L-PI-09-076, License Amendment Request (LAR) to Revise Technical Specifications in Accordance with TSTF-448, Revision 3 - Control Room Habitability

License Amendment Request (LAR) to Revise Technical Specifications in Accordance with TSTF-448, Revision 3 - Control Room Habitability

ML091760988
Person / Time
Site:	Prairie Island
Issue date:	06/24/2009
From:	Wadley M Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-09-076, TSTF-448, Rev 3
Download: ML091760988 (36)

Text

JUN 2 4 2009 L-PI-09-076 10 CFR 50.90 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 License Amendment Recluest (LAR) to Revise Technical Specifications in Accordance with TSTF-448, Revision 3 - Control Room Habitability

References:

1) Nuclear Management Company, LLC (NMC) Letter to US Nuclear Regulatory Commission (NRC), Response to Generic Letter 2003-01 : Control Room Habitability, dated December 9, 2003 (ADAMS Accession Number ML033500298)

2) NRC to NMC letter - NRC Receipt of Response to Generic Letter 2003-01 "Control Room Habitability", dated January 26, 2007 (ADAMS Accession Number ML070090514)

3) NRC Issuance of CLllP for TSTF-448, Rev.3, dated January 17, 2007

4) NMC Letter to NRC, "Supplemental Response to Generic Letter 2003-01, Control Room Habitability", dated December 18, 2006 (ADAMS Accession Number ML063520545)

5) NMC Letter to NRC, "Generic Letter 2003-01, Control Room Habitability -

Commitment Change", dated April 30, 2008 (ADAMS Accession Number ML081220704)

Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota corporation (NSPM'), doing business as Xcel Energy, hereby requests an amendment to the Technical Specifications (TS) for Prairie Island Nuclear Generating Plant (PINGP).

' On September 22, 2008, NMC transferred its operating license authority to NSMP, doing business as Xcel Energy. By letter dated September 3, 2008, NSPM assumed responsibility for actions and commitments previously submitted by NMC.

1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1121

Document Control Desk Page 2 The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with Technical Specification Task Force traveler (TSTF)-448, Revision 3, "Control Room Habitability." The availability of this TS improvement was published in the Federal Register on January 17, 2007, as part of the Consolidated Line Item Improvement Process (CLIIP).

In addition, the proposed amendment incorporates two corrections. These corrections were discussed between the NRC and the TSTF in past interactions. These corrections were also recently identified in TSTF-508, "Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation," Revision 0.

The enclosure to this letter contains the licensee's evaluation of the proposed changes.

NSPM requests approval of this LAR within one calendar year of the submittal date. Upon NRC approval, NSPM requests 180 days to implement the associated changes. In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of the LAR by transmitting a copy of this letter and enclosure to the designated State Official.

If there are any questions or if additional information is needed, please contact Mr Dale Vincent, P.E., at 651-388-1 121.

Summarv of Commitments This submittal does not contain any new commitments and no revisions to existing commitments.

This license amendment request satisfies a commitment made in NMC correspondence to the NRC (L-PI-03-114) dated December 9, 2003, "Response to Generic Letter 2003-01, Control Room Habitability". The revised commitment date for this submittal is contained in Reference 6.

I declare under penalty of Executed on JUN 2 4 2 If4jury that the foregoing is true and correct.

Michael D. Wadley 'J Site Vice President, Prairie Island Nuclear Generating Plant Units 1 and 2 Northern States Power Company - Minnesota

Enclosure:

Evaluation of Proposed Changes cc: Administrator, Region Ill, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota

ENCLOSURE Evaluation of the Proposed Changes License Amendment Reauest (LAR) to Revise Technical S~ecificationsin Accordance with TSTF-448, Revision 3 - Control Room Habitabilitv

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL EVALUATION ATTACHMENTS:

1. Technical Specification Pages (Markup)

2. Bases Pages (Markup) (For information only)

3. Technical Specification Pages (Retyped)

Page 1 of 6

Enclosure NSPM TSTF-448 - Control Room Habitability

1.0 DESCRIPTION

The proposed amendment would modify technical specification (TS) requirements related to control room habitability in TS 3.7.10, "Control Room Special Ventilation System," and TS Section 5.5.16, "Programs and Manuals."

