View source for L-2012-313, Administrative License Amendment Request No. 223 Regarding Control Room Emergency Ventilation System Technical Specification

{{Adams
| number = ML12221A392
| issue date = 08/07/2012
| title = Administrative License Amendment Request No. 223 Regarding Control Room Emergency Ventilation System Technical Specification
| author name = Kiley M
| author affiliation = Florida Power &amp; Light Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000250, 05000251
| license number = DPR-031, DPR-041
| contact person = 
| case reference number = L-2012-313, TAC ME1624, TAC ME1625
| document type = Letter type:L
| page count = 12
| project = TAC:ME1624, TAC:ME1625
| stage = Request
}}

=Text=
{{#Wiki_filter:L-2012-313 010                                                                                            CFR 50.90 AUG 0 7 2012 FPL.
U. S. Nuclear Regulatory Conmmission Attn.: Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Administrative License Amendment Request No. 223 Regarding Control Room Emergency Ventilation System Technical Specification

==Reference:==

(1) J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4 - "Issuance of Amendments Regarding Alternative Source Term (TAC Nos. ME1624 and ME1625)," Accession No. ML110800666, June 23, 2011.
On June 23, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Amendment Nos. 244 and 240 to Renewed Facility Operating License Nos. DPR-31 and DPR-41 for the Turkey Point Nuclear Plant, Units Nos. 3 and 4, respectively, with supporting Safety Evaluation Report (SER) regarding the Alternative Source Term (AST) [Reference 1].
During implementation of these amendments, it has been identified that a correction is needed to address a clerical error identified in the issued TS involving TS 3.7.5 Action "c" for Modes 5 and 6 that omitted an applicable footnote. The footnote for Modes 1-4 also needs to be modified for Modes 5-6 to include core alterations and positive reactivity changes as well as fuel movement in order to be consistent with the intent of the FPL responses to the NRC Requests for Additional Information (RAI) regarding AST and the Control Room Emergency Ventilation System (CREVS). If not corrected, TS 3.7.5 Action "c", as currently worded, could interfere with core refueling activities for the Unit 4 Cycle 27 Refueling Outage scheduled for later this fall.
Description of the proposed TS change with supporting justification and a no significant hazards determination and environmental consideration are provided in the Enclosure to this letter.
The Turkey Point Plant Nuclear Safety Committee (PNSC) has reviewed the proposed license amendments. The proposed TS change has been evaluated in accordance with 10 CFR 50.91(a)(1),
using the criteria in 10 CFR 50.92(c). FPL has determined that the proposed TS change does not involve a significant hazards consideration.
FPL has determined that the proposed amendments involve no significant increase in the amounts or types of any effluents that may be released offsite, and no significant increase in individual or cumulative occupational radiation exposure. Therefore, FPL has concluded that the proposed amendments meet the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendments.
This letter contains no new commitments and no revisions to existing commitments.
FPL requests that this license amendment request be approved and the revised TS issued prior to the onset of the Unit 4 Cycle 27 refueling outage scheduled to commence on November 5, 2012.
Florida Power & Light Company 9760 SW 344 St., Florida City, FL 33035                                                              142 0 X-(PL

Turkey Point Nuclear Plant                                                             L-2012-313 Docket Nos. 50-250 and 50-251                                                          Page 2 of 2 In accordance with 10 CFR 50.91(b)(1), a copy of this letter is being forwarded to the State Designee of Florida.
Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto, Licensing Manager, at (305) 246-7327.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on August. 7 , 2012.
Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant Enclosure cc:     USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health

Turkey Point Nuclear Plant                                                L-2012-313 Docket Nos. 50-250 and 50-251                                              Enclosure Page 1 of 10 Enclosure Turkey Point Units 3 and 4 Administrative License Amendment Request No. 223 Regarding Control Room Emergency Ventilation System Technical Specification

Turkey Point Units 3 and 4                                    L-2012-313 Docket Nos. 50-250 and 50-251                                  Enclosure Page 2 of 10 TABLE OF CONTENTS ADMINISTRATIVE LICENSE AMENDMENT REQUEST NO. 223 REGARDING CONTROL ROOM EMERGENCY VENTILATION SYSTEM TECHNICAL SPECIFICATION SECTION TITLE                PAGE Cover Sheet                                   1
---                Table of Contents                             2

