Amendment
PPL Rev. 0 CREOAS System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Outside Air Supply (CREOAS) System LCO 3.7.3 Two CREOAS subsystems shall be OPERABLE.
NOTES.
The control room habitability envelope (CRE) boundary may be opened intermittently under administrative control.
APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREOAS subsystem A.1 Restore CREOAS subsystem to 7 days inoperable for reasons other OPERABLE status.
than Condition B.
B. TweOne or more -CREOAS B.1 Initiate action to implement Immediately subsystems inoperable due mitiqatin'q actions to inoperable -'"-F-" .... A on.,-,-
habitability ..... E. AND boundary in MODES 1,2, and 3. B.2 Verify mitigating actions to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.
AND B.34-Restore ont-rol room habitability 24Ih,,..9n days enweee-CRE boundary to OPERABLE status.
(continued)
SUSQUEHANA - UNIT 2 TS / 3.7-6 Amendment 4q7,
PPL Rev. § CREOAS System 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or B not met AND in MODE 1, 2, or 3.
C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Required Action and ------------------ NOTE ----------
associated Completion Time LCO 3.0.3 is not applicable.
of Condition A not met during --------------------------------------------------
movement of irradiated fuel assemblies in the secondary containment, during CORE D.1 Place OPERABLE CREOAS Immediately ALTERATIONS, or during subsystem in pressurization/
OPDRVs. filtration mode.
OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.
AND D.2.2 Suspend CORE Immediately ALTERATIONS.
AND D.2.3 Initiate action to suspend Immediately OPDRVs.
E. Two CREOAS subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.
(continued)
SUSQUEHANA-UNIT2 TS / 3.7-7 Amendment 4:7-7,
PPL Rev. 0 CREOAS System 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREOAS subsystems -------------------- NOTE ------.....----------
inoperable during movement LCO 3.0.3 is not applicable.
of irradiated fuel assem blies --------------------------------------------------
in the secondary containment, during CORE F.1 Suspend movement of Immediately ALTERATIONS, or during irradiated fuel assemblies in OPDRVs. the secondary containment.
OR AND One or more CREOAS F.2 Suspend CORE Immediately subsystems inoperable due ALTERATIONS.
To an inoperable CRE boundary during movement AND of irradiated fuel assemblies in the secondary F.3 Initiate action to suspend Immediately containment, during CORE OPDRVs.
ALTERATIONS, of during OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREOAS filter train for > 10 31 days continuous hours with the heaters operable.
SR 3.7.3.2 Perform required CREOAS filter testing in In accordance with the VFTP accordance with the Ventilation Filter Testing Program (VFTP).
SR 3.7.3.3 Verify each CREOAS subsystem actuates on an 24 months actual or simulated initiation signal.
(continued)
SUSQUEHANA- UNIT 2 TS / 3.7-8 Amendment 4-77,
PPL Rev. 0 CREOAS System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.3.4 Perform required CRE unfiltered air inleakaae In accordance with the testingq in accordance with the Control Room Control Room' Envelope Envelope Habitability Proaram.AV44y-earh Habitability Proqram2-4 CREQASrubsyst*m caR maintain- a positive months on a STAGGERED peroccuro Of ->.2 ico wator gaugo rolativo to TERST-AS the outside atmosphereo duinth proscUrizationAfi4tatianR doo oration at a flow Fate of !* 58140- rfm.
SUSQUEHANA - UNIT 2 TS / 3.7-9 Amendment 4-54, 1
PPL Rev. 3 Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.14 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Pro-gram shall be established and implemented to ensure that CRE habitability, is maintained such that, With an OPERABLE Control Room Emergency Outside Air Supply (CREOAS) 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 program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident
.(DBA) conditions without personnel, receiving radiation exposures in excess of 5 rem whole body or its entuivalent tt-anv nart of the body for the duration of the accident.
The pro0.ram shall include the foll6wing elements:
- b. Requirements for maintaining the CRE boundary in. its design condition includihg. 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 Section C.1 ahd 0.2 of Regulatory Guide. 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii)assessing CRE habitability at the Frequencies specified in Sections C. 1,and C.2 of Regulatory Guide 1.197, Revision 0.
- d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the CREOAS 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 24 month assessment of the CRE boundary.
SUSQUEHANNA - UNIT 2 TS / 5.0-1813 Amendment
PPL Rev. 3 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued)
- e. The quantitative limits on unfiltered air inleakaqe into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakaqe measured by the testing described in paragraph c. The unfiltered air inleakaqe limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for.hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
- f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability. determining CRE unfiltered inleakage, and measuring CORE pressure and assessingq the CRE boundary as required by paragraphs c and d, respectively.