The changes are consistent with Nuclear Regulatory Commission (NRC) approved IndustryITechnical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-448, Revision 3, "Control Room Habitability." The availability of this TS improvement was published in the Federal Register on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process (CLIIP).

In addition, the proposed amendment incorporates two corrections. These corrections were discussed between the NRC and the TSTF in past interactions. These corrections were also recently identified in TSTF-508, "Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation," Revision 0.

2.0 ASSESSMENT 2.1 Applicability of Published Safetv Evaluation Northern States Power Company, a Minnesota Corporation (NSPM), doing business as Xcel Energy, has reviewed the safety evaluation (SE) 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, Rev. 3. NSPM has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Prairie Island Nuclear Generating Plant (PINGP) Unit 1 and Unit 2, and justify this amendment for the incorporation of the changes to the PINGP Units 1 and 2 TS.

2.2 Optional Chanqes and Variations NSPM is not proposing any significant variations or deviations from the TS changes described in the TSTF-448, Rev. 3, or the applicable parts of the NRC staffs model safety evaluation dated January 17, 2007. Regarding Section 3.0 of the model safety evaluation, it has been determined that Evaluations 1, 4 and 6 are applicable for the PINGP Unit 1 and Unit 2, with a clarification on Evaluation 6 described below.

Evaluation 6 in the model SE addresses relocation of the pressurization test of the overall Control Room Envelope (CRE) from a Surveillance Requirement (SR) into the CRE Habitability Program (as sub-item d), and replacement of the CRE pressurization SR with an in-leakage SR. The PINGP control room is a neutral-pressure design and does not become pressurized following a design basis accident (DBA). Therefore, NSPM does not propose to add a CRE pressurization Surveillance Requirement which requires verification that the system can maintain a positive pressure. The pressure test Page 2 of 6

Enclosure NSPM TSTF-448 - Control Room Habitability is not presently included in the PlNGP Technical Specifications surveillances.

In lieu of the pressure test included in TSTF-448, NSPM proposes a PlNGP SR that will require a leakage test of outside air intake and boundary exhaust dampers. This damper leakage SR would be included in the CRE Habitability Program as 5.5.16, sub-item (d). The addition of this SR, which will require the damper test to be performed at least once per operating cycle, is considered to be enveloped by Evaluation 6 because of the similarity in the action being taken.

Since the damper leakage test described above is not sufficient on its own to ensure ongoing OPERABILITY of the overall CRE, the CRE Habitability Program TS, proposed TS 5.5.16, sub-item (c), requires that the program include requirements for determining the unfiltered air in-leakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C . l and C.2 of Regulatory Guide 1. I 97, Revision 0. This guidance references ASTM E741 as an acceptable method for ascertaining the unfiltered leakage into the CRE. This action is also considered to be enveloped by Evaluation 6 because of the similarity in the action being taken. In addition, the acceptability of performing the damper leakage test in lieu of the CR pressure test was discussed with NRC staff during a conference call held on March 26, 2008. Sub-item (f) of the CRE Habitability Program is also revised to be consistent with the wording of sub-item (d).

To account for PlNGP specific control room habitability design and current licensing basis, the following adjustments have been incorporated into the proposed TS markups:

I.In response to GL 2003-01, dated December 9, 2003 (ADAMS Accession Number ML033500298), PlNGP provided the NRC information regarding the licensing basis for the PlNGP CR including details regarding the assumptions and basis for hazardous chemicals and smoke events effects to CR personnel. As described in the response, PlNGP licensing basis does not assume limiting CR unfiltered in-leakage during these events.

Additionally, the current CR design does not have automatic actuation systems required during these events. The actions described in the above referenced letter are manual actions by CR personnel including training and procedures on how to cope with these events. Therefore, the last sentence in the CRE Habitability Program, proposed TS 5.5.16, (e), "...Unfiltered air in-leakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions of the licensing basis," is omitted to be consistent with the PlNGP licensing basis.