==1.0                Purpose and Scope==
3 2.0                Background Information                        3 3.0                Description of Proposed Changes               4 4.0                Basis/Justification of Proposed Changes       4 5.0                List of Commitments                           5 6.0                Conclusion                                    5 7.0                No Significant Hazards Determination          5 8.0                Environmental Consideration                   6 9.0                Summary of Results                            7 10.0               References                                    7 11.0               Tables & Figures                              8

Turkey Point Units 3 and 4                                                                   L-2012-313 Docket Nos. 50-250 and 50-251                                                                 Enclosure Page 3 of 10

==1.0    Purpose and Scope==

Florida Power and Light Company (FPL) proposes to amend Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 to correct a clerical error identified in the issued TS involving TS 3.7.5 Action "c" for Modes 5 and 6 that omitted an applicable footnote. The footnote for Modes 1-4 also needs to be modified for Modes 5-6 to include core alterations and positive reactivity changes as well as fuel movement in order to be consistent with the intent of the FPL responses to the NRC Requests for Additional Information (RAI) regarding the Alternative Source Term (AST) and the Control Room Emergency Ventilation System (CREVS). If not corrected, TS 3.7.5 Action "c", as currently worded, would interfere with the core refueling activities for the Unit 4 Cycle 27 Refueling Outage scheduled for later this fall.
2.0    Background Information On June 23, 2011, the NRC issued Amendment Nos. 244 to DPR-31 and 240 to DPR-41 with supporting Safety Evaluation Report (SER) regarding the Alternative Source Term (AST) [Reference 1]. During site review of the TS for implementation, it was noted that
       **footnote at the bottom of TS page 3/4 7-16a had not being carried over and annotated against TS 3.7.5 Action "c" for Modes 5 and 6 at the top of the following TS page 3/4 7-16b. It was further noted that **footnote only addresses "movement of irradiated fuel" and not "core alterations" or "positive reactivity changes." Therefore, Action "c", as currently worded, would prevent offload of the core at the commencement of the Unit 4 Cycle 27 refueling outage if CREVS is considered inoperable (or the plant is in long term action statements). Currently, Turkey Point is in Actions a.8 and a.9 with the kitchen area and toilet motor-operated exhaust dampers closed and both exhaust ducts blanked off pending further design review.
The existing **footnote acknowledges that when an action specified in Actions a.4, a.6, a.7, a.8, or a.9 is taken and the system (CREVS) is placed into the recirculation mode, the ability of the affected (inoperable) component to perform its safety function has been provisionally restored, i.e., CREVS is fully functional. Therefore, the prohibition against fuel movement in Modes 1-4 is no longer applicable.
Similarly, this footnote when applied to TS 3.7.5 Action "c" is intended to acknowledge that when an action specified in Actions a.4, a.6, a.7, a.8, or a.9 is taken and the system (CREVS) is placed into the recirculation mode, the ability of the affected (inoperable) component to perform its safety function has been provisionally restored, i.e., CREVS is fully functional. Although the footnote does require some minor revision to reflect the Modes 5-6 action statement, the conclusion is unchanged. The prohibition against core alterations, movement of irradiated fuel in spent fuel pool, or positive reactivity changes in Modes 5-6 is no longer applicable.
The amendments proposed here will apply a ++footnote to TS 3.7.5 Action "c" that is based on the **footnote but modified to include core alterations and positive reactivity changes. The TS change will allow a resumption of core alterations, movement of irradiated fuel in the spent fuel pool, and positive reactivity changes in Modes 5 and 6 if actions have been taken that permit indefinite operation, i.e., make CREVS functional, and CREVS has been placed in recirculation mode.

