View source for CPSES-200602131, License Amendment Request 06-011, to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using Consolidated Line Item Improvement Process

{{Adams
| number = ML063040564
| issue date = 10/23/2006
| title = License Amendment Request 06-011, to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using Consolidated Line Item Improvement Process
| author name = Madden F
| author affiliation = TXU Generation Co, LP, TXU Power
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000445, 05000446
| license number = NPF-087
| contact person = 
| case reference number = CPSES-200602131, LAR 06-011, TXX-06174
| document type = License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specification, Amendment, Technical Specification, Bases Change
| page count = 34
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:TXU Power Mie 113evins Senbor Moce P~resenti &
TXU Power             Chiief Nuchear Officer                                                        Ref: I0CFR50.90 Comanche Peak Steam Ebcti Statin P. O- Box 102 (E01l)
Gle* Rose. IX 760413 Tel: 254 897 52G9 Fax- 254 897 6652 mike.blevirmsL-xu.com CPSES-200602131 Log# TXX-06174 File # 00236 October 23, 2006 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 LICENSE AMENDMENT REQUEST (LAR) 06-011, TO REVISE TECHNICAL SPECIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448, REVISION 3, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS REF:         1) Federal Register Notice, Volume 71, Pages 61075-61084, Technical Specification Improvement To Modify Requirements Regarding Control Room Envelope Habitability Using the Consolidated Line Item Improvement Process, dated October 17, 2006
: 2) NRC Generic Letter 2003-01, "Control Room Habitability,", June 12, 2003
: 3) TXU Power Letter, Logged TXX-03158, from Mike Blevins to Nuclear Regulatory Commission, dated December 4, 2003
: 4) TXU Power Letter, Logged TXX-05127, from Mike Blevins to Nuclear Regulatory Commission, dated August 22, 2005
: 5) NRC Letter from Mohan C. Thadani to M. R. Blevins, dated August 18, 2006 (TAC NOS. MC8163 AND MC8164)
: 6) TXU Power Letter, Logged TXX-06161, from Mike Blevins to Nuclear Regulatory Commission, dated September 18, 2006
: 7) TXU Power Letter, Logged TXX-06151, from Mike Blevins to Nuclear Regulatory Commission, dated October 23, 2006 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway - Comanche Peak - Diablo Canyon - Palo Verde - South Texas Project - Wolf Creek

TXX-06174 Page 2 of 4 Gentlemen:
In accordance with the provisions of 10 CFR 50.90, TXU Generating Company LP (TXU Power) is submitting License Amendment Request 06-011 for an amendment to the technical specifications (TS) for Comanche Peak Steam Electric Station (CPSES) Unit 1, Operating License (NPF-87), and CPSES Unit 2, Operating License (NPF-89).
The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3 (Reference 1).
Attachment I provides a description of the proposed change, the requested confirmation of applicability, and plant specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides a summary of the regulatory commitments made in this submittal. Attachment 5 provides the existing TS Bases pages marked up to show proposed change and is for information only.
TXU Power requests approval of the proposed License Amendment by January 15, 2007, with the amendment being implemented within 120 days of NRC approval.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the State of Texas.
In response to Reference 2, Reference 3 committed to submitting a TS change to include periodic verification of control room leakage. Reference 4 was submitted to satisfy that commitment. The NRC staff completed their initial review of Reference 4 and conveyed their concerns by letter dated August 18, 2006 (Reference 5). TXU Power's response (Reference 6) to Reference 5 indicated that the proposed control room habitability program would be updated at a later date to be consistent with the NRC's expected issuance of a model safety evaluation of TSTF-448, Revision 3, "Control Room Habitability," in the Federal Register for public comments.

TXX-06174 Page 3 of 4 License Amendment Request (LAR) 05-005 (Reference 4) has been revised (in Supplement 1) to address only the new methods and assumptions for evaluating radiological consequences of design basis accidents (Reference 7). The control room habitability program was previously submitted for approval under LAR 05-005 (Reference 4), but is now separately submitted for approval under LAR 06-011 to expedite review under the consolidated line item improvement process.
The acceptance limits used in the new Control Room Envelope Habitability Program will be based on the assumptions of the radiological dose consequences calculations.
CPSES is adopting new methods and assumptions as described in NRC Regulatory Guide (RG) 1.195, "Methods and Assumptions for Evaluating Radiological Consequences of Design Accidents at Light-Water Nuclear Power Reactors," May 2003, for the calculations of the radiological dose consequences, both to the public and to demonstrate compliance with 10 CFR 50, Appendix A, General Design Criteria (GDC) 19. These new methods and assumptions presented in Final Safety Analysis Report (FSAR) Chapters 1, 6 and 15, have been submitted to the NRC for review and approval by LAR 05-005 (Reference 4) and Supplement I to LAR 05-005 (Reference 7). Previous discussions with the NRC Staff indicated that adoption of RG 1.195 is contingent on adoption of a control room habitability program.
These changes are needed to support replacement of the Unit I steam generators in the Spring of 2007.

