Text

License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (CLIIP)
	ML13205A160
Person / Time
Site:	Hatch
Issue date:	07/23/2013
From:	Pierce C; Southern Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	NL-13-0058
	Download: ML13205A160 (72)
	v • d • e

Charles R. Pierce Southern Nuclear Regu latory Affa irs Director Operating Company, Inc.

40 Inverness Ce nter Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7872 Fax 205.992.7601 July 23, 2013 SOUTHERN ' \

COMPANY Docket Nos.: 50-321 NL-13-0058 50-366 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (CLlIP)

Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90 Southern Nuclear Operating Company (SNC) is submitting a request for an amendment to the technical specifications (TS) for Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2.

The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3. provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS pages m;:Jrked up to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides existing TS Bases pages marked up to show the proposed changes.

SNC requests approval of the proposed license amendments by February 1, 2014. The proposed changes would be implemented within 180 days of issuance of the amendment.

In accordance with 10 CFR 50.91 (b)(1), "State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated Georgia officials.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

U. S. Nuclear Regulatory Commission NL-13-0058 Page 2 Mr. C. R. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, C. R. Pierce Regulatory Affairs Director CRP/RMJ Sworn to and subscribed before me this ~3 day of C)~ , 2013.

~AA£~k Notary Publtc My commission expires: /1-0 "Z 0-/"3

Enclosures:

1. Basis for Proposed Change

2. HNP Technical Specification Marked Up Pages

3. HNP Technical Specification Clean Typed Pages

4. HNP Technical Specification Bases Marked Up Pages (for information only) cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President - Hatch Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RType: CHA02.004 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Hatch Mr. E. D. Morris, Senior Resident Inspector - Hatch State of Georgia Mr. J. H. Turner, Environmental Director Protection Division

Edwin I. Hatch Nuclear Plant license Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision Using the Consolidated line Item Improvement (ClIIP)

Enclosure 1 Basis for Proposed Change to NL-13-0058 Basis for Proposed Change Table of Contents 1.0 Description 2.0 Assessment 3.0 Regulatory Analysis 4.0 Environmental Evaluation E1-1

NL-13-0058 I-'rc,oo~:>ea Change 1.0 oro,oOl:iea amendment would modify technical specification (TS) requirements related to control room envelope habitability in 3.7.4, "Main Control Room Environmental Control (MCREC) and TS Section 5.5, "Program Manuals".

are consistent with Nuclear Regulatory Commission (NRG) approved Industryffechnical Specification Task Force (TSTF) change TSTF-448 Revision 3. The availability of this improvement was published in Register on January 17, 2007 as the consolidated line item improvement (CUIP).

2.0 Nuclear Operating Company the safety evaluation 17,2007 as part of the CLlIP. a review of the NRC as well as the supporting information to support TSTF-448. SNC concluded that the justifications presented in proposal and the safety evaluation by the NRC staff are applicable to I. Hatch Nuclear Plant (HNP), Units 1 justify this amendment for the incorporation the changes to the HNP Units 1 and 2 The Traveler and model Safety Evaluation applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GOG). HNP Unit 1 was not licensed to the 10 CFR 50, Appendix A, GOC. The HNP Unit 1 construction permit was received under the 70 general criteria, as discussed in section F.3 of the U (Appendix F has since been as historical). The HNP Unit 1 equivalents the referenced GOCs in the model

... 10 50 Appendix A Criterion 1, "Quality and Records" systems, and shall be deSigned, fabricated, erected, and tested commensurate with importance of the safety functions Where generally codes and standards are they shall be identified and to determine their applicability, and sufficiency and shall supplemented or modified as to assure a quality product in keeping with the required safety function. A quality assurance program shall be established and implemented in to provide adequate assurance that structures, systems, and components will satisfactorily perform their functions. Appropriate records of fabrication, erection, and of structures, systems, and components important to safety shall be maintained by or under the control of the unit licensee throughout the life unit.

HNP Unit 1 Equivalent: 1967 GDC 1 , "Quality Standards" system and components reactor facilities which are to prevention of accidents which the public health and safety or to mitigation of their .l"Ion1'itlol"l and

1 to NL-13-0058 Basis for Proposed Change fabricated, and erected quality standards that reflect the importance of the safety function to be performed. Where generally recognized codes or standards on design, materials, fabrication, and inspection are used, they shall be identified. Where adherence such codes or standards not suffice to assure a quality product in keeping with the safety function, they shall be supplemented or modeled a Quality assurance programs, test procedures, and inspection acceptance levels to be used shall be identified. A showing of sufficiency and applicability of codes, standards, quality assurance programs, test procedures, and inspection acceptance levels used is required.

10 CFR 50 Appendix A Criterion "Design Basis for Protection Against Natural Phenomena" Structures, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. The design for these structures, systems, and components shall reflect: (1) Appropriate consideration of the most severe of the natural phenomena that been historically reported for the site and surrounding with sufficient margin for the limited accuracy, quantity, and period of time in which historical data have been accumulated, (2) appropriate combinations of the effects of normal and accident conditions with effects of the natural phenomena and (3) the importance of the safety functions to be performed.

HNP Unit 1 Equivalent: 1967 GDC Criterion 2, "Performance Standards" Those systems and components of reactor facilities which are essential to the prevention of accidents which could the public health and safety or to mitigation of their consequences shall be deSigned, fabricated, and erected to performance that will enable the facility to withstand, without loss of the capability to protect the public, the additional forces that might be imposed by natural phenomena such as earthquakes, tornados, flooding conditions, winds, and other local site effects. The design so established shall reflect: (a)

Appropriate consideration of the most severe of these natural phenomena that have been recorded for the site and the surrounding area and (b) an appropriate margin for withstanding forces than recorded to rClTI""f'T uncertainties about historical data and their suitability as a basis for design.

10 50 Appendix A Criterion 3, Protection" Structures, systems, and components important to designed and located to minimize, consistent with other safety the probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability shall provided and designed to minimize the effects of fires on structures, systems, and components important to safety. Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair safety capability of these structures, systems, and components.

-3 to NL-13-0058 Basis for Proposed Change HNP Unit 1 Equivalent: 1967 GDC Criterion 3, Protection" The reactor facility shall be designed (1) to minimize the probability ot events such as fires and explosions and (2) to minimize the potential effects of such to satety. Noncombustible and fire resistant materials shall be used whenever practical throughout the facility, particularly in areas containing critical portions of the facility such as containment, control room, and components of engineered safety features.

10 CFR 50 Appendix A Criterion 4, "Environmental and Dynamic Effects Design Structures, systems, and components important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions with normal operation, maintenance, testing. and postulated accidents, including loss-ot-coolant accidents. structures, systems, and components shall appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit. However, dynamic with postulated pipe ruptures in nuclear power units may excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that probability of fluid system piping rupture is extremely low under conditions consistent with the deSign basis for the piping.

HNP Unit 1 does not have a direct 1967 Equivalent to 10 CFR 50 Appendix A Criterion 4. However, the Atomic Energy Commission (AEC), in their letter dated December 1 1972, requested HNP Unit 1 to provide analyses and other relevant information needed to determine the consequences of such an event (Criterion 4 of 10 CFR 50 Appendix A), using the guidance provided in the enclosure of the December 1 1 letter. The results of the evaluation are documented in Appendix N of the Unit 1 Appendix N, Section N.7 of the Unit 1 The analysis of postulated high-energy and moderate-energy line failures outside the primary containment as previously discussed in detail has completed.

The following conclusions are drawn:

A. With the plant modifications for additional vent area, no structure or structural element will fail due to pressurization or direct effects from a failure. The resultant environmental atmosphere in any room containing equipment required for shutdown of the reactor is such that the ability of the equipment to perform its required function is not precluded.

B. physical capability for safe shutdown of reactor is maintained for any postulated failure of high-energy or moderate-energy lines. The ability to shut down the reactor also includes the assurance that radioactive releases do not exceed 10 CFR 100 values, mechanical and thermal limits for catastrophic failure of fuel are not exceeded, nuclear and containment system allowed for accidents by applicable codes are to NL-13-0058 Basis for Proposed Change not exceeded, and 10 50, Appendix A, limits for control room personnel are not Although the Edwin I. Hatch Nuclear Plant-Unit 1 is designed and constructed to quality standards that makes the failure of high-energy or moderate-energy lines highly unlikely, the analysis presented in this report indicates that with the plant modifications, the plant can withstand the effects of the postulated failures.

plant modifications that were performed are provided in Section N.6.

10 CFR 50 Appendix A Criterion 5, "Sharing of Structures, Systems, and Components" Structures, systems, and components important to shall not shared among nuclear power units unless it can shown that such sharing will not significantly impair their ability to perform their safety functions, including, in event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

HNP Unit 1 Equivalent: 1967 GOC Criterion "Sharing of Reactor facilities shall not systems or components unless it is shown safety is not impaired by the sharing.

10 CFR 50 Appendix A Criterion 19, "Control Room,"

A control room shall provided from which actions can be to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.

Adequate radiation protection shall be provided to permit access and occupancy of the control room accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or equivalent to any part of the body, for the duration of the accident. Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.

HNP Unit 1 Equivalent: 1967 GOC Criterion 11, "Control Room" The facility shall be provided with a control room from which actions to maintain operational of plant can controlled. Adequate radiation protection shall be provided to permit access, even under accident conditions, to equipment in the control room or other areas as necessary to shut down and maintain control of facility without radiation exposures in excess of 10 CFR 20 limits. It shall possible shut the reactor down and maintain it in a condition if access to the control room is lost due to fire or other cause.

to NL-13-0058 Basis for Proposed Change Therefore, these differences do not alter the conclusion that the proposed change is applicable to HNP Unit 1.

