Text

(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) ...
	ML091200062
Person / Time
Site:	Browns Ferry
Issue date:	04/24/2009
From:	West R; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TVA-BFN-TS-444
	Download: ML091200062 (74)
	v • d • e

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 April 24, 2009 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 This letter responds to the March 6, 2009, Email from NRC, Brendan Moroney, to TVA requesting that BFN make administrative changes to the TS and TS Bases in TVA's proposed TS-444. provides a revision to the Units 1, 2, and 3 TS pages marked-up to show the proposed change. Enclosure 2 provides a revision to the Units 1, 2, and 3 Bases pages marked-up to show the proposed change. TVA incorporated all of the administrative NRC requested changes into Enclosures 1 and 2. Enclosures 1 and 2 provide complete markup of the proposed change.

The revised pages provided in Enclosure 1 does not alter the original determination that there are no significant hazards considerations associated with the proposed changes, nor do the changes alter the originally submitted Environmental Assessment and Finding of No Significant Impact provided by TVA's March 27, 2008 letter (Reference).

U.S. Nuclear Regulatory Commission Page 2 April 24, 2009 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. TVA currently plans to implement TS-444 within 60 days of NRC approval.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on April XX, 2009.

incerely, R. G. West Vice President Browns Ferry Nuclear Plant

Enclosures:

1. Proposed Technical Specifications Changes (Revised Mark-up)

2. Proposed Changes to Technical Specifications Bases Pages (Revised Mark-up)

Reference:

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

U.S. Nuclear Regulatory Commission Page 3 April 24, 2009 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 A. Brown, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Ms. Heather J. Gepford, Acting 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 I 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. TVA drew a line through the deleted text and a double underline for new or revised text. The changes made as a result of the NRC's request are highlighted.

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. 4wG One or More CREV B.1 Initiate action to subsystems inoperable implement mitigating Immediately due to inoperable CRE actions.

cGntrIGIreG boundary in MODES 1, 2, and 3. AND B.2 Verify mitigating actions ensure CRE occupant exoosures to radioloaical 24 Hours hazards will not exceed limits, and verify the CRE occupants are protected from smoke and chemical hazards.

AND 24*-Hmm*m B.4-.3 Restore CRE ,entrel Feem-boundary to 90 days OPERABLE status.

BFN-UNIT 1 3.7-8 Amendment No.234, 2.46, 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.234, 246, 251 September 27, 2004

CREV System 3.7.3 ACTIONS (continued)

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

OPDRVs for reasons other than Condition B.

OR Required actions and Completion times of Condition B not met during OPDRVS.

BFN-UNIT 1 3.7-11 Amendment No.234,246, 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 Habitability Venf;y eac.h CREV subsy*tem. can . maintain a Program pesitiv.e pressure ofŽ 0.125 inhe wAterU gauge Felati'je to the outAdoors du ring the 24 months on a pressurization Mod of oprtion at a flow STAGGERED rate of >Ž 27-00 cmand-< 3300 4fM. I E 2-BA1lS BFN-UNIT 1 3.7-12 Amendment No.234, 246, 251 September 27, 2004

CREV System 3.7.3 5.5.12 Primary Containment Leakage Rate Testing Program (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 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 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 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 Dreventive 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. 2,34-*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 adjacent 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.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of the CRE occupants to these hazards will be within the assumptions in the licensing basis.

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

(continued)

BFN-UNIT 1 5.0-23 Amendment No. 2Z4-,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.

-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 actions to Immediately subsystems inoperable implement mitigating due to inoperable ,entrel actions.

Feem-CRE boundary in MODES 1,2, and 3. AND B.2 Verify mitiaatina actions 24 Hours ensure CRE occupant exposures will not exceed limits AND B.4-3 Restore CRE GeRttIr r-eem boundary to OPERABLE status.

24 huf 90 days BFN-UNIT 2 3.7-9 Amendment No. 2-54-, 2-83, 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

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 2 3.7-10 Amendment No. 254-, 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- 283, 290 September 27, 2004

CREV System 3.7.3 ACTIONS (continued)

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

OPDRVs for reasons other than Condition B.

OR Required actions and Completion times of Condition B not met during OPDRVs.

BFN-UNIT 2 3.7-12 Amendment No. 254- 28,3, 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 Vorif; eac,h GREV ,ubsytem.can Maintain a Program positive pressure ef>- 0125 inches water gauge relative to the o*utdors during the 24m,R*,h* -*4--a pressurization MAde of operation at a flow STAGGERED rate o-f- 0 7100 and!!r 3300 f.T-EST- BAS 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 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 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 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 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 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.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of the CRE occupants to these hazards will be within the assumptions in the licensing basis.

