NRC-2010-0089, Supplement to License Amendment Requests 241 Alternative Source Term, Revised Proposed Technical Specifications for Control Room Envelope Habitability Program

Supplement to License Amendment Requests 241 Alternative Source Term, Revised Proposed Technical Specifications for Control Room Envelope Habitability Program

ML101890783
Person / Time
Site:	Point Beach
Issue date:	07/08/2010
From:	Meyer L Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-2010-0089
Download: ML101890783 (28)

Text

July 8, 201 0 POINT BEACH NRC 201 0-0089 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units I and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 Supplement to License Amendment Request 241 Alternative Source Term Revised Proposed Technical Specifications for Control Room Envelope Habitability Program

References:

( 1 FPL Energy Point Beach, LLC letter to NRC, dated December 8,2008, Submittal of License Amendment Request 241, Alternative Source Term (ML083450683)

(2)

NextEra Energy Point Beach, LLC letter to NRC, dated April 20, 2010, Supplement to License Amendment Request 241, Alternative Source Term, Proposed Technical Specification for Control Room Emergency Filtration System (CREFS) (MLI 01 100605)

(3)

Forthcoming Meeting with FPL Energy Point Beach, LLC Regarding the Alternative Source Term (AST), Extended Power Uprate (EPU),

Auxiliary Feedwater (AFW), and Non-Conservative Setpoint Amendments, dated May 13,201 0 (MLI 01 320722)

NextEra Energy Point Beach, LLC (NextEra) submitted License Amendment Request (LAR) 241 (Reference I ) to the NRC pursuant to 10 CFR 50.90. The license amendment would revise the current licensing basis to implement the alternative source term (AST) through reanalysis of the radiological consequences of the Point Beach Nuclear Plant (PBNP) Final Safety Analysis Report (FSAR) Chapter 14 accidents.

In Reference (2), NextEra proposed to add License Conditions, revise Technical Specification (TS) 3.7.9, Control Room Emergency Filtration System (CREFS) and add new TS 5.5.1 8, Control Room Envelope Habitability Program, to address AST-related commitments. During a public meeting on May 27,201 0, between NextEra Energy Point Beach, LLC (NextEra) and the NRC (Reference 3), the NRC staff provided additional comments for consideration based on their review of Reference (2).

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 provides the NextEra response to the NRC staff comments during the aforementioned public meeting. Enclosure 2 provides new proposed License Conditions and a revised proposed TS 5.5.18 from Reference (2). Enclosure 3 provides revised markups of the proposed Bases for TS 3.7.9, Control Room Emergency Filtration System (CREFS), from Reference (2). The TS Bases are being provided for information only. NextEra is not requesting approval of the Bases.

This letter contains no new Regulatory Commitments and no revisions to existing Regulatory Commitments.

The information contained in this letter does not alter the no significant hazards consideration contained in Reference (2) and continues to satisfy the criteria of 10 CFR 51.22 for categorical exclusion from the requirements of an environmental assessment.

The PBNP Plant Operations Review Committee has reviewed the proposed TS and Bases changes.

In accordance with 10 CFR 50.91, a copy of this letter is being provided to the designated Wisconsin Official.

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

Executed on July 8, 201 0.

Very truly yours, NextEra Energy Point Beach, LLC Larry Meyer Site Vice President Enclosures cc:

Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

ENCLOSURE I NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 SUPPLEMENT TO LICENSE AMENDMENT REQUEST 241 ALTERNATE SOURCE TERM REVISED PROPOSED TECHNICAL SPECFICATOINS FOR CONTROL ROOM ENVELOPE HABITABILIN PROGRAM During a public meeting between NextEra Energy Point Beach, LLC (NextEra) and the NRC (Reference I), the NRC staff determined that additional information was required to enable completion of the review of License Amendment Request (LAR) 241, Alternative Source Term (AST) (Reference 2). The following information is provided by NextEra in response to the NRC staff's request.

Question I Provide specifics regarding the safety classification of the mitigating filtration unit(s).

NextEra Response As discussed during the public meeting between NextEra and the NRC, and discussed in Reference (3), the safety classification of the mitigating filtration unit(s) will be equal to or better than that of the existing control room emergency filtration system (CREFS). As a minimum, the mitigating filtration unit(s) will be classified as augmented quality. This quality classification means that design, procurement, maintenance, and operational activities associated with the mitigating filtration unit(s) will fall under the NextEra 10 CFR 50, Appendix B, Quality Assurance Program. Further information regarding this classification is provided in Reference (4).

Question 2 Provide specifics regarding the power requirements for the mitigating filtration unit(s), and address loading requirements on the emergency diesel generators (EDGs).

NextEra Response The mitigating filtration unit(s) will only be placed in service when the CREFS is out of service.

The electrical power requirements for the mitigating filtration unit(s) are equivalent to the installed CREFS fans. Thus, EDG loading would not be affected if the mitigating filtration unit(s) were placed into service following a loss of offsite power.

Page 1 of 5

Question 3 Provide specifics regarding the seismic design of the mitigating filtration unit(s).