HNP Unit 2 was licensed under the 10 CFR 50, Appendix A GOC. The HNP main control room habitability systems are shared by Unit 1 and Unit 2, and are designed to meet 10 CFR 50, Appendix A GOC 19.

Generic Letter 2003-01 requested that SNC confirm the control room meets its design basis.

SNC letter dated September 1, 2006 (ADAMS Accession No. ML062480132) provided confirmation that the HNP control room meets the applicable habitability regulatory requirements (GOC 1, 3, 4, 5, and 19). The NRC stated in response letter dated October 3, 2006 (ADAMS Accession No. ML062580134) that The information you provided also supported the fact that you meet the intent of the GOCs for CRH."

The 10 CFR 10, Appendix A requirements discussed in the Traveler and model Safety Evaluation are therefore applicable to both Unit 1 and Unit 2.

2.2 Optional Changes and Variations SNC 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 staff's model safety evaluation dated January 17, 2007. Specifically, Evaluations 1, 5, and 6 of Section 3.3 of the model safety evaluation are applicable to HNP, Units 1 and 2. In order to establish standard terminology, "control room envelope" is used in place of "control room."

SNC is proposing the following deviations from the TS Bases changes described in TSTF 448, Revision 3, to provide consistency between the HNP Unit 1 and 2 licensing basis:

1. In the Background section, the second paragraph on page B 3.7-17 of both plants' TS Bases currently ends with the sentence, The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay." SNC is proposing to change this sentence to The charcoal adsorbers provide adsorption of gaseous iodine." This TS Bases change is in addition to the changes proposed in TSTF-448, Revision 3.

2. In the Applicable Safety Analysis section, TSTF-448 proposes to add the sentence, "The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release." SNC is proposing to change this sentence to, "The evaluation of hazardous chemical releases ... " (italics added for effect).

3. In the Actions section for B.1, B.2, and B.3, TSTF-448 proposes to add the sentence "During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke."

SNC proposes to add the clarifying statement "in accordance with the Control Room Habitability Program" at the end of this sentence.

4. Because HNP Units 1 and 2 have adopted the Surveillance Frequency Control Program (TSTF-425), the suggested changes for TS Bases SR 3.7.4.3 were not made.

E1-6 to NL-13-0058 Basis for Proposed Change 2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements SNC proposes the following as a license condition to support implementation of the proposed TS changes. In subpart (a) of the license condition below, SNC provides a surveillance grace period as allowed by SR 3.0.2 of 18 months, which differs from the model application value of 15 months. This discrepancy was noted in an NRC memorandum from C. Craig Harbuck to Timothy J. Kobetz, date February 2,2007 (ADAMS Accession Number ML070330657).

Upon implementation of the Amendments adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.4.4, in accordance with TS 5.5.14.c.(i), the assessment of CRE habitability as required by Specification 5.5.14.c.(ii), and the measurement of CRE pressure as required by Specification 5.5.14.d, shall be considered met. Following implementation:

a. The first performance of SR 3.7.4.4, in accordance with Specification 5.5.14.c.(i),

shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from June 2, 2006, the date of the most recent successful tracer gas test, as stated in NL-06-1930, Edwin I. Hatch Nuclear Plant Response to Generic Letter 2003-01 Control Room Habitability, dated September 1,2006, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years. Please note that the next HNP tracer gas test is scheduled for January 2014.

b. The first performance of the periodic assessment of CRE habitability, Specification 5.5.14.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from June 2, 2006, the date of the most recent successful tracer gas test, as stated in I\IL-06-1930, Edwin I. Hatch Nuclear Plant Response to Generic Letter 2003-01 Control Room Habitability, dated September 1,2006, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years. Please note that the next HNP tracer gas test is scheduled for January 2014. The first performance of the periodiC assessment of CRE habitability will be within 3 years, plus the 9-month allowance of SR 3.0.2, of the next successful tracer gas test.

c. The first performance of the periodic measurement of CRE pressure, Specification 5.5.14.d, shall be within 24 months, plus the 6 months allowed by SR 3.0.2 from the date of the most recent successful pressure measurement test, or within 6 months if not performed previously.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination SNC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CUIP. SI\lC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Edwin I.

Hatch Nuclear Plant, Units 1 and 2, and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

E1-7

1 to NL-13-0058 Basis for Proposed 3.2 There are no new regulatory commitments contained in this report.

4.0 ENVIRONMENTAL EVALUATION SNG has the environmental evaluation included in the safety evaluation dated January 17, as part of the GUlP. SNG has concluded that the findings in evaluation are applicable to HNP, Units 1 and 2, and the evaluation is hereby incorporated rot,,,ro.,,,,o for this application.

E1

Edwin I. Hatch Nuclear Plant License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (CLlIP)

Enclosure 2 HNP Technical Specification Marked Up Pages

MCREC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Main Control Room Environmental Control (MCREC) System LCO 3.7.4 Two MCREC subsystems shall be OPERABLE.

NOT E------------------------------------------------------------

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

1-----------------------------------------------------------------------------------------------

[envelope (CRE) [

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 MCREC subsystem A.i Restore MCREC 7 days inoperabl~ subsystem to OPERABLE status.

Ifor reasons other than Condition B I B. ::fwe. MCREC subsystems

~

B.+~ Restore idCRE I ~24 R9Ie1FS..E-190 days [

?1 inoperable due to ~CRE I boundary to

[One or m ore [inoperable BaRtral FI3I3FR OPERABLE status.

boundary in MODE 1, 2, or 3.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

!Insert 1 I Iinsert 2 I HATCH UNIT 1 3.7-8 Amendment No. ~

MCREC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two MCREC subsystems -----------------NOTE ------------------

inoperable during LCO 3.0.3 is not applicable.

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

t7 F.2 Suspend CORE Immediately One or more MCREe AL TERATIONS.

subsystems inoperable due to an inoperable eRE boundary during F.3 Initiate action to Immediately movement of irradiated suspend OPDRVs.

fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Operate each MCREC subsystem ~ 15 minutes. In accordance with the Surveillance Frequency Control Program SR 3.7.4.2 Perform required MCREC filter testing in In accordance with accordance with the Ventilation Filter Testing the VFTP Program (VFTP).

SR 3.7.4.3 Verify each MCREC subsystem actuates on an In accordance with actual or simulated initiation signal. the Surveillance Frequency Control Program (continued)

HATCH UNIT 1 3.7-10 Amendment No. ~

MCREC SURVEILLANCE REQUI SURVEILLANCE FREQUENCY SR 3.7.4.4 IF! 8999rEl8RIi98 wiil:!

tR9 ~wPo(9iI18R9 FeI8th.'8 t8 tRB tlz.,lFeiR8 8blilliliR~ IiIwriR§ tRB Perform required unfiltered air inleakage In accordance with testing in with the Control Room Control Room Envelope Habitability Program Habitability UNIT 1 3.7-11 Amendment No.

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

The provisions of SR 3.0.3 are to Containment Rate Testing Program.

5.5.13 This program provides shall ensure that Surveillance Specifications are performed at InTC,r;/<:l limiting Conditions for are met.

a. The Surveillance Frequency Control Frequencies of is controlled by the program.

b. to the Program shall Method for Control of

c. The provisions are to the Frequencies Frequency Control Program.

Insert 3 HATCH UNIT 1 7 Amendment No. ~

MCREC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Main Control Room Environmental Control (MCREC) System LCO 3.7.4 Two MCREC subsystems shall be OPERABLE.

NOT E------------------------------------------------------------

The main control room 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 MCREC subsystem A.1 Restore MCREC 7 days ino perabl1; subsystem to OPERABLE status.

Ifor reasons other than Condition B I B. ~MCREC subsystems 7"B.+ ~ Restore ~~~~99l 24 AOtlFS -E190 days I

,;::.:..?' inoperable due to ~ boundary to lOne or mo re linoperable S9RtF91 IZ991ZR OPERABLE status.

boundary in MODE 1, 2, or 3.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

Iinsert 11 !Insert 2 I HATCH UNIT 2 3.7-8 Amendment No. tee

CONDITION ACTION COMPLETION TIME F. MCREC subsystems inoperable during LCO 3.0.3 is not applicable.

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

F.2 Immediately

! AND to an inoperable boundary during Immediately movement fuel secondary containment, during 1 Operate each ;;:: 15 minutes.

Frequency Control Perform required In with accordance with the VFTP Program (VFTP).

Verify each MCREC actual or simulated initiation Control UNIT2 o No.i:itt

System 3.7.4

'lei if) eae~ MOREO etiBeyeleFR eaR fflaiRlaiA a

,,geith1e I:'reSGWF9 ef iii Q.1 iFl9Rge wBter §BtI!ijj9 5488 eflii.

In the Control Habitability UNIT2 3.7-11 Amendment No. ~

and Manuals 5.5 Programs and Manuals 5.5.12 of SR 3.0.3 are to the Primary Containment Leakage 5.5.13 program provides controls the Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in Technical

",,,<;,,,,,,(,,,,,t'inr,c are performed at sufficient to assure associated Limiting Conditions for Operation are met.

a. Surveillance Control Program a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the nrr\"r,,,,rn

b. to the in the Surveillance Control Program shall be made in accordance with the NEI 04-10 "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. provisions of Requirements 3.0.2 and are applicable to the established in the Frequency Control Program.

HATCH UNIT 2 5.0-17 Amendment No. i!4e

B.1 Initiate action to implement mitigating AND B.2 Verify mitigating actions ensure occupant exposures to chemical, and smoke wiil exceed limits.

