ULNRC-06025, Specific Adoption of Traveler TSTF 522-A, Revision 0, Revise Ventilation System to Operate for 10 Hours Per Month Using the Consolidated Line Item Improvement Process LAR, Change Request (LDCN) 13-0010

Specific Adoption of Traveler TSTF 522-A, Revision 0, Revise Ventilation System to Operate for 10 Hours Per Month Using the Consolidated Line Item Improvement Process LAR, Change Request (LDCN) 13-0010

ML13270A043
Person / Time
Site:	Callaway
Issue date:	09/26/2013
From:	Cox B Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06025
Download: ML13270A043 (26)

Text

~~

WAmeren Callaway Plant MISSOURI September 26, 2013 ULNRC-06025 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.90 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

PLANT SPECIFIC ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-522-A, REVISION 0, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH" USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS" LICENSE AMENDMENT REQUEST (LAR) I LICENSING DOCUMENT CHANGE REQUEST (LDCN) 13-0010 Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit," Ameren Missouri (Union Electric Company) herewith transmits an application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant.

The proposed amendment revises Technical Specification (TS) Surveillance Requirement (SR) 3.7.10.1 and SR 3.7.13.1 to reduce the required run time for periodic operation ofthe control room pressurization system filter trains and emergency exhaust system filter trains, with heaters on, from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes. The proposed amendment is consistent with plant-specific options provided in the NRC's model safety evaluation of Technical Specifications Task Force (TSTF) Traveler TSTF-522-A, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month."

The appropriate TS Bases changes for the proposed revisions toTS SR 3.7.10.1 and SR 3.7.13.1 are included for information and reflect the proposed changes.

The Enclosure provides a description of the proposed changes and the supporting assessment of applicability and plant-specific variations. Attachments 1 through 3 provide the Markup of Technical Specifications, Markup of Proposed Technical Specification Bases, and Retyped Technical Specifications changes, respectively, in support of this amendment request. Attachment 2 is provided PO Box 620 Fulton, MO 65251 AmerenMissouri.com

ULNRC-06025 September 26, 2013 Page 2 for information only. Final TS Bases changes will be processed under the program for updates per TS 5.5.14, "Technical Specifications Bases Control Program," at the time this amendment is implemented.

It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92, "Issuance of amendment." Pursuant to 10 CFR 51.22, "Criterion categorical exclusion or otherwise not requiring environmental review," Section (b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

Further, this submittal does not contain new commitments.

The Callaway Onsite Review Committee and a subcommittee of the Nuclear Safety Review Board have reviewed and approved the proposed changes and have approved the submittal of this amendment application.

Ameren Missouri requests approval ofthe requested license amendment prior to September 15, 2014 Ameren Missouri further requests that the license amendment be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance.

In accordance with 10 CFR 50.91 "Notice for public comment; State consultation," Section (b)(l), a copy of this amendment application is being provided to the designated Missouri State official.

Ifthere are any questions, please contact Scott Maglio, Regulatory Affairs Manager at 573-676-8719.

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

Sincerely, 1-aJt;;i_~

Barry L. Cox Senior Director, Nuclear Operations Executed on: September 26, 2013

Enclosure:

Description and Assessment Attachments to the

Enclosure:

1. Technical Specifications Page Markups

2. Proposed Technical Specification Bases Page Markups

3. Retyped Technical Specification Pages

ULNRC-06025 September 26, 2013 Page 3 cc: U.S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Washington, DC 20555-0001 Mr. Steven A. Reynolds Acting Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Fred Lyon Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738

ULNRC-06025 September 26, 2013 Page4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:

A. C. Heflin F. M. Diya C. 0. Reasoner III B. L. Cox L. H. Graessle J. S. Geyer S. A. Maglio Corporate Communications NSRB Secretary T. B. Elwood STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Ms. Leanne Tippett Mosby (DNR)

ULNRC-06025 Enclosure Page 1 of 4 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises Surveillance Requirements (SRs) 3.7.10.1 and 3.7.13.1 which currently require operating certain ventilation systems (the Control Room Emergency Ventilation System (CREVS) in Technical Specification (TS) 3.7.10 and the Emergency Exhaust System (EES) in TS 3.7.13) with the heaters operating for a continuous 10-hour period at a frequency controlled in accordance with the Surveillance Frequency Control Program (SFCP). (For the CREVS at Callaway this applies only to the pressurization trains)

Proposed revisions to these SRs would require operation of these systems, with the applicable heaters operating, for 15 continuous minutes at a frequency controlled in accordance with the SFCP.

