NG-07-0493, Tscr: Consolidated Line Item Improvement, Adoption of Changes to STS Under TSTF-448, Revision 3 Regarding Control Room Envelopes Habitability

Tscr: Consolidated Line Item Improvement, Adoption of Changes to STS Under TSTF-448, Revision 3 Regarding Control Room Envelopes Habitability

ML072040245
Person / Time
Site:	Duane Arnold
Issue date:	06/29/2007
From:	Vanmiddlesworth G Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Feintuch K, NRR/DORL/LPL3-1, 415-3079
References
NG-07-0493, TAC MD6020
Download: ML072040245 (31)

Text

FPL Energy Duane Arnold, LLC 3277 DAEC Road Palo, Iowa 52324 FPL Energy.

Duane Arnold Energy Center June 29, 2007 NG-07-0493 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Technical Specification Change Request (TSCR-092): Consolidated Line Item Improvement; Adoption of Changes to Standard Technical Specifications Under Technical Specifications Task Force (TSTF) Change Number TSTF-448, Revision 3 Regarding Control Room Envelope Habitability Affected Technical Specifications: Section 3.7.4 and 5.5.13 Pursuant to 10 CFR 50.90, FPL Energy Duane Arnold, LLC (FPL Energy Duane Arnold) hereby requests revision to the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC).

The proposed amendment consists of a Consolidated Line Item Improvement that adopts changes to TS section 3.7.4, Standby Filter Unit (SFU) System, and adds Technical Specification section 5.5.13, Control Building Envelope Habitability Program, consistent with Technical Specifications Task Force (TSTF) Change Traveler TSTF-448, Revision 3.

The proposed Amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c). Associated TS Bases changes will be completed per the TS Bases Control Program (TS 5.5.10).

FPL Energy Duane Arnold requests an implementation period of 180 days after issuance of the license amendment.

This application has been reviewed by the DAEC Company Nuclear Review Board. A copy of this submittal, along with the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration," is being forwarded to our appointed state official pursuant to 10 CFR 50.91.

NG-07-0493

-June 29, 2007 Page 2 of 2 Commitments made in this submittal are listed in Section 3.2 of Enclosure A. The following commitment made in our January 28, 2005 letter (ML050390308) is closed by this letter.

DAEC commits to submit to the NRC proposed changes to the Technical Specifications (and any associated plant modifications) based upon the final, approved version of Technical Specification Task Force (TSTF) - 448, adjusted, as needed, to account for plant-specific DAEC Control Room Envelope design and licensing basis, within 180 days following NRC approval of TSTF-448.

If you have any questions or require additional information, please contact Steve Catron at (319) 851-7234.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 29, 2007.

GaryVaZn Middlesworth Site Vice President, Duane Arnold Energy Center FPL Energy Duane Arnold, LLC

Enclosures:

A) Evaluation of Proposed Change B) Proposed Technical Specification and Bases Changes (Mark-Up)

C) Proposed Technical Specification Pages (Re-Typed) cc: Administrator, Region Ill, USNRC Project Manager, DAEC, USNRC Resident Inspector, DAEC, USNRC D. McGhee (State of Iowa)

ENCLOSURE A EVALUATION OF PROPOSED CHANGE

Subject:

Consolidated Line Item Improvement; Adoption of Changes to Standard Technical Specifications Under Technical Specifications Task Force (TSTF)

Change Number TSTF-448, Revision 3 Regarding Control Room Envelope Habitability

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL EVALUATION 3 Pages Follow

ENCLOSURE A Consolidated Line Item Improvement; Adoption of Changes to Standard Technical Specifications Under Technical Specifications Task Force (TSTF) Change Number TSTF-448, Revision 3 Regarding Control Room Envelope Habitability

1.0 DESCRIPTION

The proposed amendment would modify Technical Specification (TS) requirements related to control building envelope habitability in TS 3.7.4, Standby Filter Units (SFU)

System and TS Section 5.5, Administrative Controls-Programs. The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/TSTF Standard Technical Specifications (STS) change TSTF-448 Revision 3. 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).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation FPL Energy Duane Arnold has reviewed the safety evaluation dated January 9, 2007 as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-448. FPL Energy Duane Arnold has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to the Duane Arnold Energy Center (DAEC) and justify this amendment for the incorporation of the changes to the DAEC TS.

