ML20216E660

Marked-up & Revised TS Pages,Making Permanent One Time Only Changes Incorporated Into TS 3.7.9 Allowing Up to 24 Hours to Restore Control Room Pressure Boundary to Operable Status When Two Cravs Trains Inoperable

ML20216E660
Person / Time
Site:	McGuire, Mcguire
Issue date:	09/13/1999
From:	DUKE POWER CO.
To:
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ML20216E657	List: ML20216E653 ML20216E660
References
NUDOCS 9909160083
Download: ML20216E660 (28)

Text

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ATTACHMENT 1 i

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PROPOSED REVISIONS TO THE l i

MCGUIRE NUCLEAR STATION l TECHNICAL SPECIFICATIONS

2'22888R318a36, p PDR

CRAVS 3.7.9 3.7 PLANT SYSTEMS Remove

- 3.7.9 Control Room Area Ventilation System (CRAVS) Asterisk LCO 3.7.9 Two CRAVS trains shall be OPERABLE.

..........................NOTh-----------------------------------.....

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.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 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 Time of Conditiori A not AN,Q 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 met in MODE 5 or 6, or Ql3 during movement of irradiated fuel assemblies, or during CORE ALTERATIONS.

(continued) hhic notc is a ene tirne uniy eiiuwanvo 10 oe voeu iv vuriipivi .ef, ewe to CF.AVS t l Delete McGUIRE Units 1 and 2 3.7.9-1 Amendment Nos.185/167

CRAVS 3.7.9 ACTION $

CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2.1 Suspend CORE immediately ALTERATIONS.

AND C.2.2 Suspend movement of immediately irradiated fuel assemblies.

D. Two CRAVS trains D1 Suspend CORE Immediately inoperable in MODE 5 ALTERATIONS.

or 6, or during movement of irradiated AND 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 inoperable in MODE 1 Remove 2,3, or 4 (for reasons other than Condition G .

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

93 F.2 Initiate action in 7 days Remove accordance with Asterisk 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.

Ih!E iS 0 O^.c ;;-^.C Gi/if unvvvuuve iv vu used iv vvu y GtG TGpaiiG I&CP^.V5 tPi " 9 Delete McGUIRE Units 1 and 2 3.7.9-2 Amendment Nos.185/167 l

ATTACHMENT 2 REVISED McGUIRE NUCLEAR STATION TECHNICAL SPECIFICATIONS I

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• 6 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.

_.._.N OTE------------ ------- -------

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.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 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 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 met in MODE 5 or 6, or QR during movement of irradiated fuel assemblies, or during CORE ALTERATIONS.

(continued) l I

McGUIRE Units 1 and 2 3.7.9-1 Amendment Nos.

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, CRAVS 3.7.9 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2.1 Suspend CORE Immediately ALTERATIONS.

AND C.2.2 Suspend movement of immediately irradiated fuel assemblies.

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

or 6, or during movement of irradiated AND 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 inoperable 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 /> l inoperable due to boundary to OPERABLE inoperable control room status.

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

l McGUIRE Units 1 and 2 3.7.9-2 Amendment Nos.

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ATTACHMENT 3 DESCRIPTION OF PROPOSED CHANGES AND TECHNICAL JUSTIFICATION e

. Attachment 3 Page 1 of 4 Proposed Changes DEC proposes to revise the McGuire Nuclear Station TSs as described below. The proposed revisions make permanent the one time only changes that were incorporated into TS 3.7.9 via McGuire TS amendments 185/167. These revisions are consistent with generic industry changes currently under NRC review as proposed in TSTF-287. These changes will 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. The asterisk attached to the note for LCO 3.7.9 for the Control Room Area Ventilation System has been deleted. This makes permanent the option of opening the CRPB intermittently under administrative control. Corresponding BASES are added to support this change.

2. The asterisk attached to Condition G has been deleted. This makes Condition G permanent which specifies that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore an inoperable control room boundary to operable status. Corresponding BASES are added to support this change and to clarify the compensatory measures available should Condition G be entered.

