ML20195F294

Proposed Tech Specs,Facilitating one-time Addition of Condition G & Administrative Controls Note to TS 3.7.9, Cravs

ML20195F294
Person / Time
Site:	Mcguire, McGuire
Issue date:	06/10/1999
From:	DUKE POWER CO.
To:
Shared Package
ML20195F290	List: ML20195F287 ML20195F294
References
NUDOCS 9906140269
Download: ML20195F294 (27)

Text

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l ATTACHMENT 1 PROPOSED REVISIONS TO THE MCGUIRE NUCLEAR STATION TECHNICAL SPECIFICATIONS PJ288M M 8sa P pp b  !

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. . CRAVS 3.7.9 t~ '

3.7 PLANT SYSTEMS 3.7.9 Control Room Area Ventilation System (CRAVS)

LCO 3.7.9 Two CRAVS trains shall be' OPERABLE.

. _ _ _ _ . . . . m% - - - - - - - - -

l N con %I now bous der uW admyg.h p_wp,,g ,,,,,,,, mad _op,,rA inhemblh APPLICABILITY: MODES 1,2,3,4,5, and 6, During movement of irradiated fuel assemblies, l

During CORE ALTERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l A. One CRAVS train A.1 Restore CRAVS train to 7 days inoperable. OPERABLE status.

B. Required Action and B.1. Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion l Time of Condition A not - AND i met in MODE 1,2, 3, or 4. B.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 /> C. Required Action and C.1 Place OPERABLE CRAVS Immediately l associated Completion train in emergency mode.

l Time of Condition A not met in MODE 5 or 6, or OR I during movement of irradiated fuel i assemblies, or during CORE ALTERATIONS.

(continued)

Dn LJ0k W A one N Mt, onl j AflOt**n2 Is k tud& k %g npc3 b C.9A W h d n B . I McGuire Units 1 and 2 3.7.9-1 Amendment Nos.184/166 l

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. . CRAVS 3.7.9 e

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

, C. (continued) C.2.1 Suspend CORE Immediately l

ALTERATIONS.

blN.Q 1

C.2.2 Suspend movement of Immediately f irradiated fuel assemblies.

D. Two CRAVS trains D.1 Suspend CORE Immediately inoperable in MODE 5 ALTERATIONS.

or 6, or during inovement of irradiated 6N.2 fuel assemblies, or during CORE D.2 Suspend movement of immediately ALTERATIONS. Irradiated fuel assemblies.-

E. Two CRAVS trains E.1 Enter LCO 3.0.3. Immediately pe in MODE 1, ns 0 g r g 6

,3 4 Qn4%n Gf7

~ F. One or more CRAVS F.1 Restore CRAVS train (s) 7 days train (s) heater heater to OPERABLE inoperable. status.

98 F.2 Initiate action in 7 days accordance with Specification 5.6.6.

Rehe.conbl"o"

[~ Tuao CEAVS h nihs 6.1 24 houcs Inograble, dot h bouw&ar3 %

inop,& 661 rww OP u a ete 3 6 9 s.

! .6wwdary in U 0b6, I, '1, b or 4 .

I This 6 a ont 4im e. o J3 collwa,,a .% [e usg 4e cou plek gpa,.3 b mq; py,n g, McGuire Units 1 and 2 3.7.9-2 Amendment Nos. 184/166 1 1

i 1 No- c6p +Lu ge

. CRAVS 3'l*9

, Nwk, only i

. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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l , - SR 3.7.9.1 Operate each CRAVS train for 210 continuous hours 31 days with the heaters operating.

SR 3.7.9.2 Perform required CRAVS filter testing in accordance with in accordance with the Ventilation Filter Testing Program (VFTP). VFTP SR 3.7.9.3 Verify each CRAVS train actuates on an actual or 18 months simulated actuation signal.

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SR 3.7.9.4 Verify one CRAVS train can maintain a positive pressure 18 months on a of 2 0.125 inches water gauge, relative to atmospheric STAGGERED pressure during the pressurization mode of operation at a TEST BASIS makeup flow rate of $ 2200 cim.

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. McGuire Units 1 and 2 3.7.9-3 Amendment Nos. 184/166 I l

t ATTACHMENT 2 REVISED McGUIRE NUCLEAR STATION TECHNICAL SPECIFICATIONS

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CRAVS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Control Room Area Ventilation System (CRAVS)

LCO 3.7.9 Two CRAVS trains shall be OPERABLE.