2.2 Optional Changes and Variations FPL Energy Duane Arnold is not proposing any variations or deviations from the TS changes described in the TSTF-448, Revision 3, or the applicable parts of the NRC staffs model safety evaluation dated January 9, 2007 with the following exceptions:

References to chemical and smoke hazards have been deleted from Technical Specification 3.7.4, Required Action B.2 and Technical Specification 5.5.13, as well as the associated Bases sections. This is being done since the SFU system at the DAEC is not designed to protect Control Building occupants from these hazards. The DAEC Updated Final Safety Analysis Report (UFSAR) Section 6.4 specifies that surveys of hazardous chemicals have been performed and found to not pose a threat to Control Building habitability. No toxic gas detectors are provided to initiate Control Building isolation. Additionally, as part of the FPL Energy Duane Arnold Generic Letter 2003-01 response dated January 28, 2005 (ML050390308), an Engineering Evaluation was performed for chemical hazards. The purpose of the evaluation was to perform a screening of potential toxic chemical releases to identify those that may require further analysis for Control Building habitability and to perform that analysis. A qualitative

ENCLOSURE A assessment of the effect on Control Building habitability for internal or external smoke events was also performed. The hazardous chemical evaluation found that there are no on-site or off-site stationary or mobile hazardous chemical sources that threaten Control Building habitability. The smoke assessment concluded that no items were identified that would impede habitability or prevent operation of the remote shutdown panels and controls for a fire/smoke event originating in the Control Building Envelope (i.e.,

Heating, Ventilation, and Air Conditioning (HVAC) Equipment Room, Control Room or Cable Spreading Room).

The wording of the new Technical Specification 5.5.13.d has been changed to specify that the Control Building Envelope pressure is measured relative to the outside atmosphere instead of all external areas adjacent to the Control Building Envelope boundary. This is being done to reflect the current design and licensing basis of the DAEC. The current wording of Technical Specification Surveillance Requirement 3.7.4.4 specifies that pressure is measured relative to the outside atmosphere. The pressure measurement required to be performed in the new Technical Specification 5.5.13.d is intended to perform the same measurement as the current Surveillance Requirement 3.7.4.4, using the existing installed instrumentation. Appropriate Bases changes have also been performed.

Evaluations 1, 5 and 6 of the safety evaluation dated January 9, 2007 are applicable to the DAEC.

2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements FPL Energy Duane Arnold proposes the following as a license condition to support implementation of the proposed TS changes: "Upon implementation of Amendment No.

xxx adopting TSTF-448, Revision 3, the determination of control building envelope (CBE) unfiltered air inleakage as required by SR 3.7.4.4, in accordance with TS 5.5.13.c.(i), the assessment of CBE habitability as required by Specification 5.5.13.c.(ii),

and the measurement of CBE pressure as required by Specification 5.5.13.d, shall be considered met. Following implementation:

(a) The first performance of SR 3.7.4.4, in accordance with Specification 5.5.13.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from September 21, 2004, the date of the most recent successful tracer gas test.

(b) The first performance of the periodic assessment of CBE habitability, Specification 5.5.13.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from September 21, 2004, the date of the most recent successful tracer gas test.

(c) The first performance of the periodic measurement of CBE pressure, Specification 5.5.13.d, shall be within 24 months, plus the 180 days

ENCLOSURE A allowed by SR 3.0.2, as measured from February 24, 2006, the date of the most recent successful pressure measurement test."

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination FPL Energy Duane Arnold has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. FPL Energy Duane Arnold has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to DAEC and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Commitments (a) The first performance of SR 3.7.4.4, in accordance with Specification

• 5.5.13.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from September 21, 2004, the date of the most recent successful tracer gas test.

(b) The first performance of the periodic assessment of CBE habitability, Specification 5.5.13.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from September 21, 2004, the date of the most recent successful tracer gas test.