Turkey Point Units 3 and 4                                                                L-2012-313 Docket Nos. 50-250 and 50-251                                                               Enclosure Page 4 of 10 This is consistent with the intent of FPL RAI response letters L-2010-083 dated 5/21/2010, L-2010-197 dated 9/15/2010, and L-2011-185 dated 5/11/2011 [References 3, 4, and 5].
3.0    Description of Proposed Changes The proposed TS change involves TS 3.7.5 Action "c" only. In order to provide a more specific description of the proposed change, a TS mark-up is attached and a description is provided below with a brief justification.
4.0    Basis/Justification for the Proposed Changes 4.1    Changes to the PTN Technical Specifications 4.1.1   Technical Specification 3.7.5 Action "c".
Current TS
: c. With the Control Room Emergency Ventilation System inoperable, immediately suspend all operations involving CORE ALTERATIONS, movement of irradiated fuel in the spent fuel pool, or positive reactivity changes. This ACTION shall apply to both units simultaneously.
Proposed TS
: c. With the Control Room Emergency Ventilation System inoperable",
immediately suspend all operations involving CORE ALTERATIONS, movement of irradiated fuel in the spent fuel pool, or positive reactivity changes. This ACTION shall apply to both units simultaneously.
               ++If action per ACTIONS a.4, a.6, a.7, a.8, or a.9 is taken such that indefinite operation is permitted and the system is placed in recirculation mode, then CORE ALTERATIONS, movement of irradiated fuel in the spent fuel pool, or positive reactivity changes may resume.
Basis for the Change: The **footnote annotated in Actions a.4, a.6, a.7, a.8, and a.9 on TS page 3/4 7-16a that allows for the movement of irradiated fuel, when the specified action has been taken permitting indefinite operation and CREVS has been placed in recirculation mode, was intended to address not only fuel movement in the spent fuel pool in Modes 1-4 but also refueling activities in both the containment and the spent fuel pool in Modes 5 and 6.
The inclusion of core alterations and positive reactivity changes in the ++footnote for TS 3.7.5 Action "c" in Modes 5-6 is consistent with the intent of the **footnote for Modes 1-4 that allows fuel movement while CREVS is in a long-term action but still able to provide its required licensing/design basis function. The annotation of the modified ++footnote to TS 3.7.5 Action "c" is required to assure the plant's ability to offload and load fuel. TS 3.7.5 Action "c", as currently worded, would prevent the offload of the core at the commencement of the Unit 4 Cycle 27 refueling outage if Turkey Point is in a long term action, e.g., a.8 and a.9, as expected for the kitchen area and toilet exhaust dampers noting that the motor-operated dampers are closed and both exhaust ducts are blanked off pending further design review.
A markup of the proposed TS change is attached.

Turkey Point Units 3 and 4                                                                  L-2012-313 Docket Nos. 50-250 and 50-251                                                                Enclosure Page 5 of 10 5.0    List of Commitments None 6.0    Conclusion The proposed amendments correct a clerical error identified in the issued TS involving TS 3.7.5 Action "c" for Modes 5 and 6 that omitted an applicable footnote. The footnote for Modes 1-4 also needs to be modified for Modes 5-6 to include core alterations and positive reactivity changes as well as fuel movement in order to be consistent with the intent of the FPL responses to the NRC RAIs regarding AST and the CREVS. If not corrected, TS 3.7.5 Action "c", as currently worded, would interfere with the core refueling activities for Unit 4 Cycle 27 Refueling Outage scheduled for later this fall.
7.0    No Significant Hazards Determination The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazard if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
The proposed license amendments to Renewed Facility Operating Licenses DPR-31 for Turkey Point Unit 3 and DPR-41 for Turkey Point Unit 4 will correct a clerical error identified in the issued TS involving TS 3.7.5 Action "c" for Modes 5 and 6 that omitted an applicable footnote. The footnote for Modes 1-4 also needs to be modified for Modes 5-6 to include core alterations and positive reactivity changes as well as fuel movement in order to be consistent with the intent of the FPL responses to the NRC RAIs regarding AST and the CREVS. If not corrected, TS 3.7.5 Action "c", as currently worded, could interfere with core refueling activities for Unit 4 Cycle 27 Refueling Outage scheduled for later this fall.
FPL has reviewed this proposed license amendment for FPL's Turkey Point Units 3 and 4 and determined that its adoption would not involve a significant hazards consideration.
The bases for this determination are:
The proposed amendment does not involve a significant hazards consideration for the following reasons:
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
No. The proposed amendments do not change or modify the fuel, fuel handling processes, fuel storage racks, number of fuel assemblies that may be stored in the spent fuel pool (SFP), decay heat generation rate, or the spent fuel pool cooling and cleanup system. The proposed TS change will allow core alterations, fuel movement, and positive reactivity changes in Modes 5 and 6 subject to the conditions specified in the
           ++footnote that actions have been taken to permit indefinite system/component operation and the system is in recirculation mode. The proposed change corrects a clerical error by annotating TS 3.7.5 Action "c" with a modified footnote consistent with the stated intent