NextEra Response The mitigating filtration unit(s), associated ductwork and bubble tight dampers will be installed and supported to Seismic Class I requirements as defined in the Point Beach Nuclear Plant (PBNP) Final Safety Analysis Report (FSAR), Appendix A.5, Seismic Design Analysis. The mitigating filtration unit(s) will be seismically qualified in accordance with the guidelines provided in the Seismic Qualification Utility Group (SQUG) Generic lmplementation Procedure for Seismic Verification of Nuclear Plant Equipment, Revision 2, as corrected on February 14, 1992, and in the December 2006, Electric Power Research Institute (EPRI) Final Report 1014608, "Seismic Evaluation Guidelines for HVAC Duct and Damper Systems:

Revision to 1007896," as applicable.

As discussed in during the public meeting between NextEra and the NRC (Reference I),

NextEra proposes new License Conditions, provided in Enclosure 2, regarding the seismic design and installation of the mitigating filtration unit(s). The following license condition will provide the NRC additional assurance that the mitigating filtration unit(s) meet NRC seismic design requirements:

NextEra Energy Point Beach, LLC will install and support CREFS mitigating filtration unit(s) and associated ductwork and bubble tight dampers to Seismic Class I requirements as defined in FSAR Appendix A.5. The mitigating filtration unit(s) will be seismically qualified in accordance with the guidelines provided in the Seismic Qualification Utility Group (SQUG) Generic lmplementation Procedure for Seismic Verification of Nuclear Plant Equipment, Revision 2, as corrected on February 14, 1992, and in the December 2006, Electric Power Research Institute (EPRI)

Final Report 1014608, "Seismic Evaluation Guidelines for HVAC Duct and Damper Systems: Revision to 1007896," as applicable. This modification is scheduled to be completed following NRC approval of LAR 241, Alternative Source Term, no later than the Unit 2 (201 1) refueling outage.

Question 4 Consistent with the requirements of TSTF-448, Revision 3, provide assurance in the proposed Technical Specifications that Control Room Envelope occupants can maintain the reactor in safe condition following a hazardous chemical release or smoke challenge.

NextEra Response provides a revision to proposed Technical Specification (TS) 5.5.18, Control Room Envelope Habitability Program, from Reference (3). The revision includes provisions in the control room envelope (CRE) habitability program to address protection of CRE occupants from a hazardous chemical release or smoke challenge.

Page 2 of 5

The following revision to TS 5.5.18 is proposed:

Replace:

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

a.

The definition of the CRE and the CRE boundary.

b.

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

c.

Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide I.

197, Revision 0.

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the technical specification emergency mode of operation by the CREFS, operating at the flow rate required by the VFTP, at a Frequency of 18 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e.

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

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by Paragraphs c and dl respectively.

With:

"Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Filtration System (CREFS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel Page 3 of 5

receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. Additionally, separate from the CREFS, the program shall ensure CRE occupants can maintain the reactor in a safe condition following a hazardous chemical release or smoke challenge. The program shall include the following elements:

a.

The definition of the CRE and the CRE boundary.

b.

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

c.

Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide I.I 97, Revision 0.

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the technical specification emergency mode of operation by the CREFS, operating at the flow rate required by the VFTP, at a Frequency of 18 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e.

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

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by Paragraphs c and dl respectively.

g.

An adequate supply of self-contained breathing apparatus (SCBA) units in the CRE to protect CRE occupants from a hazardous chemical release.

h.

Portable smoke ejection equipment per the Fire Protection Evaluation Report and Safe Shutdown Analysis Report to address a potential smoke challenge."

Basis for the change: NextEra proposes a new administrative controls program TS consistent with the model program contained in Technical Specification Task Force (TSTF)-448, Revision 3, Control Room Habitability (Reference 5). Since CREFS is not credited for hazardous chemical release andlor smoke challenge, separate line entries (g. and h.) are provided reflecting the PBNP current licensing basis for protecting CRE occupants from these hazards, and to address the intent of TSTF-448, Revision 3.

Page 4 of 5

Question 5 Provide additional explanation of operability of active components similar to that provided for the

?urkey Point control room ventilation system.

NextEra Response provides a revision to the proposed CREFS TS Bases provided in Reference (3).

Page B 3.7.9-4a has been modified to clarify the operability requirements for the active CREFS components, similar to that provided for the Turkey Point control room ventilation system in Reference (6).

References (1)

Public Meeting between NextEra Energy Point Beach, LLC and NRC regarding AST, EPU, and Non-conservative Setpoint Amendments, on May 27,2010 (MLIOI 320722)

(2)

FPL Energy Point Beach, LLC letter to NRC, dated December 8, 2008, Submittal of License Amendment Request 241, Alternative Source Term (ML083450683)

(3)

NextEra Energy Point Beach, LLC letter to NRC, dated April 20, 201 0, Supplement to License Amendment Request 241, Alternative Source Term, Proposed Technical Specifications for Control Room Emergency Filtration System (CREFS) (MLl01100605)

(4)

NextEra Energy Point Beach, LLC letter to NRC, dated August 20, 2009, License Amendment Request 241, Alternative Source Term, Response to Request for Additional lnformation (ML092330180)