(c) The first performance of the periodic measurement of CBE pressure, Specification 5.5.13.d, shall be within 24 months, plus the 180 days allowed by SR 3.0.2, as measured from February 24, 2006, the date of the most recent successful pressure measurement test.

4.0 ENVIRONMENTAL EVALUATION FPL Energy Duane Arnold has reviewed the environmental evaluation included in the model safety evaluation dated January 9, 2007 as part of the CLIP. FPL Energy Duane Arnold has concluded that the staffs findings presented in that evaluation are applicable to the DAEC and the evaluation is hereby incorporated by reference for this application.

ENCLOSURE B PROPOSED TECHNICAL SPECIFICATION AND BASES CHANGES (MARK-UP) 17 Pages Follow

SFU System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Standby Filter Unit (SFU) System LCO 3.7.4 Two SFU subsystems shall be OPERABLE.

---

NOTE The control building envelope boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1,2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During Operations with a Potential for Draining the Reactor Vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SFU A.1 Restore SFU subsystem to 7 days subsystem OPERABLE status.

inoperable for reasonsother than Condition B.

B. T-we One or more B. 1 Initiate actions to implement Immediately SFU subsystems mitigating actions.

inoperable due to inoperable control AND building envelope B.2 Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> boundary in ensure control building MODES 1, 2, and envelope occupant

3. exposures to radiological hazards will not exceed limits.

AND B.43 Restore control building 24-heure 90 days envelope boundary to OPERABLE status.

DAEC 3.7-7 TSCR-092

SFU System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C. 1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, or

3. C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Required Action and ---- - ---------------

NOTE-------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A not met during movement D.1 Place OPERABLE Immediately of irradiated fuel SFU subsystem in the assemblies in the isolation mode.

secondary containment, during OR CORE ALTERATIONS, or during OPDRVs. D.2.1 Suspend movement Immediately of irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to Immediately suspend OPDRVs.

E. Both SFU subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

(continued)

DAEC 3.7-8 TSCR-092

SFU System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Both SFU subsystems - ------------ NOTE-------

inoperable during LCO 3.0.3 is not applicable.

movement of irradiated fuel assemblies in the F. 1 Suspend movement Immediately secondary containment, of irradiated fuel during CORE assemblies in the ALTERATIONS, or secondary during OPDRVs. containment.

OR AND One or more SFU F.2 Suspend CORE Immediately subsystems inoperable ALTERATIONS.

due to an inoperable control building envelope AND boundary duning movement of irradiated F.3 Initiate action to Immediately fuel assemblies in the suspend OPDRVs.

secondarycontainment, during CORE ALTERATIONS, or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Operate each SFU subsystem for 31 days a 15 minutes.

SR 3.7.4.2 Perform required SFU filter testing in In accordance accordance with the Ventilation Filter Testing with the VFTP Program (VFTP).

(continued)

DAEC 3.7-9 TSCR-092

SFU System 3.7.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.4.3 Verify each SFU subsystem actuates on an 24 months actual or simulated initiation signal.

SR 3.7.4.4 Perform requiredControl Building Envelope In accordance unfiltered air inleakage testing in accordance with the with the Control Building Envelope Habitability Control Program. Vent;y each SFU subsystem can Building maintain a pesitive pressure of ! 0.1 inches, Envelope water gauge relatie to the outside atmosphere Habitability drn t,,he,~.iltonmade of p*c.ati. n at a fo Program rate of 1000 cfmn +/- 10%-. 24 months era STAGGERED TEST-BAS14S DAEC 3.7-10 TSCR-092

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued)

The first Type A test after the September 1993 Type A test shall be performed no later than September 2008.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 45.7 psig.

The maximum allowable primary containment leakage rate, La, at Pa, shall be 2.0% of primary containment air weight per day.

Leakage Rate acceptance criteria are:

a. Primary Containment leakage rate acceptance criterion is < 1.0 La.