The proposed amendment is consistent with Technical Specifications Task Force (TSTF)

Traveler TSTF-522-A, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month."

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Ameren Missouri has reviewed the proposed model safety evaluation in the Federal Register Notice for Comment (77 FR 16869 dated March 22, 2012). Ameren Missouri also reviewed the NRC staffs final model safety evaluation dated September 13,2012 included with the Federal Register Notice of Availability (77 FR 58421 dated September 20, 2012, ADAMS Accession Number ML12163A421), as well as the information provided in TSTF-522-A.

Ameren Missouri has concluded that the justifications presented in TSTF-522-A and the model safety evaluation prepared by the NRC staff are applicable to Callaway Plant and justify this amendment for the incorporation of the changes to the Callaway Plant Technical Specifications.

2.2 Optional Changes and Variations Ameren Missouri is proposing only minor variations from the TS changes described in TSTF-522-A, Revision 0, and the applicable parts ofthe NRC staffs model safety evaluation dated September 13, 2012. Consistent with the bracketed, plant-specific options in the NRC's model safety evaluation, the proposed amendment retains the requirement for applicable ventilation system heaters to be operating during the surveillances and the previously approved allowance to apply the SFCP to the surveillance Frequencies (per Callaway License Amendment 202). As acknowledged in the NRC's review of License Amendment 133 (i.e., Callaway's amendment for conversion to the Improved Technical

ULNRC-06025 Enclosure Page 2 of4 Specifications (ITS)), the CREVS at Callaway includes two pressurization system trains with heaters and two filtration system trains without heaters.

It should also be noted that the Callaway Plant TSs use different system titles than the Standard Technical Specifications on which TSTF-522-A was based. Specifically, Standard Technical Specification (STS) 3. 7.10 in NUREG-1431 covers the Control Room Emergency Filtration System (CREFS) whereas Callaway TS 3.7.10 covers the Control Room Emergency Ventilation System (CREVS). STS 3.7.13 in NUREG-1431 covers the Fuel Building Air Cleanup System (FBACS) whereas Callaway TS 3.7.13 covers the Emergency Exhaust System (EES). These differences are administrative and do not affect the applicability ofTSTF-522-A to the Callaway Plant TSs.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Ameren Missouri requests adoption of an approved change to the Standard Technical Specifications in order to revise Callaway Plant Technical Specification (TS) 3.7.10, "Control Room Emergency Ventilation System (CREVS)," and TS 3.7.13, "Emergency Exhaust System (EES)." This amendment would revise Surveillance Requirements 3.7.10.1 and 3. 7.13 .1 that require these ventilation systems with the CREVS pressurization train heaters and EES train heaters operating for a continuous 10-hour period at a frequency controlled in accordance with the Surveillance Frequency Control Program (SFCP). These Surveillance Requirements would be revised to require operation of these systems with the CREVS pressurization train heaters and EES train heaters operating for 15 continuous minutes at a frequency controlled in accordance with the SFCP.

As required by 10 CFR 50.91(a), an analysis for concluding that the proposed change involves no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change replaces existing Surveillance Requirements to operate the Control Room Emergency Ventilation System (CREVS) and the Emergency Exhaust System (EES) for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period with applicable heaters operating at a frequency controlled in accordance with the SFCP, with requirements to operate these systems for 15 continuous minutes with applicable heaters operating at a frequency controlled in accordance with the SFCP.

These systems are not accident initiators (i.e., their malfunction cannot initiate an accident or transient) and therefore, these changes do not involve a significant increase in

ULNRC-06025 Enclosure Page 3 of4 the probability of an accident. The proposed system and filter testing changes are consistent with current regulatory guidance for these systems and will continue to assure that these systems perform their design function which may include mitigating accidents.

Therefore, the change does not involve a significant increase in the consequences of an accident.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The change proposed for these ventilation systems does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met and the system components are capable of performing their intended safety functions. The change does not create new failure modes or mechanisms and no new accident precursors are generated.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The design basis for the ventilation system heaters in the EES and in the pressurization trains of the CREVS includes the capability to heat the incoming air, reducing the relative humidity (and thereby increasing adsorber efficiency). The heater testing change proposed will continue to demonstrate that the heaters are capable of heating the air and will thus perform their design function. The proposed change is consistent with regulatory guidance.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Enclosure to ULNRC-06025 Page 4 of4 Based on the above, Ameren Missouri concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Enclosure to ULNRC-06025 Page 1 of3 ATTACHMENT 1 TECHNICAL SPECIFICATIONS PAGE MARKUPS

Enclosure to ULNRC-06025 Page 2 of3 CREVS 3.7.10 15" SURVEILLANCE REQUIR~.