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

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.

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. T-wG One or more CREV B. 1 Initiate actions to Immediately subsystems inoperable implement mitigating due to inoperable Getrel actions.

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

AND B.43 Restore CRE Gentrel 24-, ..... 90 days F-eem boundary to OPERABLE status.

BFN-UNIT 3 3.7-9 Amendment No. 214-241, 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- 241, 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, 244, 249 September 27, 2004

CREV System 3.7.3 ACTIONS (continued)

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

OPDRVs for reasons other than Condition B.

OR Required actions and Completion times of Condition B not met during OPDRVs.

BFN-UNIT 3 3.7-12 Amendment No. 2-14-241, 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 Verify each GRE" sublytemI can maintain a program positive Ipressure of Ž!0.125 incher,water gauge rel-ative to-the outdooers during the :24 mnnho4A mode of operation at a flow

.ressurization STAGGERED rate of Ž!2700 cftf and !53300 cm. ISig TS -II BFN-UNIT 3 3.7-13 Amendment N4 214 September 08, 1998

CREV System 3.7.3 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; andb. 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 Ž_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 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 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.

BFN-UNIT 3 3.7-14 Amendment No. 2[4 September 08, 1998

CREV System 3.7.3

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

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

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one 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. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of the 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 boundar as required by paragraphs c and d, respectively.

BFN-UNIT 3 3.7-15 Amendment No. 2[4 September 08, 1998

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 Changes to Technical Specifications Bases Pages (Revised Mark-up)

TVA has revised the enclosed pages. TVA drew a line through the deleted text and a double underline for new or revised text. The changes made at the request of NRC are highlighted.

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. adilgiGal controlled environment from ,which the '-unit cr-n be _afely operated following a Design Basis Accident (1DIBA).

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 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 boundar must be maintained to ensure that the inleakage of unfiltered air (continued)

BFN-UNIT 1 B 3.7-17 Revision 0, 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 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 con-trol rom perFG,,,,), the CREV System automatically switches to the pressurization mode of operation to minimize pievent infiltration of contaminated air into the CRE -etrte re,-F,. A system of dampers isolates the CRE citr! rFeem. 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 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 CRE centrel room e,,'ironment (continued) 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 centreree,- to about 0.125 inches water gauge to minimize pFevent infiltration of air from all surrounding areas adjacent to CRE boundary -bud;,s and the outdoors. CREV System operation in maintaining CRE Gentre Feem-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 rentre- ree..; 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, leos of coolant accideRt, main steam line bra, and conrol rodak dro cindent (for the control rod drop accident and- m-ain steam line break, no credit is taken for any filtration by the G-RE"V System) as discussed in the FSAR, Section 14.6 (Ref. 4). The analyses for radiological doses to CRE occupants c-on-pitrol ,roo..m personnel 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 Gnt+e. room.

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 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 actuation is required for hazardous chemical releases or smoke (continued)

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

CREV System B 3.7.3 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, arsumig if a single active failure disables the other subsystem.

Total CREV Asystem 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 CRE occupants co-ntrol rom operato.r in the event of a DBA.

The Each CREV System subsystem is considered OPERABLE when the individual components necessary to limit CRE occupant ,en..,,--pe at,÷ exposure are OPERABLE -beth 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 addition, the control room bouRdary must be mnaintaine4d Dincluding the integrity of the walls, floors, ceilings, ductWork, and access-or dooGrs.

In order for the CREV subsystems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a larae 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 analysis. Therefore, BFN has no specific limits on chemical hazards or smoke.

(continued)

BFN-UNIT 1 B 3.7-21 Revision 0, 29 Armnendm-ennt nin 246 January 25, 2005

CREV System B 3.7.3 The LCO is modified by a Note allowing the CRE mai-GoFI FrooR boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE 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 1 B 3.7-22 Revision G, 29 Amendmert No. 246 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 ,ntI .Gpe.

expesuFe 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 GGRtFGt roo radia protection function. However, the overall reliability is reduced because a-sikgle failure in the OPERABLE subsystem could result in loss of the FedU*ed CREV System function Gapability. 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 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 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 Program 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 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 mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA conseauences 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 period, and the use of mitigating actions. The 90 day (continued)