2. NSPM does not include "Mode 5 and 6" in TS 3.7.10, Required Action E, as the PlNGP TS 3.7.10 is not applicable in Mode 5 and 6.

3. During development of Revision 3 to TSTF-448, an agreement was reached with the NRC that smoke requirements were qualitative rather than quantitative, and the concept of smoke limits was therefore deleted from Section 5.5 of the Control Room Habitability Program, sub-item (e). In the Page 3 of 6

Enclosure NSPM TSTF-448 - Control Room Habitability NRC meeting minutes that agreed to this change to Section 5.5 (ADAMS Accession Number ML061310293, page 2 of minutes dated May 12,2006), it was noted that this was acceptable because general qualitative requirements for protecting CRE occupants from smoke challenges are retained in the first paragraph of the proposed Administrative Controls Control Room Envelope Habitability Program, along with licensing basis discussion in the "Applicable Safety Analyses" section of the Bases. Together these adequately address the licensing basis requirements for protecting CRE occupants from smoke.

To be consistent with this concept, Required Action 8.2 is being revised to refer to limits for radiological hazards, but does not include a reference to limits for smoke. The proposed wording in Required Action B.2 with respect to smoke is consistent with the words used in Evaluation No. 1 of the NRC model safety evaluation; and with the words in the Bases for Required Action B.2.

The explicit reference to limits on chemical hazards has also been removed from Required Action B.2. The proposed wording of Required Action B.2 with respect to chemicals is consistent with the words used in Evaluation No.

1 of the NRC model safety evaluation; and with the words in the Bases for Required Action 8.2.

In addition, these changes are consistent with the industry proposed changes indentified in TSTF-508, which is currently under NRC staff review.

4. In order to be consistent with sub-item (c) of the Control Room Envelope Habitability Program, the last sentence of sub-item (d) is revised to use the term "periodic" in lieu of the bracketed phrase "18 month." The model TS indicates that periodic CRE relative pressure measurements shall "be trended and used as part of the [ I 8 month] assessment of the CRE boundary." However, the only periodic assessment required by the TSTF-448 model TS occurs at intervals specified in Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Section C. 1, as specified by sub-item (c). This assessment is normally performed every 36 months, but the 36 month frequency appears only in the RG and does not appear in the TS. Therefore, to be consistent with the remainder of the program, the bracketed phrase " [ I 8 months]" is replaced with the word "periodic." This substitution resolves the inconsistency in a manner consistent with the published regulatory guidance.

In addition, these changes are consistent with the industry proposed changes indentified in TSTF-508, which is currently under NRC staff review.

5. Section 2.3 proposes a License Condition specifying the schedule for the initial performance of new surveillance and assessment requirements.

Consistent with a NRC memorandum dated February 2, 2007 (ADAMS Accession Number ML070330657), the 15 month periods described in model Page 4 of 6

Enclosure NSPM TSTF-448 - Control Room Habitability License Condition sub-item (a) are corrected to be 18 months (25% of six years).

Also, Section 2.3, sub-item (c) is revised to include the appropriate references to the 18-month damper test, in lieu of the 18-month pressure test.

6. TS bases changes deviate from the TSTF-448, Rev. 3, standard changes due to license basis differences.

The changes noted above are to account for PlNGP specific control room habitability design and current licensing basis, or the changes improve the usability and quality of the presentation of the TS. These changes have no impact on safety, and therefore, are acceptable.

In addition, the changes noted above in regard to a pressure-neutral control room, and changes 3, 4 and 5, are consistent with the following precedent: First Energy Nuclear Operating Company, Perry Nuclear Plant, LAR dated September 18, 2007 (ADAMS Accession Number ML072680852). The NRC approved this LAR precedent on April 25, 2008 (ADAMS Accession Number ML080310794).

2.3 License Condition Reqardinq Initial Performance of New Surveillance and Assessment Requirements NSPM proposes the following as a license condition to support implementation of the proposed TS changes.