TXX-06174 Page 4 of 4 If you should have any questions regarding this submittal, please contact Mr. Carl Corbin at (254) 897-0121.
I state under penalty of perjury that the foregoing is true and correct.
Executed on October 23, 2006.
Sincerely, TXU Generation Company LP By:      TXU Generation Management Company LLC Its General Partner Mike Blevins By: Ad/zIJ
             !lrFd W. Madden 221r-_
Director, Oversight and Regulatory Affairs CBC Attachments       1. Description and Assessment
: 2. Proposed Technical Specification Changes
: 3. Revised Technical Specification Pages
: 4. Regulatory Commitments
: 5. Proposed Technical Specification Bases Changes c -     B. S. Mallet, Region IV M.C. Thadani, NRR Resident Inspectors, CPSES Ms. Alice Rogers Environmental & Consumer Safety Section Texas Department of State Health Services 1100 West 4 9 th Street Austin, Texas 78756-3189 to TXX-06174 Page 1 of5 ATTACHMENT 1 to TXX-06174 DESCRIPTION AND ASSESSMENT

==1.0    DESCRIPTION==

2.0    ASSESSMENT

==3.0    REGULATORY ANALYSIS==

4.0    ENVIRONMENTAL EVALUATION

Attachment I to TXX-06174 Page 2 of 5

==1.0    DESCRIPTION==

The proposed amendment would modify technical specification (TS) requirements related to control room envelope habitability in TS 3.7.10, Control Room Emergency Filtration / Pressurization System (CREVS) and TS Section 5.5, "Administrative Controls- Programs and Manuals."
The changes are consistent with Nuclear Regulatory Commission (NRC) noticed Industry/Technical Specification Task Force (TSTF) STS change TSTF-448 Revision 3.
This TS improvement was published in the Federal Register for public comment on October 17, 2006 as part of the consolidated line item improvement process (CLI[P).
2.0    ASSESSMENT 2.1      Applicability of Published Safety Evaluation TXU Power has reviewed the safety evaluation dated October 17, 2006, as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-448. TXU Power has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Comanche Peak Steam Electric Station (CPSES) Units I and 2, and justify this amendment for the incorporation of the changes to the CPSES Units I and 2 TS.
2.2     Optional Changes and Variations TXU Power is not proposing any variations or deviations from the TS changes described in the TSTF-448, Revision 3, or the NRC staff's model safety evaluation dated October 17, 2006, except as noted below.
TXU Power proposes to reference NEI 99-03, Revision 0, dated June 2001, in the TS bases for TS 3.7.10, instead of Revision 1, dated March 2003, because the NRC has not formally endorsed Revision 1.
In the Applicable Safety Analyses of TS Bases 3.7.10, the discussion of hazardous chemical releases and smoke challenges is clarified by inserting the following, "The analysis for Comanche Peak has determined no CREFS actuation is required for hazardous chemical releases or smoke and no Surveillance Requirements are required to verify operability for hazardous chemicals or smoke." This clarification represents the current plant specific design. In the future, if the Comanche Peak design or environment change, new Action B.2 of TS 3.7.10 addresses hazardous chemicals and smoke to assure that appropriate mitigating actions and / or design feature(s) are considered.

Attachment I to TXX-06174 Page 3 of 5 In Surveillance Requirement SR 3.7.10.4, of TS Bases 3.7.10, the discussion of hazardous chemical releases and smoke challenges is clarified by inserting the following, "For Comanche Peak, there is no CREFS actuation for hazardous chemical releases or smoke and there are no Surveillance Requirements that verify operability for hazardous chemicals or smoke." This clarification represents the current plant-specific design. In the future, if the Comanche Peak design or environment change, new Action B.2 of TS 3.7.10 addresses hazardous chemicals and smoke to assure that appropriate mitigating actions and / or design feature(s) are considered.
In addition there were minor differences in TS numbering and in the TS Bases references. These differences are administrative in nature and do not have any safety significance.
2.3    License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements TXU Power proposes the following as a license condition to support implementation of the proposed TS changes:
Upon implementation of License Amendment Request No. 06-011 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.10.4, in accordance with TS 5.5.20.c.(i), the assessment of CRE habitability as required by Specification 5.5.20.c.(ii), and the measurement of CRE pressure as required by Specification 5.5.20.d, shall be considered met.
Following implementation:
(a)     The first performance of SR 3.7.10.4, in accordance with Specification 5.5.20.c.(i), shall be within the specified Frequency of 6 years, plus the 15-month allowance of SR 3.0.2, as measured from December 13, 2001, the date of the most recent successful tracer gas test, as stated in the December 4, 2003, letter response to Generic Letter 2003-01, or within the next 15 months if the time period since the most recent successful tracer gas test is greater than 6 years.