(5)

Technical Specification Task Force, TSTF-448, Revision 3, "Control Room Habitability,"

August 8,2006 (ML062210095)

(6)

FPL letter to NRC, dated May 21, 2010, Supplement to License Amendment Request (LAR) 196 and March 24, 201 0 Request for Additional lnformation (RAI) Regarding Alternative Source Term (TAC Nos. ME1624 and ME1625) (MLI 01450028)

Page 5 of 5

ENCLOSURE 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 SUPPLEMENT TO LICENSE AMENDMENT REQUEST 241 ALTERNATIVE SOURCE TERM REVISED PROPOSED TECHNICAL SPECIFICATIONS FOR CONTROL ROOM EMERGENCY FILTRATION SYSTEM (CREFS)

PROPOSED APPENDIX C LICENSE CONDITIONS AND TECHNICAL SPECIFICATION 5.5.18 MARKUPS 6 pages follow

APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE DPR-24 FPL Energy Point Beach, LLC shall comply with the following conditions and the schedules noted below:

Amendment Number Additional Conditions Implementation Date -

228 At the time of the closing of the transfer of the licenses from Wisconsin Immediately Electric Power Company (WEPCO) to FPLE Point Beach, WEPCO shall transfer to FPLE Point Beach WEPCO's decommissioning funds in an aggregate minimum value of $200.8 million for Point Beach Unit 1. FPLE Point Beach shall deposit such funds in an external decommissioning trust fund established by FPLE Point Beach for Point Beach Units I and 2. The trust agreement shall be in a form acceptable to the NRC.

FPLE Point Beach shall take no actions to cause FPLE Group Capital, or Immediately its successors and assigns, to void, cancel, or modify its $70 million Support Agreement (Agreement) to FPLE Point Beach, as presented in its application dated January 26, 2007, or cause it to fail to perform or impair its performance under the Agreement, without the prior written consent from the NRC. The Agreement may not be amended or modified without 30 days prior written notice to the Director of Nuclear Reactor Regulation or his designee. An executed copy of the Agreement shall be submitted to the NRC no later than 30 days after the completion of the license transfers.

Also, FPLE Point Beach shall inform the NRC in writing anytime it draws upon the $70 million Agreement.

Upon implementation of Amendment Nos. XXXIXXX adoptina TSTF-448, Immediatelv Revision 3, the determination of control room envelope (CRE) unfiltered air inleakaae as required bv SR 3.7.9.6. in accordance with TS 5.5.1 8.~4). the assessment of CRE habitabilitv as reauired bv Specification 5.5.1 8.c.(ii),

and the measurement of CRE pressure as reauired bv Specification 5.5.1 8.d. shall be considered met. Followina implementation:

a. The first performance of SR 3.7.9.6. in accordance with Specification 5.5.1 8.c.(i). shall be within 18 months of implementation of this amendment.

b. The first performance of the periodic assessment of CRE habitabilitv, Specification 5.5.18.c.(ii). shall be within three (3) vears of completion of the testina prescribed in item a. above.

c. The first performance of the periodic measurement of CRE pressure, Specification 5.5.1 8.d. shall be within 18 months of implementation of this amendment.

Point Beach Unit I Amendment No. 22%

APPENDIX C ADDITIONAL CONDITIONS OPEWTING LICENSE DPR-24 NextEra Energy Point Beach, LLC shall comply with the following conditions and the schedules noted below:

Amendment Additional Conditions Implementation Number Date

&XJ NextEra Enerav Point Beach. LLC will modify the PBNP control room (CR) radiation shieldina to ensure CR habitabilitv reauirements are maintained. This modification is scheduled to be completed followina Nuclear Reaulatory Commission (NRC) approval of LAR 241. "Alternative Source Term." no later than the Unit 2 (201 1) refueling outaae.

NextEra Enerqv Point Beach. LLC will revise PBNP Emeraencv Oueratina procedures lEOPs1 to direct continued containment sprav while on sump recirculation. These procedure chanaes will be implemented followina NRC approval of LAR 241, "Alternative Source Term." no later than the Unit 2 (201 1) refuelina outaae.

NextEra Energy Point Beach. LLC will modify the control room emeraencv filtration svstem (CREFS) to create a new alianment for the accident mode that provides a combination of filtered outside air and filtered recirculation air. The modifications will include redundancv for all CREFS active components that must reposition from their normal o~eratina position. and auto-start capability on loss of offsite power in,

conjunction with a containment isolation or hiah control room radiation sianal from an emeraencv diesel aenerator supplied source for the CREFS fans required for the new svstem alianment. These modifications will be completed followina NRC approval of LAR 241. "Alternative Source Term." no later than the Unit 2 (201 1) refuelina outaae.

NextEra Enerav Point Beach. LLC will modify the primary auxiliary buildina (PAB]

ventilation svstem (VNPAB) to ensure redundancv of active components needed to operate the PAB exhaust svstem. VNPAB components credited for AST will be uparaded to an auamented auality status. No credit is taken bv AST for the PAB charcoal filters. NextEra Enerav Point Beach. LLC will revise PBNP EOPs to address startina the VNPAB fans. This modification is scheduled to be completed following Nuclear Reuulatorv Commission (NRC) approval of LAR 241. "Alternative Source Term," no later than the Unit 2 (201 1) refuelina outaae.