SUSQUEHANNA - UNIT 2 TS / 5.0-18C Amendment
Attachment 3 to PLA-6359 Proposed Technical Specification Bases Changes Units 1 & 2 (Mark-ups - For Information Only)
PPL Rev. 0 CREOAS System B 3.7.3 B 3.7 PLANT SYSTEMS B 3.7.3 Control Room Emergency Outside Air Supply (CREOOAS) System BASES BACKGROUND The CREOAS System provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.radiol"gically.... rolod o...i*nmt fom .Which tho unit can be safoly operated f9ooWing* a Decign Bacis Accidont (DBA). This radiologically controlled environment is termed the Control Roomto habitability-9 Envelope (CRE) and is comprised of Control Structure floor elevations 697'-0" through 783'-0" including the stairwells as described in FSAR Section 6.4 (Ref. 5-1-). I The safety related function of the CREOAS 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 inleaka-ge of unfiltered air. Each CREOAS subsystem consists of an electric heater, a prefilter, an'upstream high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section, a downstream HEPA filter, a CREOAS fan, a control structure heating and ventilation fan, a control room floor cooling fan, a computer room floor cooling fan, and the associated ductwork, valves or dampers, doors, barriers, and instrumentation-and dampers. Prefilters and HEPA filters remove particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay. With the exception of the CREOAS fan, all other CREOAS subsystem fansoperate continuously to maintain the affected compartments environment. These other ventilation fans operate independently of the CREOAS fans and are required to operate to ensure a positive pressure in the control structure is maintained utilizing filtered outside air supplied by the CREOAS fans.
The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is Protected during normal oPeration, natural events,'and (continued)
SUSQUEHANNA - UNIT 1 TS / B 3.7-12 Revision 4- 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES BACKGROUND accident conditions. The CRE boundary is the combination of walls, floor, (continued) roof, ductin-g, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.
Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to plant .p..ato-" in the habitabiit envelepeCRE occupants), the CREOAS System automatically switches to the pressurization/filtration mode of operation to PFeve9*minimize infiltration of contaminated air into the habitability.nv...p.R,, . A system of dampers aligns the outside air intake to the CREOAS fan suction and filter train.
Outside air is taken in at the normal ventilation intake and passed through one of the charcoal adsorber filter subsystems. The filtered air leaving the CREOAS filtration train is routed to the inlet of the other ventilation fans for distribution.
One of the CREOAS System design requirements is to maintain the nentrel room nvi-ronmonta habitable environment in the CRE for a 30 day continuous occupancy after a DBA without exceeding 5 rem whole body dose or its equivalent to any part of the body. A single CREOAS subsystem operatingq at a flow rate of S 5810 cfm with an intact control 6tr-cturo habitability
- Y*lope_ ýRE will pressurize the habitabWit .n...po. CRE (which includes the control room)_to greater than or equal to 0.125 inches water gauge relative to external areas adiacent to the CRE boundary to buildingsalf minimize t;-9pevent infiltration of air from currounding surrounding areas adiacent to the ORE boundary; CREOAS System operation in maintaining the habitability onvolopo onvironmont ORE habitability is discussed in the FSAR, Chapters 6 and 9, (Refs. 1 and 2, respectively)
APPLICABLE The ability of the CREOAS System to maintain the habitability of the eeftle SAFETY ctF6.ctUr, habitability onvelopoCRE is an explicit assumption for the safety I ANALYSES analyses presented in the FSAR, Chapters 6 and 15 (Refs. 1 and 3, (continued)
SUSQUEHANNA - UNIT 1 TS /B 3.7-13 Revision 4- 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES APPLICABLE respectively). The pressurization/ filtration mode of the CREOAS System is SAFETY assumed to operate following a DBA loss of coolant aGccident, fuol handling ANALYSES accident, aRnd contr! rod drop ,ccidont, as discussed in the FSAR, (continued) Section 6.4.1 (Ref. 41-). The radiological doses to the CRE occupants plant operator inthe. hab.itability oop.....as a result of the various DBAs are summarized in Reference 3. No single active failure will cause the loss of outside or recirculated air from the CRE.
The CREOAS System provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release (Ref. 5). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or'from the remote shutdown panels (Ref. 6).
The CREOAS System satisfies Criterion 3 of the NRC Policy Statemont.
(Refl-4)1 CFR 50.36(c)(2)(ii).