Attachment I to TXX-06174 Page 4 of 5 (b)     The first performance of the periodic assessment of CRE habitability, Specification 5.5.20.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from December 13, 2001, the date of the most recent successful tracer gas test, as stated in the December 4, 2003, letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
(c)     The first performance of the periodic measurement of CRE pressure, Specification 5.5.20.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from July 27, 2006, the date of the most recent successful pressure measurement test.

==3.0    REGULATORY ANALYSIS==

3.1    No Significant Hazards Consideration Determination TXU Power has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.
TXU Power has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to CPSES Units I and 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
3.2    Verification and Commitments As discussed in the notice published in the Federal Register on October 17, 2006, for this TS improvement, plant-specific verifications were performed as follows:
: 1.       TXU Power commits to the guidance of NEI 99-03, Revision 0, "Control Room Habitability Assessment Guidance" dated June 2001, as reflected in the proposed changes to the TS and TSB.
: 2.       TXU Power will revise procedures to implement the new surveillance and programmatic TS requirements related to CRE habitability.
: 3.       TXU Power commits to Regulatory Positions C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, with the following exceptions:

Attachment I to TXX-06174 Page 5 of 5 TS 5.5.20.c.(ii).I identifies the following exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:
: 1. C. - Section 4.3.2, "Periodic CRH Assessment" from NEI 99-03 Revision I will be used as input to a site specific Self Assessment procedure.
Justification: Appendix H of NEI 99-03 Revision 0 is specifically written to support the initial assessment.
Section 4.3.2 "Periodic CRH Assessment" of NEI 99-03 Revision 1 is specifically written to support the periodic assessments required by Figure 1 of Regulatory Guide 1.197.
: 2. C. 1.2 - No peer reviews are required to be performed.
Justification: Vulnerabilities were identified in Comanche Peak's self-assessment conducted March 6-9, 2000. Three offsite peers were involved in the assessment. Corrective actions (plant modifications) were completed prior to the successful ASTM E741 Tracer Tests conducted in December 2001. Maintenance level of effort is appropriate for the Control Room Envelope Habitability Program.
4.0    ENVIRONMENTAL EVALUATION TXU Power has reviewed the environmental evaluation included in the model safety evaluation dated October 17, 2006, as part of the CLIIP. TXU Power has concluded that the staff's findings presented in that evaluation are applicable to CPSES Units I and 2, and the evaluation is hereby incorporated by reference for this application.
to TXX-06174 Page 1 of 7 ATTACHMENT 2 to TXX-06174 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)
Pages 3.7-23 3.7-24 3.7-25 5.0-28a Inserts (2 pages)