3. The asterisk attached to Condition E has been deleted. This makes Condition E permanent which, in the event of two inoperable CRAVS trains in Modes 1 - 4, excludes entry into this condition when the trains are inoperable because of the degraded CRPB. The associated BASES for Condition E are revised accordingly.

Basis for Proposed Changes

Background:

The CRAVS is shared between Units 1 and 2 and consists of two redundant safety related trains. The system's purpose is to provide normal and emergency ventilation requirements for the Control Room. During an emergency, each CRAVS train can draw outside fresh air through its own filters and activated charcoal absorber for use in pressurizing the Control Room. This ,

pressurization function ensures that radiation dose to the Control Room operators from airborne radioactive material released during a loss of coolant accident is less than the 10 CFR 50 Appendix A limit. Two independent and redundant CRAVS trains are required to be OPERABLE to ensure that at least one is available to pressurize the Control Room if needed, assuming a single failure disables the other train. In addition, to ensure

. Attachment 3 Page 2 of 4 adequate Control Room pressurization during an event, the CRPB must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors.

The existing LCO 3.7.9 TSSRs that test the integrity of the control room boundary require a positive pressure limit to be satisfied with one required ventilation 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 the design assumptions for i post accident operator doses. Currently, there are no corresponding permanent 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 effect any required repairs, perform corrective maintenance activities, or implement TS related surveillance testing.

The proposed revisions make permanent the one time only changes that were incorporated into TS 3.7.9 via McGuire TS amendments 185/167. These changes establish actions to be taken for inoperable control room ventilation systems due to a degraded CRPB and provide for intermittent opening of the CRPB under administrative controls. These changes are consistent with the generic change proposed by TSTF-287. That TSTF justifies the proposed changes based on the low probability of a Design Basis  !

Accident occurring during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time or while the CRPB is opened intermittently under administrative controls.

l Exigent Criteria MNS TSSR 3.7.9.2 requires that the filters and activated charcoal absorbent in each CRAVS train Control Room pressurization flow path be periodically tested in accordance with the McGuire VFTP as described in section 5.5.11 of the McGuire TSs. As part of this testing, the CRAVS train being tested is declared inoperable while the other train remains operable to pressurize the Control Room if needed. A representative sample of charcoal absorbent is then obtained from the train being tested by removing a bolted hatch cover on that train's filter / absorber package. Removing this cover provides a breach in the CRPB. Given that neither train's discharge check valves are leak tested, the potential exists for backflow through this breach from the operable CRAVS train. Consequently, McGuire's past practice was to ensure the operability of the non-tested CRAVS train by stationing dedicated

a Attachment 3 Page 3 of 4

. plant personnel at the breach in the tested train with instructions to re-install the hatch cover upon notification of an event by Control Room personnel.

The next performance of TSSR 3.7.9.2 on the McGuire CRAVS Train "B" was originally scheduled for June 1999. However, Technical Interface Agreement (TIA) 98008 (TAC No. MA2467 and MA2468),

promulgated the NRC position that, given existing wording in the McGuire TSs, administrative controls such as those McGuire used in the past to maintain the operability of the non-tested CRAVS train could not be credited for TS compliance. At the time that TIA was issued, the NRC and industry groups were proposing l

generic changes to the STS, as described in TSTF-287, that would allow intermittent breaching of the CRPB under administrative controls. Indications were that TSTF-287 would be approved prior to September 25, 1999, the late date for performance of TSSR 3.7.9.2 on CRAVS Train "B" after incorporating the 25% extension of the surveillance frequency allowed by TSSR 3.0.2.

Consequently, McGuire planned to submit changes to TS 3.7.9 based upon the post-TSTF version of the STS and perform the surveillance on CRAVS Train "B" prior to September 25, 1999.

