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Proposed Tech Specs Submitting TS Change Request 208 to Establish New TS Limiting Condition for Operation Applicable to Control Complex Habitability Envelope Allowing Breaches to Exist
	ML20117G661
Person / Time
Site:	Crystal River
Issue date:	08/28/1996
From:	; FLORIDA POWER CORP.
To:	;
Shared Package
ML20117G655	List: 3F0896-18, Application for Amend to License DPR-72,by Submitting TS Change Request 208 Wich Proposes to Establish New TS LCO Applicable to Control Complex Habitability Envelope Allowing Breaches to Exist; ML20117G661;
References
	NUDOCS 9609050276
	Download: ML20117G661 (9)
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, i CCHE i

3.7.18 1

l 3.7 PLANT SYSTEMS j

3.7.18 . Control Complex Habitability Envelope (CCHE) i

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i LC0 3.7.18 The CCHE shall be OPERABLE by restricting breaches to within '

limits.

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P APPLICABILITY: MODES 1, 2, 3, and 4, ;

. During movement of irradiated fuel assemblies. ,

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! ACTIONS i j _........_____.......................N0TE------------------------------------- !

i 1 Personnel and equipment passage through the CCHE is permissible on a !

continuous basis provided doors are closed immediately following passage.

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r CONDITION REQUIRED ACTION COMPLETION TIME i

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. A. Control Complex _

A.1 Restore CCHE 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

Habitability Envelope boundary. [

(CCHE) breached ~1n !

excess of limits. Og l

A.2.1 Establish capability 1 Hour !

to close or seal the '

breach. !

a. AND A.2.2 Restore CCHE 24 Hours boundary.

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l 1 B. Required Action and B.1 Enter LC0 3.0.3. Immediately associated Completion Time of Condition A not met in MODE 1, 2, 3 or 4.

(Continued) l 1

Crystal River Unit 3 3.7- Amendment No.

96o9050276 960028 2 s eDR ADOCK 0500

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$ CCHE 3.7.18 0

i - ACTIONS-(Continued)

. . l CONDITION ~ REQUIRED ACTION COMPLETION TIME !

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C. Required Action and C.1 Suspend movement of Immediately 1 associated Completion irradiated fuel j Time of Condition A assemblies.

i not met in MODE 5 or 6 during movement of I irradiated fuel 2

assemblies.

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i-i 1 . i Crystal River Unit 3 3.7- Amendment No.

CCHE 3.7.18 SURVEILLANCE REQUIREMENTS l l

SURVEILLANCE FREQUENCY i i

SR 3.7.18.1 Verify CCHE door seals are in good 31 Days condition with no missing, loose, or damaged parts.

SR 3.7.18.2 Verify CCHE floor drain loop seals are 31 Days filled with water.

SR 3.7.18.3 Verify the CCHE/CREVS isolation dampers are 24 Months

, 'in good condition with no missing, loose, or damaged parts'.

SR 3.7.18.4 Verify the CCHE penetrations are sealed. 24 Months l

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l Crystal River Unit 3 3.7- Amendment No.

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l CCHE I B 3.7.18 B 3.7 PLANT SYSTEMS B 3.7.18 Control Complex Habitability Envelope (CCHE)

BASES BACKGROUND The Control Complex Habitability Envelope (CCHE) is the space within the Control Complex served by the Control Room l Emorgency Ventilation System (CREVS). This includes Control l Complex floor elevations from 108 through 180 feet and the j stair enclosure from elevation 95 to 198 feet. The elements i which comprise the CCHE are walls, doors, a roof, floors, floor drains, penetration seals, and ventilation isolation dampers. Together the CCHE and CREVS provide an enclosed environment from which the plant can be operated following an uncontrolled release of radioactivity or toxic gas.