Immediately 24

5.5.14 Program A be established and habitability is maintained such that, with an Control (MCREC) CRE occupants can control reactor under normal conditions and maintain it condition following a radiological event, hazardous chemical release, or shall ensure that adequate radiation protection access and occupancy of the CRE under design basis conditions without personnel receiving radiation exposures in 5 rem dose equivalent (TEDE) for the duration of the shall include the following elements:

a. and the bounda~.

b. maintaining the CRE bounda~ in its design condition control and preventive maintenance.

c. (i) determining the unfiltered air inleakage past the in accordance with the testing methods and at the in Sections C.1 and C.2 of Regulato~ Guide 1.1 "Demonstrating Control Room Envelope Integrity at Nuclear Power

" 0, May 2003, and (ii) assessing CRE habitability at the in Sections C.1 and C.2 of Regulato~ Guide 1.1 at designated locations, of the CRE pressure relative to all areas to CRE bounda~ during the pressurization by one subsystem of the MCREC System, operating at the flow by the VFTP, at a Frequency of 24 months on a STAGGERED shall be trended and used as part of the month boundary.

e. on unfiltered air inleakage into the CRE. These limits in a manner to allow direct comparison to the unfiltered air measured by the testing described in paragraph c. The unfiltered for challenges is the inleakage flow rate assumed in the licensing analyses of DBA consequences. Unfiltered air hazardous chemicals must ensure that exposure of will be within the assumptions in the licensing basis.

f. are to the Frequencies for ~"'_P"'

habitability, determining CRE unfiltered inleakage, and pressure the CRE boundary as required by

Edwin I. Hatch Nuclear Plant license Amendment Request to Revise Technical Specifications ...... ,n"" ......

Room Envelope Habitability in Accordance with TSTf-448, ......"",.....

Consolidated line Item Improvement (ClIIP)

Enclosure 3 HNP Technical Specification

TABLE OF CONTENTS 3.9 REFUELING OPERATIONS (continued) 3.9.6 Reactor (RPV) Water ................................................ 3.9-8 Residual Removal (RHR) - High Water .............

Residual Heat Removal (RHR) - Low Water Level............................... ........ 1 3.10 .;:::;.::...=:.:..=:....::::..:'--""-'...:::;..;:..:.:.="-"= .... .. .... ... ***** . .. . .. .. .. .. ........ .. .. .. .. .. ... .... . ...... .. * .... . . .... ... 3.1 0-1 0.1 Inservice and Hydrostatic Operation ........................................ 3.10-1 3.10.2 ","'0",,\.11 Mode Switch Interlock ......................................................... 3.10-3 3.1 Single Control Withdrawal - Hot Shutdown ............................................ 3.1 3.10.4 Single Control Withdrawal - Cold Shutdown .......................................... 3.10-8 3.10.5 Single Control Rod Drive (CRD) Removal- Refueling .................................. 3.10-12 0.6 Multiple Control Rod Withdrawal - Refueling ................................................. 3.10-14 3.10.7 Control Testing - Operating ................................................................... 3.10-16 3.10.8 SHUTDOWN MARGIN (SDM) Test Refueling ............................................ 3.10-18

.!::!.Ej~!:!"'!:'5!:iJ~~ .................................................................................... 4.0-1 4.1 ................................................................................................................ 4.0-1 Re,act(x Core ................................................................................................. 4.0-1 4.3 Fuel Storage ..................................................................................................

....................................................... 5.0-1 5.1 Responsibility .............................................................................................. .

5.2 5.3 Unit Qualifications .................................................................................

5.4 Procedures .................................................................................................... 5.0-6 Programs Manuals ................................................................................. 5.0-7 Reporting Requirements ............................................................................... 5.0-19 5.7 High Radiation Area ...................................................................................... 5.0-22 (continued)

HATCH UNIT 1 iv Amendment No.

MCREC System 3.7.4 3.7 PLANT SYSTEMS Main Control Room Control (MCREe) ....'Torn LCO 3.7.4 Two MCREC shall be control room envelope boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 3, During movement irradiated fuel in secondary During CORE During operations with a potential for draining reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One MCREC subsystem 7 days to OPERABLE status.

B. One or more MCREC Initiate action to immediately inoperable due implement mitigating to inoperable CRE actions.

boundary in MODE 1, 2, or 3.

B.2 mitigating actions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant to radiological, chemical, and smoke hazards will not exceed limits.

CRE boundary to OPERABLE status.

(continued)

HATCH UI\IIT 1 Amendment No.

3.7.4 CONDITION ACTION Action and in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met in MODE 1, 2, or 3.

in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Action and Completion Time A not met movement of irradiated fuel assemblies in D.1 OPERABLE secondary containment, MCREC subsystem in during CORE pressurization mode.

ALTERATIONS, or during OPDRVs.

1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

CORE ALTERATIONS.

Initiate action to Immediately OPDRVs.

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

(continued)

UNIT 1 3.7-9 Amendment No.

3.7.4 CONDITION REQUIRED ACTION

N OTE------------------

during LCO 3.0.3 is not applicable.

movement irradiated fuel in the F.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

F.2 Suspend CORE to an boundary ALTERATIONS.

during movement of AND F.3 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE ENCY Operate each MCREC subsystem 2: 15 minutes.

Perform required MCREC filter testing in with accordance with the Ventilation Filter Testing Program (VFTP).

Verify each MCREC subsystem actuates on an actual or simulated initiation signal.

1 3.7-10 No.

SURVEILLANCE SR required CRE unfiltered air inleakage In with to",1~lnl"l in accordance with the Control Room the Control Room Habitability Program.

Habitability Program HATCH UN 1 3.7-11 Amendment No.

Programs and Manuals 5.5 Programs and Manuals 5.5.12 provisions of SR 3.0.3 are applicable to the Primary Containment Testing Program.

5.5.13 program provides controls for the Surveillance Frequencies.

shall ensure that Surveillance Requirements in the Technical Specifications are performed at intervals limiting Conditions for Operations are met.

a. Surveillance Control shall control a of Frequencies of Surveillance Requirements for which Frequency is controlled by program.

b. Changes to the listed in Surveillance Control Program shall made in accordance with the NEI 04-10 "Risk-Informed Method for Control of Surveillance " Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to Frequencies established in the Surveillance Control Program.

5.5.14 A Control Room (CRE) Habitability shall be and implemented to ensure CRE habitability is maintained such that, with an Main Control Room Environmental Control (MCREC) CRE occupants can control the reactor safely under normal conditions and maintain it in a condition following a radiological chemical or a smoke challenge. program shall ensure that adequate radiation protection is to permit access of under nne",.....,

acc::lOjent (DBA) without radiation vALJV"

excess of 5 rem total dose equivalent (TEDE) for accident. The program shall include the following elements:

a. The definition the CRE and the boundary.

b. ReqUirements maintaining the boundary in its condition including control and maintenance.

c. Requirements (i) determining unfiltered air the CRE boundary into CRE in with the testing methods and at the Frequencies in Sections C.1 and C.2 of 1.197, "Demonstrating Control Room Integrity at Nuclear Power Reactors," 0, May 2003, and (ii) assessing habitability at the HATCH UNIT 1 5.0-17 Amendment No.

Programs Manuals 5.5 Programs Manuals 5.5.14 Control Room Envelope Habitability Program (continued) lont';o<:: <::1"\,:>1'11'101"1 in i::>ectlcms C.1 and of Guide 1.1 Revision O.

d. Measurement, at designated locations, of the CRE ovr,.,. .."""" areas to the CRE during the mode of operation by one subsystem of MCREC System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a TEST BASIS. results trended and as part of the 24 month assessment of CRE boundary.

e. The quantitative limits on unfiltered inleakage into the These be 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 licensing of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within in licensing

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

HATCH UN 1 8 Amendment No.

Reporting 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Deleted.

5.6.2 Annual Radiological Environmental Operating Report A a multiple unit station. submittal combine sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the calendar year shall be submitted by May 15 of each year. summaries, interpretations, and trends of the results of Radiological Environmental Monitoring Program the reporting period. material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, I, IV.B.2. IV.B.3. and IV.C.

The Annual Radiological Environmental Operating Report shall include results of analyses radiological environmental samples and all environmental taken during the period locations specified in and figures in the ODCM. as well as and tabulated results analyses and measurements in the UNIT 1 5.0-19 Amendment No.

h'onnrTU,,1"I Requirements 5.6 5.6 Reporting Requirements

...=.:...:.=::=..:...:.====-=.:...:...:..:..:.=..:..:"""""",-,=,,-=.c:..;:::.=.:...:..=L.-'-==:":' (continued) in the Branch Position.

Revision 1, November 1979. that some individual are not y"nl"u,JI'" for inclusion with report shall be noting and explaining the reasons for the results. The missing shall be submitted in a supplementary report as soon as possible.

5.6.3 submittal may be made for a multiple unit station.

c""....'T.n'" common to all the station; c"""",r'3t", radwaste systems, shall specify the reIl3a~>es radioactive material from each unit.

The Radioactive Effluent Release Report covering the operation of the unit shall be in accordance with 10 CFR 50.36a. The include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste from the unit. material provided shall consistent with the

' 0 ..... 1\1£'" outlined in the aDCM Process Control and in I"nrltnnm<:>,"It"o with 10 CFR 10 CFR 50, Appendix I, Section IV.B.1.

5.6.4 5.6.5

a. operating limits to prior to any remaining portion of a reload cycle, and in the COLR for the following:

1) The Average Heat Generation for Specification 3.2.1.

The Minimum Power Ratio for Specification 3.2.2.