During the first startup following testing in accordance with this program, the leakage rate acceptance criteria are: < 0.60 La for the Type B and Type C tests; and, _<0.75 La for the Type A tests; and

b. The air lock testing acceptance criterion is overall air lock leakage rate <

0.05 La when tested at > Pa.

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

5.5.13 Control Buildinq Envelope HabitabilityProgram A ControlBuilding Envelope (CBE) HabitabilityProgramshall be established and implemented to ensure that CBE habitabilityis maintainedsuch that, with an OPERABLE Standby Filter Unit System, CBE occupants can control the reactorsafely under normal conditions and maintain it in a safe condition following a radiologicalevent. The program shall ensure that adequate radiationprotection is provided to permit access and occupancy of the CBE under design basis accident (DBA) conditions without personnel receiving radiationexposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

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

b. Requirements for maintainingthe CBE boundaryin its design condition including configuration control andpreventive maintenance.

DAEC 5.0-18 TSCR-092

Programs and Manuals 5.5 5.5 Programsand Manuals 5.5.13 Control Building Envelope HabitabilityProgram (continued)

c. Requirements for (i) determining the unfiltered air inleakage past the CBE boundary into the CBE in accordancewith the testing methods and at the Frequenciesspecified in Sections C. I and C.2 of Regulatory Guide 1.197, "DemonstratingControl Room Envelope Integrityat NuclearPower Reactors," Revision 0, May 2003, and (ii) assessing CBE habitabilityat the Frequenciesspecified in Sections C. 1 and C.2 of Regulatory Guide 1.197, Revision 0.

d. Measurement,at designatedlocations, of the CBE pressure relative to the outside atmosphere during the pressurizationmode of operation by one subsystem of the SFU System, operatingat the flow rate requiredby the VFTP, at a Frequencyof 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CBE boundary.

e. The quantitative limits on unfiltered air inleakage into the CBE. These limits shall be stated in a manner to allow direct comparison to the unfiltered airinleakage measured by the testing described in paragraph

c. The unfiltered air inleakage limit for radiologicalchallenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.

f. The provisions of SR 3.0.2 are applicable to the Frequenciesfor assessing CBE habitability,determining CBE unfiltered inleakage, and measuring CBE pressure and assessing the CBE boundary as required by paragraphsc and d, respectively.

DAEC 5.0-19 TSCR-092

SFU System B 3.7.4 B 3.7 PLANT SYSTEMS B 3.7.4 Standby Filter Unit (SFU) System BASES BACKGROUND The SFU System provides a protected environment from which occupants can control the unit following an uncontrolledrelease of radioactivityradiologi*ally controlled enVironment f#ro which the unit can be safely operated following a Design Basis Accident The safety related function of the SFU System includes two independent and redundant high efficiency air filtration subsystems for emergency treatment of outside supply air and a ControlBuilding Envelope (CBE) boundary that limits the inleakage of unfiltered air. Each SFU subsystem consists of a demister, an electric heater, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section, a second HEPA filter, a fan, and the associated ductwork, valves or dampers, doors, barriers,and instrumentationduGt-*-ar aid dampeFs. Demisters remove water droplets from the airstream.

HEPA filters remove particulate matter, which may be radioactive.

The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay.

The CBE is the area within the confines of the CBE boundary that contains the spaces that control building occupants inhabit to control the unit during normal and accidentconditions. This area encompasses the control building, and may encompass other non-criticalareas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CBE is protected during normal operation,natural events, and accident conditions. The CBE boundary is the combination of walls, floor, roof, ducting, doors, penetrationsand equipment that physically form the CBE. The OPERABILITY of the CBE boundary must be maintained to ensure that the inleakage of unfiltered airinto the CBE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CBE occupants. The CBE and its boundaryare defined in the Control Building Envelope HabitabilityProgram.

DAEC B 3.7-18 TSCR-092

SFU System B 3.7.4 BASES BACKGROUND The SFU System is a standby system, parts of which also operate (continued) during normal unit operations to maintain the CBE Oe0trer rOGR enviienmen . Upon receipt of the initiation signal (indicative of conditions that could result in radiation exposure to CBE occupants contro* room personnel), the SFU System automatically starts and a system of dampers isolates the CBE contrOI buildin to minimize prevent infiltration of contaminated air into the CBE centrol-rem.