The CCHE design is based on outside air in-leakage of greater than or equal to 6% of the enclosed CCHE volume per hour. The

, calculations for operator dose allow in-leakage to the CCHE of 355 cubic feet per minute (cfm) (Ref.1). A certain amount of 1 this total is attributed to specific elements of the CCHE i boundary such as ventilation isolation dampers and doors.

There is al so an amount of leakage attributed to

' unidentified' leakage paths that may exist, such as open penetration seals, or compromised door or damper sealing ,

surfaces. )

Design calculations allow a finite area of ' unidentified' I leakage paths or breaches (Ref. 2). Breaches in excess of the !

calculated area requires entry into CONDITION A of LC0 3.7.18. '

Routine opening and closing of CCHE doors for personnel passage and the movement of equipment is accounted for in the design calculations. A continuous leakage of 10 cubic feet per minute is assumed to account for this. Holding doors open for short periods of time to allow passage of personnel or material does not constitute a breach of the CCHE as long as the doors can be closed immediately upon notification of a radiological or toxic gas release.

(continued)

Crystal River Unit 3 B 3.7- Revision No. O

'. CCHE B 3.7.18 BASES APPLICABLE During emergency operations the design basis of the CCHE SAFETY ANALYSIS is to provide radiation protection to the control room )

operators. The limiting accident which may threaten the habitability of the control room (i.e., accidents resulting in release of airborne radioactivity) is the postulated design basis loss of coolant accident (LOCA), which is assumed to occur while in MODE 1. The consequences of this event in MODE 1 envelope the results for MODES 2, 3, and 4, and results in the limiting radiological source term for the control room habitability evaluation (Ref.1). A fuel handling accident (FHA) may also result in a challenge to control room habitability, and may occur in any MODE, including the defueled condition, during the movement of irradiated fuel.

However, due to the severity of the design basis LOCA and the MODES in which the postulated accident can occur, the FHA is the limiting accident only 'in MODES 5 and 6, and when defueled. The CCHE together with the CREVS ensures that the control room will remain habitable following all postulated design basis events, maintaining exposures to control room operators within the limits of GDC 19 of 10 CFR 50 Appendix A l (Ref. 3). i l

The CCHE integrity is not in the primary success path for any '

accident analysis. This specification is established to provide limited periods for breaches to exist and is supported by safety assessments which demonstrate that there will be no significant decrease in safety as a result of allowing ;

breaches to exist for limited and controlled periods of time.

l LCO The CCHE is a single train system consisting of walls, doors, !

a roof, floors, penetration seals, and ventilation isolation i dampers. Breaches in the CCHE in excess of allowed I

' unidentified' leakage pathway sizes as specified in approved design calculations must be controlled to provide assurance that radiation dose to control room operators remains within limits in the unlikely event of an accident. The CCHE also

, limits the control room concentration that may result from an

[ onsite toxic gas release.

(continued)

Crystal River Unit 3 B 3.7- Revision No. 0

CCHE B 3.7.18 BASES l

l APPLICABILITY In MODES 1, 2, 3, and 4, the CCHE must be OPERABLE to ensure '

that the Control Complex will remain habitable during and following a postulated DBA. During movement of irradiated ;

fuel assemblies, the CCHE must be OPERABLE to cope with a radiological release due to a fuel handling-accident. )

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ACTIONS A.1 With breaches in the CCHE in excess of allowed ' unidentified' leakage pathway sizes as specified in approved design calculations, actions should be taken to close or seal the breaches and restore the CCHE to OPERABLE status within I hour. Restoration is not limited to returning the opening to its pre-breached condition, but can also be accomplished using j temporary sealing measures as described in plant procedures i and/or work instructions. j However, when planned maintenance or modifications require breaches to be created, or where permanent restoration of a discovered breach is preferred to temporary sealing, and there is 'no threat of a radiological or toxic gas challenge to the CCHE,. ACTIONS A.2.1 and A.2.2 are an option. ;

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1 (continued)