NextEra Enerav Point Beach. LLC will perform Train B Emeraencv Diesel Generator load testina over a ranae of 2877 to 2950 kW at rated power factor followinp im~lementation of LAR 241 in accordance with the testina schedule. This license condition will remain in effect.unti1 implementation of LAR 261 for Unit 2.

NextEra Enerav Point Beach, LLC will install and support CREFS mitiaatina filtration unit(s) and associated ductwork and bubble tiaht dampers to Seismic Class I reauirements as defined in FSAR Appendix A.5. The mitiaatinq filtration unit(s) will be seismicallv qualified in accordance with the auidelines provided in the Seismic Qualification Utility Group (SQUG) Generic Implementation Procedure for Seismic Verification of Nuclear Plant Eaui~ment, Revision 2, as corrected on Februarv 14. 1992. and in the December 2006. Electric Power Research Institute

{EPRI) Final Report 1014608, "Seismic Evaluation Guidelines for HVAC Duct and Damper Svstems: Revision to 1007896." as ap~licable. This modification is scheduled to be completed followina NRC approval of LAR 241. Alternative Source Term." no later than the Unit 2 f2011) refuelina outaae.

Point Beach Unit 1 C-3 Amendment No. 228

APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE DPR-27 FPL Energy Point Beach, LLC shall comply with the following conditions and the schedules noted below:

Amendment Number Additional Conditions Implementation Date -

233 At the time of the closing of the transfer of the licenses from Wisconsin Immediately Electric Power Company (WEPCO) to FPLE Point Beach, WEPCO shall transfer to FPLE Point Beach WEPCO's decommissioning funds in an aggregate minimum value of $189.2 million for Point Beach Unit 2. FPLE Point Beach shall deposit such funds in an external decommissioning trust fund established by FPLE Point Beach for Point Beach Units I and 2. The trust agreement shall be in a form acceptable to the NRC.

FPLE Point Beach shall take no actions to cause FPLE Group Capital, Immediately or its successors and assigns, to void, cancel, or modify its $70 million Support Agreement (Agreement) to FPLE Point Beach, as presented in its application dated January 26, 2007, or cause it to fail to perform or impair its performance under the Agreement, without the prior written consent from the NRC. The Agreement may not be amended or modified without 30 days prior written notice to the Director of Nuclear Reactor Regulation or his designee. An executed copy of the Agreement shall be submitted to the NRC no later than 30 days after the completion of the license transfers. Also, FPLE Point Beach shall inform the NRC in writing anytime it draws upon the $70 million Agreement.

xXx Upon implementation of Amendment Nos. XXXJXXX adopting Immediately TSTF-448. Revision 3, the determination of control room envelope

{CRE) unfiltered air inleakaqe as required bv SR 3.7.9.6. in accordance with TS 5.5.18.c.li). the assessment of CRE habitability as required bv Specification 5.5.1 8.c.lii). and the measurement of CRE pressure as required bv Specification 5.5.18.d. shall be considered met. Following implementation:

a. The first performance of SR 3.7.9.6. in accordance with Specification 5.5.1 8.c.fi). shall be within 18 months of implementation of this amendment.

b. The first performance of the periodic assessment of CRE habitability, S~ecification 5.5.1 8.c.(ii). shall be within three (3) vears of completion of the testina prescribed in item a. above.

c. The first performance of the periodic measurement of CRE pressure, S~ecification 5.5.18.d. shall be within 18 months of implementation of this amendment.

Point Beach Unit 2 C-2 Amendment No. 233

APPENDIX C ADDITIONAL CONDITIONS OPEFWTING LICENSE DPR-27 NextEra Energy Point Beach, LLC shall comply with the following conditions and the schedules noted below:

Amendment Additional Conditions Implementation Number Date XXX NextEra Enerav Point Beach. LLC will modifv the PBNP control room (CR) radiation shieldina to ensure CR habitability requirements are maintained. This modification is scheduled to be completed followina Nuclear Reaulatory Commission (NRC) aporoval of LAR 241. "Alternative Source Term." no later than the Unit 2 (201 1) refueling outaae.

NextEra Eneruv Point Beach. LLC will revise PBNP Emeraencv Operatina procedures

/EOPs) to direct continued containment sprav while on sump recirculation. These procedure chanaes will be implemented followina NRC approval of LAR 241, "Alternative Source Term." no later than the Unit 2 (201 1) refuelina outaae.

NextEra Enerav Point Beach. LLC will modifv the control room emeraencv filtration svstem (CREFS) to create a new alianment for the accident mode that orovides a combination of filtered outside air and filtered recirculation air. The modifications will include redundancv for all CREFS active components that must reposition from their normal operatina oosition, and auto-start casability on loss of offsite power in coniunction with a containment isolation or hiah control room radiation siqnal from an emeraencv diesel aenerator suoplied source for the CREFS fans reauired for the new svstem alianment. These modifications will be comoleted followina NRC approval of LAR 241. "Alternative Source Term," no later than the Unit 2 (201 1 ) refuelina outaae.