Outside air is taken in at the normal ventilation intake and is passed through one of the charcoal adsorber filter subsystems for removal of airborne radioactive particles before being mixed with the recirculated air. The air (outside and/or recirculated) is cooled by Air Conditioning (AC) units supplied by the Control Building Chillers (CBCs). The SFUs and AC units share common ductwork such that either SFU may supply outside air to either AC unit. However, the CBCs and AC units are addressed as part of LCO 3.7.5, "Control Building Chiller System."

The SFU System is designed to maintain a habitable environment in the CBE the control ro m en.irnment

. for a 30 day continuous occupancy after a DBA without exceeding 5 rem total effective dose equivalent (TEDE). A single SFU subsystem operatingat a flow rate of 1000 cfm +/-10% will pressurize the CBE entrFI rFOm to _>

0. 1 inches water gauge pressure above atmospheric pressure, under calm wind conditions (i.e. less than 5 mph wind speed) relative to the outside atmosphere. This will minimize pFevent infiltration of air from the outside atmosphere-......

s buildings.

,uding-Other areas in the CBEGtr.,buildmi-ng

,, that directly communicate with the CBE contr4I From via HVAC system ductwork or doors are also required to maintain a positive pressure relative to the adjacent areas outside the CBE ,,,v building. ,,I This will assure that leakage is from the CBE to the adjacent areas or outdoors.

,eFt,bu.ilding SFU System operation in maintaining a habitableenvironment in the CBE cont*ro room habiability; is discussed in the UFSAR, Sections 6.4 and 9.4.4, (Refs. 1 and 2, respectively).

(continued)

DAEC B 3.7-19 TSCR-092

SFU System B 3.7.4 BASES APPLICABLE The ability of the SFU System to maintain the habitability of the SAFETY CBE cOntFGI-r Om is an explicit assumption for the safety analyses ANALYSES presented in the UFSAR, Sections 6.4 and 15.2 (Refs. 1 and 3, respectively). The SFU System is assumed to operate in the isolation mode following a DBA loss of coolant accident, fucl handling accident, main steanm line break, and cont*rol*rd drop aseident. The radiological doses to the CBE occupants entF0I FGGm*.peFS..nel as a result of the various DBAs are summarized in Reference 3. No single active failure will cause the loss of CBE "G"G-*Ir.G.. habitability.

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

LCO Two redundant subsystems of the SFU System are required to be OPERABLE to ensure that at least one is available, assuming if a single active failure disables the other subsystem. Total SFU Ssystem failure, such as from a loss of both ventilation subsystems or from an inoperable CBE boundary, could result in exceeding a dose of 5 rem TEDE to the CBE occupantsto-the control room operator in the event of a DBA.

T-he Each SFU subsystem System is considered OPERABLE when the individual components necessary to limit CBE occupant exposure co*ntro operator +.p.s... are OPERABLE On-bath su-bsystems. A subsystem is considered OPERABLE when its associated:

a. Fan is OPERABLE;

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

c. Heater, demister, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

(continued)

DAEC B 3.7-20 TSCR-092

SFU System B 3.7.4 BASES LCO inaddition, the contro.roo. boundary must be maintained ina (continued) condition suffi.iently leak tight such that the pressur-zation limit of SR 3.7-.4.4 can be mnet. However, it is accGeptable for access doors to be open for normal coentrol roomn entry and exit and not co-nsider it to be a failure to mneet the LCO-.

In orderfor the SFU subsystems to be consideredOPERABLE, the CBE boundarymust be maintainedsuch that the CBE occupant dose from a large radioactiverelease does not exceed the calculated dose in the licensing basis consequence analyses for DBAs.

The LCO is modified by a Note allowing the CBE Gnt'el-buildi* g boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CBE boundary that can be rapidly restoredto the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through the 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 proceduralizedand consist of stationing a dedicated individual at the opening who is in continuous communication with the operatorsin the CBEeontFel teem. This individual will have a method to rapidly close the opening and to restore the CBE boundary to a condition equivalent to the design condition when a need for CBE GGntFGl buildiRg isolation is indicated.

