NG-08-0312, Updated Technical Specification and Bases Pages Related to Technical Specification Change Request (TSCR-092): Consolidated Line Item Improvement; Adoption of Changes to Standard Specifications . .

Updated Technical Specification and Bases Pages Related to Technical Specification Change Request (TSCR-092): Consolidated Line Item Improvement; Adoption of Changes to Standard Specifications . .

ML081420014
Person / Time
Site:	Duane Arnold
Issue date:	05/08/2008
From:	Richard Anderson Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-08-0312, TSCR-092, TSTF-448, Rev 3
Download: ML081420014 (28)

Text

FPL Energy Duane Arnold, LLC 0 FPL Energy.

3277 DAEC Road Palo, Iowa 52324 Duane Arnold Energy Center May 8, 2008 NG-08-0312 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Updated Technical Specification and Bases Pages Related to 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

References:

1. Letter, G. Van Middlesworth (FPL Energy Duane Arnold) to Document Control Desk (USNRC), "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," dated June 29, 2007, NG-07-0493 (ML072040245)

2. Letter, K. Feintuch (USNRC) to Richard L. Anderson (FPL Energy Duane Arnold), "Request for Additional Information Related to Amendment Request to Change Technical Specification Sections 3.7.4 and 5.5.13 Based on Model Text from Technical Specifications Task Force Traveler TSTF-448, Revision 3, Control Room Habitability (TAC No. MD6020)," dated December 3, 2007 (ML073201102)

3. Letter, Richard L. Anderson (FPL Energy Duane Arnold) to Document Control Desk (USNRC), Response to Request for Additional Information Related to 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," dated January 28, 2008, NG-08-0001 (ML080390536)

In Reference 1, FPL Energy Duane Arnold requested an amendment to the Duane Arnold Energy Center (DAEC) Technical Specifications (TS) consisting 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 /14 Z TSTF-448, Revision 3.

Aco(

NG-08-0312 May 8, 2008 Page'2 of 2 By letter dated December 3, 2007, the Staff issued a request for additional information (Reference 2) regarding Reference 1. A conference call with the NRC on Reference 2 was also held on January 8, 2008. In this phone call, it was agreed that the DAEC TS should reflect the testing that was performed in the response to Generic Letter 2003-01, "Control Room Habitability." FPL Energy Duane Arnold also agreed to perform a periodic surveillance of on-site and off-site stationary and mobile hazardous chemical sources that could potentially threaten Control Building (CB) habitability. Reference 3 provided replacement marked-up TS and Bases pages, as well as replacement clean-typed TS pages, reflecting the responses to the requests of Reference 2.

In a phone call with the NRC dated March 27, 2008, the NRC expressed concerns that References 1 and 3 did not fully address the smoke and chemical hazards described in TSTF-448, Revision 3. FPL Energy Duane Arnold agreed to review and update the TS and Bases pages in the Reference 1 and 3 submittals.

Enclosure 1 to this letter provides replacement marked-up TS and Bases pages and Enclosure 2 provides the clean-typed TS pages, reflecting the changes discussed in the phone call dated March 27, 2008. These pages supersede their corresponding pages in References 1 and 3.

This letter does not alter the evaluation or conclusions of Reference 1. 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.

A copy of this submittal is being forwarded to our appointed state official pursuant to 10 CFR 50.91.

Commitments made in References 1 and 3 remain valid and are not changed by this submittal.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on May 8, 2008.

Richard L. Anderson Vice President, Duane Arnold Energy Center FPL Energy Duane Arnold, LLC Enclosures cc: Administrator, Region Ill, USNRC Project Manager, DAEC, USNRC Senior Resident Inspector, DAEC, USNRC D. McGhee (State of Iowa)

Enclosure 1 to NG-08-0312 Enclosure 1 Revised Proposed Technical Specification Pages (Marked-Up) and Bases Pages (Marked-Up) 18 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.

-- -------------------------------------- IIL j r- -------------------------------------------------

The control building envelope (CBE) 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. Two One or more B. 1 Initiate actions to implement Immediately SFU subsystems mitigating actions.

inoperable due to inoperable Gentrel AND buildin CBE 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 CBE occupant MODES 1, 2, and exposures to radiological

3. hazards will not exceed limits and verify by administrativemeans that CBE occupants are protected from smoke and chemical hazards.