LCO Two redundant subsystems of the CREOAS System are required to be OPERABLE to ensure that at least one is available, assum*n9f-a single active failure disables the other subsystem. Total CREOAS Seystem failure, such as from a los of both ventilation subsystems or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem whole body or equivalent to plan*te.patre i;n tho habitability onvo.Iopthe ORE occupants in the event of a DBA.
The-Each CREOAS SubsVstemSyste*n is considered OPERABLE when the individual components necessary to limit CRE occupant GGe4pat exposure are OPERABLE in both subsystems. Both subsystems are considered OPERABLE when:
- a. Both filter trains each consisting of a CREOAS fan heater, a HEPA filter, and charcoal adsorber which is not excessively restricting flow is OPERABLE; and
- b. Both Control Structure Heating and Ventilation fans, Computer Room Floor Cooling fans, and Control Room Floor Cooling fans are OPERABLE; and (continued)
SUSQUEHANNA - UNIT 1 TS / B 3.7-14 Revision 2 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES LCO c. Ductwork, valves, and dampers are OPERABLE, and air circulation can (continued) be maintained.
- d. Neither Smoke Removal Fan (OV104NB) is in operation.
One subsystem is considered OPERABLE when:
- a. One filter train consisting of a CREOAS fan, heater, a HEPA filter, and charcoal adsorber which is not excessively restricting flow is OPERABLE; and
- b. The 'A' Control Structure Heating and Ventilation fan (OV103A) and the
'A' Computer Room Floor Cooling fan (OV1 15A) and the 'A' Control Room Floor Cooling fan (OV1 17A) are OPERABLE OR The 'B' Control Structure Heating and Ventilaiton fan (OV103B) and the
'B' Computer Room Floor Cooling fan (OV1 15B) and the 'B' Control Room Floor Cooling fan (OV1 17B) are OPERABLE (These fans are not dedicated to either CREOAS subsystem. As a result when any one set of fans is not OPERABLE, one arbitrarily determined CREOAS subsystem is not OPERABLE): and
- d. Neither Smoke Removal Fan (OV1 04A/B) is in operation.
!n addition, the habitability envolope must be maintained, including the inRtogrity of tho walls, floors, coilingp, ductwork, and access. doo-rs to mnaintain a positiv pcssuro.ln order for the CREOAS subsystems to be considered OPERABLE, the CRE boundaqr must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs. and that CRE occupants are protected from hazardous chemicals and smoke.
Note the h.itbiit on.elopoCRE can not be maintained with a smoke removal fan (OV104A or OV104B) in operation.
(continued)
SUSQUEHANNA - UNIT 1 TS / B 3.7-15 Revision 2 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES LCO (continued) The LCO is modified by a Note allowing the control room habitability enelepeCRE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the ORE 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 CREne.4.-el Feemi. This individual will have a method to rapidly close the opening and to, restore the CRE boundaryjto-a condition equivalent to the desiqn condition when a need for contro- room habitability n*-i,,lpeCgRE isolation is indicated.
APPLICABILITY In MODES 1, 2, and 3, the CREOAS System must be OPERABLE to ensure that the-CRE will remain habitablecont.Ro. oporatr
.xpesure 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 CREOAS System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:
- a. During operations with a potential for draining the reactor vessel (OPDRVs);
- b. During CORE ALTERATIONS; and
- c. During movement of irradiated fuel assemblies in the secondary containment.
(continued)
SUSQUEHANNA - UNIT 1 TS / B 3.7-16 Revision 2
PPL Rev. 0 CREOAS System B 3.7.3 BASES (continued)
ACTIONS A.1 With one CREOAS subsystem inoperable, for reasons other than an inoperable .CRE boundary, the inoperable CREOAS subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE CREOAS subsystem is adequate to perform i4s rad;atielnthe CRE occupant protection function. However, the overall reliability is reduced because a sikwje-failure in the OPERABLE subsystem could result in loss of the edueed CREOAS System functioneapability. 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.
B.1, 8ý2, and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radioloqical dose greater.than the calculated dose of the licensinq basis analyses of DBA consequences (allowed to be up to 5 rem whole bodyor its equivalent to any part of'the body), or inadeguate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE' bundarywithin 90 days.
During. the period that the CRE boundary is considered iooPerable, action muStbe initiated to implement mitigating actionsJo lessen ,the: effect on CRE occupants from the potential hazards of ,a radiological or chemical'event or a challeI'e from smoke. Actions must be taken within24 hours to verify. that in the event of, a DBA. the mitigating actions will en`sure that CRE occupaht radioloqical exposures will not exceed the calculated dose:of the licensing basis analyses of DBA consequences, and. that CRE occupants are irottected from hazardous chemicals and srmoke. These mitigating- actions (i6e., actions that are takento offset the cohseguences of the inoperable GREboUndary) should bepreplahned for, implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.