Upon implementation of Amendment No. adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air in-leakage as required by SR 3.7.10.5, in accordance with TS 5.5.16.c(i), and the assessment of CRE habitability as required by Specifications 5.5.16.c(ii), shall be considered met. Following implementation:

(a) The first performance of SR 3.7.10.5, in accordance with Specifications 5.5.16.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 3, 2004, the date of the most recent successful tracer gas test, as stated in the December 18, 2006 letter response to Generic Letter 2003-01, 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, Specifications 5.5.16.c (ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from December 3, 2004, the date of the most recent successful tracer gas test, as stated in the December 18, 2006 letter response to Generic Letter 2003-01, or within the next 9 months if the time Page 5 of 6

Enclosure NSPM TSTF-448 - Control Room Habitability period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of outside air intake and boundary exhaust damper leakage, Specification 5.5.16.d, shall be within 18 months, plus the 135 days allowed by SR 3.0.2, as measured from the date of the most recent successful damper leakage test, or within 135 days if not performed previously.

3.0 REGULATORY ANALYSIS

3.1 No Siqnificant Hazards Consideration Determination NSPM has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register on January 17, 2007 (72 FR 2022) as part of the CLIIP. NSPM has concluded that the proposed NSHCD presented in the Federal Register notice (72 FR 2022) is applicable to PlNGP Units 1 and 2, and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

4.0 ENVIRONMENTAL EVALUATION NSPM has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007 as part of the CLIIP. NSPM has concluded that the staff's findings presented in that evaluation are applicable to PlNGP Units 1 and 2, and the evaluation is hereby incorporated by reference for this application.

Page 6 of 6

ATTACHMENT 1 to ENCLOSURE Technical Specification Pages (Markup) 7 pages follow

CRSVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Special Ventilation System (CRSVS)

LC0 3.7.10 Two CRSVS trains shall be OPERABLE.

.................................... NOTE ...................................

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

APPLICABILm MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies.

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

other than Condition B.

Prairie Island Unit 1 - Amendment No. 448 Units 1 and 2 3.7.10-1 Unit 2 - Amendment No. 4 4

CRSVS 3.7.10 ACTIONS (continued)

B. *One CONDITION or more CRSVS trains inoperable due to inoperable CRE

-boundary in B.l -

REQUIRED ACTION Y

sk%sInitiate action to implement mitigating COMPLETION TIME MODES 1,2, 3, or 4. actions.

AND B.2 Verifv mitigating, actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant radiological exposures will not exceed limits, and CRE occupants are protected from chemical and smoke hazards.

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

C. Required Action and C.l BeinMODE3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 BeinMODE5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Prairie Island Unit 1 - Amendment No. 43%

Units 1 and 2 3.7.10-2 Unit 2 - Amendment No. W

CRSVS 3.7.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D. 1 Place OPERABLE CRSVS Immediately associated Completion train in operation.

Time of Condition A not met during movement of irradiated fuel assemblies.

D.2 Suspend movement of Immediately irradiated fuel assemblies.

E. Two CRSVS trains E. 1 Suspend movement of Immediately inoperable during irradiated he1 assemblies.

movement of irradiated fuel assemblies.

One or more CRSVS trains inoperable due to an inoperable CRE boundan, during movement of irradiated fuel assemblies.

F. Two CRSVS trains F.l Enter L C 0 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

Prairie Island Unit I - Amendment No. 4-58 44%

Units 1 and 2 3.7.10-3 Unit 2 - Amendment No. 449 4%

CRSVS 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRSVS train > 15 minutes. 3 1 days SR 3.7.10.2 Perform required CRSVS filter testing in In accordance accordance with the Ventilation Filter Testing with VFTP Program (VFTP).

SR 3.7.10.3 Verify each CRSVS train actuates on an actual or 24 months simulated actuation signal.