3) The Linear Rate for HATCH UNIT 1 on/'1m,onf No.

Reporting Requirements 5.6 Requirements 5.6.5 (continued)

b. The analytical methods used to determine the core operating limits shall be those previously and approved by NRC, specifically those described in N 1-P-A, Standard Application for " (applicable amendment specified in the COLR).

c. The core ........ " ..""1*....,., limits be determined all applicable limits (e.g., mechanical limits, core hydraulic limits, Emergency Core Systems (ECCS) limits, nuclear limits such as SDM, transient limits and accident limits) of the safety analysis are met.

d. The COLR, including mid-cycle revisions or shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 When a report is required 3.3.3.1, "Post Accident Monitoring (PAM)

Instrumentation," a report submitted within following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of inoperability, and the schedule for restoring instrumentation channels of the Function to status.

HATCH 1 Amendment No.

Reporting Requirements 5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area 5.7.1 Pursuant to 10 paragraph 20.1601, in lieu of the requirements of 10 CFR 20.1601a, high radiation area, as defined in 10 20, in which the intensity of radiation is > 100 mrem/hr but < 1000 mrem/hr, 30 cm from source or from any surface the radiation nQ'~QT"'"

shall barricaded and conspicuously posted as a high radiation area.

Entrance by requiring issuance of a Permit (RWP). qualified in radiation protection Health Physics or personnel continuously by such individuals may be from the RWP issuance requirement during performance of their duties in high radiation areas with ""L/V"' .... '

< 1000 mrem/hr, provided they are otherwise following plant procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall provided with or by one or more of the following:

a. A radiation monitoring 1'1"'\,"""'" that continuously indicates rate in area.

b. A radiation monitoring device that continuously integrates the radiation dose rate in when a preset integrated areas with this monitoring """,n"",

rate in the area have been r<::t"1,nn,ol are aware of them.

c. An protection procedures with a radiation who is responsible for providing within the area and shall perform at the frequency specified by the facility in the RWP.

5.7.2 In addition to the of Specification 5.7.1, areas with radiation

~ 1000 mrem/hr, at 30 cm from the radiation source or from any surface the radiation but less than 500 Rads in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at 1 meter from source or from any surface that the radiation penetrates, shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of Shift Supervision on duty or Health Physics supervision.

UNIT 1 Amendment No.

TABLE OF CONTENTS

......................................... 5.0-1 5.1 ................................................................................................ 5.0-1

................................................................................................. 5.0-2 5.4 5.6 5.7 HATCH UNIT2 v No.

System 3.7.4 PLANT 3.7.4 Main Control Room Environmental Control (MCREC) _ .....'1'."""'"

LCO 3.7.4 Two MCREC ,n""I"'TC'rTl'" shall OPERABLE.

The main control room envelope (CRE) boundary be opened intermittently under administrative control.

APPLICABILITY: 1, 2, and 3, During movement of irradiated assemblies in secondary containment, During ALTERATIONS.

During operations with a potential for draining the reactor (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One MCREC subsystem A.1 7 days for reasons other than Condition B, status.

One or more B.1 Initiate action to Immediately subsystems inoperable implement mitigating to CRE boundary in MODE 1, or 3.

B.2 Verify 24 ensure CRE occupant to radiological, chemical, and smoke hazards will not AND 8.3 ' 90 days

( continued)

HATCH UN 2 3.7-8 Amendment No.

MCREC System 3.7.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Action and C.1 Be in 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion of Condition A or B AN D not met in MODE 1, 2. or 3.

C.2 Be in hours Action and aS~)OClatE~a Completion LCO of Condition A not met during movement of irraldiailed fuel D.1 Immediately in secondary containment, during CORE or during D.2.1 Suspend movement of Immediately irradiated fuel in secondary containment.

AND D.2.2 Immediately 0.2.3 Initiate action to Immediately suspend subsystems E.1 Immediately in MODE 1, 2, or 3 reasons other than Condition B.

(continued) 2 Amendment No.

System ACTIONS CONDITION REQUIRED ACTION COMPLETION F. ------------------NOTE-----------------

LCO 3.0.3 is not applicable.

F.1 movement irradiated fuel assemblies in the secondary containment.

Suspend CORE Immediately AL TERATIONS.

to an boundary during movement in the ",or'"n""," Initiate action to Immediately containment, during suspend OPDRVs.

or during OPDRVs.

SURVEI SURVEILLANCE subsystem;;:: 15 minutes.

SR 3.7.4.2 iJo,"t"rl'Y'l required MCREC filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

SR each MCREC subsystem actuates on an actual or simulated initiation signal.

(continued)

HATCH UNIT 2 3.7-10 Amendment No.

MCREC System 3.7.4 SURVEILLANCE FREQUENCY 3.7.4.4 Perfonn unfiltered air In accordance with testing in accordance with the Control Room the Control Room nuc,"" ..",,, Habitability Program. Envelope Habitability Program HATCH UNIT2 3.7-11 No.

Programs Manuals 5.5 Programs and Manuals 12 (continued) to the Primary 13 This program provides controls for the Surveillance Frequencies. program shall ensure that Surveillance specified in the Technical Specifications are performed at intervals sufficient to assure the Limiting Conditions for Operation are

a. Surveillance Frequency Program shall contain a of IO""~IO'" of those Requirements for which Frequency by the program.

b. to the Frequencies Control shall be made in with the NEI 04-10 "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1

c. prOVisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

14 Envelope Habitability Program shall mnlt:>""t:>ntt:>rI to ensure that habitability is maintained Main Control Room Control (MCREC) '\I'::lIrrt occupants can control the reactor under normal conditions and maintain it in a condition following a hazardous chemical or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident conditions without receiving radiation exposures in 5 rem total effective equivalent (TEDE) for duration of the program shall following elements:

a. definition of the the boundary.

b. ReqUirements for maintaining the CRE boundary in condition including configuration and preventive maintenance.

c. Requirements for (i) determining the unfiltered air past the CRE boundary into the in accordance with the testing methods and at the It:>n(-;t:>c:: specified in C.1 and C.2 of Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power

" Revision 0, May 2003, and (ii) assessing habitability at the HATCH UNIT 1 7 Amendment No.

Programs and Manuals Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued) in C.1 and of 1.197, Revision O.

d. Measurement, at designated locations, of the pressure relative to all external areas to CRE boundary during the mode of operation by one subsystem the MCREC System, operating at flow rate required by the at a Frequency of months on a TEST BASIS. results trended and as part of the 24 month assessment of the boundary.

e. The quantitative limits on unfiltered inleakage into the These limits be in a manner to allow direct comparison to the unfiltered measured by described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the

'VClI'l.C1!.,I'V flow rate in licensing basis of consequences. Unfiltered air inleakage limits hazardous chemicals must ensure that exposure of CRE occupants to these will be within assumptions in licensing

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

HATCH UNIT2 5.0-18 Amendment No.

Reporting Requirements 5.6 ADM INISTRATIVE CONTROLS 5.6 Reporting Requirements following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Deleted.

5.6.2 for a unit station. submittal should sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during previous calendar year shall submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Environmental Monitoring Program for the period. provided shall consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in*

10 50, Appendix I, IV.B.3, and The Annual Radiological Environmental Operating Report shall include the results of all radiological environmental and of all environmental radiation measurements taken during period pursuant to the locations specified in the table and figures in the ODCM, as as summarized and tabulated of and in the format the (continued)

HATCH UNIT 2 5.0-19 Amendment No.

Requirements 5.6 Requirements table in the Radiological Assessment Branch rnu:>rnll"lor 1979. In event that some individual are not inclusion with the report, the report shall submitted noting explaining reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

Radioactive Effluent Release Report A submittal may be made for a multiple unit station. should combine sections common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the of radioactive material from each unit.

Radioactive Effluent Release Report covering submitted in accordance with 10 CFR 50.36a. report a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided with the objectives outlined in the ODCM and the Control conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, ::se,ctlcm Deleted.

CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1) The Average Planar Linear Heat Generation Rate for Specification 3.2.1.

2) The Minimum Critical Power Ratio for Specification 3.2.2.

3) The Linear Heat Generation Rate for Specification UNIT2 5.0-20 Amendment No.

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in NEOE-24011-P-A, "General Electric Standard Application for Reactor Fuel," (applicable amendment specified in the COLR).

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SOM, transient analysis limits and accident analysis limits) of the safety analysis are met.

d. The COLR, including any mid-cycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Post Accident Monitoring (PAM) Instrumentation Report When a report is required by LCO 3.3.3.1, "Post Accident Monitoring (PAM)

Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

HATCH UNIT 2 5.0-21 Amendment No.

Reporting Requirements 5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area 5.7.1 to 10 CFR 20, 20.1601, in lieu of the requirements of 20.1601 a, each high radiation area, as defined in 10 CFR 20, in which intensity of radiation is > 100 mrem/hr but < 1000 measured at 30 cm from the radiation source or from any surface penetrates, barricaded and conspicuously posted as a high area.

~nltr<:lrv'o thereto shall by requiring a Radiation Work (RWP). Individuals qualified in radiation protection procedures (e.g.,

Health Physics Technicians) or personnel continuously by such may be exempt from the RWP issuance during the performance of their assigned duties in high radiation areas with exposure rates

< 1000 mrem/hr, provided are otherwise following radiation protection for entry into high radiation areas.