NOTE *- -

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

APPLICABILITY: MODES 1,2, 3,4,5, and 6, During movement of irradiated fuel assemblies, {

During CORE ALTERATIONS.

l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l

A. One CRAVS train A.1 Restore CRAVS train to 7 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion i Time of Condition A not AND met in MODE 1,2,3, or 4. B.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 /> C. Required Action and C.1 Place OPERABLE CRAVS Immediately associated Completion train in emergency mode.

Time of Condition A not l met in MODE 5 or 6, or QR during movement of irradiated fuel l assemblies, or during CORE ALTERATIONS.

(continued)

This note is a one time only allowance to be used to complete repairs to CRAVS train B. l McGuire Units 1 and 2 3.7.9 1 Amendment Nos.

CRAVS 3.7.9 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l

C. (continued) C.2.1 Suspend CORE immediately ALTERATIONS.

AND l

C.2.2 Suspend movement of immediately irradiamd fuel assemblies. i i

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D. Two CRAVS trains D.1 Suspend CORE Immediately inoperable in MODE 5 ALTERATIONS. ,

or 6, or during j movement of irradiated AND '

l fuel assemblies, or -

during CORE D.2 Suspend movement of immediately ALTERATIONS. irradiated fuel assemblies.

E. Two CRAVS trains E.1 Enter LCO 3.0.3. Immediately inoperabie in MODE 1, 2, 3, or 4 (for reasons other than Condition G)*.

F. One or more CRAVS F.1 Restore CRAVS train (s) 7 days train (s) heater heater to OPERABLE inoperable. status.  ;

OB F.2 Initiate action in 7 days accordance with Specification 5.6.6.

G.* Two CRAVS trains G.1 Restore control room 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inoperable due to boundary to OPERABLE inoperable control room status.

boundary in MODE 1,2, 3, or 4.

This is a one time only allowance to be used to complete repairs to CRAVS train B. l McGuire Units 1 and 2 3.7.9-2 Amendment Nos.

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e ATTACHMENT 3 l

DESCRIPTION OF PROPOSED CHANGES AND TECHNICAL JUSTIFICATION

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. Attachment 3 Page 1 of 2 1

i Proposed Changes j

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I DEC proposes to revise the McGuire Nuclear Station TS's as  !

described below. The proposed revisions establish actions to be taken for inoperable control room ventilation systems.due to a degraded control room pressure boundary.

The proposed changes are as follows:

1. A note has been added to LCO 3.7.9 for the Control Room Area Ventilation System to allow the control room boundary'to be opened intermittently under administrative control.

l Corresponding Bases'have been added which establish the administrative controls that are required to minimize the consequences of the open boundary.

'2. Condition G is added to LCO 3.7.9 to specify that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l are allowed to restore an inoperable control room boundary l to operable status. Corresponding Bases are added to l support this change.

3. Condition E of LCO 3.7.9 for two inoperable CRAVS trains in Modes 1 - 4 is modified to exclude entry into this condition when the trains are inoperable because of the degraded control room pressure boundary. The associated Bases for Condition E are revised accordingly.

Basis for Proposed Changes

Background:

The existing LCO 3.7.9 surveillance requirements that test the integrity of the control room boundary require a positive pressure limit to be satisfied with one required ventilation I train operating. While other surveillance requirements in the same specification test the operability and function of the ventilation train, the pressure test ensures that the control room pressure boundary leak tightness is adequate to meet design ,

assumptions for post accident operator doses. J Currently, there are no corresponding conditions, required actions, or completion times specified in LCO 3.7.9 should the control room pressure boundary surveillance not be met. Under the existing specifications, LCO 3.0.3 must be entered (for two-train inoperability). Requiring the plant to enter LCO 3.0.3 when the ventilation boundary is not intact does not provide time to affect required repairs or corrective maintenance activities.

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, Attachment 3 Page 2 of 2 The proposed change is consistent with a generic change (TSTF-287 R2) proposed by the industry owners groups and is similar to LCO

?.C.16 for the Reactor Building. LCO 3.6.16 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the reactor building envelope to operable status before requiring an orderly shutdown from operating conditions.

Conclusion:

The proposed change would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (during Modes 1, 2, 3, or 4) to restore the capability to maintain control room boundary pressure before requiring the unit to perform an orderly shutdown and also allows intermittent opening of the control room boundary under administrative control. The administrative controls establish appropriate compensatory measures to n.inimize the consequences of an event during this time. For example, when the control room boundary is opened for other than entry through doors, the proposed Bases require that a dedicated individual be stationed in the area in continuous contact with the control room to rapidly restore the boundary.