SURVEILLANCE _.,-- /h r,u-/e.r FREQUENCY SR 3.7.10.1 0~ """" CR~.:"""""""" flUe<""'

for ~ O)continuous with the heaters operating In accordance with the and e ch CREVS train filtration filter unit for Surveillance

~ 15A'"inutes. Frequency Control Program d6nl-rn IC61AS' SR 3.7.10.2 Perform required CREVS filter testing in accordance In accordance with with the Ventilation Filter Testing Program {VFTP). theVFTP SR 3.7.10.3 Verify each CREVS train actuates on an actual or In accordance simulated actuation signal. with the Surveillance Frequency Control Program SR 3.7.10.4 Perform required unfiltered air inleakage testing of the In accordance with CRE and CBE boundaries in accordance with the the Control Room Control Room Envelope Habitability Program. Envelope Habitability Program CALLAWAY PLANT 3.7-31 Amendment No. 202

Enclosure to ULNRC-06025 Page 3 of3 Emergency Exhaust System 3.7.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY lh~~

SR 3.7.13.1 Operate each EES train for~ 4&-;fOntlnuous ~ In accordance with the heaters operating. IS" with the Surveillance Frequency Control Program SR 3.7.13.2 Perform required EES filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP). theVFTP SR 3.7.13.3 Verify each EES train actuates on an actual or In accordance simulated actuation signal. with the Surveillance Frequency Control Program SR 3.7.13.4 Verify one EES train can maintain a negative pressure In accordance

~ 0.25 inches water gauge with respect to with the atmospheric pressure in the auxiliary building during Surveillance the SIS mode of operation. Frequency Control Program SR 3.7.13.5 Verify one EES train can maintain a negative pressure In accordance

~ 0.25 inches water gauge with respect to with the atmospheric pressure in the fuel building during the Surveillance FBVIS mode of operation. Frequency Control Program CALLAWAY PLANT 3.7-38 Amendment No. 202

Enclosure to ULNRC-06025 Page 1 of 12 ATTACHMENT 2 TECHNICAL SPECIFICATIONS BASES PAGE MARKUPS

Enclosure to ULNRC-06025 Page 2 of 12 CREVS B3.7.10 B 3. 7 PLANT SYSTEMS B 3. 7.10 Control Room Emergency Ventilation System (CREVS)

BASES BACKGROUND The CREVS provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity. The CREVS consists of two independent, redundant trains that pressurize, recirculate, and filter the control room air. Each CREVS train consists of a filtration system train and a pressurization system train. Each filtration system train consists of a fan, a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines. Each pressurization system train consists of a fan, a moisture separator, an electric heater, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines. Ductwork, valves or dampers, and instrumentation also form part of the CREVS system.

The CREVS is an emergency system which may also operate during normal unit operations. Upon receipt of the actuating signal, normal air supply and exhaust to the control room envelope (CRE) is isolated, a portion of the ventilation air is recirculated through the system filter trains, and the pressurization system is started. The prefilters remove any large particles in the air, and a moisture separator removes any entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each pressurization system train for at least~per month, with the heaters functioning, reduces moisture buildup o the HEPA filters and adsorbers. The heaters are important to the

• eness_of1tt:'e charcoal adsorbers.

Is tt7;;, "T't!..r Actuation of the CREVS by a Control Room Ventilation Isolation Signal (CRVIS), places the system in the emergency mode of operation.

Actuation of the system to the emergency mode of operation closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the air within the CRE through the redundant trains of HEPA and the charcoal filters. The emergency (CRVIS) mode also initiates pressurization and filtered ventilation of the air supply to the CRE.