BFN-UNIT 1 B 3.7-24 Revision 0, 29 Amendment hio. 246 January 25, 2005

CREV System B 3.7.3 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 main control roomn boundary is inoperable in MODES 1, 2, and 3, the CREV trains cannt per*Form their intended functions Actions must be taken to restore an OPERABLE main controe room bounda'y Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . DurinRg the period that the main control room boundary is inoperable, apprpriate compensato measures (consistent ,,Aith the intenRt, o-f GQDCn19) should be utilized to protectOcoto roo operators from potential ha-zardsr-such as rad-ioac~tive cont~am.inat~ion, toXic chemnicals, smo~ke-,

temperature and relative humidity, and physical security.'

concerns for intentional and unintentioa*l eRntY into the c-ndcfitin. The :21 ho*ur Cmpletion Timle is reasonable based On the low probability of a DIA occurring during this time period, andl the use Of omrpeRsatofr m,,easures. The 21 hr, ,

Completion Time ius a typically reasrnhableýtime to dliagne, plan and peosibly repair, and test mest problems with the main rontrol roonm boundar,'-.

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREV subsystem or the CRE G tGI- reeom 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 conditions in an orderly manner and without challenging unit systems.

(continued)

BFN-UNIT 1 B 3.7-25 Revision g, 29 Amnurdmet No. 2165 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 Amendnment o. 216 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 bo.undar (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 During OPDRVs, with two CREV subsystems inoperable or with one or more CREV subsystems inoperable due to an inoperable CRE boundary, 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 Amendment No. 2006 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 Frequency of 24 months is based on BFN's normal operating 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 greater than the flow rate assumed in the licensing basis analysis of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for 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 1 B 3.7-29 Revision 0, 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 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 RR verifies the integrity Of the control room encnloure and the assumed inleakage rates of potentially contaminated- air. The cone-trol room-n positive pressure, with respect4 to outdooers is periodically tested to verify proper fun"tion o,,f thte CREV Syste÷m. During- he emnergency moede of operation, the CREV System; i6 designed to slightly pre66urize the control room Ž!0.125 inc~hes, water gauge positive presrsure with Frespect to the outdoors to prevent unfiltered inleakage. The CREV Systemn is designed to mnaintain this positive pressure at-a flow rate of Ž! 2700 cfmn and !* 3300 cfM to the control roomn in the peressurization mode. The Frequency o9 24 moenths on a STAG-G-E"R'ED -T-EST- BASIS is consistent wi.At-h ind-ustrFY practice anRd other filtration systems SRs.

(continued)

BFN-UNIT 1 B 3.7-31 Revision 0, 29 January 5, 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 Regulatory 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.

MIL040300694)

9. FSAR, Chapter 10.12.5.3, Toxic Gas Protection (continued)

BFN-UNIT 1 B 3.7-32 Revision 0, 29 January 5, 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 radioactivity., adioo*gically o*t*rGoled envi9ronmnt from which the unit can be safely operated following a Desig Basis Accident (OBA).

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 aP4 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 freaquent 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 exceed the inleakage assumed in the licensing basis analysis of (continued)

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

CREV System B 3.7.3 design basis accident (CBA) 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 GGtr-l psnn),

.... the CREV System automatically switches to the pressurization mode of operation to minimize-pfeveý infiltration of contaminated air into the CRE ntFroe rFeoo. A system of dampers isolates the CRE GotF .lreeom. 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 CRE the control room (continued) eR.Fnmei-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 Gentrav ree,4 to about 0.125 inches water gauge to minimize preveRt infiltration of air from all surrounding areas adiacent to CRE boundary [,Abid-n and the outdoors. CREV System operation in maintaining CRE G*G.-,re r.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 ontrI rFeeom 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 a*ccident, mnain steam break, mine -and-controlrGod d ient Fl (for the controm rddp accident anld Main steam line break, 9n creditis taken fr any filtratioen by the GRE, system), as discussed in the FSAR, Section 14.6 (Ref. 4). The analyses for radiological doses to CRE occupants control room per.on*el 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 GO-MM'f ee.

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 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 2 B 3.7-19 Revision Q, 29 January 25, 2005

CREV System B 3.7.3 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, ass. *-" if a 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 occupants GGRtre4 reom eperteir* in the event of a DBA.

The Each CREV subsystem y6t is considered OPERABLE when the individual components necessary to limit CRE occupant ""te-"peatmrexposure 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.

I* addition, the control roo..m bounda"y must be maintained, inc~luding the integrity of the walls, floors, ceilings, ductwerk, and aGGess de~frs-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 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 analysis. Therefore, BFN has no specific limits on chemical hazards or smoke.