However, in mid-August 1999 when it became apparent that approval of TSTF-287 might be delayed, McGuire began the process of evaluating alternative means of performing the required surveillance testing of CRAVS Train "B". These evaluations

, concluded that the best alternative for maintaining operability of CRAVS Train "A" during testing of Train "B" was to isolate Train "B" by closing and gagging its dampers. McGuire Engineering was then assigned the task of finalizing the details for accomplishing this isolation of the CRAVS Train "B". At that time, DEC anticipated that isolation of CRAVS Train "B" using 1 that train's dampers would allow successful completion of TSSR 3.7.9.2 on CRAVS Train "B" prior to September 25, 1999. Review .

of this alternative proceeded at a pace that facilitated an accurate and thorough evaluation without any unnecessary delays.

l On September 9, 1999, Engineering personnel determined that complete isolation of CRAVS Train "B" using that train's dampers may not be possible given the lack of any required leak testing

of those dampers. Consequently, it might be possible that, when the hatch cover is removed from the CRAVS Train "B"

! filter / absorber package to allow carbon sampling, the operability of CRAVS Train "A" could be affected by back flow through the breach in Train "B".

At no time prior to September 9, 1999 was DEC aware that isolation of CRAVS Train "B" using its dampers might not ensure the operability of Train "A". Upon identifying the operability concerns associated with isolation of CRAVS Train "B" using its dampers and after concluding there were no other acceptable

Attachment 3 Page 4 of 4

, al.ternatives for performing the surveillance testing, DEC immediately notified the NRC of the need for a change to TS 3.7.9. However, given the September 25, 1999 late date for performance of TSSR 3.7.9.2 on CRAVS Train "B", less than 30 days exists to allow for the normal comment period under 10 CFR 50.91.

Absent the performance of the surveillance or an amendment, Unit 2 would be forced to shutdown under the requirements of TS 3.0.3 and, since it will be in a scheduled refueling outage, Unit 1 would be required to suspend core alterations or movement of irradiated fuel assemblies under the requirements of TS 3.7.9.

Given the above and the determination that this LAR involves no significant hazards as specified under 10 CFR 50.92, DEC believes the criteria for exigency as described in 10 CFR 50.91 are met.

Consequently, DEC requests that this LAR be processed as an exigent change pursuant to the requirements of 10 CFR 50.91 (6)

(i) which allows for local media notice if less than 14 days exists for the FEDERAL REGISTER notice.

Conclusion:

The proposed changes would make permanent the one time only changes that were incorporated into TS 3.7.9 via McGuire amendments 185/167. These changes will 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 provide appropriate measures to minimize 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 have a probability of occurrence of approximately 1E-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 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.

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ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSIDERATIONS

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. Attachment 4 Page 1 of 2 No Significant Hazards 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.

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

J No. The Control Room Area Ventilation System and Control Room boundary are not assumed to be an initiator of any analyzed 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 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 j available compensatory measures to mitigate operator dose.

Compensatory measures include the use of the alternate control ,

room intake to select 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 i under administrative control, appropriate administrative measures l 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 administrative controls required to rapidly restore an opened i 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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. Attachment 4 Page 2 of 2

2. Does the change create the possibility of a new or different

. kind of accident from any accident previously evaluated?

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 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 control room boundary provide a protected environment for the l control room operators during analyzed events. The proposed l change would allow the boundary to be degraded for a limited period of time. However, administrative controls would be in place to rapidly restore an opened boundary and existing compensatory measures (e.g., breathing apparatus) would be implemented 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, the proposed change is not i considered to result in a significant reduction in a margin of safety.

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ATTACHMENT 5 l

ENVIRONMENTAL IMPACT ASSESSMENT I

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. Attachment 5 Page 1 of 1

. Environmental 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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PROPOSED REVISIONS TO THE MCGUIRE NUCLEAR STATION TECHNICAL SPECIFICATION BASES ,

i CRAVS B 3.7.9 BASES i

LCO (continued) i I

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 walls, floors, ceilings, ductwork, and access doors. 1 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 Remove OPERABLE because the system is shared. If a CRAVS component Asterisk becomes inoperable, or normal or emergency power to a CRAVS l component becomes inoperable, then the Required Actions of this LCO l 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 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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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.