APPLICABILITY In MODES 1, 2, and 3, the SFU System must be OPERABLE to ensure that the CBE will remain habitableG"÷t"GI .pefa.e" expes during and following a DBA, since the DBA could lead to a fission product release.

In MODES 4 and 5, the probability and consequences of a DBA are reduced because of the pressure and temperature limitations in these MODES. Therefore, maintaining the SFU System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:

a. During Operations with a Potential for Draining the Reactor I Vessel (OPDRVs);

(continued)

DAEC B 3.7-21 TSCR-092

SFU System B 3.7.4 BASES APPLICABILITY b. During CORE ALTERATIONS; and (continued)

c. During movement of irradiated fuel assemblies in the secondary containment.

ACTIONS A.1 With one SFU subsystem inoperable, for reasons other than an inoperable CBE boundary,the inoperable SFU subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE SFU subsystem is adequate to perform the CBE occupant control room rndiation protection function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of the FedUced SFU System function Gapabi~lit. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities.

B.1, B.2, and B.3 If the unfiltered inleakage of potentially contaminatedairpast the CBE boundary and into the CBE can result in CBE occupant radiologicaldose greaterthan the calculateddose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), the CBE boundaryis inoperable. Actions must be taken to restore an OPERABLE CBE boundary within 90 days.

During the period that the CBE boundaryis considered inoperable,action must be initiatedto implement mitigating actions to lessen the effect on CBE occupants from the potential hazards of a radiologicalevent. 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 CBE occupant radiologicalexposures will not exceed the calculateddose of the licensing basis analyses of DBA consequences. These mitigating actions (i.e., actions that are (continued)

DAEC B 3.7-22 TSCR-092

SFU System B 3.7.4 BASES ACTIONS taken to offset the consequences of the inoperable CBE (continued) boundary) should be preplannedfor implementation upon entry into the condition, regardlessof whether entry is intentionalor 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 reasonablebased on the low probability of a DBA occurringduring this time period, and the use of mitigatingactions. The 90 day Completion Time is reasonablebased on the determinationthat the mitigating actions will ensure protection of CBE occupants within analyzed limits while limiting the probabilitythat CBE occupants will have to implement protective measures that may adversely affect their ability to control the reactorand 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 CBE boundary.

Ifthe main control building boundary is inaperabi MODES 1,2, and 3, the SFUJ trains cannot pe~fOrm their nene functeins. Acftens must be taken to restore an OPERABLE control building boundary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the period that the control building bounda. y is inoperable, appfopiae*

compensatory mneasures (consistent with the intent of GDC 19) should be utilized to protect control roomn operators from potential hazards such as radioactive contamination, tOXiG chemicals, smoke, temperature and relative humidity, and to ensure physica securiy Prplned mneasures should be available to address t esecncerns for intentional and unintentional entry into the condition. The 24 houI Copletion Gr Timne is reasonable based on the loW probability of a DRA occurring during this time period,an the use ofcmesatory measures. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time isatpial easonable time to diagnose, plan and possibly repaIr and test mo9st problems with the control building boundary.-

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable SFU subsystem or the CBE G.Rt.b.building boundary cannot be restored to OPERABLE status within the assoeiated 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 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 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 (continued)

DAEC B 3.7-23 TSCR-092

SFU System B 3.7.4 BASES ACTIONS conditions from full power conditions in an orderly manner and (continued) without challenging unit systems.

D.1, D.2.1, D.2.2, and D.2.3 LCO 3.0.3 is not applicable in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, if the inoperable SFU subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE SFU subsystem may be placed in the isolation mode (i.e., one SFU subsystem in operation with the control building isolated). This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action D. 1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the CBE GAtcIl reeom. This places the unit in a condition that minimizes the accident risk.

If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Action must continue until the OPDRVs are suspended.