Attachment 2 to TXX-06174 Page 2 of 7                                                                                     CREFS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Filtration/Pressurization System (CREFS)
LCO 3.7.10              Two CREFS trains shall be OPERABLE NOTE The Control Roomjboundary may be opened intermittently under administrative con ls.
APPLICABILITY:          MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies ACTIONS CONDITION                       REQUIRED ACTION              COMPLETION TIME A. One CREFS train                   A.1     Restore CREFS train to     7 days inoperable for reasons                   OPERABLE status.
other than Condition B.
O*e a                   a, flbC.Two              REFS Trains              B1      Restore conto roo,         2   ours        9 inoperable due to   Y -boundary                   to OPERABLE inoperable          R                    status.
O boundary in 3, and 4.
foahunto h 1 dy      o     n Dime impleMnotdtftion t De completed dunng iRF1I and 2RF09 C. Required Action and               C.1     Be in MODE 3.              6 hours associated Completion Time of Condition A or B        AND not met in MODE 1, 2, 3, or 4.                           C.2     Be in MODE 5.              36 hours (continued) 2 Ver;#j rnryaltj acr74s resOs eM C, 6WcC*,, 4 1&t ZO h4r.0 r5 C           HE PEAK - UNITS 1 AND 2            3.7-23               Amendment No. 6. 408. 4*-
to TXX-06 174 Page 3 of 7                                                                                CREFS 3.7.10 ACTIONS (continued)
CONDITION                      REQUIRED ACTION              COMPLETION TIME D. Required Action and              D.1      Place OPERABLE            Immediately associated Completion                    CREFS train in Time of Condition A not met              emergency recirculation in MODE 5 or 6, or during                mode.
movement of irradiated fuel assemblies.                     OR D.2.1   Suspend CORE               Immediately ALTERATIONS.
AND D.2.2   Suspend movement of        Immediately irradiated fuel assemblies.
E. Two CREFSin trains      5 or 6,( E.1     Suspend CORE               Immediately inoperable MODE of                      ALTERATIONS.
or during  movement           ,
assembliesfor irradiated fuelto 14cays        AND "except for up one time implementation 0a of the Turbine    E.2      Suspend movement of       Immediately for each unit                            irradiated fuel Generator Protectiont Modification;           assemblies.
System Digital during.*
to be  completed 2RF0O b**1RF11Iand F. Two CREFS trains                 F.1      Enter LCO 3.0.3.          Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.
CRr bovadti           7/1 P10cE 5 or~&,
O~r ehrTA1                              Invmn f/tdic
             -Poe(I a5svvmblis.
COMANCHE PEAK - UNITS 1 AND 2                 3.7-24               Amendment No. 64,408.4Qe-to TXX-06174 Page 4 of 7                                                                                 CREFS 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.7.10.1   Operate each CREFS train's Emergency Pressurization       31 days Unit for _>10 continuous hours with the heaters operating and Emergency Filtration Unit > 15 minutes.
SR 3.7.10.2   Perform required CREFS testing in accordance with the     In accordance with Ventilation Filter Testing Program (VFTP).                VFTP       (H;)
SR 3.7.10.3 Verify each CREFS train actuates on an actual or            18 months simulated actuation signal.
SR 3.7.10.4 Verify one CREFS train can maintain a positive pressuree    18 months on a oprto tamku lwrt f580cm of&#x17d;> 0.125 inches water gauge, relative to the adjacent areas during the emergency recirculation mode of STAGGERED TEST BASIS 6&A*-torkoom~ &#xa3;6ve/opeIr/d                                    'Caam E,1ve/6pe prosqr~m                                                    // 4 1k'; 4;/rt/
COMANCHE PEAK - UNITS 1 AND 2                 3.7-25                      Amendment No. Sir to TXX-06174 Page 5 of 7 Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.19       Battery Monitoring and Maintenance Program                                           113 This Program provides for restoration and maintenance, based on the recommendations of IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer for the following:
: a.      Actions to restore battery cells with float voltage < 2.13 V, and
: b.      Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates.
COMANCHE PEAK - UNITS 1 AND 2               5.0-28a                           Amendment No. 4+r to TXX-061 74 Page 6 of 7 Insert A (page 5.0-28a) 5.5.20         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, hazardous chemical release, 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 (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body 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 1.197, Revision 0.
The following are exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:
: 1.      C. - Section 4.3.2 "Periodic CRH Assessment" from NEI 99-03 Revision 1 will be used as input to a site specific Self Assessment procedure.
: 2.      C.1.2 - No peer reviews are required to be performed.
to TXX-06174 Page 7 of 7 Insert A (page 5.0-28a) (continued)
: d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month 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. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
: f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.
to TXX-06174 Page 1 of 6 ATTACHMENT 3 to TXX-06174 REVISED TECHNICAL SPECIFICATION PAGES Pages 3.7-23 3.7-24 3.7-25 5.0-28a 5.0-28b to TXX-06174 Page 2 of 6 CREFS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Filtration/Pressurization System (CREFS)
LCO 3.7.10             Two CREFS trains shall be OPERABLE
                                                --------      NOTE---------------