(continued)
SUSQUEHANNA - UNIT 1 TS / B3.7-17 Revision 2 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES ACTIONS B.1, B.2, and B.3 (continued)
The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurrinrg during this time period, and the use of mifigating actiohs. 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 abiliiy to control the reactor and maintain it in a safe shutdown condition in the event of a DBA.
In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.
If the control room habitability onV.,.p, bo'unda" is inoperable in MODES 1, 2, and 3, the CREOAS trains cannot, thirFerntondd functionsG.
Actions must be taken to restore an OPERABLE control room habitabilit enV9lope bcunRdar-y wi4.thin P21 hoursF. During the9 period that the contr6l rom habitabilty en.elope boundary is inoperable, aPpropriateompen.atory moas(Fcoen. e With the intnt of G.DG 19) should be, utilized to prt*ec*
control roo opraos9rM potential hazards such as, ra;dioati contamination;, toaxic chmcas moke, temperaturle and relative humidi4y, andph;Ysical security. Proplannod measu~eres huld be avoai;lableto adderes th9se conceFrn for intentional and u-nintentionAal enRy into theCondition. The DBA occGurring dur1ing this time period, and the Use of comApensatory mesue. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CoMPletion Time 1s a typically reasonable timeG to diagnose, plan and possibly repair, and test moest problemRs Wit h the control room napitatmiii envelope [DunoarY-.
C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREOAS subsystem or eotebfro roo habitabilitY onwclopethe CRE boundary cannot be restored to OPERABLE status within the a6ssciated~reqUired 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
(continued)
SUSQUEHANNA - UNIT 1 TS / B 3.7-18 Revision 2 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES ACTIONS D.1, D.2.1, D.2.2, and D.2.3 (continued)
The Required Actions of Condition- D0are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.
Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require either an entry into LCO 3.0.3 or a reactor shutdown in accordance with LCO 3.0.3.
During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, if the inoperable CREOAS subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREOAS subsystem may be placed in the pressurization/filtration 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 suspend activities that present a potential for releasing radioactivity that might require isolation of the ceRteI FeermCRE. This places the unit in a condition that minimizes the accident risk.
If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately.
Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be initiated immediately 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.
E. 1 If both CREOAS subsystems are inoperable in MODE 1, 2, or 3, for reasons other than an inoperable centroel room hbitability onve,,poCRE boundary (i.
e., Condition B) the CREOAS 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.
(continued)
SUSQUEHANNA - UNIT 1 TS / B 3.7-18A Revision 0 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES ACTIONS F.1, F.2, and F.3 (continued)
The Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.
Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require either an entry into LCO 3.0.3 or a reactor shutdown in accordance with LCO 3.0.3.
During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, with two CREOAS subsystems inoperable or with one or more CREOAS subsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require pressurization of the habitabili envaeleCRE. This places the unit in a condition that minimizes the accident risk.
If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately.
Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, 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.
SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that a CREOAS fan in a standby mode starts on demand from the control room and continues to operate with flow through the HEPA filters and charcoal adsorbers. 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 (continued)
SUSQUEHANNA - UNIT 1 TS / B 3.7-18B Revision 0 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.1 (continued)
REQUIREMENTS ambient air. Systems with heaters must be operated for > 10 continuous hours with the heaters energized. Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the availability of two redundant subsystems.
This SR verifies that the required CREOAS 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.
SR 3.7.3.3 This SR verifies that on an actual or simulated initiation signal, each CREOAS subsystem starts and operates. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.5 overlaps this SR to provide complete testing of the safety function. The 24 month Frequency is consistent with industry practice and other filtration systems SRs.
SR 3.7.3.4 This SR verifies the OPERABILITY of the-GRE boundary bY testinq fo unfilte*ed air inieakaqe pastithe CRE boundary and into the CRE. The details of the testing are specified in the'Control Room EnVelope Habitabilit Program.