SR 3.7.10.4 Verify each CRSVS train in the Emergency Mode 24 months on a delivers 3600 to 4400 cfm through the associated STAGGERED CRSVS filters. TEST BASIS SR 3.7.10.5 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Habitability Program Prairie Island Unit 1 - Amendment No. MS 188 Units 1 and 2 3.7.10-4 Unit 2 - Amendment No. 449 470

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

d. Leakage Rate acceptance criteria are:

1. Primary containment leakage rate acceptance criterion is < 1.0 La.

Prior to unit startup, following testing in accordance with the program, the combined leakage rate acceptance criteria are 5 0.60 La for all components subject to Type B and Type C tests and

< 0.75 La for Type A tests.

2. Air lock testing acceptance criteria are:

a) Overall air lock leakage rate is < 0.05 La when tested at 2 46 psig.

b) For each door intergasket test, leakage rate is 5 0.01 La when pressurized to > 10 psig.

e. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

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

Battery Monitoring and Maintenance Program -

This Program provides for restoration and maintenance of the 125V plant safeguards batteries and service building batteries, which may be used instead of the safeguards batteries during shutdown conditions in accordance with manufacturer's recommendations, as follows:

a. Actions to restore battery cells with float voltage < 2.13 V will be in accordance with manufacturer's recommendations, and

b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

Prairie Island Unit 1 - Amendment No. 44% 4-65 1 Units 1 and 2 5.O-29 Unit 2 - Amendment No. 4-49

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.16 Control Room 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 Special Ventilation System (CRSVS),

CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving- radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body, or 5 rem total effective dose equivalent JTEDE), as applicable, for the duration of the accident. The program shall include the following elements:

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

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

c. Requirements for (i) determining the unfiltered air in-leakage 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 of leakage through the outside air intake and boundary exhaust dampers at a Frequency of 18 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

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

The unfiltered air in-leakage limit for radiological challenges is the in-leakage flow rate assumed in the licensing basis analysis of DBA consequences.

Prairie Island Unit 1 - Amendment No. 44-84-77 Units 1 and 2 5.0-30 Unit 2 - Amendment No. 4-49 4-67

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 Control Room Habitability Program (continued)

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing- CRE habitability, determining CRE unfiltered in-leakage, and measuring- outside air intake and boundary exhaust damper leakage and assessing the CRE boundary as required by paragraphs c and d, respectively.

Prairie Island Unit 1 - Amendment No. 4% 477 Units 1 and 2 5.0-3 1 Unit 2 - Amendment No. 4-49 4-67

ATTACHMENT 2 to ENCLOSURE Bases Pages (Markup)

(For Information Only) 11 pages follow

CRSVS B 3.7.10 B 3.7 PLANT SYSTEMS B 3.7.10 Control Room Special Ventilation System (CRSVS)

BASES BACKGROUND The CRSVS provides a protected environment from which epemkws occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals or smoke.

The CRSVS consists of two independent, redundant trains that recirculate and filter the control room &envelope (CRE): and a CRE boundary that limits the inleakage of unfiltered air. Each CRSVS train consists of an air handling unit, a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a cleanup fan.

Ductwork, valves or dampers, and instrumentation also form part of the system.

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 non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

The CRSVS is an emergency system, parts of which may also operate during normal unit operation.

Prairie Island Unit 1 - Revision 44%

Units 1 and 2 Unit 2 - Revision 44%

CRSVS B 3.7.10 BASES BACKGROUND Upon receipt of the actuating signal(s), normal air supply to the (continued) CRE- is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilters remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal adsorbers.

Actuation of the CRSVS is initiated by:

a. High radiation in the control room ventilation duct; or

b. Safety injection signal.

Actuation of the system closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the e m t w h e m a i r within the CRE through the redundant trains of HEPA and the charcoal filters. The operating condition initiates filtered ventilation of the air supply to the CREemtmhmm.

The CRSVS operation is discussed in the USAR (Ref. 1).

Redundant supply and recirculation trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally open isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The CRSVS is designed in accordance with Seismic Category I requirements.