The Control Room envelope (CRE) boundary may be opened intermittently under administrative controls.
APPLICABILITY:         MODES 1,2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies ACTIONS CONDITION                         REQUIRED ACTION                  COMPLETION TIME A. One CREFS train                   A.1       Restore CREFS train to        7 days inoperable for reasons                     OPERABLE status.
other than Condition B.
B. One or more CREFS Trains          B.1       Initiate action to            Immediately inoperable due to                          implement mitigating inoperable CRE boundary                    actions.
in MODES 1, 2, 3, and 4.
AND B.2       Verify mitigating actions     24 hours to ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.
AND B.3       Restore CRE boundary to       90 days OPERABLE status.
C. Required Action and               C.1       Be in MODE 3.                 6 hours associated Completion Time of Condition A or B         AND not met in MODE 1, 2, 3, or 4.                            C.2       Be in MODE 5.                 36 hours (continued)
COMANCHE PEAK - UNITS 1 AND 2                   3.7-23                 Amendment No. 66,4-99,4-2-0, to TXX-06 174 Page 3 of 6                                                                          CREFS 3.7.10 ACTIONS (continued)
CONDITION                  REQUIRED ACTION             COMPLETION TIME D. Required Action and          D.1    Place OPERABLE            Immediately associated Completion              CREFS train in Time of Condition A not            emergency recirculation met in MODE 5 or 6, or             mode.
during movement of irradiated fuel assemblies. OR D.2.1  Suspend CORE              Immediately ALTERATIONS.
AND D.2.2  Suspend movement of       Immediately irradiated fuel assemblies.
E. Two CREFS trains             E.1    Suspend CORE              Immediately inoperable in MODE 5 or 6,         ALTERATIONS.
or during movement of irradiated fuel assemblies. AND OR                          E.2    Suspend movement of       Immediately irradiated fuel One or more CREFS trains           assemblies.
inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies.
F. Two CREFS trains             F.1    Enter LCO 3.0.3.          Immediately inoperable in MODE 1,2, 3, or 4 for reasons other than Condition B.
COMANCHE PEAK - UNITS 1 AND 2           3.7-24               Amendment No. 64,4-98,4-2-0, to TXX-06174 Page 4 of 6                                                                               CREFS 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                   FREQUENCY SR 3.7.10.1   Operate each CREFS trains Emergency Pressurization        31 days Unit for _>10 continuous hours with the heaters operating and Emergency Filtration Unit > 15 minutes.
SR 3.7,10.2   Perform required CREFS testing in accordance with the     In accordance with Ventilation Filter Testing Program (VFTP).                the VFTP SR 3.7.10.3   Verify each CREFS train actuates on an actual or          18 months simulated actuation signal.
SR 3.7.10.4   Perform required CRE unfiltered air inleakage testing in  In accordance with accordance with the Control Room Envelope Habitability    the Control Room Program.                                                  Envelope Habitability Program COMANCHE PEAK - UNITS 1 AND 2                3.7-25                      Amendment No. 64, to TXX-06174 Page 5 of 6                                                                                    Manuals Programs andMaul 5.5 5.5 Programs and Manuals (continued) 5.5.19        Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance, based on the recommendations of IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer for the following:
: a.      Actions to restore battery cells with float voltage < 2.13 V, and
: b.      Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates.
5.5.20        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, hazardous chemical release, 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 (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body 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 1.197, Revision 0.
The following are exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:
: 1.      C. - Section 4.3.2 "Periodic CRH Assessment" from NEI 99-03 Revision 1 will be used as input to a site specific Self Assessment procedure.
(continued)
COMANCHE PEAK - UNITS 1 AND 2                 5.0-28a                         Amendment No. 44-3, to TXX-06174 Page 6 of 6                                                                     Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20        Control Room Envelope Habitability Program (continued)
: 2.       C.1.2 - No peer reviews are required to be performed.
: d.      Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month 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. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
: f.      The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.
COMANCHE PEAK - UNITS 1 AND 2                 5.0-28b                              Amendment No.
to TXX-06174 Page 1 of 1 Attachment 4 - Regulatory Commitments The following table identifies those actions committed to by TXU Power in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. Carl Corbin at (254) 897-0121.
Regulatory Commitments                             Due Date / Event TXU Power commits to the guidance of NEI           Commitment number 27413 will be 99-03, Revision 0, "Control Room                   implemented with license amendment.
Habitability Assessment Guidance" dated June 2001, as reflected in the proposed changes to the TS and TSB.
to TXX-06174 Page 1 of 11 ATTACHMENT 5 to TXX-06174 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (For Information Only)
Pages B 3.7-54 B 3.7-55 B 3.7-56 B 3.7-57 B 3.7-58 B 3.7-59 B 3.7-60 B 3.7-61 Inserts (2 pages)