Turkey Point Units 3 and 4                                                                 L-2012-313 Docket Nos. 50-250 and 50-251                                                               Enclosure Page 6 of 10 of the original license submittals. The proposed amendments do not cause any physical change to the existing spent fuel storage configuration or fuel makeup. The proposed amendments do not affect any precursors to any accident previously evaluated or do not affect any known mitigation equipment or strategies.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
No. The proposed amendments do not change or modify the fuel, fuel handling processes, fuel racks, number of fuel assemblies that may be stored in the pool, decay heat generation rate, or the spent fuel pool cooling and cleanup system. The proposed TS change will allow core alterations, fuel movement, and positive reactivity changes in Modes 5 and 6 subject to the conditions specified in the ++footnote that actions have been taken to permit indefinite system/component operation and the system is in recirculation mode. The proposed change corrects a clerical error by annotating TS 3.7.5 Action "c" with a modified footnote consistent with the stated intent of the original license submittals.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in the margin of safety?
No. The proposed amendments do not change or modify the fuel, fuel handling processes, fuel racks, number of fuel assemblies that may be stored in the pool, decay heat generation rate, or the spent fuel pool cooling and cleanup system. Therefore, the proposed amendments have no impact to the existing margin of safety for subcriticality required by 10 CFR 50.68 (b)(4).
Therefore, the proposed amendments do not involve a significant reduction in the margin of safety.
Based on the above discussion, FPL has determined that the proposed change does not involve a significant hazards consideration.
8.0    Environmental Consideration 10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment.
A proposed amendment of an operating license for a facility requires no environmental assessment, if the operation of the facility in accordance with the proposed amendment does not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (3) result in a significant increase in individual or cumulative occupational radiation exposure. FPL has reviewed this LAR and determined that the proposed amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement

Turkey Point Units 3 and 4                                                                 L-2012-313 Docket Nos. 50-250 and 50-251                                                                Enclosure Page 7 of 10 or environmental assessment needs to be prepared in connection with the issuance of this amendment. The basis for this determination follows.
Basis This change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:
: 1. As demonstrated in the 10 CFR 50.92 evaluation, the proposed amendment does not involve a significant hazards consideration.
: 2. The proposed amendment does not result in a significant change in the types or increase in the amounts of any effluents that may be released offsite. The proposed amendments do not change or modify the fuel, fuel handling processes, fuel racks, number of fuel assemblies that may be stored in the pool, decay heat generation rate, or the spent fuel pool cooling and cleanup system. The proposed amendments do not change the design or operation of the spent fuel or spent fuel storage system. The proposed amendments do not directly or indirectly affect effluent discharges.
: 3. The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure. The proposed amendments do not change or modify the fuel, fuel handling processes, fuel racks, number of fuel assemblies that may be stored in the pool, decay heat generation rate, or the spent fuel pool cooling and cleanup system. The proposed amendments do not change the design or operation of the spent fuel or spent fuel storage system. The proposed amendments do not directly or indirectly affect the radiological source terms.
9.0    Summary of Results The proposed amendments correct a clerical error identified in the issued TS involving TS 3.7.5 Action "c" for Modes 5 and 6 that omitted an applicable footnote. The footnote for Modes 1-4 also needs to be modified for Modes 5-6 to include core alterations and positive reactivity changes as well as fuel movement in order to be consistent with the intent of the FPL responses to the NRC RAIs regarding AST and the CREVS. If not corrected, TS 3.7.5 Action "c", as currently worded, would interfere with the core refueling activities for Unit 4 Cycle 27 Refueling Outage scheduled for later this fall.
10.0   References
: 1. J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4 - "Issuance of Amendments Regarding Alternative Source Term (TAC Nos. ME1624 and ME1625),"
Accession No. ML110800666, June 23, 2011.
: 2. J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4 - "Issuance of Amendments Regarding Control Room Habitability Technical Specification Task Force (TSTF)-448 (TAC Nos. ME4277 and ME4278)," Accession No. ML12067A176, March 30, 2012.
: 3. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-083), "Supplement to License Amendment Request (LAR) 196 and 3/24/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST)," Accession No. ML101450028, May 21, 2010.

Turkey Point Units 3 and 4                                                         L-2012-313 Docket Nos. 50-250 and 50-251                                                        Enclosure Page 8 of 10
: 4. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-197), "Response to Request for Additional Information (RAI) Regarding Alternative Source Term (AST)
License Amendment Request (LAR) 196 and Proposed Changes to Technical Specification (TS) 3/4.7.5 on Control Room Emergency Ventilation System (CREVS)
(TAC Nos. ME1624 and ME1625)," Accession No. ML102630160, September 15, 2010.
: 5. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2011-185), "Supplemental Response for Alternative Source Term License Amendment Request No. 196 and Proposed Changes to Technical Specification 3.7.5 on Control Room Emergency Ventilation System," Accession No. MLI 1554A035, May 11, 2011.