(continued)

DAEC B 3.7-24 TSCR-092

SFU System B 3.7.4 BASES ACTIONS (continued) E.1 If both SFU subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable CBE GGntFrI building boundary (i.e., Condition B), the SFU System may not be capable of performing the intended function and the unit is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

F.1, F.2, and F.3 LCO 3.0.3 is not applicable in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, with two SFU subsystems inoperable, or with one or more SFU subsystems inoperable due to an inoperable CBE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the CBE GontFrI -9re9M. This places the unit in a condition that minimizes the accident risk.

If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended.

(continued)

DAEC B 3.7-25 TSCR-092

SFU System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.1 REQUIREMENTS Operating each SFU subsystem for Ž! 15 minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage or fan or motor failure, can be detected for corrective action. Since the SFU charcoal is tested at a Relative Humidity > 95%, extended operation of the electric heaters is not required. Thus, each subsystem need only be operated for _Ž15 minutes to demonstrate the function of each subsystem. The function of the SFU electric heaters is to pre-heat incoming air to above 40°F to ensure adsorption occurs within the temperature range that charcoal testing is performed. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.

SR 3.7.4.2 This SR verifies that the required SFU testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test Ffrequencies and additional information are discussed in detail in the VFTP.

SR 3.7.4.3 This SR verifies that on an actual or simulated initiation signal, each SFU subsystem starts and operates. This SR also ensures that the control building ROOm isolates. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.7.1, "Standby Filter Unit Instrumentation," overlaps this SR to provide complete testing of the safety function. While this Surveillance can be performed with the reactor at power, operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was found to be acceptable from a reliability standpoint.

SR 3.7.4.4 This SR Yerifies the integrity of the control room cnclosurc and the assumned inleakage rates of potentially contaminated air. The cOntaminatcd adjacent areas, as periodically tested to Yerify prope function of the SFUL System. During the emergency mode of control room Ž!0.1 inches water gauge above atmospheric_

(continued)

DAEC B 3.7-26 TSCR-092

SFU System B 3.7.4 BASES SURVEILLANCE pressure, under c.alm. wind onditions (i.e. less than 5 mph wind REQUIREMENTS speed) t,-r-event un...f.lte-ed inleakag.. The SFU System . iS (continued) d to maintain this po8itive pressure at a floW rate of 1

,.fm ' 10% to the control room in the isol"io medi. The Frequency of 24 F,,,,nts on a STAGGER ED ITES. BA-1-;,

consisteent with industr,' paratice and ether filtration systems SRs.

This SR verifies the OPERABILITY of the CBE boundary by testing for unfiltered airinleakage past the CBE boundary and into the CBE. The details of the testing are specified in the Control Room Envelope HabitabilityProgram.

The CBE is consideredhabitable when the radiologicaldose to CBE occupants calculatedin the licensingbasis analyses of DBA consequences is no more than 5 rem TEDE. This SR verifies that the unfiltered airinleakage into the CBE is no greaterthan the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greaterthan the assumed flow rate, Condition B must be entered. RequiredAction B.3 allows time to restore the CBE boundary to OPERABLE status provided mitigating actions can ensure that the CBE remains within the licensing basis habitabilitylimits for the occupants following an accident. Compensatorymeasures 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 Appendix F (Ref. 5). These compensatory measures may also be used as mitigating actions as requiredby Required Action B. 2.

Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 6).

Options for restoringthe CBE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairingthe CBE boundary,or a combination of these actions.

Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CBE boundary has been restoredto OPERABLE status.

DAEC, B 3.7-27 TSCR-092

SFU System B 3.7.4

BASES, REFERENCES 1. UFSAR, Section 6.4.

2. UFSAR, Section 9.4.4.

3. UFSAR, Section 15.2.

4. Regulatory Guide 1.196.

5. NEI 99-03, "ControlRoom HabitabilityAssessment," June 2001.

6. Letter from Eric J. Leeds (NRC) to James W, Davis (NEI) dated January30, 2004, "NEI Draft White Paper,Use of Generic Letter 91-18 Processand Altemative Source Terms in the Context of Control Room Habitability."

(ADAMS Accession No. ML040300694).