Attachment 5 to TXX-06 174 Page 2 of ervel~p~e (UI~aXidQ                    ,boca
          -the                  aeirj f u,7fliteradCRF                                                       CREFS 8.3.7.10 B 3.7   PLANT SYSTEMS                               hae~ar&5~cheit icql , or srnAC B 3.7.10 Control Room Emergency Filtration/Pressurization System (CREFS)
BASES
    ,.BACKGROUND            The CREFS provides a protected environment from which*'i*J&#xfd; control the unit following an uncontrolled release of radioactivi" The CREFS consists of two independent, redundant trains pressurize, recirculate and filter thicontro roo, air. Eac train contains two filtration units: an emergency pressurization unit and al emergency filtration unit. Each filtration unit consists of a prefilter, high efficiency particulate air (HEPA) filters, an activated charcoal adsorber section for dl  0   &#xfd; trr         r.S. removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers and instrumentation also form part of the system, as well as demisters to remove water droplets from the air stream. A second bank of HEIA filters follows the adsorber section to collect carbon fines and provide backup in case of failure of the main HEPA filter bank. In addition, the emergency pressurization units contain a demister and a heater to maintain the humidity of the incoming air below 70%.
(44ilserT        ~JL-~P.
                            - he GREES is an emergency system wholly contained within the Control T
Room Air Conditioning System, parts of which operate during normal unit cg*                   oper tions. Upon r ceipt of the actuating signal(s), normal air supply fans to the control roo are isolated, and the stream of ventilation air is provided by the emergency pressurization units and then recirculated through the emergency filtration units. The demisters and heaters in the emergency pressurization units remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train's emergency pressurization unit for at least 10 hours per month, with the heaters on, reduces moisture buildup on the HEPA filters and adsorbers. Both the demister and heater are important to the effectiveness of the charcoal adsorbers.
(continued)
COMANCHE PEAK - UNITS 1 AND 2                 B 3.7-54                              Amendment No. 64