Additionally, the proposed change is considered acceptable because of the low probability of an event requiring an intact control room boundary occurring during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> action completion time associated with Condition "G". On a per unit basis, the most severe condition, a core damage accident, is estimated to occur with a probability of approximately 1.4E-07 during a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. The probability of a LOCA, a less severe condition, is estimated to heve a probability of occurrence of approximately lE-05 during a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. The probability of an SGTR, which is the the least severe event, is estimated to occur with a probability of approximately 4E-05 during a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.

Based cn the low probability of an event occurring in this time and the availability of compensatory measures to minimize the consequences during an event, the proposed change is considered acceptable,

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f ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSIDERATIONS i 1

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l, Attachment 4 l Page 1 of 2 No Significant lzards Considerations:

In accordance with the criteria set forth in 10 CFR 50.91 and 50.92, McGuire Nuclear Station has evaluated this proposed Technical Specification change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.

l 1. Does the change involve a significant increase in the l probability or consequences of an accident previously l 1

evaluated?

No. The Control Room Area Ventilation System and Control Room l boundary are not assumed to be an initiator of any analyzed l accident; they are provided to minimize doses to the control room operators during an accident. Therefore, these proposed changes have no impact on the probability of occurrence of any previously l analyzed accident.

The proposed changes also have no impact on offsite dose consequences. The control room ventilation system and control room boundary provide protection for control room personnel only and do not mitigate radiological effluents released offsite.

With the control room boundary inoperable and not pressurized, the accident analyses assume unfiltered air would enter the control room and operator doses would be significantly increased.

Conservative accident analysis assumptions do not take credit for available compensatory measures to mitigate operator dose. These include the use of the alternate control room intake to select I

the intake with the lowest radioactivity level, filtration of outside air by an operable CRAVS train, and the availability of self-contained breathing apparatus.

Additionally, for cases where the control room boundary is opened under administrative control, compensatory measures would be required by the proposed TS to ensure the boundary can be rapidly restored. Based on the compensatory measures available to the control room operator to minimize dose, the compensatory measures required to rapidly restore an opened boundary, and considering the. low probability of an event occurring in this short time period, the consequences are not considered to be significantly increased. Operators maintain the ability to mitigate a design basis event.

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. e i c Attachment 4 Page 2 of 2 l

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2. ,Does the change create the possibility of a new or different kind of accident-from any accident previously evaluated?

I No. No changes are being made to actual plant hardware which will. result in any new accident causal mechanisms. Also, no changes are being made to the way in which the plant is being operated. Therefore, no new accident causal mechanisms will be generated.

-3. Does:this change involve a significant reduction in a margin of safety?-

No, Margin of-' safety is related to the ability of the fission product barriers to perform their design functions during and l .following. accident conditions. These barriers include the fuel cladding, the reactor coolant system, and the containment system.

The performance of these barriers will not be degraded by the proposed' changes. The Control Room Ventilation System and j control' room boundary provide a protected environment for the control room operators during analyzed events. The proposed change would allow the boundary to be degraded for a limited period of time. However, compensatory measures would be in place to rapidly restore an opened boundary and to utilize existing measures (breathing apparatus) to minimize operator dose.

Therefore, it is expected that operators would maintain the ability to mitigate design basis events and none of the fission product barriers would be affected by this change. Therefore, j the proposed change is not considered to result in a significant i reduction in a margin of safety. l l

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• W ATTACHMENT 5 4

ENVIRONMENTAL IMPACT ASSESSMENT i

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p Attachment 5 Page 1 of 1 En'vironmental Impact Assessment:

The proposed Technical Specification amendment has been reviewed

'against the criteria of 10 CFR 51.22 for environmental considerations. The proposed amendment does not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor increase individual or cumulative occupational radiation exposures.

Therefore, the proposed amendment meets the criteria given in 10 CFR 51.22 (c) (9) for a categorical exclusion from the requirement for an Environmental Impact Assessment.

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ATTACHMENT 6 PROPOSED REVISIONS TO THE MCGUIRE NUCLEAR STATION i TECHNICAL SPECIFICATION l BASES I

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CRAVS

, B 3.7.9 BASES LCO (continued)

a. An Outside Air Pressure Filter Train fan and a Control Room Air Handling unit are OPERABLE;

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

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

In addition, the control room boundary must be maintained, including the integrity of the wils, floors, ceilings, ductwork, and access doors.

The CRAVS is shared between the two units. The system must be OPERABLE for each unit when that unit is in the MODE of Applicability.

Additionally, both normal and emergency power must also be OPERABLE because the system is shared. if a CRAVS component becomes inoperable, or normal or emergency power to a CRAVS component becomes inoperable, then the Required Actions of this LCO must be entered independently for each unit that is in the MODE of I applicability of the LCO.