(continued)

BFN-UNIT 2 B 3.7-21 Revision G, 29

,Amendment No. 283 January 25, 2005

CREV System B 3.7.3 The LCO is modified by a Note allowing the CRE maih*GGRt-9 From 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 pluas 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 Ame*ndment 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 enr#eI -peratr expesu~eduring 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 GGntF9t room radia protection function. However, the overall reliability is reduced because a Sihgle failure in the OPERABLE subsystem could result in loss of the FedU*ed CREV System function a . 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 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 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 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 Program 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 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 mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition. regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 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 period, and the use of mitigating actions. The 90 day (continued)

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

CREV System B 3.7.3 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 main r0ntrol room boundar is inoprble in MODES 1, 2, aR aUI, I ' i i ; t iIIIIUL IUGIaI LIIUII IF ILt U II QLIUIi;.

A~ctions mu-t be taken to restore an OPER-A.LE main contrOl room boundary ,within "2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . During the period that the main control rOOm bo.unday is inoperable, appropriate compensatory m:easures (Ronsis'tePntl With the intent of GDC 19) should be utilized to.prtect controlI room operator from potential haza**s SUch as.radioactie contamination, tGXic chemicals, smoke,*

temperature and relative humidity, and physical security.

Prepla.ed. measures should be available to.adre these concern. intentional and

-for unintentional entry into the conditior. The 24 hur COmPletion Time is reasonable based On the loW probability f a DBA occu-'rr'ng du.rig this time perid a*nd the use Of compensatory m .easures. The 21 hour2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months G er pletieR T im e nG a tynpi,-* lh, reas-* abl-el wernal-e ..... ,

plan and possibly repair, and test most problem-s with the mmin conrol1 room boundar.9p C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREV subsystem or the CRE ronntroI r-,,m boundary cannot be restored to OPERABLE status within the reguired assGGoated 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 2 B 3.7-25 Revision 0, 29 Amend*mpnt ho. 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 3.7-26 Revision 0, 29 Amendment No. 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 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 or with one or more CREV subsystems inoperable due to an inoperable CRE boundary, 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.

(contfinued)

BFN-UNIT 2 B 3.7-27 Revision 0, 29 Am~endrment 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 3.7-28 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 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 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 consequences. When unfiltered air inleakage is greater than the assumed flow rate. Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for 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 compensatorv measures to restore OPERABILITY (Ref. 8). Options for restoring the CRE boundary to OPERABLE status include (continued)

BFN-UNIT 2 B 3.7-29 Amendment 255 November 30, 1998

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

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

(continueL)-

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

CREV System B 3.7.3 T-his SR verifies the integrity of the control room enclosure and the asumed iloakage rates of potentially ntaminated ai The control room positie pra.r, with respecot to- out-doors is period ically tested tovrfIpoe function) of the CREV~ System.

During the emergec- md of operation, the CRE=V System is6 designed to slightly pressurize the cntrmIl room Ž 0.125 inches water gauge porsitive pressure with respect to the outdoors to prevent unfiltereFPd inleakage. The CREV. System is designed to maritain this positive pessue at a flowFate of Ž 27-00 ,f+ ;and

"3300 cfm to the control room in the pressurization mode. The

....... 9 n) MG H6UILIt ORI a S

-r A -f 7Mr7AI

~xL F=FeqUeRGY Q IL con~sistent WitnM iar'practice ana otner nitation systems SR6-.

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.

7. NEI 99-03, "Control Room Habitability Assessment," June 2001.

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

BFN-UNIT 2 B 3.7-31 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 radioactivity ralogicaRlly controlled en..iro.....

fromn w.hicrh. the uit can be safely operated following a Design Basis 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 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 end 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 design basis accident (DBA) consequences to CRE occupants.

(continued)

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

CREV System B 3.7.3 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 centret

,G.M-Pe.SO.eI), the CREV System automatically switches to the pressurization mode of operation to minimize pie~ent infiltration of contaminated air into the CRE nnmtrc I-n-rm,-. A system of dampers isolates the CRE -entre- reo-.m 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 corntrol room (continued) eFenmffent a 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 centrel roee to about 0.125 inches water gauge to minimize pFeveRt infiltration of air from all surrounding areas adjacent to CRE boundary,,,,,,,*r, and the outdoors.

CREV System operation in maintaining CRE coiGr# oFom 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 GcntGI- reoom 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, loss of coolant acident, mnain steam line break, and controlrodopacen (for the conrol1 rod drop accident and- main steam line br~eak, no cnredit i3 taken for any filtration by the GRE" 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 CRE GGR#9e F-GGM.