NextEra Enerav Point Beach, LLC will modify the primarv auxiliarv buildina (PAB) ventilation svstem (VNPAB) to ensure redundancy of active components needed to operate the PAB exhaust svstem. VNPAB comoonents credited for AST will be uparaded to an auamented quality status. No credit is taken bv AST for the PAB charcoal filters. NextEra Enerav Point Beach. LLC will revise PBNP EOPs to address startina the VNPAB fans. This modification is scheduled to be comoleted following Nuclear Reaulatory Commission (NRC) approval of LAR 241. "Alternative Source Term." no later than the Unit 2 (2011) refuelina outaae.

NextEra Enerrv Point Beach. LLC will serform Train B Emeraencv Diesel Generator load testina over a ranae of 2877 to 2950 kW at rated power factor followinq imslementation of LAR 241 in accordance with the testina schedule. This license condition will remain in effect until imolementation of LAR 261 for Unit 2.

NextEra Enerav Point Beach. LLC will install and susport mitigating filtration unitfs) and associated ductwork and bubble tiaht dampers to Seismic Class I requirements as defined in FSAR Appendix A.5. The mitigatina filtration unit(s) will be seismicallv qualified in accordance with the auidelines srovided in the Seismic Qualification Utility Group (SQUG) Generic Implementation Procedure for Seismic Verification of Nuclear Plant Eaui~ment. Revision 2. as corrected on February 14. 1992, and in the December 2006. Electric Power Research Institute (EPRI) Final Report 1014608, "Seismic Evaluation Guidelines for HVAC Duct and Damper Svstems: Revision to 1007896." as applicable. This modification is scheduled to be completed followinq NRC aooroval of LAR 241. Alternative Source Term. no later than the Unit 2 (201 1) refuelina outaae.

Point Beach Unit 2 C-3 Amendment No. 233

Programs and Manuals 5.5 5.0 Programs and Manuals 5 5 1 8.

Control Room Envelooe Habitability Proaram A Control Room Envelope (CRE) Habitability Proaram shall be established and imolemented to ensure that CRE habitabilitv is maintained such that, with an OPERABLE Control Room Emeraencv Filtration Svstem @REFS). CRE occupants can control the reactor safelv under normal conditions and maintain it in a safe condition followina a radioloaical event. The proaram shall ensure that adeauate radiation protection is orovided to permit access and occuoancv of the CRE under desian basis accident (DBA) conditions without personnel receivina radiation exposures in excess of 5 rem total effective dose eauivalent (TEDE) for the duration of the accident. Additionallv. separate from the CREFS. the proqram shall ensure CRE occuoants can maintain the reactor in a safe condition followina a hazardous chemical release or smoke challenae. The oroqram shall include the followina elements:

a. -

The definition of the CRE and the CRE boundary.

b. -

Requirements for maintaining the CRE boundary in its desian condition includina confiauration control and preventive maintenance.

C. -

Reauirements for (i) determinina the unfiltered air inleakaae past the CRE boundarv into the CRE in accordance with the testina methods and at the Frequencies specified in Sections C.l and C.2 of Reaulatory Guide I.I 97, "Demonstratina Control Room Envelope Intearity at Nuclear Power Reactors," Revision 0. Mav 2003, and fii) assessina CRE habitability at the Freauencies specified in Sections C.l and C.2 of Reaulatorv Guide I.I 97, Revision 0.

d. -

Measurement. at desianated locations. of the CRE pressure relative to all external areas adjacent to the CRE boundary durina the technical soecification emeraencv mode of operation bv the CREFS, operatina at the flow rate required bv the VFTP. at a Frequencv of 18 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e. -

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakaae measured bv the testina described in Paraaraph c.

The unfiltered air inleakaqe limit for radioloaical challenaes is the inleakaae flow rate assumed in the licensina basis analvses of DBA consequences.

f. -

The provisions of SR 3.0.2 are applicable to the Freauencies for assessing CRE habitabilitv. determinina CRE unfiltered inleakage. and measuring CRE pressure and assessina the CRE boundary as required bv Paraqraphs c and d. resoectivelv.

An adeauate supplv of self contained breathing apparatus (SCBA) units in the CRE to protect CRE occupants from a hazardous chemical release.

Point Beach 5.5-1 8 Unit 1 - Amendment No.

Unit 2 - Amendment No.

Programs and Manuals 5.5 5.0 Programs and Manuals

h. -

Portable smoke ejection equipment per the Fire Protection Evaluation Report and Safe Shutdown Analvsis Report to address a ~otential smoke challenae.

Point Beach 5.5-1 8a Unit I - Amendment No.

Unit 2 - Amendment No.