Any individual or group of permitted to enter areas shall be with or accompanied by one or more of the T(\Ii(\W'lnn

a. A radiation monitoring nO\,'II"O that continuously the radiation dose rate in the area.

b. A radiation monitoring that continuously ntonr<:l,toc>

dose rate in the area alarms when a preset dose is received. Entry into such areas with this monitoring no,""o may be made after the dose rate in the area have been and personnel are aware of

c. individual qualified in with a radiation dose rate monitoring providing positive control over the perform periodic radiation surveillance at frequency specified by facility Health Physics supervision in the RWP.

5.7.2 In to the requirements 5.7.1, areas with levels

2: 1000 mrem/hr, measured at cm from the radiation source or any the radiation penetrates, but less than 500 Rads in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months measured at 1 meter from the radiation source or from any surface that the radiation shall be provided with locked or continuously doors to nrOMOIt unauthorized shall be

'Tr<:lTH/O control of HATCH UNIT 2 Amendment No.

Edwin I. Nuclear Plant License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement (CLlIP) 4 HNP T~'l"tn'I"'::II1 Specification Ba!5eS Marked Up Pages (for information only)

MCREC System B 3.7.4 B 3.7 PLANT SYSTEMS B 3.7.4 Main Control Room Environmental Control (MCREC) System BASES BACKGROUND The MCREC System provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity. hazardous chemicals. or smokeradiologically controlled environment from which the unit can be safely operated following a Design Basis Accident (DBA).

The safety related function of 1OO..MCREC System includes two independent and redundant high efficiency air filtration subsystems for emergency treatment of recirculated air and outside supply air.Jlllii.a Q.RE;_9pUPJ!oo! th?t limi~s_ !b.~.lp l~akgge qJ ulJ.filt~!~dg.ir. Each MCREC subsystem consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section, a second HEPA filter, a booster fan, and the associated ductwork and damporsductwork. valves or dampers, doors, barriers. and

.i.~tLl.JmentalLQn. Additionally, one air handling unit (AHU) fan is required for each subsystem to assist in the pressurization function.

AHU fans are also addressed as part of LCO 3.7.5, "Control Room Air Conditioning (AC) System." Prefilters and HEPA filters remove particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period for.ill1sorotion of gaseous iodine, allO'.ving time for decay.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses th.e.cootcol [QQIlLi;lO.dJnay eo.c_Q.mpas.s.olbe r..D..Qn-:cT,i.l1.caJ aro.&lJUO which frequent personnel access Qr continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal QRElrillLQl'l....DatUIaL.e...YJ~ntsL..ao.d...a.cQid.enLQ!:md.i1ions ...Th e.. CR.E boundary is the combination of walls, floor, roof ducting, doors.

penetrations and equipment that physically form the CREJOO.

QEE:BAB1LJ.IY. oLthe.~RE .b.Q_undarY.JIlus.tbJ:LIDaiota.ine..d to ensure that tbe inleakage of unfiltered air into the CRE will not exceed the inleSlJruqe assumed in the licensing basis anal~f desiQIL~

gcc.iqent LOS(\) co nseaueQg~§J9 G.B.!; gCC!JQ.§J)t?, Tbe GJ3E;_and its boundary are defined in the.. Control Room Envelope Habitability Program .

The MCREC System is a standby system, parts of which also operate during normal unit operations to maintain the control room.eRE.

environment. Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to control room (continued)

HATCH UNIT 1 B 3.7-17 REVISION 70

MCREC System B3.7.4 personneleRE occupants), the MCREC System automatically switches to the pressurization mode of operation to prevent minimize infiltration of contaminated air into the control roemCRE. A system of dampers isolates the control room,G.B.E, and a part of the recirculated air is routed through either of the two filter subsystems. Outside air is taken in at the normal ventilation intake and is mixed with the recirculated air before being passed through one of the charcoal adsorber filter subsystems for removal of airborne radioactive particles and gaseous iodines.

The MCREC System is designed to maintain the control room environmenta habitable environment in the eRE for a 30 day continuous occupancy after a DBA without exceeding the dose limits of 10 CFR 50.675 rem total effective dose equivalent (TEDEl. A single MCREC subsystem QpJililt.ing"at a..~.ub.s,'is..lem flQWIaill.Q.l~

2750 cfm and an outside air flow rate of < 400 cfm will pressurize the control roomCRE to ~ 0.1 inches water gauge relative to external

~~. agjac.entJo the."CRE_bo.l",md.QJY to minlmiz..e.Jo prevent infiltration of air from all surr9unding areas adjacent to the CRE b.oondarysurrounding buildings. MCREC System operation in maintaining control room~R~ habitability is discussed in the Unit 2 FSAR, Sections 6.4 and 9.4.1, (Refs . 1 and 2, respectively).

(continued)

HATCH UNIT 1 B 3.7-18 REVISION 70

MCREC System B 3.7.4 BASES (continued)

APPLICABLE The ability of the MCREC System to maintain the habitability of the SAFETY ANALYSES control roomCRE is an explicit assumption for the safety analyses presented in the FSAR, Section 5.2 and Chapter 14 (Refs. 3 and 4, respectively). The pressurization mode of the MCREC System is assumed to operate following a DBAloss of coolant accidont, fuel handling accident, main steam line break, and control rod drop accident, as discussed in the Unit 2 FSAR, Section 6.4.1.2.2 (Ref. 5).

The radiological doses to control room personnelthe CRE occupants as a result of the various DBAs are summarized in Reference 6. No single active or passive failure will cause the loss of outside air or recirculated air from the control roomCRE.

TheJy1CREC System provides protection from smoke and hazardous chemicals to the CRE occupants. The evaluation of hazardous flJ.e!:Dic~I EeJeJ;t!?~§ .d~JJlon~tr:ates tb~~ the tQ.X.icity lim il§..are DQl exceeded in the CRE following a hazardous chemical release (Ref.

12). The evaluation of a smoke cba'tlenge demonstrates that it will not result in the ioability of the CRE occupants to control the reactor either from the cootrol room or from the remote shutdown panels (Ref. 2).

The MCREC System satisfies Criterion 3 of the NRC Policy Statement (Ref. 7).

LCO Two redundant subsystems of the MCREC System are required to be OPERABLE to ensure that at least one is available, assuming ita single active failure disables the other subsystem. Total MCREC

~system failure. such as from a loss of both ventilation subsystems OL p:'QJIL.aJl.lnQperabl e CRE boun~~ could result in exceeding tRe-4-(}

~0.67 dose limits (Ref. 10) for the control room operatorsa dose of 5 rem TEDE to the CRE occupants in the event of a DBA.

+Re-Each MCREC System subsystem is considered OPERABLE when the individual components necessary to control oporatorlimit CRE occupaot exposure are OPERABLE in both subsystems. A subsystem is considered OPERABLE when its associated:

a. Filter booster fan is OPERABLE;

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

c. Associated ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained; (continued)

HATCH UNIT 1 B 3.7-19 REVISION 70

MCREC System B 3.7.4

d. One AHU fan is OPERABLE. and either operating or having its control switch in "Standby" with OPERABLE automatic start capability; and

e. Associated AHU COOling coils, water cooled condensing units.

refrigerant compressors. and associated instrumentation and controls to ensure loop seal is maintained.

(continued)

HATCH UNIT 1 B 3.7-20 REVISION 70

MCREC System B 3.7.4 BASES LCO OPERABILITY of two MCREC subsystems entails satisfying the (continued) requirements listed above for each subsystem and, in addition, satisfying other limitations on AHU fan OPERABILITY. For both MCREC subsystems to be OPERABLE, the two required AHU fans must be independently powered; i.e., one fan via 1R24-S002 and one fan via 1R24-S003. (Note that AHU C is treated as powered from 1R24-S002 or S003, depending upon the source of power for 1R24-S029.) Furthermore, with one of the two required AHU fans inoperable (Le., not independently powered, or not operating or capable of automatic start), one MCREC subsystem shall be declared inoperable. However, the inoperability may be assigned to either MCREC subsystem. OPERABILITY details for various configurations are outlined in the Technical Requirements Manual (TRM) (Ref. 8),

Section 2.0.

In order fO[ tbe MCREC subsystems to be considered OPERABLE, the CRE boundarY must be maintained such that the CRE occupant dose fmm a large radioactive release does not exceed the calculated

.d0U the licensing basis consequence analyses for DBAs and that eRE QQk.up.antS8re proJe..c.ted JrOJJJ hazacd.Q..L!s..me.mj.!::aJ~ and smoke.ln addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors, such that the pressurization limit of SR 3.7.4.4 can bo met,.

The LCO is modified by a Note allowing the main control room~B.E boundary to be opened intermittently under administrative controls.

Ibis~te only applies to openings in the CRE boundarY t.hat can be rapidly restor~d to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the main control roomoperators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundarY to ,l CQndjJio[U;}fJl..tiYalenUo the de.s..ia..oJ;:;Q!}gjj:JQ.!1when a need for maffi control roomCRE isolation is indicated.

Each of the main control room exhaust fan ducts is equipped with only one isolation damper (1 Z41-F018A1B). During normal system operation, the dampers are maintained closed. However, when an exhaust fan is operated and its associated damper is opened, a single failure could prevent isolation of that penetration and adversely impact main control room habitability. Consequently, when a MCREC system exhaust fan (1Z41-C011AfB) is operated or its associated damper (1Z41-F018AfB) is opened, one of the two MCREC (continued)

HATCH UNIT 1 B 3.7-21 REVISION 23

MCREC System B 3.7.4 subsystems must be declared inoperable. Optional allowances for inoperable subsystems do not preclude changing the declared inoperable subsystem to best accommodate other plant circumstances; e.g., inoperable diesel generators, Safety Function Determination Program. However, in these instances, the Condition for one inoperable MCREC subsystem shall not be evaluated for Completion Time extensions, in accordance with Section 1.3.