The CRE istconsidered habitable when the radiological dose to CRE.
occupantscalculated in the liensinShq basis analyses of DBA-consequences is no more than 5 rem whole body or its equivalent to any part of the body and the -CRE.occupants are.protected from hazardous chemicals and smoke. This SR verifies that the, unfiltered air inleakaqe&into the CRE is no (continued)
SUSQUEHANNA - UNIT 1 TS / B 3.7-18C Revision 0 1
PPL Rev. G CREOAS System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.4 (continued)
REQUIREMENTS greater than the flow rate assumed in the licer'sinq basis analyses of DBA consequences. When unfiltered air inleakaqe is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensinq basis habitability limits for the occupants followinq an accident. Compensatory measures are discussed in Regqulatory Guide 1.196, Section C.2.7.3, (Ref. 7) which endorses, with exceptions, NEI 99-63, Section 8.4 and Appendix F (Ref, 8).
These compensatory measures may also be used as mitigatinq actions as iequired by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restoreOPERABILITY (Ref. 9). Options for restoring the.CRE boundary to -OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depenrdingq upon the nature, of the problem and the corrective action* a full scope inleakawe test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.
This SR verifiesA the intogrity of the.haiaiiybovlopo and !he assumod ineakago rates of poental contamated afir. The habitability; envelopo positiVe pressure9, With respect to poenial G cotmnte Gdaent areas (the turbine bUilding), is periodically tobo*d to Yrify propor function Of the
,RE.AS Sy6,em and the integrity of the habitability envelope. During the em",,rgenY mode of operation, the CRE, AS SytemF-n designed to slightly pressrize the contr,,ol strUcue ,! 0.125 inches water gauge positive presure ith rospect to the outid 4atmshr t rvnuflee inRloakago. The CREQAS System is designed to maintain this positive pressure at ag flow4. rate o)f ! 5810(cfM to, th conRtrol structure i h prsuiation/kfitation moede. The control structur habitability envelope is maitai~dwhen the control structure habitability envelope can be prsuied to ŽG.125 inches water gage positive pressure with Frespect to outsAride -atmosphere.The Frequency of 24 months,on a ST-AGGERED TEST BASIS6 i~s consstenpt with ind-ust practice an;d othOF filtfation sysem SUSQUEHANNA - UNIT 1 TS/ B 3.7-18D Revision 0 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES (continued)
REFERENCES 1. FSAR, Chapter 6.
- 2. FSAR, Chapter 9.
- 3. FSAR, Chapter 15.
- 4. FSAR, Section 6.4.1 F.nal Policy Statomont on Technical Spocifications
- 5. FSAR, Section 6.4.
- 6. FSAR, Section 9.5.
- 8. NEI 99-03, "Control Room Habitability Assessment," June 2001
- 9. 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 Habitabilitv." (ADAMS Accession No. ML040300694).
SUSQUEHANNA - UNIT 1 TS / B 3.7-18ý Revision 0 1
PPL Rev. 0 CREOAS System B 3.7.3 B 3.7 PLANT SYSTEMS B 3.7.3 Control Room Emergency Outside Air Supply (CREO9AS) System BASES BACKGROUND The CREOAS System provides a protected environment from which occupants can control the-unit following an uncontrolled release of radioactivity, hazardous chemicals, or smok..adi...Gicll co.ntro..e onvir Onmt 4fro Whichl tho unit can bo safely operated following a Dosign B;asi*OAGccident (^DBA).This radiologically controlled environment is termed the habitability-Control Room eEnvelope (CRE) and is comprised of Control Structure floor elevations 697'-0" through 783'-0" including the stairwells as described in FSAR Section 6.4, (Ref. ).
The safety related function of the CREOAS 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 inleakagqe of unfiltered air. Each CREOAS subsystem consists of an electric heater, a prefilter, an upstream high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section, a downstream HEPA filter, a CREOAS fan, a control structure heating and ventilation fan, a control room floor cooling fan, a computer room floor cooling fan, and the associated ductwork, valves or dampers, doors, barriers, ahd instrumentation-apA1 dlamrpeers. Prefilters and HEPA filters remove particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay. With the exception of the CREOAS fan, all other CREOAS subsystem fans operate continuously to maintain the affected compartments environment. These other ventilation fans operate independently of the CREOAS fans and are required to operate to ensure a positive pressure in the control structure is maintained utilizing filtered outside air supplied by the CREOAS fans.
The CRE is the area within the confines of the CRE boundary that contains the spaces that control room. occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural.events, and accident conditions. The ORE boundary is the combination of walls, floor, roof, ductin.q doors; penetrations and (continued)
SUSQUEHANNA - UNIT 2 TS / B 3.7-12 Revision 4- 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES BACKGROUND equipment that physically form the CRE. The OPERABILITY of the CRE (continued) boundary must be maintained to ensure that the inleakaqe of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.
Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to plant operators in the hebit-bilit eGRe91 CRE occupants), the CREOAS System automatically switches to the pressurization/filtration mode of operation to ..ever. *inimize infiltration of contaminated air into the habitability en.vopeR"-E. A system of dampers aligns the outside air intake to the CREOAS fan suction and filter train. Outside air is taken in at the normal ventilation intake and passed through one of the charcoal adsorber filter subsystems. The filtered air leaving the CREOAS filtration train is routed to the inlet of the other ventilation fans for distribution.
One of the CREOAS System design requirements is to maintain a habitable environment in the CREtho control roo.m nironment for a 30 day continuous occupancy after a DBA without exceeding 5 rem whole body dose or its equivalent to any part of the body. A single CREOAS subsystem operating at a flow rate of < 5810 cfm with an intact eetei structure habitability envelope ORE will pressurize the habitablih eRV9ep9CeRE (which includes the control room) to greater than or equal to 0.125 inches water gauge relative to external areas adiacent to the CRE boundary to minimize tepee.4-infiltration of air from all surroundingq areas adiacent to the CRE boundar..urr.updig,* building.
CREOAS System operation in maintaining the-CRE habitability eRnVelop e.i*.-romnt is discussed in the FSAR, Chapters 6 and 9, (Refs. 1 and 2, respectively).
APPLICABLE The ability of the CREOAS System to maintain the habitability of the SAFETY ANALYSES control struct-re habitability enva!opcCRE is an explicit assumption for the safety analyses presented in the FSAR, Chapters 6 and 15 (Refs. 1 and 3, respectively). The pressurization/filtration mode of the OREOAS System is assumed to operate following a DBAleoss of cooelant accidont, fuel haRdling accident, a*d con*to rod drop accident, as discussed in the FSAR, Section 6.4.1 (Ref. 4-4). The radiological doses to planpeatem in the habitability enVelopethe CRE occupants as a result of the various DBAs are summarized in Reference 3. No single active failure will cause the loss of outside or recirculated air from the CRE.
(continued)
SUSQUEHANNA - UNIT 2 TS / B 3.7-13 Revision 2
0 PPL Rev. 0 CREOAS System B 3.7.3 BASES APPLICABLE The CREOAS System provides protection from smoke and hazardous SAFETY ANALYSES chemicals to the CRE occupants. The analysis of hazardous chemical (continued) releases demonstrates that the toxicity limits are not exceeded in the CRE followinq a hazardous chemical release (Ref. 5). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Ref. 6).
The CREOAS System satisfies Criterion 3 of the NRCC Policy Statemont.
(Ref.--)10 CFR 50.36(c)(2)(ii).
LCO Two redundant subsystems of the CREOAS System are required to be OPERABLE to ensure that at least one is available, ausswg if a single active failure disables the other subsystem. Total CREOAS sSystem failure, such as from a loss of both ventilations subsystems or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem whole body or equivalent to plant operators in the habitability .. v.lopo.*he CRE occupants in the event of a DBA.
T-he-Each CREOAS Sste gsubsystem is considered OPERABLE when the individual components necessary to limit CRE occupanteentFG1 e.eateo exposure are OPERABLE in both subsyctems. Both subsystems are considered OPERABLE when:
- a. Both filter trains each consisting of a CREOAS fan, heater, a HEPA filter, and charcoal adsorber which is not excessively restricting flow is OPERABLE; and
- b. Both Control Structure Heating and Ventilation fans, Computer Room Floor Cooling fans, and Control Room Floor Cooling fans are OPERABLE; and
- d. Neither Smoke Removal Fan (OV104A/B) is in operation.
(continued)
SUSQUEHANNA - UNIT 2 TS / B 3.7-14 Revision 2 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES LCO One subsystem is considered OPERABLE when:
(continued)
- a. One filter train consisting of a CREOAS fan, heater, a HEPA filter, and charcoal adsorber which is not excessively restricting flow is OPERABLE; and
- b. The 'A' Control Structure Heating and Ventilation fan (OV1 03A) and the 'A' Computer Room Floor Cooling fan (OV1 15A) and the 'A' Control Room Floor Cooling fan (OVi 17A) are OPERABLE OR The 'B' Control Structure Heating and Ventilation fan (OVi 03B) and the 'B' Computer Room Floor Cooling fan (OV1 15B) and the 'B' Control Room Floor Cooling fan (OV1 17B) are OPERABLE (These fans are not dedicated to either CREOAS subsystem. As a result when any one set of fans is not OPERABLE, one arbitrarily determined CREOAS subsystem is not OPERABLE); and
- d. Neither Smoke Removal Fan (OV104A/B) is in operation.