ENCLOSURE 3 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 SUPPLEMENT TO LICENSE AMENDMENT REQUEST 241 ALTERNATIVE SOURCE TERM PROPOSED TECHNICAL SPECIFICATIONS FOR CONTROL ROOM EMERGENCY FILTRATION SYSTEM (CREFS)

PROPOSED TECHNICAL SPECIFICATION BASES MARKUPS (FOR INFORMATION ONLY) 13 pages follow

CREFS B 3.7.9 B 3.7 PLANT SYSTEMS B 3.7.9 Control Room Emergency Filtration System (CREFS)

BASES BACKGROUND The CREFS provides a protected environment from which epxatws occu~ants can control the unit following an uncontrolled release of radioactivity.

I The CREFS consists of one emergency m a b t p a i r filtration unit, two emergency wak-tpfans, two recirculation fans, and the required ducts, valves. instrumentation. doors. barriers. and dampers necessary to establish the required flow paths and isolation boundariesu recirculate and filter the air in the control room envelope (CRE) and a CRE boundary that limits the inleakaae of unfiltered air. Doors. walls, floor, roof. penetrations, and barriers also form part of the svstem. The CREFS is an emergency system, parts of which operate during normal unit operations.

The CRE is the area within the confines of the CRE boundarv that contains the maces that the control room occupants inhabit to control the unit durina normal and accident conditions. This area encompasses the control room. and mav encompass other non-critical areas to which frequent personnel access or continuous occupancv is not necessary in the event of an accident. The CRE is protected during normal operation. natural events and accident conditions. The CRE boundary is the combination of walls. floor. roof. ductina. doors, penetrations. and eauipment that phvsicallv form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakaae of unfiltered air into the CRE will not exceed the inleakaae assumed in the licensina basis analvsis of desian basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Proaram.

The CREFS has M& modes of operation, however onlv Mode 5 is credited in the FSAR Cha~ter 14 radioloaical analvses. FSAR 9.8

/Ref. I) provides a svstem description for all five modes of CREFS operation.

Point Beach B 3.7.9-1 nn133/3nn3

CREFS B 3.7.9 Point Beach B 3.7.9-la

CREFS B 3.7.9 BASES BACKGROUND (continued)

Mode 5 (emeraencv HEPA/charcoal filtered outside air and HEPAIcharcoal filtered return air) allows a combination of outside air Point Beach B 3.7.9-2

CREFS B 3.7.9 BASES BACKGROUND and return air 21955 cfm to pass throuah the emeraencv lcontinued)

HEPAIcharcoal filter unit to the suction of the control room recirculation fan for a total flow rate of 4950 cfm 51 0%. This makeup flow rate is sufficient to assure a positive pressure that will prevent excessive unfiltered in-leakaae into the CRE. Mode 5 is automaticallv initiated by a containment isolation sianal. or bv a hiah radiation sianal from the control room monitor RE-101. or bv a hiah radiation sianal from the noble aas monitor RE-235 located in the supplv duct to the control room. This mode of operation can also be manuallv initiated from the control room. Operation of the CREFS in Mode 5 is the assumed mode of o~eration for the control room habitabilitv analvses. and is therefore, the onlv mode of operation addressed bv the Technical Specification LCO.

Point Beach

CREFS B 3.7.9 BASES BACKGROUND The limiting design basis accident for the CRE-dose (continued) analysis is the large break LOCA. CREFS automatically restart2 after being load shed following a loss of offsite power+mamA The control room emergency fftake-ty3-and recirculation

-&n included in the emergency diesel generator loading p

r o

f i

l e

i I

APPLICABLE The CREFS provides airborne radiological protection for CRE occu~ants SAFETY ANALYSES -

as demonstrated by the limiting CRE-ee&~el reefft dose analyses for the design basis large break LOCA-less-ef CRE-dose analysis assumptions are presented in the FSAR, Section 14.3.5 (Ref. 2).

The CREFS satisfies Criterion 3 of 10 CFR 50,36(c)(2)(ii).

The CREFS (=Mode 45) is required to be OPERABLE to ensure that the CRE-habitability limits are met following a-limiting design basis ~ a c c i d e n t s.

Total system failure could result in exceeding the control room operator total effective dose equivalent

/TEDE) limit of 5 rem in the event of a large radioactive release. The CREFS is considered OPERABLE when the individual components necessary to filter and limit CRE-in-leakage are OPERABLE. CREFS is considered OPERABLE when:

I

a. Both emergency wakwpfans (W-14A and W-14B) are OPERABLE; I

b.

recirculation fang (W-I 3B1 W-13l.32)

OPEKBLE; I

c. Emergency *filter unit (F-16), HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; I

Point Beach B 3.7.9-3

CREFS B 3.7.9 BASES LC0 (continued)

d. Both emeraencv fan control dampers (VNCR-4851 C and VNCR-4851 D) are OPERABLE;

e. Both isolation dampers in the kitchen area exhaust duct (CV-6748 and CV-6748A) are OPERABLE; Point Beach B 3.7.9-3a

CREFS B 3.7.9 BASES LC0 (continued)

f.

Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained; and CREFS is capable of being automaticallv and manually initiated in the emergency wakxpmode of operation (wNode 43).

. Irr J

m u

s t

be maintained such that the CRE occupant dose from a larae radioactive release does not exceed the calculated dose in the licensing basis conseauence analvses for DBAs.