(continued)

HATCH UNIT 1 B 3.7-22 REVISION 23

MCREC System B 3.7.4 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, the MCREC System must be OPERABLE to control operator exposureensure that the CRE will remain habitable 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 MCREC 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 movement of irradiated fuel assemblies in the secondary containment. Moving irradiated fuel assemblies in the secondary containment may also occur in MODES 1, 2, and 3;

b. During CORE ALTERATIONS; and

c. During operations with apotential for draining the reactor vessel (OPDRVs).

ACTIONS With one MCREC subsystem inoperable, for reasons other than an inoperable CRE boundarY. the inoperable MCREC subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE MCREC subsystem is adequate to perform control room radiationtb.!l-CB£._o_<!,cJJ.P..an1 protection function. However, the overall reliability is reduced because a sffiWe failure in the OPERABLE subsystem could result in reduced loss of the ,MCREC System fyogtioncapability. 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 . 2, and B.3 If the main control room boundary is inoperable in MODE 1, 2, or 3, MCREC trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE main control room boundary 'Nithin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the period that the main control room boundary is inoperable, appropriate compensatory measures (consistent 'Nith the intent of GDC 1Q) 'Nill be utilized to provide physical security and to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity. Preplan ned measures should be available to

( continued)

HATCH UNIT 1 B 3.7-23 REVISION 23

MCREC System B 3.7.4 BASES ACTIONS B.1 ,..1?.2.. CJDdJ:3.~ (continued) address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the uso of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems ',,,'ith the main control room boundary.

JJthe.J.rn.fille.redJolea!$~=9t.PJ.>ot~ntiaJl:i£Q..,l1.tgmt[:t9~d air R~l.st ~CRE boundary and into the CRE can result io CRE occupant radiological dose greater than the calculated dose of the licensing 'basis analyses 9JJ2BlL~QIJ.Sgtuence~.ialL~Q~YP-1Q..5...rem.~I;.QE.L2J inad~uate protection of CRE occupants from hazardous chemicals or

.smoke, the CRE boundary is inoperable. Actions must be taken to

[~~!ore a9 QPEB.f.\B~E CR(;_boJJDqac:x: wit~jn 90.s;!9VR:

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological oL.c.b.emic.al..eye.l}t.or a...challenge from SJJlQIs.e.JIl.ac.c.oc.d.anc.o.with...the..

Control Room Habitability Program. Actions mustbe taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA the mitigating actions will e.nsJJreJhaLC8£. ~UQao1 rg.diQJQglc.aLe)~Qosure.~JLnQj e.~.ceedJ.b.e.

calculated dose of the licensing basis analyses of DBA

.c.ons..equences. and that CRE occupants...are protected from

.hazardousc.~f9Is~<;mcL~J;tl~~l~J~J;1~~s.e=n;)j1igEJlQ9 actions (L.e.w.

actions that are taken to offset the con§eauences of the inoperable

.cEE..'.Qoundarv) should be preplan ned for implementation upon entry into the condition. regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on thJ~jQwprQb..abHit¥.Qf aQB.A.occ.l.!rrlnQ...durlng thtsJime....R.eJiocL...aD.dJb..o.

use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigaJjpg actions will ensure protectLQD_.of C.RE-QcC!.Ipants..'lJflthi[Lan.aJ.}@illJjmits..Yv'_hil.e.JirnlltogJhe probability fhat CRE occupants wi ll have to imprement protective measures that may adversely affect their ability to control the reactor andmaLot.aio..itio._Q sgfe_shutdCtW!l.c.o.m:l itLQO inlb..e...ev.er:l1.Qf..a.Q68....ln addition. the 90 da'tilomoletioo Time is a reasonable time to diagnose, plao and possibly repair. and test most problems with the CSf.2 bo)..!ndqr.Y.~

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable MCREC subsystem or control fe9ffithe eRE boundary cannot be restored to OPERABLE status within the associated NQ.l.J.iN,d..Completion Time, the unit must be (continued)

HATCH UNIT 1 B 3.7-24 REVISION 23

MCREC System B 3.7.4 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

0.1, 0.2.1. 0.2.2. and 0.2.3 The Required Actions of Condition 0 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 MCREC subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE MCREC subsystem may be placed in the pressurization mode. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation have occurred, and that any active failure will be readily detected.

An alternative to Required Action 0.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control roomCRE. 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 (continued)

HATCH UNIT 1 B 3.7-25 REVISION 23

MCREC System B 3.7.4 BASES ACTIONS D.1! 0.2.1, 0.2 .2, and 0.2.3 (continued) 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. Actions must continue until the OPDRVs are suspended.

If both MCREC subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable control roomCRE boundary (i.e.,

Condition B), the MCREC System may not be capable of performing the intended function and the unit is in a condition outside~ the accident analyses . Therefore, LCO 3.0.3 must be entered immediately.

F.1! F.2, and F.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 MCREC subsystems inoperable or with one or more MCREC subsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the control roomCH.E.. This places the unit in a condition that minimizes the gccid.en.lrisk.

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 OPDEVRs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

(continued)

HATCH UNIT 1 B 3.7-26 REVISION 23

MCREC System B 3.7.4 BASES (continued)

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts on demand and continues to operate. Standby systems should be checked periodically to ensure that they start and function properly.

As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every 31 days provides an adequate check on this system . Since the MCREC System does not have heaters, each subsystem need only be operated for

~ 15 minutes to demonstrate the function of the subsystem . The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.2 This SR verifies that the required MCREC 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 Efrequencies 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 MCREC subsystem starts and operates. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.4 overlaps this SR to provide complete testing of the safety function . This Surveillance can be performed with the reactor at power. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.4 This SR verifies the integrity of the centrol room enclosure and tho assumed inleakage rates of potentially contaminated air. The control room positive prossure, 'Nith respect to potentially contaminated adjacent areas (the turbine building), is poriodically tested to verify proper function of tho MCREC System. During the pressurization mode of operation, the MCREC System is dosigned to slightly pressurize the control room> 0.1 inches 'Nater gauge positive pressure with respect to the turbine building to prevont unfiltered inleakage. The MCREC System is designed to maintain this positive (continued)

HATCH UNIT 1 B 3.7-27 REVISION 69

MCREC System B3.7.4 BASES SURVEILLANCE SR 3.7.4.4 (continued)

REQUIREMENTS pressure at a tim" rate ot ~ 2750 cfm through the control room in the pressurization mode. This SR ensures the total flow rate meets the design analysis value of 2500 cfm ... 10% and ensures the outside air flow rate is < 400 ctm. The Surveillance Frequency is centrolled under the Surveillance Frequenoy Control Program.

This SR 'lerifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE.

The details of the testing are specified in the Control Room Envelope Habitabilit¥ f:Jrogram .

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the eRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA C.@.-S.eque.nc..e...s..,.YVbe..!Lunfllter.e.d....!lli..1nle.akage if,LQma.terJb.aIl . tb.e.

as..s.um.eJj.fl~Jate.,.c..QnditjQ1] .8 must be ern.ere!i 8.eqYire.d.Act [on .8.3.

gJlgw~Jo re§!Q[~e-lb.e..,~E~I;,.-P9.undary to OPE. 8.~J~J""o~,§1.at!J§

~L9yjded miUa.9tiOSLW;!ti2D.S. gm ensure tbat t.be C.B!;.!.§JJJain§ witb.to

~he.-'iQ~f1_si.Q,9 basisb.?bitabilitvli.fl}it§.. for t~~ occ.!:lJ,~ant.§_ follQ,yYil}g 9n accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3. (Ref. 9) Which endorses. with exceptions. NEI 99-03. Section 8.4 and Appendix F ('Ref. 10). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restor§..9PERABILITY (Ref. 11 ).

Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA conseque.nce analysis, repairing the

.eRE 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 CRE boundary has been restored to OPERABLE status.

REFERENCES 1. Unit 2 FSAR, Section 6.4.

2. Unit 2 FSAR, Section 9.4.1.

3. FSAR, Section 5.2.

4. FSAR, Chapter 14.

5. Unit 2 FSAR, Section 6.4.1.2.2.

6. Unit 2 FSAR, Table 15.1-28.

HATCH UNIT 1 B 3.7-28 REVISION 70

MCREC System B 3.7.4

7. NRC No.93-102, "Final Policy Statement on Technical Specification Improvements," July 23, 1993.

8. Technical Requirements Manual, Table T2.1-1.

10. 10 CFR 50.67*N£,;1 9~::p3. ':S:;9~!f91 RO()J] HC.lbi~qp'jllli{

t\~?es§!ILe nt,~'.J \,J.D.lL4.Q_Q-L

11. Letter Jrom Eric J. Leeds (NRC) to James W. Davis (NEI) dated Januarv 30, 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)

12. Unit 2 ESAR. Section 15.4 HATCH UNIT 1 B 3.7-29 REVISION 70

MCREC System B 3.7.4 B 3.7 PLANT SYSTEMS B 3.7.4 Main Control Room Environmental Control (MCREC) System BASES BACKGROUND The MCREC System provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity. hazardous chemicals. or smokeradiologically controlled environment from ',tIhich the unit can be safely operated following a Design Basis Accident (DBA).

The safety related function of lh~LMCREC System includes two independent and redundant high efficiency air filtration subsystems for emergency treatment of recirculated air and outside supply air and a gSE boundary that limits the _ iol~akqge of unfiltered air. Each MCRI;C subsystem consists of a prefilter, a high efficiency particu,late air (HEPA) filter, an activated charcoal adsorber section, a second HEPA filter, a booster fan, and the associated ductwork and damporsductwork. valves or dampers, doors, barriers, and iostn,u::ne.nta.1i.o_n. Additionally, one air handling unit (AHU) fan is required for each subsystem to assist in the pressurization function.