1 APPLICABILITY In MODES 1,2,3,4,5, and 6, and during movement of irradiated fuel assemblies and during CORE ALTERATIONS, CRAVS must be OPERABLE to control operator exposure during and following a DBA. .

During movement of irradiated fuel assemblies and CORE ALTERATIONS, the CRAVS must be OPERABLE to cope with the release from a fuel handling accident.

ACTIONS 6.d When one CRAVS train is inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CRAVS train is adequate to perform the control room protection function. However, the overall reliability is reduced because a .

single failure in the OPERABLE CRAVS train could result in loss of I CRAVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability, t TQ h a n Nt onl3alk.e fs be ufek fu WPO' McGuire Units 1 and 2 B 3.7.9-3 Revision No. AN

BASES LCO lNSERT The LCO is modified by a Note allowing the control room boundary to be opened intermittently under administrative controls. 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 consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for control room area isolation is indicated.

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CRAVS

. B 3.7.9 t

BASES-ACTIONS (continued)

B.1 and B.2 in MODE 1,2,3, or 4, if the inoperable CRAVS train cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 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.

C.1. C.2.1. and C.2.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS, if the inoperable CRAVS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CRAVS train in the emergency mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected. An alternative to Required Action C.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk.~ This does not preclude the movement of fuel to a safe position.

D.1 and D.2 in MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS, with two CRAVS trains inoperable, action  ;

must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

(Ge rtasom ofker U  % ce 6 M G)

If both CRAVS trains are inoperable in MODE 1,2,3, or 46he CRAVS 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.

Y This n a ont Nt el3 ejtu.eu b k u3,D b coupi tk vtpst b Cl2AVS hl, g, l

McGuire Units 1 and 2 B 3.7.9-4 Revision No.M j l

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CRAVS I

. B 3.7.9 BASES 3- ACTIONS (continued) l F.1 and F.2 Action F.1 allows one or more CRAVS heater inoperable, with the heater restored to OPERABLE status within 7 days. Altematively, Action F.2 requires if the heater is not retumed to OPERABLE within the 7 days, a report to be initiated per Specification 5.6.6, which details the reason for the heater's inopertbsity and the corrective action required to retum the l heater to OPERABLE status.

l The heaters do not affect OPERABILIW of the CRAVS filter train because charcoal absorber efficiency testing is performed at 30 C and 90 q  % relative humidity. The accident analysis shows that site boundary S60.T radiation doses are within 10 CFR 100 limits during a DBA LOCA under these conditions.

l' SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they l function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month l provides an adequate check of this system. Monthly heater operations dry out any moisture accumulated in the charcoal from humidity in the l ambient air. Systems with heaters must be operated from the control room for 210 continuous hours with the heaters energized and flow through the HEPA filters and charcoal adsorbers. The 31 day Frequency is based on the reliability of the equipment and the two train redundancy availability.

l SR 3.7.9.2 This SR verifies that the required CRAVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CRAVS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 4).

The VFTP includes testing the performance of the HEPA filter, charcoal

adsorber efficiency, minimum flow rate, and the physical properties of the l activated charcoal. Specific, test Frequencies and additional information are discussed in detailin the VFTP.

Y 34 s a onc M of ally.m h h usc$ fo togel<h rtpss b WH h E.

McGuire Units 1 and 2 B 3.7.9-5 Revision No.

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, i BASES ACTIONS INSERT G.1 1 if the control room boundary is inoperable in MODES 1,2, 3, or 4 such that the CRAVS trains can not establish or maintain the required pressure, action must be taken to restore an OPERABLE control room boundary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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, the availability of the CRAVS to provide a filtered environment (albeit with potential control room inleakage), and compensatory measures available to the operator to minimize doses (e.g. self contained breathing apparatus and alternate control room air intakes).

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ATTACHMENT 7 REVISED McGUIRE NUCLEAR I STATION TECHNICAL SPECIFICATION BASES i

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0 CRAVS B 3.7.9 BASES l LCO (continued)

a. An Outside Air Pressure Filter Train fan and a Control Room Air Handling unit are OPERABLE;

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

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

In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors.

The CRAVS is shared between the two units. The system must be OPERABLE for each unit when that unit is in the MODE of Applicability.

l Additionally, both normal and emergency power must also be OPERABLE because the system is shared. If a CRAVS component becomes inoperable, or normal or emergency power to a CRAVS component becomes inoperable, then the Required Actions of this LCO must be entered independently for each unit that is in the MODE of applicability of the LCO.

The LCO is modified by a Note allowing the control room boundary to be opened intermittently under administrative controls. 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 l controls consist of stationing a dedicated individual at the opening who is 1

in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for control room area isolation is indicated.