The control room pressurization system draws in outside air, processing it through a particulate filter charcoal adsorber train for cleanup. This outside air is diluted with air drawn from the cable spreading rooms and the electrical equipment floor levels within the control building and distributed back into those spaces for further dilution. The control room filtration units take a portion of air from the exhaust side of the (continued)

CALLAWAY PLANT B 3.7.10-1 Revision 10

Enclosure to ULNRC-06025 Page 3 of 12 CREVS B 3.7.10 BASES ACTIONS D.1. D.2 1. and p.2.2 (continued) 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 CRE. Required Actions D.2.1 and D.2.2 would place the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

E,1 and E2 During movement of irradiated fuel assemblies, with two CREVS trains inoperable or one or more CREVS trains inoperable due to an inoperable CRE or CBE boundary, action must be taken immediately to suspend activities that could result In a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

If both CREVS trains are inoperable in MODE 1, 2, 3, or 4, for reasons other than an inoperable CRE and CBE boundary (i.e., Condition B), the CREVS 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 fe.,..;u/ru./13 REQUIREMENTS Standby systems should beeecked periodically to ensure that they function properly. As the e ironment and normal operating conditions on this system are not severe, esting each traithRCP mcpr:y ~9Rtlt, by initiating from the control room, flow through e HEPA filters and charcoal adsorbers of both the filtration and pressurization systems, provides an adequa~ chec~ of this system.

t:'!-rfDtlrc

-MePitiol:t'fteater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air. Each pressurization system (continued)

CALLAWAY PLANT B 3.7.10-7 Revision 10

Enclosure to ULNRC-06025 Page 4 of 12 CREVS B3.7.10 BASES SURVEILLANCE SR 3.7.101 (continued) £ /~ frl(nl/fu REQUIREMENTS train must be operated for<!: 4Jcontinuous ~th the heate functioning. Functioning heaters will not necessarily have th eating elements energized continuously for  ; but will cycl Cfepending on the air temperature. Each filtration system train need onf be operated for

<!: 15 minute~o demonstrate the function the system. he Surveillance Frequency I ased on operating experfe , equipment reliability, and plant risk a is controlled under the Su eillance Frequency Control Program. 1, I

~1'\..,..,ntADU.r'J jt) ~il1rleS" SR 3.7.102 This SR verifies that the required CREVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The CREVS fiHer tests use the test procedure guidance in Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing the performance of the HEPA fiHer, 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.

SR 3 710 3 This SR verifies that each CREVS train starts and operates on an actual or simulated actuation signal. The actuation signal includes Control Room Ventilation Isolation or Fuel Building Ventilation Isolation. The CREVS train automatically switches on an actual or simulated CRVIS signal into a CRVIS mode of operation with flow through the HEPA filters and charcoal adsorber banks. The Surveillance Requirement also verifies that a control room ventilation isolation signal (CRVIS) will be received by the LOCA sequencer to enable an automatic start of the Diesel Generator loads that are associated with a CRVIS. Verification that these loads will start and operate at the appropriate step in the LOCA sequencer and that other auto-start signals for these loads will be inhibited until the LOCA sequencer is reset is accomplished under Surveillance Requirement SR 3.8.1.12. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

(continued)

CALLAWAY PLANT B3.7.10-8 Revision 10

Enclosure to ULNRC-06025 Page 5 of 12 INSERT 1 The 15-minute run time is based on Position C.6.1 of Reference 10.

Enclosure to ULNRC-06025 Page 6 of 12 CREVS B3.7.10 BASES SURVEILLANCE SR 3.7.104 REQUIREMENTS (continued) This SR verifies the OPERABILITY of the CRE and CBE boundaries credited in the accident analysis by testing for unfiltered air inleakage past the credited envelope boundaries 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 CALLAWAY, there is no CREVS 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 CRE and CBE boundaries credited in the accident analysis 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 envelope boundary credited in the accident analysis to OPERBALE 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 envelope boundary credited in the accident analysis to OPERABLE status Include changing the licensing basis DBA consequence analysis, repairing the envelope boundary credited in the accident analysis, 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 envelope boundary credited in the accident analysis has been restored to OPERABLE status.

REFERENCES 1. FSAR, Section 6.4, Habitability Systems.

2. FSAR, Chapter 15A.3, Control Room Radiological Consequences Calculation Models.

3. Regulatory Guide 1.52, Rev. 2, Design, Testing, and Maintenance Criteria for Atmospheric Cleanup System Air Filtration and Adsorption Units of Light Water Cooled Nuclear Power Plants.

(continued)

CALLAWAY PLANT B 3.7.10-9 Revision 10

Enclosure to ULNRC-06025 Page 7 of 12 CREVS 83.7.10 BASES REFERENCES 4. Regulatory Guide 1. 196, "Control Room Habitability at Light-Water (continued) Nuclear Power Reactors; Revision 1.