The CRSVS is designed to maintain a habitable environment in the CRE C f o r 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding i+5 rem whole body dose or its equivalent to any part of the body or 5 rem total effective dose equivalent (TEDE), as a p p l i c a b l e ~

Prairie Island Unit 1 - Revision 478 Units 1 and 2 B 3.7.10-2 Unit 2 - Revision 44%

CRSVS B 3.7.10 BASES (continued)

APPLICABLE The CRSVS components are arranged in redundant, safety related SAFETY ventilation trains. The location of components and ducting within ANALYSES the C-RE ensures an adequate supply of filtered air to all areas requiring access. The CRSVS provides airborne radiological protection for the C -RE occupants, as demonstrated by the C -RE occupant dose analyses for the most limiting design basis less-&

eedas&accident fission product release presented in the USAR (Ref. 2). The CRSVS function also plays a significant role in protecting CRE -.+-.p'ersonnel during a fuel handling accident in the spent fuel pool enclosure or the containment,affaa (Ref. 2).

The worst case single active failure of a component of the CRSVS does not impair the ability of the system to perform its design function.

The CRSVS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

This L C 0 applies to single or dual unit operation since there is a single CRSVS for both units.

Two independent and redundant CRSVS trains are required to be OPERABLE to ensure that at least one is available m i f a single active failure disables the other train. Total system failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem whole body or its equivalent to any part of the body or 5 rem TEDE, as applicable, 5 rc~rm.+(Ref.

3) to the CRE occupants -during the worst 4 week exposure following a postulated accident.

%Each CRSVS train is considered OPERABLE when the individual components necessary to limit qiwaksCRE occupant exposure are OPERABLE4i&M&mk. A CRSVS train is OPERABLE when the associated:

Prairie Island Unit 1 - Revision 478 Units 1 and 2 B 3.7.10-3 Unit 2 - Revision 444

CRSVS B 3.7.10 BASES LC0 a. Cleanup fan is OPERABLE; (continued)

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

c. Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained; I

d. Instrumentation, including associated radiation monitor for starting the cleanup fan, is OPERABLE, or the system is aligned to perform its safety function and is operating; and I

e. Air Handling Unit is OPERABLE. 1 In order for the CRSVS trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

Opening a door for personnel ingress or egress does not make the m C R E boundary inoperable. Blocking a door open (e.g., for maintenance) without a person present to close the door requires entry into an ACTION.

The L C 0 is modified by a Note allowing the a C R E boundary to be opened intermittently under administrative controls.

The 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 Prairie Island Unit 1 - Revision 4-78 Units 1 and 2 B 3.7.10-4 Unit 2 - Revision 4-78

CRSVS B 3.7.10 BASES LC0 individual at the opening who is in continuous communication with (continued) 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- isolation is indicated.

APPLICABILITY In MODES 1,2, 3, and 4 for either unit, CRSVS must be OPERABLE to ensure that the CRE will remain habitable ex+t~~A

-during and following a DBA.

In addition, during movement of irradiated fuel assemblies, the CRSVS must be OPERABLE to cope with the release from a fuel handling accident.

When one CRSVS train is inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 7 days.

In this Condition, the remaining OPERABLE CRSVS train is adequate to perform the CRE occupant ee&mbmmprotection function. However, the overall redundancy is reduced because only a single CRSVS train remains OPERABLE.

The 7 day Completion Time is based on the low probability of a DBA or fuel handling accident occurring during this time period, and ability of the remaining train to provide the required capability.

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CRSVS B 3.7.10 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 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 5 rem TEDE, as applicable), 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 mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e.

actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless

- of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring- during this time period, and the use of mitigating

- actions. The 90 day Completion Time is Prairie Island Unit 1 - -Revision 448 Units 1 and 2 B 3.7.10-6 Unit 2 - -Revision 449

CRSVS B 3.7.10 BASES ACTIONS B.l, B.2, and B.3 (continued) reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants- within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

C.l and C.2 In MODE 1 , 2 , 3 , or 4, if the inoperable CRSVS train or the CRE em&&wemboundary cannot be restored to OPERABLE status within the required Completion Time, both units must be placed in a MODE that minimizes accident risk. To achieve this status, the units must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.l and D.2 If the inoperable CRSVS train cannot be restored to OPERABILE status within the required Completion Time, Required Action D. 1 must be taken to immediately place the OPERABLE CRSVS train in operation. This is a reasonable action, based on engineering judgement, to assure the CRE -.a'ir is filtered in the event of an accident.