The LC0 is modified bv a Note allowina the CRE boundary to be o~ened intermittentlv under administrative controls. This Note only a~plies to openinas in the CRE boundary that can be rapidlv restored to the desian condition, such as doors. hatches. floor pluas. and access panels. For entry and exit throuah doors, the administrative control of the openina is performed bv the personk) enterina or exitina the area.

For other o~eninas. these controls should be ~roceduralized and consist of stationina an individual at the openina who is in continuous communication with the o~erators in the CRE. This individual will have a method to rapidlv close the openina and to restore the CRE boundary to a condition equivalent to the desian condition when a need for CRE isolation is indicated.

APPLICABILITY In MODES I, 2, 3,4, and during movement of irradiated fuel assemblies, CREFS must be OPERABLE t v

ensure that the CRE will remain habitable during and following a DBA.

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

ACTIONS A. 1 Condition A is modified by a Note indicating that separate Condition entry is allowed for each component. --

IC-Point Beach Unit 1 - Amendment 3""

Unit 2 - Amendment 2343

CREFS B 3.7.9 BASES ACTIONS (continued) Two recirculation fans are reauired since in the event of a sinale failure, onlv one recirculation fan would be available. Each recirculation fan is considered a 100% capacitv fan. In the case of an inoperable recirculation fan. the fan is required to be restored to OPERABLE status within 7 davs based on the low probabilitv of a DBA occurrina durina this time period, and continued capabilitv of its redundant recirculation fan to perform its safetv function.

Two emeraencv fans are reauired since in the event of a sinale failure, onlv one emeraencv fan would be available. Each emeraencv fan is considered a 100% capacitv fan. In the case of an inooerable emeraencv fan, the fan is required to be restored to OPERABLE status within 7 davs based on the low orobabilitv of a DBA occurrina durina this time period. and the continued capabilitv of its redundant emeraencv fan to perform its safetv function.

Each emeraencv fan control damper is sufficient to support emeraencv operation. In the case of an inoperable emeraencv fan control damper, the damper is required to be restored to OPERABLE status within 7 davs based on the low probabilitv of a DBA occurrina durina this time period. and continued caoabilitv of its redundant damper to perform its safetv function.

The kitchen area exhaust isolation dampers consist of two dampers in series. In case one of the dampers is inoperable. the damper can either be restored within 7 davs. or the affected flow path isolated bv closing and maintainina the other damper in a closed position. When one isolation damper in the kitchen area exhaust duct is inoperable. action must be take'n to restore the damper to OPERABLE status within 7 davs or the other isolation damper in the same duct must be placed and maintained in the closed oosition within 7 davs. The 7 dav Completion Time is based on the low orobabilitv of a DBA challenaina control room habitabilitv occurrinq durina this time period.

C.l, C.2, and C.3 Condition C is modified by a Note indicating that separate Condition entry is allowed for each component. When two control room recirculation fans are inooerable. or two control room emeraencv fans are inoperable. or two control room emeraencv fan control dampers are inoperable, or the filter train is inoperable for reasons other than an inooerable CRE boundary: immediatelv initiate actions to implement mitiaatina actions to lessen the effect on CRE occupants from the Point Beach B 3.7.9-4a Unit 1 - Amendment No. 22%

Unit 2 - Amendment No. 230

CREFS B 3.7.9 BASES ACTIONS (continued) potential hazards of a radioloaical event: immediatelv suspend movement of irradiated fuel assemblies until the followina action is completed: verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the mitiaatina actions taken ensure CRE occupant radioloaical exposures will not exceed limits: and restore the inoperable fans. dampers. or filter train to OPERABLE status within 7 davs.

The mitiaatina actions (i.e., actions that are taken to offset the consequences of the inoperable fans, dampers. or filter train) should be preplanned for implementation upon entry into the condition. reaardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probabilitv of a DBA occurring durina this time period. and the use of mitiaatina actions such as filtration unit(s1 and administration of Kl. as appropriate. The 7 dav Completion Time is reasonable based on the determination that the mitiaatina actions will ensure protection of CRE occupants within analvzed limits. while limitina the probabilitv that CRE occupants will have to implement protective measures that mav adverselv affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition. the 7 dav Completion Time is a reasonable time to diaanose, plan and possiblv repair. and test most problems with the inoperable fans, dampers. and/or filter train.

D.1, 0.2, and D.3 Condition D is modified by a Note indicating that separate Condition entry is allowed for each component. If the unfiltered inleakaae of potentiallv contaminated air past the CRE boundary and into the CRE can result in CRE occupant radioloaical dose areater than the dose limit of the licensina basis analyses of DBA consequences (allowed to be up to 5 rem TEDE). the CRE boundary is inoperable. When the filter train is inoperable due to an inoperable CRE-boundary: immediatelv initiate actions to implement mitiaatina actions to lessen the effect on CRE occupants from the potential hazards of a t-adioloaical event; immediatelv suspend movement of irradiated fuel assemblies until the followina action is completed: verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the mitigating actions taken ensure CRE occupant radioloaical exposures will not exceed limits: and restore the CRE boundary to OPERABLE status within 90 davs.