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 AHematlve Source Terms In the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

7. FSAR Section 2.2, Nearby Industrial, Transportation, and Military Facllllties.

8. Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release,

• Rev. 0.

CALLAWAY PLANT B 3.7.10-10 Revision 1Od

Enclosure to ULNRC-06025 Page 8 of 12 Emergency Exhaust System B 3.7.13 BASES ACTIONS P.1 and P2 (continued)

When Required Action A. 1 cannot be completed within the associated Completion Time during movement of Irradiated fuel assemblies in the fuel building, the OPERABLE Emergency Exhaust System train must be immediately started in the FBVIS mode per Required Action 0.1. This action ensures that no undetected failures preventing system operation exist, and that any active failure will be readily detected.

An alternative to Required Action 0.1 Is to immediately suspend movement of irradiated fuel assemblies In the fuel building per Required Action 0.2. This precludes activities that could result in a fuel handling accident and the associated release of radioactivity that might require operation of the Emergency Exhaust System. This action does not preclude the movement of fuel assemblies to a safe position.

When two trains of the Emergency Exhaust System are inoperable during movement of irradiated fuel assemblies in the fuel building, action must be taken to place the unit in a condition in which the LCO does not apply.

Action must be taken immediately to suspend movement of irradiated fuel assemblies in the fuel building. This does not preclude the movement of fuel to a safe position. This condition only applies to the EES components required to support the FBVIS mode of operation, including the fuel building pressure boundary.

SURVEILLANCE REQUIREMENTS sR 3.7.13.1 ferr 1 tlrt!I.I'J_

Standby systems should be chEedperiodically to ensure that they function properly. As the envi nmental and normal operating conditions on this system are not severe, *ng each trai,A;e euar;y R'lllmh, by f/&rl4,{i(! t:

initiating from the Control Room flow through th HEPA filters and charco~ adsorpers, provides an adequate check on this system. ,.

IS""

-Merlthl~'f!eater operation dries out any oisture accum ated in the charcoal from humidity In the ambient ir. Each Erne~ ncy Exhaust 1

/l'ltnlff'll..r System train must be operated for ;;: ntinuous lth the heaters functioning. Functioning heaters would not necessarily have the heating elements energized continuously for~ but will cycle depending on the temperature. This SR can be sati d with the EES in the SIS or FBVIS lineup during testingi4.

r::Nsetr :::t /S 111;,. ~

(continued)

CALLAWAY PLANT 83.7.13-5 Revision 10

Enclosure to ULNRC-06025 Page 9 of 12 INSERT2 The 15-minute run time is based on Position C.6.1 of Reference 10.

Enclosure to ULNRC-06025 Page 10 of 12 Emergency Exhaust System B 3.7.13 BASES SURVEILLANCE SR 3.7 13 1 (continued)

REQUIREMENTS The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and Is controlled under the Surveillance Frequency Control Program.

SR 3,7.13.2 This SR verifies that the required Emergency Exhaust System filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The Emergency Exhaust System filter tests are In accordance with Regulatory Guide 1.52 (Ref. 7). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal.

Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.13,3 This SR verifies that each Emergency Exhaust System train starts and operates on an actual or simulated actuation signals. These actuation signals include a Safety Injection Signal (applicable in MODE 1, 2, 3 and 4) and high radiation signal from the Fuel Building Exhaust Radiation

-Gaseous channels (applicable during movement of irradiated fuel in the fuel building).

During emergency operations the Emergency Exhaust System will automatically start in either the SIS or FBVIS lineup depending on the initiating signal. In the SIS lineup, the fans operate with dampers aligned to exhaust from the Auxiliary Building and prevent unfiltered leakage. In the FBVIS lineup, which is initiated on a high radiation signal from the Fuel Building Exhaust Radiation - Gaseous channels, the fans operate with the dampers aligned to exhaust from the Fuel Building to prevent unfiltered leakage. Normal exhaust air from the Fuel Building Is continuously monitored by radiation detectors. One detector output will automatically align the Emergency Exhaust System in the FBVIS mode of operation. This surveillance requirement demonstrates that each Emergency Exhaust System train can be automatically started and properly configured to the FBVIS or SIS alignment, as applicable, upon receipt of an actual or simulated SIS signal and an FBVIS signal. It is not required that each Emergency Exhaust System train be started from both actuation signals during the same surveillance test provided each actuation signal is tested independently. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