APPLICABILITY In MODES 1,2,3,4,5, and 6, and during movement of irradiated fuel ]

l assemblies and during CORE ALTERATIONS, CRAVS must be l OPERABLE to control operator exposure during and following a DBA. l During movement of irradiated fuel assemblies and CORE l

ALTERATIONS, the CRAVS must be OPERABLE to cope with the

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l release from a fuel handling accident.

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• This is a one time only allowance to be used to complete repairs to CRAVS Train B.

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l McGuire Units 1 and 2 B 3.7.9-3 Revision: 4 ,

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. I CRAVS B 3.7.9 BASES ACTIONS .A_1 When one CRAVS train is inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CRAVS train is adequate to perform the control room protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CRAVS train could result in loss of CRAVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B.1 and B.2 in MODE 1,2,3, or 4, if the inoperable CRAVS train cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 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.

C.1. C.2.1. and C.2.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS, if the inoperable CRAVS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CRAVS train in the emergency mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected. An alternative to Required Action C.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

D.1 and D.2 4 In MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS, with two CRAVS trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the control room. This places the McGuire Units 1 and 2 B 3.7.9-4 Revision: 4 j

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l' CRAVS B 3.7.9 BASES ACTIONS (continued) unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

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If both CRAVS trains are inoperable in MODE 1,2,3, or 4 for reasons

• other than Condition G, the CRAVS 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 and F.2 Action F.1 allows one or more CRAVS heater inoperable, with the heater restored to OPERABLE status within 7 days. Altematively, Action F.2 requires if the heater is not returned to OPERABLE within the 7 days, a report to be initiated per Specification 5.6.6, which details the reason for the heater's inoperability and the corrective action required to return the heater to OPERABLE status.

The heaters do not affect OPERABILITY of the CRAVS filter train because charcoal absorber efficiency testing is performed at 30 C and 90

% relative humidity. The accident analysis shows that site boundary radiation doses are within 10 CFR 100 limits during a DBA LOCA under l these conditions.

G.1 If the control room boundary is inoperable in MODES 1,2, 3, or 4 such that the CRAVS trains can not establish or maintain the required pressure, action must be taken to restore an OPERABLE control room

• boundary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 l based on the low probability of a DBA occurring during this time period, i the availability of the CRAVS to provide a filtered environment (albeit with potential control room inleakage), and compensatory measures available

to the operator to minimize doses (e.g. self contained breathing I

apparatus and alternate control room air intakes).

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• This is a one time only allowance to be used to complete repairs to CRAVS Train B.

McGuire Units 1 and 2 B 3.7.9-5 Revision: 4 l

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C CRAVS B 3.7.9 BASES SURVEILLANCE SR 3.7.9.1 REQUIREMENTS

. 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. Monthly heater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air. Systems with heaters must be operated from the control room for 210 continuous hours with the heaters energized and flow through the HEPA filters and charcoal adsorbers. The 31 day Frequency is based on the reliability of the equipment and the two train redundancy availability. j

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SR 3.7.9.2 j This SR verifies that the required CRAVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The

- CRAVS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 4).

The VFTP includes testing the performance of the HEPA filter, charcoal j adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detailin the VFTP. g SR 3.7.9.3 l

This SR verifies that each CRAVS train starts and operates with flow ,

through the HEPA filters and charcoal adsorbers on an actual or j simulated actuation signal. The Frequency of 18 months is specified in Regulatory Guide 1.52 (Ref. 4).

SR 3.7.9.4 i This SR verifies the integrity of the control room enclosure, and the assumed inleakage rates of the potentially contaminated air. The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper functioning of the CRAVS.

During the emergency mode of operation, the CRAVS is designed to ,

pressurize the control room 2 0.125 inches water gauge positive pressure l with respect to atmospheric pressure in order to prevent unfiltered '

inleakage. The CRAVS is designed to maintain this positive pressure .

with one train at a makeup flow rate of 5 2200 cfm. The Frequency of l 18 months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800 (Ref. 5).

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l McGuire Units 1 and 2 B 3.7.9-6 Revision: 4

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CRAVS B 3.7.9 l

BASES i

REFERENCES 1, UFSAR, Section 6.4.

2. UFSAR, Chapter 15.

3. 10 CFR 50.37, Technical Specifications, (c)(2)(ii).

4. Regulatory Guide 1.52, Rev. 2.

5. NUREG-0800, Section 6.4, Rev. 2, July 1981.

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McGuire Units 1 and 2 B 3.7.9-7 Revision: 4