An alternative to Required Action D. 1 is to immediately suspend activities that could result in a release of radioactivity that might Prairie Island Unit 1 - -Revision 44-8 Units 1 and 2 B 3.7.10-7 Unit 2 - V R e v i s i o n 149

CRSVS B 3.7.10 BASES ACTIONS D. 1 and D.2 (continued) require isolation of the CREee&d+mm. Required Action D.2 places the plant in a condition that minimizes the accident risk. This does not preclude the movement of he1 to a safe position.

If two CRSVS trains are inoperable or with one or more CRSVS trains inoperable due to an inoperable CRE boundary during movement of irradiated fuel assemblies, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE-M.

This places the plant in a condition that minimizes theaccident risk.

This does not preclude the movement of fuel to a safe position.

If both CRSVS trains are inoperable in MODE 1, 2, 3, or 4, for reasons other than inoperable CRE ..--+r,lboundary (i.e., Condition B) the CRSVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, L C 0 3.0.3 must be entered immediately for both units.

SURVEILLANCE SR3.7.10.1 RFJQ-Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. Each train must be operated for 215 minutes to demonstrate the system functions. The 3 1 day Frequency is based on the reliability of the equipment and the two train redundancy+waiMw&.

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Units 1 and 2 B 3.7.10-8 Unit 2 - -Revision 149

CRSVS B 3.7.10 BASES SURVElLLANCE SR3.7.10.2 REQ-(continued) This SR verifies that the required CRSVS filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.

The CRSVS may be actuated by either a safety injection signal or a high radiation signal. This SR verifies that each CRSVS train starts and operates on an actual or simulated safety injection actuation signal and verifies each CRSVS train starts and operates on an actual or simulated high radiation signal. The Frequency of 24 months allows performance when a unit is shutdown.

This SR verifies proper functioning of the CRSVS in the Emergency Mode (Ref. I). During operation, in the Emergency Mode, the CRSVS train is designed to provide 4000 2 10% cfm through the PAC filter unit.

The Frequency of 24 months on a STAGGERED TEST BASIS is consistent with industry component reliability experience.

This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air in-leakage 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 than 5 rem whole body or its equivalent to any part of the body or 5 rem TEDE, as applicable, and the CRE occupants are protected from hazardous Prairie Island Unit 1 - Revision 478 Units 1 and 2 Unit 2 - Revision 47%

CRSVS B 3.7.10 BASES SURVEILLANCE SR 3.7.10.5 (continued)

REQ-chemicals and smoke. This SR verifies that the unfiltered air in-leakage

- into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air in-leakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 4) which endorses, with exceptions, NEI 99-03, Section 8.4 and BASES Appendix F (Reference 5).

These cornpensatow 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. 6). 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 in-leakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

REFERENCES 1. USAR, Section 10.3.

2. USAR, Section 14.9.

3. 10 CFR 50 Appendix A, GDC Criterion 19.

4. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," dated January 2007.

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

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[Jnits 1 and 2 B 3.7.10-10 Unit 2 - Revision 4-78

CRSVS B 3.7.10 BASES REFERENCES 6. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated (continued) January 30,2004, "NEI Draft White Paper, Use of Generic Letter 9 1- 18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

Prairie Island Unit 1 - Revision 4-78 Units 1 and 2 Unit 2 - Revision 44%

ATTACHMENT 3 to ENCLOSURE Technical Specification Pages (Retyped) 7 pages follow

CRSVS 3.7.10 2.7 PLANT SYSTEMS 3.7.10 Control Room Special Ventilation System (CRSVS) 1,C'O 3.7.10 Two CRSVS trains shall be OPERABLE.

---

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

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

I~PPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies.

AC'TIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRSVS train A. 1 Restore CRSVS train to 7 days inoperable for reasons OPERABLE status.

other than Condition B.