DAEC B 3.7-28 TSCR-092

ENCLOSURE C PROPOSED TECHNICAL SPECIFICATION PAGES (RE-TYPED) 6 Pages Follow

SFU System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Standby Filter Unit (SFU) System LCO 3.7.4 Two SFU subsystems shall be OPERABLE.

---

NOTE The control building envelope boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During Operations with a Potential for Draining the Reactor Vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SFU A.1 Restore SFU subsystem to 7 days subsystem OPERABLE status.

inoperable for reasons other than Condition B.

B. One or more B.1 Initiate actions to implement Immediately SFU subsystems mitigating actions.

inoperable due to inoperable AND control building B.2 Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> envelope ensure control building boundary in envelope occupant MODES 1, 2, and exposures to radiological

3. hazards will not exceed limits.

AND B.3 Restore control building 90 days envelope boundary to OPERABLE status.

DAEC 3.7-7 Amendment No.

SFU System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C. 1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or AND B not met in MODE 1, 2, or 3. C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Required Action and -------------- NOTE------------

associated LCO 3.0.3 is not applicable.

Completion Time of Condition A not met D.1 Place OPERABLE SFU Immediately during movement of subsystem in the irradiated fuel isolation mode.

assemblies in the secondary OR containment, during CORE D.2.1 Suspend movement Immediately ALTERATIONS, or of irradiated fuel during OPDRVs. assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to Immediately suspend OPDRVs.

E. Both SFU subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

(continued)

DAEC 3.7-8 Amendment No.

SFU System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Both SFU subsystems- ------------ NOTE-------

inoperable during LCO 3.0.3 is not applicable.

movement of irradiated fuel assemblies in the F. 1 Suspend Immediately secondary containment, movement of during CORE irradiated fuel ALTERATIONS, or assemblies in the during OPDRVs. secondary containment.

OR AND One or more SFU subsystems inoperable F.2 Suspend CORE Immediately due to an inoperable ALTERATIONS.

control building envelope boundary during AND movement of irradiated fuel assemblies in the F.3 Initiate action to Immediately secondary containment, suspend OPDRVs.

during CORE ALTERATIONS, or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Operate each SFU subsystem for 31 days

_ 15 minutes.

SR 3.7.4.2 Perform required SFU filter testing in In accordance with accordance with the Ventilation Filter Testing the VFTP Program (VFTP).

(continued)

DAEC 3.7-9 Amendment No.

SFU System 3.7.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.4.3 Verify each SFU subsystem actuates on an 24 months actual or simulated initiation signal.

SR 3.7.4.4 Perform required Control Building Envelope In accordance unfiltered air inleakage testing in accordance with the with the Control Building Envelope Habitability Control Program. Building Envelope Habitability Program DAEC 3.7-10 Amendment No.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Primary Containment Leakage Rate Testing Program (continued)

The first Type A test after the September 1993 Type A test shall be performed no later than September 2008.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 45.7 psig.

The maximum allowable primary containment leakage rate, La, at Pa, shall be 2.0% of primary containment air weight per day.

Leakage Rate acceptance criteria are:

a. Primary Containment leakage rate acceptance criterion is < 1.0 La.

During the first startup following testing in accordance with this program, the leakage rate acceptance criteria are: < 0.60 La for the Type B and Type C tests; and, _<0.75 La for the Type A tests; and

b. The air lock testing acceptance criterion is overall air lock leakage rate _<

0.05 La when tested at > Pa.

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

5.5.13 Control Building Envelope Habitability Program A Control Building Envelope (CBE) Habitability Program shall be established and implemented to ensure that CBE habitability is maintained such that, with an OPERABLE Standby Filter Unit System, CBE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CBE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

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

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

DAEC 5.0-18 Amendment No.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Control Building Envelope Habitability Program (continued)

c. Requirements for (i) determining the unfiltered air inleakage past the CBE boundary into the CBE 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 CBE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

d. Measurement, at designated locations, of the CBE pressure relative to the outside atmosphere during the pressurization mode of operation by one subsystem of the SFU System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CBE boundary.

e. The quantitative limits on unfiltered air inleakage into the CBE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.

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

DAEC 5.0-18a Amendment No.