Inaddition, the habitability,onvolopo must be maintained, including the integrity of the walls, floors, ceilings, dwucw9Fk, an;d accesss dooers-tc maintain a po"itive pr.ssur.. In order for the CREOAS 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 consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke. Note the habitability ..., l.po RE can not be maintained with a smoke removal fan (0V104A or 0V104B) in operation.
(continued)
SUSQUEHANNA - UNIT 2 TS / B 3.7-15 Revision 2 1
p PPL Rev. 0 CREOAS System B 3.7.3 BASES LCO (continued) The LCO is modified by a Note allowing the contro room habitability eCvel "eCRE boundary to be opened intermittently under administrative controls. This Note only applies to openingts in the CRE boundary that can be rapidly restored to the design conditibn, 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 CREGenr* reelm. 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 control ro.m habitability .n... O--*RE isolation is indicated.
APPLICABILITY In MODES 1, 2, and 3, the CREOAS System must be OPERABLE to ensure that the CRE will remain habitablcontrolv op ator.. oxpou*
. 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 CREOAS System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:
- a. During operations with apotential for draining the reactor vessel (OPDRVs);
- b. During CORE ALTERATIONS; and c During movement of irradiated fuel assemblies in the secondary containment.
(continued)
SUSQUEHANNA - UNIT 2 TS / B 3.7-16 Revision-2 I
1 PPL Rev. 0 CREOAS System B 3.7.3 BASES (continued)
ACTIONS A.1 With one CREOAS subsystem inoperable, for reasons other than an inoperable CRE boundary, the inoperable CREOAS subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE CREOAS subsystem is adequate to perform the CRE occupantitr&Fa4i#tGR protection function. However, the overall reliability is reduced because a sih, gle-failure in the OPERABLE subsystem could result in loss of thefeduied CREOAS System functionapabifity. 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.
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 CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences. (allowed to be up to 5 rem whole body or its equivalent to any part of the body), or inadequate protection of CRE Occupants from hazardous chemicals or smoke, the.CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.
During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigatinq actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the -event of a DBA, the mitigating actions will ensure. that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke.ý These mitigating actions (if.e., actions that are taken to offset the consequences of the inoperable.CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion (continued)
SUSQUEHANNA - UNIT 2 TS /B 3.7-17 Revision 2 1
PPL Rev. G CREOAS System B 3.7.3 BASES ACTIONS B.1. B.2. andB.3 (continued)
Time-is reasonable based on the determination that the mitigating actions Will ensure protection of CRE occupantswithin analyzed limits While limiting the probability that ORE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it ina safe shutdown condition in the event of a DBA.
In addition, the 90 day Completion'Time isa reasonable time to diaqnbse.
planand possibly repair, and test most problems with the CRE boundarvif tho otrlromhbtaiiy nolp oudr i npeal In MODES 1,2, ar 3, the CREOAS traine CR nOt posyrm toir intended functions. Actionrs mut be taken t re stora e control rOoER habitability envelope boundary withii 24 ho During the periCo that the coanto room habitability mnivmlpe bundey nt riskiopeable, appoprisate compensatory mteacue i(naesiastOEnt with the intent Of GDC 19) should be utilizedbtoprotect ontrol roomA operator frmptntial hazards such as
- 0. 'and C.2 es rolativo humidity, and phsia seuiy.. Proplannod measu~ro. holid i be, available.to address thoe9 concerns for intentional and unintentional entr iODthe Cndition. The 21 h-ou Completion Time is reasonable basbdon thbedlow pbability of a DBeA icetiog duric g thise ti p t ond the usre of compensatory measures. T~heK 241 hour0.00279 days <br />0.0669 hours <br />3.984788e-4 weeks <br />9.17005e-5 months <br /> Completion, Time is a typically feasnable time to diagnose, plan,and postibly repair, and test mast problemAs With the conrol1 room habitability envelope boundary.
0.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREOAS subsystem or GQtgl4el4OGR habitability, envelopethe ORE boundary cannot be restored to OPERABLE status within the aes~eiated reguired 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
(continued)
SUSQUEHANNA - UNIT 2 TS / R 3.7-18 Revision 2 1
V PPL Rev. 0 CREOAS System B 3.7.3 BASES ACTIONS D.1, D.2.1, D.2.2, and D.2.3 (continued)
The Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require either an entry into LCO 3.0.3 or a reactor shutdown in accordance with LCO 3.0.3.