Prairie Island Unit 1 - Amendment No. 438 IJnits 1 and 2 3.7.10-1 Unit 2 - Amendment No. 4-49

CRSVS 3.7.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

13. One or more CRSVS B. 1 Initiate action to Immediately trains inoperable due to implement mitigating inoperable CRE boundary actions.

in MODES l , 2 , 3, or 4.

AND B.2 Verify mitigating actions ensure CRE occupant 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> radiological exposures will not exceed limits, and CRE occupants are protected from chemical and smoke hazards.

AND B.3. Restore CRE boundary to OPERABLE status. 90 days C'. Required Action and C.l BeinMODE3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Prairie Island Unit 1 - Amendment No. 458 Ilnits 1 and 2 3.7.10-2 Unit 2 - Amendment No. 449

CRSVS 3.7.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

11. Required Action and D. 1 Place OPERABLE CRSVS Immediately associated Completion train in operation.

Time of Condition A not met during movement of irradiated fuel assemblies.

D.2 Suspend movement of Immediately irradiated fuel assemblies.

I?. Two CRSVS trains E. 1 Suspend movement of Immediately inoperable during irradiated fuel assemblies.

movement of irradiated fuel assemblies.

One or more CRSVS trains inoperable due to an inoperable CRE boundary during movement of irradiated fuel assemblies.

I.. Two CRSVS trains F. 1 Enter L C 0 3.0.3. Immediately inoperable in MODE 1, 2,

3. or 4 for reasons other than Condition B.

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CRSVS 3.7.10 SURVEILLANCE REOUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRSVS train 2 15 minutes. 3 1 days SIX 3.7.10.2 Perform required CRSVS filter testing in In accordance accordance with the Ventilation Filter Testing with VFTP Program (VFTP).

SII 3.7.10.3 Verify each CRSVS train actuates on an actual or 24 months simulated actuation signal.

SR 3.7.10.4 Verify each CRSVS train in the Emergency Mode 24 months on a delivers 3600 to 4400 cfm through the associated STAGGERED CRSVS filters. TEST BASIS SR 3.7.10.5 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Habitability Program I

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Programs and Manuals 5.5 5.5 Programs and Manuals

-5. d5. 14 Containment Leakage Rate Testing Program (continued)

d. Leakage Rate acceptance criteria are:

1. Primary containment leakage rate acceptance criterion is 1.0 La.

Prior to unit startup, following testing in accordance with the program, the combined leakage rate acceptance criteria are 5 0.60 La for all components subject to Type B and Type C tests and

-< 0.75 La for Type A tests.

2. Air lock testing acceptance criteria are:

a) Overall air lock leakage rate is 1 0 . 0 5 La when tested at > 46 psig.

b) For each door intergasket test, leakage rate is ( 0.01 La when pressurized to 2 10 psig.

e. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

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

5.5.15 Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance of the 125V plant safeguards batteries and service building batteries, which may be used instead of the safeguards batteries during shutdown conditions in accordance with manufacturer's recommendations, as follows:

a. Actions to restore battery cells with float voltage < 2.13 V will be in accordance with manufacturer's recommendations, and

b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

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Programs and Manuals 5.5 5.5 Programs and Manuals (continued) I 5.5.16 Control Room 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 Special Ventilation System (CRSVS),

CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body, or 5 rem total effective dose equivalent (TEDE), as applicable, for the duration of the accident. The program shall include the following elements:

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

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

c. Requirements for (i) determining the unfiltered air in-leakage 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 of leakage through the outside air intake and boundary exhaust dampers at a Frequency of 18 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

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

The unfiltered air in-leakage limit for radiological challenges is the in-leakage flow rate assumed in the licensing basis analysis of DBA consequences.

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Programs and Manuals 5.5 5.5 Programs and Manuals I

5.5.16 Control Room Habitability Program (continued) I

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered in-leakage, and measuring outside air intake and boundary exhaust damper leakage and assessing the CRE boundary as required by paragraphs c and d, respectively.

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