Attachment 5 to TXX-06174 Page 3 of 11                                                                                                CREFS B.3.7.10 BASES (continued)
BACKGROUND                 Actuation of the CREFS by a Safety Injection, Loss of Offsite Power or (continued)               Intake Vent High Radiation signal places the system in the emergency recirculation mode. Actuation of the system to the emergency recirculation mode of operation, closes the unfiltere      tside air supply path and the system exhaust dampers, stops normal u             and exhaust fans, and aligns the system for recirculation of the nt.on roo air (Lt&it25... T                C;'     I-A through the redundant trains of HEPA and the charcoa            ers. The emergency recirculation mode also initiates pressurization and filtered ventilation of       air           the SOutsideair is     e     ,an  dded to th air bein recirculated from the 1fr.Pressurization                                of th control roomreven "nfiltration of 0A unfiltered air froqthe s         nding area o     e-plab C        . h-the                          The air entering the nis                continuously monitored by radiation kC       i4OLoA*(yt                    detectors. One detector output a7ov the setpoint will cause actuation of the em' enrecirculation modeC./W e        r       *3      ct    0.           A sin e          will pressurize the ntro roo to abo       .125 inches water TX0          no'7i 0            [f     /F'*g'*."he         CREFS operation in maintaining the n ro roo habitable is discu sed in the FSAR, Sections 2.2, 6.4, 6.5, 7.3, and 9.4 (Ref. 1).
The CPSES CREFS design is zone isolation, with filtered recirculation air,      27 and with a positive pressure. This design maximizes the iodine protection factors and minimizes the dose from iodine. The total unfiltered infiltration rate in the control room is conservatively assumed to be 12 cfm, including re          -iv e -t exAtle-               10 cfm due to ingress/egress and 2 cfm leakage from the ductwork Y      ,4S            '
aceA-,      /       passing through the control room pressure boundary. Filtered inleakage d i ..                   through the closed dampers due to the pressure differential is also Ye CF'E b6,d5                   mq /*"
included. The damper leakage air will be filtered by the recirculation filtration units.
Because the control room door ingress/egress is to a stairwell which is equivalent to a two-door vestibule, backflow will not occur with the CPSES CREFS design and the 10 cfm is not applicable per SRP 6.4. The ductwork has all welded joints which were leak tested prior to operation.
Therefore, the assumed unfiltered inleakage from adjacent areas is conservative with respect to the SRP review criteria.
The Control Room Habitability is maintained by limiting the inleakage of potentially contaminated air into the Control Room Envelope. The potential leakage paths for the Control Room Envelope include the control room enclosure (e.g., walls, penetrations, floors, ceilings, joints, etc.), and other potential paths such as pressurized ductwork from other HVAC systems, pressurized air systems (e.g., instrument air) or isolated HVAC intakes.
The periodic surveillance pressurization tests verify the integrity of the control room enclosure with respect to potentially contaminated adjacent (continued)
COMANCHE PEAK - UNITS 1 AND 2                        B 3.7-55                                 Revision 27

Attachment 5 to TXX-06174 Page 4 of II                                                                                           CREFS B.3.7.10 BASES (continued)
BACKGROUND            areas in accordance with SRP 6.4. It does not verify filtered inleakage            27 (continued)          internal to the filtration units and ductwork nor does it verify unfiltered inleakage from internal pressurized sources (e.g. instrument air). These sources of inleakage are addressed separately from TS surveillances.
e         Redundant supply and recirculation trains provide the required filtration e Vi rnent n                should an excessive pressure drop develop across the other filter train.
The CREFS is designed in accordance with Seismic Category I liie CRErequirements.
The CREFS is designed to maintai the control room environmen for 30 days of continuous occupancy a er a esign asis cci en                   BA) without exceeding a 5 rem whole body dose or its equivalent to any part of the body.                                                  .             -_.C__
APPLICABLE        JThe CREFS components are arranged in redundant, safety related
       *SAFETY              \ventilationlitrais The location of components and ducting within the ANALYSES       ja-cntrol room e ~elo )e,,s                aqaeuate supply of filtered air to all
             ~~areas                  requiring a ccess. The CREFS provid!es airborne radiological_._/
C_..                 ._protection for th contro             rato ,* demonstrated by th ontro ose nalyses for the most limiting design basi oss o O cc VPn1-t                  __accident,
                        -,--< Chapter              fission product release presented in the FSA 15 (Ref. 2).
*O-se"          j     "
The Control Room post accident mode of operation is the emergency recirculation mode. In the emergency recirculation mode, both the Emergency Filtration and Emergency Pressurization Units are functioning and they operate in series. In other words, all air which passes through the Emergency Pressurization Unit in each train will pass through the corresponding Emergency Filtration Unit before it is released into the Control Room. The safety analysis which confirmed the CREFS design took credit for no more than 99% filter efficiency of the Emergency Filtration Units only. If the Emergency Pressurization Units do not meet the surveillance requirement criteria for filtration the safety analyses and the associated acceptance criteria continue to be met by the Emergency Filtration Units. Thus, the operators will continue to be provided the protection identified in the licensing bases for CPSES.
The analysis of toxic gas releases demonstrates that the toxicity      limits are not exceeded in the control rom followng a tgoxic chemical release,          as presented in Reference 1. Isolation of the control room is not automatic for a toxic chemical release event.
The worst case single active failure of a component of the CREFS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.
The CREFS satisfies Criterion 3 of 10CFR50.36(c)(2)(ii).
(continued)
COMANCHE PEAK - UNITS I AND 2                   B 3.7-56                                  Revision 27