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 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 actuation is required for hazardous chemical releases or smoke (continued)

BFN-UNIT 3 B 3.7-19 Revision 0, 29 January 25, 2005

CREV System B 3.7.3 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 Q, 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, assumn if 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 occupants GGR*Gt

.. .. +'-'-r in the event of a DBA.

The Each CREV-System subsystem is Considered OPERABLE when the individual components necessary to limit CRE occuDant ,Gn+,. vpefate-exposure are OPERABLE i-bet-h SubSyste*e. 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 addition, the control room bou-nday must be maintained including the integrity 'of the walls,, flomor, Gcelings, ducerk, and access doors6.

In order for the CREV subsystems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occurpant dose from a larae 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 analysis. Therefore, BFN has no specific limits on chemical hazards or smoke.

(continued)

BFN-UNIT 3 B 3.7-21 Revision 0, 29 Amed*ment No. 21 January 25, 2005

CREV System B 3.7.3 The LCO is modified by a Note allowing the CRE main e~ri From 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 operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE m-ain control room isolation is indicated.

(continued)

BFN-UNIT 3 B 3.7-22 Revision Q, 29 Amendment No. 2I11 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 ,G,,GI-,p...

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 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 144 rGoGm iatin protection function. However, the overall reliability is reduced because a sigle failure in the OPERABLE subsystem could result in a loss of the redUGed CREV System function-Gapablity. 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 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 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 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 Program 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 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 mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 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 period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that (continued)

BFN-UNIT 3 B 3.7-24 Revision Q, 29 AmenRdment No. 211-January 25, 2005

CREV System B 3.7.3 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 maiR control room boundary MODES 1, 2, and 3, the GREV trains, cannot perfor~m theirF intended functions.

Actio urgt+ be taken t*o u.s.... + an.

. erestore ER-A-BLE main control room boundary WAithin 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months . DuFrig the period that the mnain control roo boundaryis 1in mOMpensato rble, appropriate measures (consistent With the intent of GIDC 19) should be utilized to protect control room operator*s fromr potential hazards such as radioactiVe contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security.

Preplanned measures shoul-id be available to address ths oRnce*rn for intentiroal aRd unintentional entny in*o the onndtion. Th* :24 hnou Completion Time is reasonable based on the low probability of a DBA occurring duFrig this time period, vvmupmemvl R Timev is a tuypvvmirsal *llly l ,esva time te-dign vm~m

anmd thme u m21 Of compensato' measures. The hou plan and possibly repair, and test mot pmrblems with the main control room boundar9,.

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREV subsystem or the CRE control room boundar.y cannot be restored to OPERABLE status within the reguired 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 conditions in an orderly manner and without challenging unit systems.

(continued)

BFN-UNIT 3 B 3.7-25 Revision Q, 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 QO, 29 Amendmert hi. 241 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 bounda. y (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 or withi one or more CREV subsystems inoperable due to an inoperable CRE boundary, 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 AmendmeRnt No. 241 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 SIR 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 operating 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 Reguirements 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 consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for 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 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 3 B 3.7-29 Revision 0, 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 3 B 3.7-30 Revision 0, 29 January 25, 2005

CREV System 3.7.3 BASES SURVEILLANCE 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 SDR .erifies the integrity of the con.÷trol room enclosure an the* ass me iie nnpvuu.*emuntI kg Fatesnv Ofn QU aml v

cntaminRated air. The control room positive pressure,ith respec.t to outdoor is periodically tested to werify proper funcfTiorn oaf t GRE'.' ihe- System. Duing the em ergencY mod*

of operation, the GREV System is designed to slightly pmressuize the c-ontroGlm room Ž 0.125 inches water gauge positive pessuire wIth respect to the outdoors to prevent unfiltered

, The GRE" System is designed to maintaain this porsitive pressure at a flow rate of ->22700- cfm and !* 33900 c-fm to the control room in the pressuri-zation-1 moede. The FrFequency of 24 monOths, on a'STAGGERED TFEST BRASIS iscnitn vihids practiceA and- other filtration systems SRs.f 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.

(continued)

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

CREV System 3.7.3

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

(continued)

BFN-UNIT 3 3.7-32 Revision G, 29 January 25, 2005

CREV System 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 (continued)

BFN-UNIT 3 3.7-33 Revision 0, 29 January 25, 2005

ML091200062

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7.3 REFERENCES

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7.3 REFERENCES

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