AHU fans are also addressed as part of LCO 3.7.5, "Control Room Air Conditioning (AC) System." Prefilters and HEPA filters remove particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period foradsorotion of gaseous iodine, allO'.ving time for decay.

The CRE is the area within the coofin,es of the CRE boundary that contains jhe spaces that control room occupants inhabit to control the unit during normal and accident conrljtjoos. This are.a encompasses lhe.J;ootr.QiIQQIJL..aruim.-Sl-Y .enc.omp,ass..Qt.h e.CO.QD-CIiti.Gal are.as.Jo_whiQ.h_

frequent personnel access or cQntinuous occupancy is not necessary in the event Qf all accident. The CRE is protected during normal 2~e.rqliQn.L-n;.;!1.ur9.L.e.Y.ents..,~-D.d..acQd..e.nl~Qngjtj..Q.o.s.., _T bJLC RJ;__ bQ.1J. nQ;.;!ry is the cQmbination of walls. fIQQr. roof. ducting, doors, penetrations and equipment that physically form the CRE. ThELOPERABILITY of1he.

CBE _b.QU.o..da ry m!.1st be...maintaine..dJQJm.sJ.! (e.JllilJJ.b..e iole.c:lliaQ..e_. Qf unfiltered air into the eRE will not exceed the linlea'kage assumed in the licensing basis analysis Qf design basis accident (DBA)

S!.QpseqyenGe~ to CRE QCC.!-lQRot§. TheCRE qnd its bouodaO( are defined in the Control Room Envelope Habitability Program.

The MCREC System is a standby system, parts of which also operate during normal unit operations to maintain the control roomCRE environment. Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to control room personnelCRE occupants), the MCREC System automatically (continued)

HATCH UNIT 2 B 3.7-17 REVISION 74

MCREC System B 3.7.4 switches to the pressurization mode of operation to prevent minimize infiltration of contaminated air into the control roomCRE. A system of dampers isolates the control roomCRE, and a part of the recirculated air is routed through either of the two filter subsystems. Outside air is taken in at the normal ventilation intake and is mixed with the recirculated air before being passed through one of the charcoal adsorber filter subsystems for removal of airborne radioactive particles and gaseous iodines.

The MCREC System is designed to maintain the control room environmenta habitable environment in the CRE for a 30 day continuous occupancy after a DBA without exceeding 5 rem total

.~ffectiy~ qg.?e ~Q\JiYSlI.@.ntLIEJ::>'.l;J.the dose limits of 10 CFR 50.67. A single MCREC subsystem operating at a subsystem flow rate of ~

2Z5.Q .cfm.a.n.d .!:'l.n_Q.u.tsJd.e..air flow Iate..QL~_4QQ..cfm_will pressurize the CREcontrol room to ~ 0.1 inches water gauge relative to external areas adjacent to the CRE boundary to minimizeto provont infiltration of air from .aJLS!J((Q!JD.dm.~La[(~itS adia.c.e.nttQJ.bst CB~

boundarysurrounding buildings. MCREC System operation in maintaining control roomCRE habitability is discussed in the FSAR ,

Sections 6.4 and 9.4.1, (Refs. 1 and 2, respectively).

( continued)

HATCH UNIT2 B 3.7-18 REVISION 74

MCREC System B 3.7.4 BASES (continued)

APPLICABLE The ability of the MCREC System to maintain the habitability of the SAFETY ANALYSES control roomCRE is an explicit assumption for the safety analyses presented in the FSAR, Chapters 6 and 15 (Refs. 3 and 4, respectively). The pressurization mode of the MCREC System is assumed to operate following a PBAloss of coolant accident, fuel handling accident, main steam line break, and control rod drop accident, as discussed in the FSAR, Section 6.4.1.2.2 (Ref. 5) . The radiological doses to control room personnelthe CRE occupants as a result of the various DBAs are summarized in Reference 6. No single active or passive failure will cause the loss of outside air or recirculated air from the control roomCRE.

The MCREC System provides protection from smoke and hazardous G.b..e.m.k;als to the CRE occupants , The evaluation of hazardous c!lemical (ele8s~s demonstrates th~ILth§ t9xici~J!mi!§ ar~Dot exceeded in the CRE following a hazardous chemical [olease (Ref.

12), The evaluation of a smoke challenge demonstrates that it will not result in the inabilLtv of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Ref. 2).

The MCREC System satisfies Criterion 3 of the NRC Policy Statement (Ref. 7).

LCO Two redundant subsystems of the MCREC System are required to be OPERABLE to ensure that at least one is available, Uassuming a single active failure disables the other subsystem. Total MCREC

~system failureJ.,lLch as from a loss of both ven.tilation subsystems or ff-QIl1--Mln.Q. Rerat2~ _CB~I;- b.oJ.ill.dQ~ could result in exceeding tRe--t-G CFR 50.67 dose limits (Ref. 10) for the control room operatorsa dose of 5 rem TEDE to the CRE occupants in the event of a DBA.

+Ae.-Each MCREC subsystemSystem is considered OPERABLE when the individual components necessary to control operatorlimit CRE occupant exposure are OPERABLE in both subsystems. A subsystem is considered OPERABLE when its associated:

a. Filter booster fan is OPERABLE;

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

c. Associated ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained;

d. One AHU fan is OPERABLE, and either operating or having (continued)

HATCH UNIT 2 B 3.7-19 REVISION 74

MCREC System B 3.7.4 its control switch in "Standby" with OPERABLE automatic start capability; and

e. Associated AHU cooling coils, water cooled condensing units, refrigerant compressors, and associated instrumentation and controls to ensure loop seal is maintained.

(continued)

HATCH UNIT 2 B 3.7-20 REVISION 74

MCREC System B 3.7.4 BASES LCO OPERABILITY of two MCREC subsystems entails satisfying the (continued) requirements listed above for each subsystem and, in addition, satisfying other limitations on AHU fan OPERABILITY. For both MCREC subsystems to be OPERABLE, the two required AHU fans must be independently powered; i.e., one fan via 1R24-S002 and one fan via 1R24-S003. (Note that AHU C is treated as powered from 1R24-S002 or S003, depending upon the source of power for 1R24-S029.) Furthermore, with one of the two required AHU fans inoperable (Le., not independently powered, or not operating or capable of automatic start), one MCREC subsystem shall be declared inoperable. However, the inoperability may be assigned to either MCREC subsystem. OPERABILITY details for various configurations are outlined in the Technical Requirements Manual (TRM) (Ref. 8),

Section 2.0.

In order for the MCREC subsystems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licBosing basis consequence analyses for DBAs, and that CRE Q.CCUR.ants....aHLQIQlo_cted {mOl. hazacoQu.s. c.b.emic...aLs...and....s mQk e. ffi addition, the control room boundary must be maintained, including tho integrity of tho walls, floors, seilings, dusp.vork, and access doors, such that tho pressurization limit of SR 3.7.4.4 can be met.

The LCO is modified by a Note allowing the mail control room.cRE boundary to be opened intermittently under administrative controls.

This Note only applies to openings in the CRE boundarv that can be rnpidly restored to the design condition, suclu!s goors, hatches. floor plugs, and access panels. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the QReJ..aiQf§ in_.1b.e .-<~EEmain control room. This individual will have a method to rapidly close the opening and to restore the CRE boundarv to a conill1iQn equivalent to the design condition when a need for maffi control roomGRE isolation is indicated.

Each of the main control room exhaust fan ducts is equipped with only one isolation damper (1Z41-F018AJB). During normal system operation, the dampers are maintained closed. However, when an exhaust fan is operated and its associated damper is opened, a single failure could prevent isolation of that penetration and adversely impact main control room habitability. Consequently, when a MCREC system exhaust fan (1Z41-C011A1B) is operated or its associated damper (1 Z41-FO 18A1B) is opened, one of the two MCREC subsystems must be declared inoperable. Optional allowances for (continued)

HATCH UNIT 2 83.7-21 REVISION 29

MCREC System B 3.7.4 inoperable subsystems do not preclude changing the declared inoperable sUbsystem to best accommodate other plant circumstances; e.g., inoperable diesel generators, Safety Function Determination Program. However, in these instances, the Condition for one inoperable MCREC subsystem shall not be evaluated for Completion Time extensions, in accordance with Section 1.3.

(continued)

HATCH UNIT 2 B 3.7-22 REVISION 29

MCREC System B 3.7.4 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, the MCREC System must be OPERABLE to aontrol operator exposureensure that the CRE will remain habitable 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 MCREC 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 movement of irradiated fuel assemblies in the secondary containment. Moving irradiated fuel assemblies in the secondary containment may also occur in MODES 1, 2, and 3;

b. During CORE ALTERATIONS; and

c. During operations with a.potential for draining the reactor vessel (OPDRVs).