AND B.4-3 Restore ,-,-r-I build-ing 24heuFs 90 days CBE 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 secodaryisolation 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 CBE 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

Ž15 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 required CBE unfiltered airinleakage In accordance testing in accordance with the Control Building with the Envelope HabitabilityProgram. Verify-eaGh Control SFU1 subsystem* an maintain a positive Building pres'ure of " 0.1 inches water gauge relativ. to Envelope the outside atmosphere during the isolation Habitability mode of operation at a flow rate oEf 1000 ,f., + Program 10T%. 24EmSnth-OR-a STAGGERED TEST-BASIS DAEC 3.7-10 TSCR-092

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testingq Progqram (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 HabitabilityProgram A Control Building Envelope (CBE) HabitabilityProgramshall be established and implemented to ensure that CBE habitabilityis maintainedsuch that, with an OPERABLE Standby FilterUnit System, CBE occupants can control the reactorsafely under normal conditions and maintain it in a safe condition following a radiologicalevent, hazardous chemical release, or a smoke challenge. 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 radiation exposures 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 boundary in its design condition including configurationcontrol and preventive maintenance.

(continued)

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 inleakagepast the CBE boundary into the CBE in accordance with the testing methods and at the Frequenciesspecified in Sections C. I and C.2 of Regulatory Guide 1.197, "DemonstratingControl Room Envelope Integrity at NuclearPower Reactors," Revision 0, May 2003, and (ii) assessing CBE habitabilityat the Frequenciesspecified in Sections C. I and C.2 of Regulatory Guide 1.197, Revision 0.

d. Measurement, at designated locations, of the CBE pressure relative to all external areasadjacent to the CBE boundary 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 quantitativelimits on unfiltered airinleakage 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 radiologicalchallenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered airleakage limits for hazardouschemicals must ensure that the exposure of CBE occupants to these hazards will be within the assumptions in the licensing basis.

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 uncontrolled release of radioactivity,hazardous chemicals or smoke. ,adiel"gially contrOlleed environment from which the unit can be safely operate following a Design Basis Accident (DB/A'*)

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 Control Building 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 instrumentationdUtcw-rk aPnd damper-s. 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 accident conditions. This area encompasses the control building, and may encompass other non-criticalareasto 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 maintainedto 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 boundary are defined in the Control Building Envelope HabitabilityProgram.

(continued)

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 control room ervionment. Upon receipt of the initiation signal (indicative of conditions that could result in radiation exposure to CBE occupants ontrol rom persoe l), the SFU System automatically starts and a system of dampers isolates the CBE controel-bufilin to minimize prevent infiltration of contaminated air into the CBE control -oomre.

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 tho control room enVironment 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 control room 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 Reactor Building and outside atmosphere. A single SFU subsystem operatingat a flow rate of 1000 cfm +/-10% will also pressurize the CBE to a positive pressure above atmosphericpressure, under calm wind conditions (i.e. less than 5 mph wind speed) relative to external areasadjacent to the CBE boundary. This will minimize pFevent infiltration of air from all surroundingareas adjacentto the CBE boundary surrounding bu,"ildingS.

Other areas in the CBE contol- buil&4ng that directly communicate with the CBE contro! room via HVAC system ductwork or doors are also required to maintain a positive pressure relative to the adjacent areas outside the CBE control building. This will assure that leakage is from the CBE control-building to the adjacent areas or outdoors.

SFU System operation in maintaining a habitableenvironment in the CBE control roorn habitability 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 centreGroom 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 lo66 of coolant accident, fuel handling accident, mnain steamn line break, and control rod drop aGGident. The radiological doses to the CBE occupants Genti4 er-o pe.senne. as a result of the various DBAs are summarized in Reference 3. No single active failure will cause the loss of CBE

.,nt,-,

, ee. n habitability.

There are no offsite or onsite hazardouschemicals that would pose a credible threat to CBE habitability(Ref. 7). Consequently, engineered controls for the CBE are not requiredto ensure habitabilityagainsta chemical threat.

The evaluation of a smoke challenge demonstratedthat smoke will not result in the inability of the CBE occupants to control the reactoreither from the control room or from the remote shutdown system (Ref. 7). The assessment verified that a fire or smoke event anywhere within the plant would not simultaneously render the remote shutdown system and the CBE uninhabitable,nor would it prevent access from the CBE to the remote shutdown system in the event remote shutdown is required. No automatic SFU actuation is requiredfor hazardouschemical releases or smoke and no Surveillance Requirements are requiredto verify OPERABILITY in cases of hazardous chemicals or smoke.