During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, if the inoperable CREOAS subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREOAS subsystem may be placed in the pressurization/filtration 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 suspend activities that present a potential for releasing radioactivity that might require isolation of the nerAF 9 CRE. This places the unit in a condition that minimizes the accident risk.
If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, ifapplicable, actions must be initiated immediately 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.
E._1 If both CREOAS subsystems are inoperable in MODE 1, 2, or 3, for reasons other than an inoperable control roo9m habitability .nv,,"pCrE boundary (i. e., Condition B) the CREOAS 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.
(continued)
SUSQUEHANNA - UNIT 2 TS / B 3.7-18A Revision 0 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES ACTIONS F.1, F.2, and F.3 (continued)
The Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require either an entry into LCO 3.0.3 or a reactor shutdown in accordance with LCO 3.0.3.
During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, with two CREOAS subsystems inoperable or with one or more CREOAS subsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require pressurization of the habitability eRVelel.CRE. This places the unit in a condition that minimizes the accident risk.
If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, 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.
SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that a CREOAS fan in a standby mode starts on demand from the control room and continues to operate with flow through the HEPA filters and charcoal adsorbers. 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. Systems with heaters must be operated for _>10 continuous hours with the heaters energized. Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the availability of two redundant subsystems.
(continued)
SUSQUEHANNA - UNIT 2 TS / B 3.7-1813 Revision 0 1
ap PPL Rev. O CREOAS System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.2 REQUIREMENTS (continued) This SR verifies that the required CREOAS 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.
This SR verifies that on an actual or simulated initiation signal, each CREOAS subsystem starts and operates. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.5 overlaps this SR to provide complete testing of the safety function. The 24 month Frequency is consistent with industry practice and other filtration systems SRs.
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 conseguences is no more than 5 erem whole body or its equivalent to any part of the body and the' CRE occupants are protected from hazardbous chemicals and smoke. This SR verifies that the, unfiltered air inleakaqe into the ORE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiftered air inlekaqge is greater than the assumed!flow rate, Condition B must be entered.
Required Action B.3 allows time to restore the CRE boundary to
.OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the 6ccupants followinq an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 7) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 8). These compensatory measures may also be used as mitigating actions as required by Required Action B.2.
(continued)
SUSQUEHANNA - UNIT 2 TS / B 3.7-18SC Revision 0 1
PPL Rev. 0 CREOAS System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.4 (continued)
REQUIREMENTS Temporary analytical methods may also be used as compensatory measures.to restore OPERABILITY (Ref. 9). Options for restoring the CRE bOundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending 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 Yorifiosthe integrity of the habitability onvolopo and the assumed inloakago rcates of potontially contaminatod air. T-ho habitability envolope-positivo preesuro, with resepoc to Ootontially contaminatod aijacont areas (the turbino building), is,peoiodically toýAtod to Yerify p,-ropo,-r f Oof tho CREOtGAS System aRd the itegr*ity of the habiability envelope. During the emorgoncy mo~de of operation,th "RE'ASSyst" m is designed to ulightdy presphurize the cn.trol StRucture
.. 1.25 cho wat . gaugo positiVe pro. With ropet tte. o atmqspheor to preVent unfiltorod. inloakago. The CREQAS Syst! ~
designed to maintain this positivo prossuro at a flowo r-ate of!r 5810 9 cfmA to the control structuro8 in the pressur~ization/filtraion mod-e. The coentrol istrucsturo habitability onvelope i6maintained Whon the control Structuro habitability enveopep can be prossurized to Ž!0. 125 inc~hos water gauge positive prosSUro With respoct to outcido atmosphoro. The FroguoncY of
- 21. monAthso on a STAGGERED TEST BASIS isconsistent with. industr, pr~actico and other filt4rato sYstoms SPs-.
REFERENCES 1. FSAR, Chapter 6.
- 2. FSAR, Chapter 9.
- 3. FSAR, Chapter 15.
- 4. FSAR, Section 6.4.1.
- 5. FSAR, Section 6.4.
- 6. FSAR, Section 9:5&
- 8. NEI 99-03, "Control Room Habitability Assessment,' June2001 SUSQUEHANNA - UNIT 2 TS / B 3.7-18D Rev ision 0 I
PPL Rev. Q CREOAS System B 3.7.3 BASES REFERENCES 9. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated (continued) January 30, 2004, "NEI Draft White Paper, Use Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).
,. Fin1l Policy Statoment on Tochnical Spocificatione Imprvemeonte, July22, 1993 (58 FR 39.132).
SUSQUEHANNA - UNIT 2 TS / B 3.7-18E Revision 0 1