Attachment 5 to TXX-06174 Page 5 of
                                            ~               osdI' tI                                                    CR.EFSS Or'A S-            fi-a m ao 1655b Ci6f a&t                 venfa'h            -rr;4              B.3.7.10 C~rfro      Oolarelrdoa            era    sie.?   ba~
(otn           ed)FAscnie TAE                                 OERBEwe            h nivda onoet exceeding adose of 5 rerrto thek*to rooprtinheevent of a "CREFS             train is OPERABLE when both filtration units (i.e., the emergency AVlo(Q Oo4J &deg;i''i"1T          Or"'> [  pressurization PEALE Aunit            (EPU) utandisOPERABLE ltaioOPERABLE filtrat         emergency filtration when the unitassociated:
(EFU)) are myS''  e~/~//*i             .    "T7"o a.       Fan is OPERABLE; b0y                  *_aub.                 HEsPA filters and charcoal adsorbers are not excessively restricting c    flow,ean a       re capable of performing their filtration functions (the EFU must meet Ventilation Filter Testing Program (VFTP) requirements; the EPU must meet VFTP requirements, except for filtration requirements); and
: c.       Heater (EPU only), demister (EPU only), ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.
in         4        o"        )*       including the integrity of the walls, floors, ceilings, ductwork,a              c
/  AC-0/t*         be'
                   *
* The LCO is modified by a Note allowing the(6ontro room boundary to be opened intermittently under administrative controls.FFor entry and exit Y0 Ce d r1[ z(                 oed rj  through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings these contro s nsist of stationing a dedicated individual at the opening who is 6pe ratr~r i ri                        incontihnous communication with thei ontro1Iis                         individual will PTr1   C[C                        haveamethod&deg;to ra idly closetheo-i nin wheneeddrntrolr&deg;oo
__________            isolatioa-7 smd            I .tedfP)I okrl anl Q/ f has 7:>openr                         tAe                   Prndt1?    7%4 r p4~,5$ee0~           n/ ~  QpJ  ~
k  c-4 bo.S LT-     0 ...
J-.
                -I       .
COMANCHe PdeK -IT                c,1AN2                    37-7 COMANCHE PEAK - UNITS 1 AND 2                            B 3.7-57A                                mendment No. 64 to TXX-06174 Page 6 of I1 CREFS evnsre tk1aT -th               e CI?       w Wi/rem~iAkabefbbk          B.3.7.1O0 BASES (continued)
APPLICABILITY          In MODES 1, 2, 3, 4, 5, 6, and during movement of irradiated fuel f,-.*assemblies               CREFS must be OPERABLE tofc             operator exposure-..
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             an iaoperable CRE boon.a When one CREES train is inoperable for reasons other than Conditi action must be taken to restore OPERABLE status within 7 days. In this C            C               C ndition,
                                      ;there      ining OPERABLE CREFS train is adequate to perform control roo protection function. However, the overall reliability is reduced because a single failure 'in the OPERABLE CREFS train could result in loss of CREFS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.
that the CREFS trains can not establish or maintain the required pressure, action must be taken to restore an OPERABLE control room boundary within 24-hours. The 24 hour completion time is reasonable based on the low probability of a DBA occurring during this time period, and the availability of CREFs to provide a filtered environment (albeit with potential control room inleakage),
A temporary Completion Time is connected to the Completion Time                EP requirements of 24 hours. The temporary Completion Time is 14 days and applies to the implementation of the Turbine Generator Protection)          I 41 System Digital Modification for each unit during 1RF1 1 and 2RF09.              I (continued)
COMANCHE PEAK - UNITS 1 AND 2                 B 3.7-58                                  Revision 41 to TXX-06174 Page 7 of 11 CREFS B.3.7.10 BASES ACTIONS              C.1 and C.2                                                  the      Ck (continued)
In MODE 1, 2, 3, or 4, if the inoperable CREFS train o boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours. 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.
D.1, D.2.1, and D.2.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, if the inoperable CREFS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CREFS train in the emergency mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.
An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control roo         his places the unit in a condition that minimizes risk.
This does not preclude the movement of fuel to safe sitio E.+h ndE.
E.1 and E.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, with two CRES trains inope              except for up to 14 days for a one time          U im*Inman    atrn   err mah, ,nif ^f fhp T* irhinQ -*nnrafrr  Prtpf*rfinn  Q Qftmn 141
       *.      re-        mu eModification L~~igital    aken immediately tobe completed      dtiv1F1and 2F9action to sus durng                      result in a        r_--1 ffo s Jf     release of radioactivity that mightrI)the ontrroo                 his places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe pos&#xfd;ition (continued) ort'            on 0- more C/?&FS Trq s                        ijoperable dad -to a
           )vioperaJ~l'   CI?6 bcunwiary COMANCHE PEAK - UNITS 1 AND 2                  B 3.7-59                                     Revision 41 to TXX-06174 Page 8 of I I CREFS B.3.7.1 0 BASES ACTIONS             F.1                       e    RE (continued)
If both CREFS trains are MODE 1, 2, 3, or 4, for reasons other than an inoperablecontroloroo ndary (i.e., Condition B), the CREFS 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.
SURVEILLANCE        SR 3.7.10.1 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, each train once every month provides an adequate check of this system. Monthly heater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air.
Filtration units with heaters must be operated for > 10 continuous hours with the heaters energized. Filtration units without heaters need only be operated for &#x17d; 15 minutes to demonstrate the function of the system. The 31 day Frequency is based on the reliability of the equipment and the two train redundancXabila&#xfd;!Iit        &#xfd; SR 3.7.10.2 This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREFS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 3).
The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.
The VFTP filtration testing requirements of Sections 5.5.1 la, b, and c are not required for an Emergency Pressurization Unit when being testing (1) during a periodic test (e.g., 18 months or after 720 hours of operation), (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (3) following painting, fire, or chemical release for the corresponding CREFS train to be OPERABLE.
(continued)
COMANCHE PEAK - UNITS 1 AND 2               B 3.7-60                          Amendment No. 64 to TXX-06174 Page 9 of II t ase      A ;,1 vsTm. o eratni&#xfd; exper ietCe a l i5CREFS1 d
QSLJOt  .S          '?P                                                             B..3.7.10 cOJSSte,'t       wifA     -the t yo;Ca( re-fae/;i,                  cycle.
BASES SURVEILLANCE         SR 3.7.10.3 REQUIREMENTS (continued)         This SR verifies that each CREFS train starts and operates on an actual or simulated Safety Injection, Loss-of-Offsite Power, or Intake Vent-High Radiation actuation signal. The Frequency of 18 month s              ified.in t         _e&#xfd;g u&#xfd;Iato ry Guide 1.52 (Ref. 3).) Each actuation signal must be verified (overlapping testing is acceptable).
SR 3.7.10.4 This roomSR     verifies the envelope.      Thecapability  of the control room     CREFS to pressurize the control           27 positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify this function of the CREFS. During the emergency recirculation mode of ns e   "            operation, the CREFS is designed to pressurize the control room
                           !0.125 inches water gauge positive pressure with respect to adjlacent minimize unfiltered inleakage. The CREFS is designed            27 areas to maintain    thistopositive in order              pressure with one train at a makeup flow rate of 800 cfm.
BASIS          The Frequency is consistent               18 months on a STAGGERED TEST with theofguidance                                         I1 provided in NUREG-0800 (Ref. 4).
REFERENCES           1.      FSAR, Sections 2.2, 6.4, 6.5, 7.3,         r94.
: 2. FSAR, Chapter 15.
: 3. Regulatory Guide 1.52
 -X'je*r-                 4. NUREG-0800, Section 6.4, Rev. 2, July 1981.
COMANCHE PEAK - UNITS 1 AND 2                    B 3.7-61                                   Revision 27 to TXX-06174 Page 10 of 11 Insert B (page B 3.7-54) 1 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 the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy 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, ducting, doors, penetrations and equipment that physically form the CRE.
The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.
Insert C (page B 3.7-56)
The CREFS provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release (Ref. 1).
The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Ref. 1). The analysis for Comanche Peak has determined no CREFS actuation is required for hazardous chemical releases or smoke and no Surveillance Requirements are required to verify operability for hazardous chemicals or smoke.
Insert D (page B 3.7-57)
In order for the CREFS trains 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 licensing basis consequence analyses for DBA's, and that CRE occupants are protected from hazardous chemicals and smoke.
Insert E (page B 3.7-58)
If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem whole body or its equivalent to any part of the body), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable.
Actions must be taken to restore an OPERABLE CRE boundary within 90 days.
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. Actions must be taken within 24 hours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions to TXX-06174 Page I Iof II Insert E (page B.7-58) (continued) that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely 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 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.
Insert F (page B 3.7-61)
This SR verifies 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 Habitability Program.
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 whole body or its equivalent to any part of the body and the CRE occupants are protected from hazardous chemicals and smoke. For Comanche Peak, there is no CREFS actuation for hazardous chemical releases or smoke and there are no Surveillance Requirements that verify operability for hazardous chemicals or 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 consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 4) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 5). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 6). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE 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.
Insert G (page B 3.7-61)
: 4.        Regulatory Guide 1.196.
: 5.       NEI 99-03, "Control Room Habitability Assessment," June 2001.
: 6.        Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 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).}}