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 occupantste-the co,-ntrl room operators in the event of a DBA.

The Each SFU subsystem Systemn is considered OPERABLE when the individual components necessary to limit CBE occupant exposure control operator exposure are OPERABLE On-both (continued)

DAEC B 3.7-20 TSCR-092

SFU System B 3.7.4 BASES LCO subsystems. A subsystem is considered OPERABLE when its (continued) 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.

in addition, the control rom boundary must be maintained i condition sufficientlY leak tight such that the pressurization limnit otf SR 3.7.4. caR be met. However, it is acceptable for access doors to be open for normnal control roomr entry, and exit and no consider it to be a failure to meet the LCO-.

In order for the SFU subsystems to be considered OPERABLE, the CBE boundary must be maintainedsuch that the CBE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs. In the event of an inoperable CBE boundary in MODES 1, 2, or 3, mitigating actions are required to ensure CBE occupants are protected from hazardous chemicals and smoke.

DAEC does not have automatic SFU actuation for hazardous chemicals or smoke. Currentpracticesat DAEC do not utilize chemicals in sufficient quantity to present a chemical hazard to the CBE. Smoke is not consideredin the DAEC safety analysis.

Therefore, there are no specific limits at DAEC for hazardous chemicals or smoke.

The LCO is modified by a Note allowing the CBE vn ,bui&,4,g boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CBE boundary that can be rapidlyrestored to 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 CBE GOntF0l reem. This individual will have a method to rapidly close the (continued)

DAEC B 3.7-21 TSCR-092

SFU System B 3.7.4 BASES LCO opening and to restore the CBE boundary to a condition (continued) equivalent to the design condition when a need for CBE GGetrel building isolation is indicated.

APPLICABILITY In MODES 1, 2, and 3, the SFU System must be OPERABLE to ensure that the CBE will remain habitable ""te"-e" .per."

expesufe 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 Vessel (OPDRVs);

b. During CORE ALTERATIONS; and

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 radiation protection function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of the Fedueed SFU System function ,apability.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.

(continued)

DAEC B 3.7-22 TSCR-092

SFU System B 3.7.4 BASES ACTIONS B.1, B.2, and B.3 (continued) If the unfiltered inleakage of potentially contaminated airpast 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 boundary is inoperable. As discussed in the Applicable Safety Analyses section, the DAEC licensing basis identifies that CBE inleakage limits for hazardous chemicals and smoke are not necessary to protect the CBE occupants. Allowing verification by administrativemeans for hazardous chemicals and smoke is consideredacceptable, since the limit establishedfor radiologicalevents is the limiting value for determiningentry into Condition B for an inoperable CBE boundary. These administrative controls consist of the following:

• Verification that the periodic check of onsite and offsite hazardouschemical sources has been performed within the last year; and

• Verification that the smoke analysis of Reference 7 remains valid and current.

A periodic check of onsite and offsite hazardous chemical sources takes place once peryear to ensure no onsite or offsite sources of hazardous chemicals exist that could present a chemical hazard to CBE ocupants. No onsite or offsite sources of hazardous chemicals currently exist that could present a chemical hazard to CBE occupants.

Actions must be taken to restore an OPERABLE CBE boundary within 90 days.

During the period that the CBE boundary is considered inoperable,action must be initiatedto implement mitigating actions to lessen the effect on CBE occupants from the potential hazards of a radiologicalor chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CBE occupant radiologicalexposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences.

These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CBE boundary)should be (continued)

DAEC B 3.7-23 , TSCR-092

SFU System B 3.7.4 BASES ACTIONS (continued) preplanned for 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 probabilityof a DBA occurringduring this time period,and the use of mitigating actions. The 90 day Completion Time is reasonable based 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 theirability 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 reasonabletime to diagnose, plan and possibly repair,and test most problems with the CBE boundary.