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

= i= a em i = e:::y ;;;a..e.we te be used te ev ..gim ::p;i: ie ORAV6 i l

l McGuire Units 1 and 2 B 3.7.9-3 Revision No. 4

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o. CRAVS j B 3.7.9 BASES ACTIONS 61 j When one C9AVS 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, l 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 i

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

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. s CRAVS B 3.7.9 BASES

]sk ACTIONS (continued) unit in a condition that minimizes accident risk. This does not preclude I the movement of fuel to a safe position.

U 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 h

U 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. Alternatively, 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 mses are within 10 CFR 100 limits during a DBA LOCA under these conditions.

Remove Asterisk G.1 Revise 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 Ab'ndary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.JThe 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable) y 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 Delete consistent with the intent of GDC 19 that are available to the operator to minimize doses (e.g. self contained breathing apparatus and alternate control room air intakes). These measures should be available for (intentional and unintentional entry into the condition.

e a one he c=y ;L,e.mo te b6 used to -,,,giv.c mp=h te GRAV8 l

McGuire Units 1 and 2 B 3.7.9-5 Revision No. 4

ac-CRAVS B 3.7.9 BASES SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Standby systems should be onecked 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.

SR 3.7.9.2 This SR verifies that the required CRAVS testing is performed in accordance with t6.e 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 activated charcoal. Specific test Frequencies and additionalinformation are discussed in detailin the VFTP.

SR 3.7.9.3 This SR verifies that each CRAVS train starts and operates with flow through the HEPA filters and charcoal adsorbers on an actual or simulated actuation signal. The Frequency of 18 months is specified in i Regulatory Guide 1.52 (Ref. 4).

S.R 3.7.9.4 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 ,

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 18 months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800 (Ref. 5).

l McGuire Units 1 and 2 B 3.7.9-6 Revision No. 4

CRAVS B 3.7.9 BASES RE'FERENCES 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 No.4

s ATTACHMENT 7 REVISED McGUIRE NUCLEAR STATION TECHNICAL  !

3PECIFICATION BASES 1

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CRAVS B 3.7.9 BASES _

LCO (continued) l 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 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 controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will j have a method to rapidly close the opening when a need for control room I I

area isolation is indicated.

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.

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l* CRAVS B 3.7.9 BASES

. ACTIONS .A_m, 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 G 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 I 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 mignt enter the control room. This places the l

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

l l M 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 l the intended function and the unit is in a condition outside the accident l analyses. Therefore, LCO 3.0.3 must be entered immediately.

F.1 and F.2 l

Action F.1 allows one or more CRAVS heater inoperable, with the heater 1 restored to OPERABLE status within 7 days. Alternatively, Action F.2 I require.s 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 I heater to OPERABLE status. l 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 these conditions.

1 G.1 If the controi 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 />. rhe 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 consistent with the intent of GDC 19 that are available to the operator to minimize doses (e.g. self contained breathing apparatus and alternate control room air intakes). These measures should be available for intentional and unintentional entry into the condition.

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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.

SR 3J C.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 4 adsorber efficiency, minimum flow rate, and the physical properties of the )

activated charcoal. Specific test Frequencies and additionalinformation are discussed in detailin the VFTP.

SR 3.7.9.3 This SR verifies that each CRAVS train starts and operates with flow through the HEPA filters and charcoal adsorbers on an actual or simulated actuation signal. The Frequency of 18 months is specified in Regulatory Guide 1.52 (Ref. 4). i SR 3.7.9.4 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 l inleakage. The CRAVS is designed to maintain this positive pressure with one train at a makeup flow rate of s 2200 cfm. The Frequency of 18 months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800 (Ref. 5).

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. CRAVS B 3.7.9 BASES

. 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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l McGuire Units 1 and 2 B 3.7.9-7 Revision No. 5