(continued)

CALLAWAY PLANT B 3.7.13-6 Revision 10

Enclosure to ULNRC-06025 Page 11 of12 Emergency Exhaust System B 3.7.13 BASES SURVEILLANCE SR 37134 REQUIREMENTS (continued) This SR verifies the integrity of the auxiliary building enclosure. The ability of the auxiliary building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the Emergency Exhaust System. During the SIS mode of operation, the Emergency Exhaust System is designed to maintain a slight negative pressure In the auxiliary building, to prevent unfiltered leakage. The Emergency Exhaust System is designed to maintain a negative pressure ~ 0.25 inches water gauge with respect to atmospheric pressure at the flow rate specified in the VFTP. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 37135 This SR verifies the integrity of the fuel building enclosure. The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the Emergency Exhaust System. During the FBVIS mode of operation, the Emergency Exhaust System is designed to maintain a slight negative pressure in the fuel building, to prevent unfiltered leakage.

The Emergency Exhaust System is designed to maintain a negative pressure ~ 0.25 inches water gauge with respect to atmospheric pressure at the flow rate specified in the VFTP. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. FSAR, Section 6.5.1, Engineered Safety Features (ESF) Filter Systems.

2. FSAR, Section 9.4.2, Fuel Building HVAC.

3. FSAR, Section 9.4.3, Auxiliary Building HVAC.

4. FSAR, Section 15.7.4, Fuel Handling Accidents.

5. Regulatory Guide 1.25, Rev. 0, Assumptions Used for Evaluating the Potential Radiological Consequences of a Fuel Handling Accident in the Fuel Handling and Storage Facility for Boiling and Pressurized Water Reactors.

(continued)

CALLAWAY PLANT B 3.7.13-7 Revision 10

Enclosure to ULNRC-06025 Page 12 of 12 Emergency Exhaust System B 3.7.13 BASES REFERENCES 6. Regulatory Guide 1.4, Rev. 2, Assumptions Used for Evaluating (continued) the Potential Radiological Consequences of a Loss of Coolant Accident from Pressurized water Reactors.

7. Regulatory Guide 1.52 (Rev. 2), Design, Testing and Maintenance Criteria for Atmospheric Cleanup System Air Filtration and Adsorption Units of Light water Cooled Nuclear Power Plants.

8. NUREG-0800, Section 6.5.1, Rev. 2, July 1981, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants.

9. Procedure EDP-ZZ-04107, HVAC Pressure Boundary and watertight Door Control.

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CALLAWAY PLANT B3.7.13-8 Revision 1Od

Enclosure to ULNRC-06025 Page 1 of3 ATTACHMENT 3 RETYPED TECHNICAL SPECIFICATIONS PAGES

Enclosure to ULNRC-06025 CREVS 3.7.10 Page 2 of3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREVS train pressurization filter unit In accordance for ~ 15 continuous minutes with the heaters with the operating and each CREVS train filtration filter unit for Surveillance

~ 15 continuous minutes. Frequency Control Program SR 3.7.10.2 Perform required CREVS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.10.3 Verify each CREVS train actuates on an actual or In accordance simulated actuation signal. with the Surveillance Frequency Control Program SR 3.7.10.4 Perform required unfiltered air in leakage testing of the In accordance with CRE and CBE boundaries in accordance with the the Control Room Control Room Envelope Habitability Program. Envelope Habitability Program CALLAWAY PLANT 3.7-31 Amendment No.###

Enclosure to ULNRC-06025 Emergency Exhaust System 3.7.13 Page 3 of3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Operate each EES train for ~ 15 continuous minutes In accordance with the heaters operating. with the Surveillance Frequency Control Program SR 3.7.13.2 Perform required EES filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.13.3 Verify each EES train actuates on an actual or In accordance simulated actuation signal. with the Surveillance Frequency Control Program SR 3.7.13.4 Verify one EES train can maintain a negative pressure In accordance

~ 0.25 inches water gauge with respect to with the atmospheric pressure in the auxiliary building during Surveillance the SIS mode of operation. Frequency Control Program SR 3.7.13.5 Verify one EES train can maintain a negative pressure In accordance

~ 0.25 inches water gauge with respect to with the atmospheric pressure in the fuel building during the Surveillance FBVIS mode of operation. Frequency Control Program CALLAWAY PLANT 3.7-38 Amendment No.###