The mitiaatina actions (i.e.. actions that are taken to offset the consequences of the inoperable filter train due to an inoperable CRE boundary. includina two kitchen area exhaust duct isolation dampers inoperable) should be preplanned for implementation upon entry into the condition. reaardless of whether entry is intentional or unintentional.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability Point Beach B 3.7.9-4b Unit 1 - Amendment No. 2%

Unit 2 - Amendment No. 233

CREFS B 3.7.9 BASES ACTIONS (continued) of a DBA occurrina durina this time period. and the use of mitigating actions to include temporary patches. plates. andlor pluas. The 90 dav Com~letion Time is reasonable based on the determination that the mitiaatina actions will ensure protection of CRE occupants within analvzed limits, while limitina the probabilitv that CRE occupants will have to imolement protective measures that mav adverselv affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition. the 90 dav Com~letion Time is a reasonable time to diaanose. Plan and possiblv repair. and test most problems with the CRE boundary.

B.?, B.2 zmd-EME.1, E.2 and E.3 I

If CREFS cannot be restored to OPERABLE status within the required Completion Time of Condition A. B. C. or D with movement of irradiated fuel in p r o g r e s s, ' " ) c action must be taken to immediatelv sus~end activities that could result in a release of radioactivitv that miaht require isolation of the CRE. This 8

a places the units in a condition that minimizes the accident risk-.

This does not preclude the movement of fuel to a safe position.

In MODE I, 2,3, or 4, if CREFS cannot be restored to OPERABLE status within the required Completion Time of Condition A. B. C. or Dl the unit2 must be placed in a MODE that minimizes accident risk. To achieve this status, the units must be placed in at least MODE 3 within I 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Point Beach B 3.7.9-4c Unit I - Amendment No. 224 Unit 2 - Amendment No. 2343

CREFS B 3.7.9 BASES SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each fan subsystem once every month provides an adequate check of this system. Systems without heaters need only be operated for 2 15 minutes to demonstrate the function of the system. The 31 day Frequency is based on the reliability of the equipment.

This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).-rFke HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.

This SR verifies that each CREFS emergency and recirculation make-up I fan starts and operates on an actual or simulated actuation signal. The Frequency of 18 months i s

s based on industry operating exoerience and is consistent with the typical refuelina cvcle.

This SR verifies that each CREFS automatic damper in the emergency mabupmode flow path will actuate to its required position on an actuation signal. The Frequency of 18 months-is based on industry operatina experience and is consistent with the tvpical refuelina cvcle.

This test verifies manual actuation capability for CREFS. Manual actuation capability is a required for OPERABILITY of the CREFS. The 18 month Frequency is acceptable based on the inherent reliability of manual actuation circuits.

Point Beach B 3.7.9-5 Unit 1 - Amendment No. 204-Unit 2 - Amendment No. ZN3

CREFS B 3.7.9 BASES SURVEILLANCE SR 3.7.9.6 REQUIREMENTS (continued)

This SR verifies the OPERABILITY of the CRE boundary bv testina for unfiltered air inleakaae past the CRE boundary and into the CRE. The details of the testina are specified in the Control Room Envelope Habitabilitv Proaram.

The CRE is considered habitable when the radioloaical dose to CRE occupants calculated in the licensina basis analvses of DBA consequences is no more than 5 rem TEDE. This SR verifies that the unfiltered air inleakaae into the CRE is no areater than the flow rate assumed in the licensina basis analvses of DBA consequences. When unfiltered air inleakaae is areater than the assumed flow rate, Condition D must be entered. Reauired Action 0.4 allows time to restore the CRE boundary to OPERABLE status provided mitiaatinp actions can ensure that the CRE remains within the licensina basis habitabilitv limits for the occupants followina an accident.

Compensatorv measures are discussed in Reaulatory Guide 1.196, Section C.2.7.3. (Ref. 3) which endorses with exceptions. NEI 99-03, Section 8.4 and Appendix F (Ref. 4). These compensatory measures mav also be used as mitiaatina actions as required bv Required Action D.3. Temporary analvtical methods mav also be used as compensatory measures to restore OPERABILITY (Ref. 5). Options for restorina the CRE boundary to OPERABLE status include chanaina the licensing basis DBA consequence analvsis. repairinq the CRE boundary, or a combination of these actions. De~endina upon the nature of the problem and the corrective action. a full scope inleakaae test mav not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

Point Beach B 3.7.9-5a Unit I - Amendment No. 204 Unit 2 - Amendment No. 206

CREFS B 3.7.9 BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES I. FSAR. Section 9.8.

2. FSAR. Section 14.3.5.

3.

?.53Do\\rReaulatow Guide I.I 96

4.

NEI 99-03. "Control

5. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated Januarv 30. 2004. "NEI Draft White Pa~er. Use of Generic Letter 91-1 8 Process and Alternative Source Terms in the Context of Control Room Habitabilitv." (ADAMS Accession No. ML040160868).

Point Beach B 3.7.9-6

-