If the mrain contrl. buildinRg boundar,' is nrable in MODES 1,2, and 3, the SFUJ trains canno~t pe~fOrm their itne

+.

functios. Actio must be taken to.resore an OPERABLE control building boundar'h ' within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Durnrg the period that the cor-ntrol building b.undar;i inoperable apprprite com.pensatory m.easures (consistent with the intent of GDC 19) should be utilized to protect control room operators frompteta hazards such as radioeative contaminatien, toxic chemicals, smoke, temperature and relative humidity, and to ensure physical security. Preplanned mneasures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Comnpletion Time is reasonable based o the low probability of a DB3A occurring during this time period, and the use Of comnpensator; measures. The 24 hoGur Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problemns with the co~ntrol building boundar,'.-

CA1 and C.2 In MODE 1, 2, or 3, if the inoperable SFU subsystem or the CBE GentreI-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 conditions from full power conditions in an orderly manner and without challenging unit systems.

(continued)

DAEC B 3.7-24 TSCR-092

SFU System B 3.7.4 BASES ACTIONS D.1, D.2.1, D.2.2, and D.2.3 (continued) 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 cnteI roeeom. 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.

E.1 If both SFU subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable CBE ,GR-rl, bui,,P4, 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.

(continued)

DAEC B 3.7-25 TSCR-092

SFU System B 3.7.4 BASES ACTIONS F.1, F.2, and F.3 (continued)

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 entrcI- Frm. 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 3.7-26 TSCR-092

SFU System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.1 REQUIREMENTS Operating each SFU subsystem for >_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 > 15 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 verifies the integFrity Of the Gontrol room enclosure ard the assumcd inleakage rates of potentially conRtaminated air. The controFl roorn positive p-ressue, with respect to) potentially conRtaminated adjacent areas, is periodically tested to verify prope-r fURtion of the SFU System. During the emergency mode ot opc.ation, the SF. System is designed to slightly pressurize the ontFrol room Ž 0.1 inches wateFr gauge above atmospnenhric (continued)

DAEC B 3.7-27 TSCR-092

SFU System B 3.7.4 BASES SURVEILLANCE pre.suro, under c*am wind conditions (i.e. less than 5 mph wind REQUIREMENTS speed) to prevent unfiltered inleakage. The SFU System is (continued) designed to maintain this p.siti'..e pressure at a f.ow rate of 1000 cfm +/- 109%to the control rOom in the isolatioRn mode. The Frequency of 24 monnths 6n a STAGGEREID TEST BASIS is consfiste-nt wi4th indust~' practice and other 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 considered habitable when the radiologicaldose to CBE occupants calculatedin the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CBE occupants are protected from hazardous chemicals and smoke.

ForDAEC, there is no automatic SFU actuation for hazardous chemical releases or smoke and there are no Surveillance Requirements that verify OPERABILITY in cases of hazardous chemicals or smoke. This SR verifies that the unfiltered air inleakage 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. Required Action B.3 allows time to restore the CBE boundary to OPERABLE status provided mitigatingactions 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 restoring the 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 restored to OPERABLE status.

DAEC B 3.7-28 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 Process and Alternative Source Terms in the Context of Control Room Habitability."

(ADAMS Accession No. ML040300694).

7. Letter from Mark A. Peifer (NMC, LLC) to Document Control Desk (USNRC) dated January28, 2005, "Generic Letter 2003-01: Control Room Habitability- Design Bases, Licensing Bases and Inleakage Testing Results. "(ADAMS Accession No. ML050390308).

DAEC B 3.7-28A TSCR-092

Enclosure 2 to NG-08-0312 Enclosure 2 Revised Proposed Technical Specification Pages (Clean-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 (CBE) 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 SFU B.1 Initiate actions to implement Immediately subsystems mitigating actions.

inoperable due to inoperable CBE AND boundary in 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 /> MODES 1, 2, and ensure CBE occupant

3. exposures to radiological hazards will not exceed limits and verify by administrative means that CBE occupants are protected from smoke and chemical hazards.

AND B.3 Restore CBE boundary to 90 days 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 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 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 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 CBE 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 accordance with the Ventilation Filter Testing with 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 CBE unfiltered air inleakage In accordance testing in accordance with the Control Building with the Envelope Habitability Program. Control Building Envelope Habitability Program DAEC 3.7-10 Amendment No.

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 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, hazardous chemical release, or a smoke challenge. 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 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 maintaining the CBE boundary in its design condition including configuration control and preventive maintenance.

(continued)

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 all external areas adjacent to the CBE boundary 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. Unfiltered air leakage limits for hazardous chemicals must ensure that the exposure of CBE occupants to these hazards will be within the assumptions in the licensing basis.

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.