Turkey Point Units 3 and 4,                                                                                           L-2012-313 Docket Nos. 50-250 and 50-251                                                                                           Enclosure Page 9 of 10
                            ~INo                            Change PLANT SYSTEMS
     .34.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LiMMITI-G_*ONDMIT.N FOQ,                  RAION Ifmcorkttanued a.4    With one recirculation damper inoperable, immediately suspend all movement of Irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or place and maintain at least one of the recirculation dampers in the open position and place the system In recIrculatlon mode-or be in at reast HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be In HOT STANDBY within 12 hours and inCOLD SHUTDOWN within the following 30 hours.
a.5    With the filter train inoperable, e.g., an Inoperable filter, and/or two Inoperable recirculation fans, andlor two inoperable recirculationdampers, immediately suspend all movement of irradiated fuel, and, immediately initiate action to implement mitigating actions (e.g., use of the compensatory filtration unit is required to be immediately initiated), and, within 24 hours, verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits and, within 7 days, restore the fter train to OPERABLE status.
With the above requirements not met, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
a.6    With an inoperable damper inthe normal outside air intake, immediately suspend all movement of irradiated fuel and, within 7 days, restore the Inoperable damper to OPERABLE status or place and maintain at least one of the normal outside air intake isolation dampers in the closed position and place the system in recirculation mode"' o&#xa2; be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
a.7    With an inoperable damper inthe emergency outside air intake, immediately suspend all movement of irradiated fuel and, within 7 days. restore the Inoperable damper to OPERABLE status or place and maintain at least one of the emergency outside air intake isolation dampers in the open position" or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Ifthis ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
a.8    With an isolation damper inoperable in the kitchen area exhaust duct, immediately suspend au movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or isolate the flow path" or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be In HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours, a.9    With an isolation damper inoperable in fthtoilet area exhaust duct, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or isolate the flow path" or be in at least HOT STANDBY within the next 6 hours and inCOLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
      **If action is taken such that Indefinite operation is permitted and the system is placed in recirculation mode, then movement of irradiated fuel may resume.
TURKEY POINT- UNITS 3 &4                                    3/4 7-16a            ANE')N     T NOS.- 248 AND1 244

Turkey Point Units 3 and 4                                                                                        L-2012-313 Docket Nos. 50-250 and 50-251                                                                                         Enclosure Page 10 of 10 PLANTSBYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEIy
: b. With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary, immediately suspend all movement of irradiated fuel in the spent fuel pool, and Immediately initiate action to implement mitigating actions, and within 24 hours, verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits and CRE occupants are protected from smoke hazards, and restore CRE boundary to OPERABLE status within 90 days, or
: 1. With the requirements not met, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: 2.      Ifthis ACTION applies to both units s[multaneously, be in HOT STANDBY within 12 hours and inCOLD SHUTDOWN within the following 30 hours.
MODES 5 and 6:
: c. With the Control Room Emergency Ventilation System Inoperabl          .lmmediately   suspend all operations involving CORE ALTERATIONS, movement of irradiated fuel in the spent fuel pool, or positive reactivity changes. This ACTION shall apply to both units simultaneously.
A       ,L.M,*f..           8EW__ NT.
4.7.5    The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:
: a. At least once per 12 hours by verifying that the control room air temperature is less than or equal to 1201F;
: b. At least once per 31 days by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes"*;
c,    At least once per 18 months or (1) after 720 hours of system operation, or (2) after any structural maintenance on the HEIPA filter or charcoal adsorber housings, or (3) following exposure of the filters to effluents from painting, fire, or chemical release Inany ventilation zone communicating with Ihe system that may have an adverse effect on the functional capability of the system, or (4) after complete or partial replacement of a filler bank by:
       ++If action per ACTIONS a.4, a.6, a.7, a.8, or a.9 is taken that permits indefinite operation and the system is placed in recirculation mode, then CORE ALTERATIONS, movement of irradiated fuel in the spent fuel pool, and positive reactivity changes may resume.
        **Asthe mitigation actions of TS 3.7,5 Action a.5 may include the use of the compensatory filtration unit, the unit shall meet the surveillance requirements of TS 4.7.5.b, by manual initiation from outside the control room and TS 4.7,5.c and d.
TURKEY POINT - UNITS 3 & 4                                 3/47-1Gb            ANENUlENU NTIS. 248 ANr) 244}}