ACTIONS With one MCREC subsystem inoperable, for reasons other than an in-2J2.§.@ble CRE boundary, the inoperable MCREC subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE MCREC subsystem is adequate to perform ~~RE..Q.Q.Q!J.J;Lg[lJcontrol room radiation protection fl.Jm;JlQn. However, the overall reliability is reduced because a sffiWe failure in the OPERABLE subsystem could result in roducedloss of the MCREC System fYos:liQQcapability. 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 main control room boundary is inoperable in MODE 1, 2, or 3, the MCREC trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE main control room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the period that the main control room boundary is inoperable, appropriate compensatory measures (aonsistent with the intent of GOG 19) INili be utilized to provide physical security and to protect control room operators from potential hazards such as radioacti'/e contamination, toxic chemicals , smoke, temperature and relative humidity. Preplan ned measures should be available to (continued)

HATCH UNIT 2 B 3.7-23 REVISION 29

MCREC System B 3.7.4 BASES ACTIONS address those GOncorns for intontional and unintentional ontry into tho condition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Cempletion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the main control room boundary.

ltJp.e.JJ,ofll.rer~Q i 1]!§~1~19~ ofJ2-R~Qti9JlY-.-c.on1anlillilleq,J~jLQg.§tLi1~<;=~t; boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses o.t.D.ELJ\..c.Q.n~eau e nces (allowed to be upJo 5 rem TE;PJ~1o-.QL inadequate pmtection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inQperable. Actions must be taken to r.~.~19re aoo.PEgf.\I?M= CRr;_PO,=!.~g9!)LwithJn 90 da~

Dur-ing th§ per.iod that the CRE bQundary is considered inQperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological QLclJemlG.aLeve.ot Qr .a..Qtlallengf:Uron:Ls.mQ.ke!Jn..a~r:.d.a.o.Q...e wLttL~

Contml Room Habitability Pmgram. l2fiions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA. tbe mitigating actions will SlJlSuLeJ.batCBI~ Q.Qc.UQant.rru,jiQIQqlcJ;!Lex.QQs..u.re..s.. wilLnQLeX.Q~edJh...e g.alculated dose of the licensing basis analyses of PBA consequenc...e.s~d that CRE occupants a...re...prote.cted fmm b~a?;&r:dQus..ch-ernJ.,g~l~~ng =~Q~.e..s..e=lJlltigg!iQ~ljQJ)'§O,§!.~

actions that are taken to Qffset the coosequences Qf the inoperable QBE bQ.Ylliiarv) should be oreplanned for implementation upon entry into the condition. [egarqless of whether entry is intentiQnal Qr unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months CQmpletion Time is reasonable based on ltleJ.Qw..PIo_b.g bjJjtY._QLlD..6.i:'LQ.QCl,mioQ.,d u.riogJh.is._timSl Qe.riQQ *.. a.oQ..the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure pmJe.c1lQ.n Qt.G8.E.o.cr;uQao..ts.. . wlthln_anaJyzed_.I.lmits whilaJim.i.t.IoSLth.a probabilitv that CRE occupants will have to implement protective measures that may gdyersely affect their ability to control the reactor a.ndJJlllintain itJu.Q. safe...sllutQQwnc.QJlditiQo.ioJb_e.e.y-.enLQLa..D.B.8, In addition, the 90 day Completion Time is a reasonable time to d1ggoose, Dian and possibly repair. and test most probleJIlS with the

.QR.I;.. Q9 Undg [Y..

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable MCREC subsystem or control fOeffithe CRE boundary cannot be restored to OPERABLE status within the r~associated Completion Time, the unit must be (continued)

HATCH UNIT 2 B 3.7-24 REVISION 29

System B 3.7.4 placed in a MODE that To achieve status, unit must 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in MODE 4 within hours. allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner without challenging unit systems.

Required Actions Condition D are modified not If moving irradiated or 3, the movement is independent of reactor ore.tn,*o inability to suspend movement of irradiated reason to require a reactor shutdown.

During movement of irradiated fuel assemblies in the secondary containment. CORE ALTERATIONS, or OPDRVs, if the inoperable subsystem cannot restored to status within the required Completion Time, the OPERABLE MCREC C'\JC'TO'..... may be in the mode. action ensures that the remaining subsystem is that no failures that would prevent automatic actuation have occurred, and that any failure will readily rlol,,,,,,,ihol'i An alternative to Required Action D.1 is to immediately suspend activities that present a potential releasing radioactivity that might require isolation of the places the unit in a condition that minimizes ~~~~='

If applicable, ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended Suspension of activities shall not HATCH UNIT 2 B REVISION 29

MCREC System B 3.7.4 BASES ACTIONS 0.1, 0.2.1, 0 .2.2, and 0.2.3 (continued) 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. Actions must continue until the OPDRVs are suspended.

E.1 If both MCREC subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable control roomCRE boundary (i.e .,

Condition B), the MCREC System may not be capable of performing the intended function and the unit is in a condition outside£! the accident analyses. Therefore, LCO 3.0 .3 must be entered immediately.

F.1, F.2. and F.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 MCREC subsystems inoperable or with one or more MCREC sUbsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the CREcontrol room . This places the unit in a condition that minimizes thf3 gC.9~df3 f!Lrisk.

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. Actions must continue until the OPDRVs are suspended.

(continued)

HATCH UNIT 2 B 3.7-26 REVISION 29

MCREC System B 3.7.4 BASES (continued)

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts on demand and continues to operate. Standby systems should be checked periodically to ensure that they start and function properly.

As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every 31 days provides an adequate check on this system. Since the MCREC System does not have heaters, each subsystem need only be operated for

~ 15 minutes to demonstrate the function of the subsystem. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.2 This SR verifies that the required MCREC 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 Efrequencies 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 MCREC subsystem starts and operates. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.4 overlaps this SR to provide complete testing of the safety function. This Surveillance can be performed with the reactor at power. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.4.4 This SR verifies the integrity of the control room enclosure and the assumed inleakage rates of potentially contaminated air. The control room positive pressure, ,,"ith respect te potentially contaminated adjacent areas (the turbine building), is periodically tested to verify proper function of the MCREC System. During the pressurization mode of operation, the MCREC System is designed to slightly pressurize the control room> 0.1 inches water gauge positive pressure with respect to the turbine building to prevent unfiltered inleakage. The MCREC System is designed to maintain this positive (continued)

HATCH UNIT 2 B 3.7-27 REVISION 79

MCREC System B3.7.4 BASES SURVEILLANCE SR 3.7.4.4 (continued)

REQUIREMENTS pressure at a flow rate of < 2750 cfm through the control room in the pressurization mode. This SR ensures the total flow rate meets the design analysis value of 2500 cfm ~ 10% and ensures the outside air flow rate is < 400 cfm. Tho Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

TillS R y_er.ifies.Jh~QP£R88JU.IY .m..ltle-.C8Ebo.undaJy.bYJ.e.sting

[QLuofilte.r.e.d.airjo.ie.akage..p..ast1be.. CB..E.bQJJI1d.ar¥.andtn.tQ t.h..e.. eRE...

ln~ deta ils of tile t~.sliru:La~pe cifL~Rinlbe ControlEQ.QDl.E~lQP~

ttgpitaqiH1ti>.r9}l[am,.

T he CRE is considered habitable wben the radiological dose to CRE 2<tcupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem IEDE aDd the CRE occupants a*re prgtected from hazardous chemicals and smoke . This SR..-V'ocifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the ilicensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate. Condition B must be entered Required Action B.3 allows time.tQ restore the CRE boundary to OPE8ABLE sta~

provided mitigatina actions can ensure that the CRE remains within the licensing basis habitability limits for the Qccupants following an accident. Compensatory measures are discussed in Regulatorv Guide lJ..96..Be.ctiQo C.. .2..L3...lReJ..JD. wlli.c.b endQIses*..wJtb...ex.c_ep-UQ-D s--' N.EJ.

99:0_3.....5e.cUou 8.A.flndAppeIlQii.£ ffief._1QLlbes!i..CJdffiRensatQa fTleasJ!Ie.s.ms;t~~.~~:9...Q§"Use.d..a.Lll1ill~.{tc.tiQj}s_aS..lemJlr§~

B.~gYi[§d Action e*2 . I§tT)POfsU:Y.JmelVligSlLmethqgs m aY21~0 be l!~§q:

e~ .fompen~~toQ(..r:r.J.~Jl~!,Ir§§ t9 tl~1Qr~LOPERABILlTY.m{Ref. 11l Options.JQu:e.s1Qrlng the CRE boundary to OPERABLE status include

.changinq.Jbe licensing basis DBA consequence analysis. repairing the CRE boundary. or a combination of these actions. Dgpending upon the nature of the oroblem and the corrective action. a full scope inleakage test may not be necessarY to establish that the CRE boundarY has been restored to OPERABLE status.

REFERENCES 1. FSAR, Section 6.4.

2. FSAR, Section 9.4.1.

3. FSAR, Chapter 6.

4. FSAR, Chapter 15.

5. FSAR, Section 6.4.1.2 .2.

6. FSAR, Table 15.1-28.

7. NRC No.93-102, "Final Policy Statement on Technical HATCH UNIT 2 B 3.7-28 REVISION 79

MCREC System B 3.7.4 Specification Improvements," July 23, 1993.

8. Technical Requirements Manual , Table T2.1-1 .

.9... .... 10 CfR 50.67.8.e9.ulalQr,L,GJ.tid.e.1.J.9.Q

,1Q~,... N E I 99-03.* "CQntIQLB...QQIJ] Hab.ita.b.lli!~~?-es.sm~J.me 2.Q.9l, 11 , Letter from Eric J, Leeds (NBC) to James W. Davis (NEI) dated January 30 . 2004. nNEI Draft White Paper. Use of Generic Letter 91 -18 Process and Alternative Source Terms in the Context of Control Room Habitabil ity." (ADAMS Accession No. ML040300694) fh12. FSAR. Section 15.4 HATCH UNIT2 B 3.7-29 REVISION 79

NL-13-0058, License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (CLIIP)

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Enclosures:

3.0 REGULATORY ANALYSIS

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NL-13-0058, License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (CLIIP)

Text

Enclosures:

3.0 REGULATORY ANALYSIS

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