Crystal River Unit 3 8 3.7- Revision No. O

CCHE B 3.7.18 BASES ACTIONS. A.2.1 ACTION A.2.1 requires that a contingency response be ,

established which is capable of closing or sealing the breach ,

immediately upon notification from the control room. Closure is not limited to returning the opening to its pre-breached condition, but can also be accomplished using temporary !

sealing measures as described in plant procedures and/or work '

instructions. This response capability will be described in I plant procedures, and must include the following elements:

continuous presence of a person or persons at the breach ;

site capable of sealing or closing the breach, and '

capability for immediate communication between the <

control room and the breach site, and '

materials staged at the breach site for sealing or '

closing the breach.

A.0 2 In combination with the contingency response provided by ACTION A.2.1, this ACTION requires sealing or closure of CCHE ;

breaches within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Allowing the existence of breaches for reasonable periods of time is . supported by the low .

probability of a core damage accident with containment failure, or of a release of toxic gas which would threaten control room operators. No significant increase in risk to the operators or to the public is created by the existence of breaches under these conditions. The allowed Completion Time is reasonable for restoration of breaches in the CCHE when the capability to immediately close or seal the breach, upon 1 notification of a threat, has been established. The time at I which a breach is made or discovered is considered to be the j start of the allowed outage time. !

IL1 In MODE 1, 2, 3, or 4, if breaches in the CCHE in excess of l allowed leakage pathway sizes cannot be closed or sealed within the associated Completion Time, the CREVS may not be capable of performing its intended function and the plant is in a condition outside the accident analysis. Therefore, LC0 3.0.3. must be entered immedintely.

(continued) l Crystal River Unit 3 B 3.7- Revision No. O

CCHE B 3.7.18 BASES ACTIONS Cd

-During movement'of irradiated fuel assemblies, if breaches in the CCHE in excess of allowed leakage pathway sizes cannot be restored within the associated Completion Time, action must be taken immediately to suspend activities that could release radioactivity that could enter the control room. This places the plant in a condition that minimizes the accident risk.

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

SURVEILLANCE SR 3.7.18.1 REQUIREMENTS CCHE doors should be visually inspected to verify that door seals are in good repair with no missing, loose, or damaged parts that degrade a door's capability to close and seal the envelope. Since total leakage calculations assume a certain leakage through doors, their condition must be verified to assure their capability is maintained. Due to the high traffic through Control Complex doors, surveillance every 31 days is judged to be prudent.

SR 3.7.18.2 Control Complex floor drains are routed to collection tanks in the Auxiliary Building. If the loop seals in these drains do not remain filled with water and the collection tank level is below the end of the drain discharge pipe, then a breach will exist in the CCHE. This SURVEILLANCE will verify that loop seals are refilled each 31 days.

SR 3.7.18.3 Isolation dampers should 'oe visually inspected periodically to verify that damper components are in good repair with no missing, loose, or damagad parts that degrade a damper's capability to close and seal the envelope. Since total leakage calculations assume a certain leakage through isolation dampers, their condition must be verified to assure their capability is maintained. Inspection of dampers creates breaches in the CCHE, therefore, inspection will be conducted during refueling outages.

(continued)

Crystal River Unit 3 8 3.7- Revision No. 0

CCHE B 3.7.18 BASES SURVEILLANCE SR 3.7.18.4 REQUIREMENTS CCHE penetration seals should be inspected periodically to i veri fy that they are in good repair and that no gaps or i unsealed areas exist between the seal and CCHE walls, or I around items penetrating the seal. This is accomplished by l

performing visual inspection of one side of the penetration. ,

Since penetration seals are passive components of the CCHE, I inspection once per 24 months is considered appropriate.

REFERENCES 1. CR-3 Control Room Habitability Evaluation Report, submitted to NRC on June 30, 1987, via letter 3F0687-16 i

2. FPC Engineering Calculation I-92-00ll.

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

I Crystal River Unit 3 8 3.7- Revision No. 0 l l

ML20117G661

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