ML082670890

Response to NRC Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit 2, Two Inoperable Control Room Air Conditioning Subsystems

ML082670890
Person / Time
Site:	Nine Mile Point
Issue date:	09/08/2008
From:	Polson K Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD6352
Download: ML082670890 (24)

Text

{{#Wiki_filter:i'VI~j Keith J. Poison P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax 0 Constellation Energy, Nine Mile Point Nuclear Station September 8, 2008 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Nine Mile Point Nuclear Station Unit No. 2, Docket No. 50-410 Response to NRC Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2, Two Inoperable Control Room Air Conditioning Subsystems (TAC No. MD6352)

REFERENCES:

(a) Letter from K. J. Polson (NMPNS) to Document Control Desk (NRC), dated July 30, 2007, Application for Technical Specification Change TSTF-477, Revision 3, "Add Action for Two Inoperable Control Room AC Subsystems" to the Technical Specifications Using Consolidated Line Item Improvement Process (b) Letter from K. J. Polson (NMPNS) to Document Control Desk (NRC), dated April 7, 2008, Response to NRC Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2, Two Inoperable Control Room Air Conditioning Subsystems (TAC No. MD6352) (c) Letter from R. V. Guzman (NRC) to K. J. Polson (NMPNS), dated July 11, 2008, Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2, Two Inoperable Control Room Air Conditioning Subsystems (TAC No. MD6352) Pursuant to 10 CFR 50.90, Nine Mile Point Nuclear Station, LLC, (NMPNS) requested, in Reference (a), approval of an amendment to the Nine Mile Point Unit 2 (NMP2) Renewed Facility Operating License NPF-69 to revise Technical Specification (TS) 3.7.3, "Control Room Envelope Air Conditioning (AC) System," by adding an action statement for two inoperable control room AC subsystems. In Reference (b), NMPNS responded to the first NRC request for additional information (RAI) concerning this amendment request. The purpose of this letter is to provide a response to the second RAI transmitted to NMPNS in Reference (c).

Document Control Desk September 8, 2008 Page 2 Response to the RAI is provided in Attachment 1. This response affects the No Significant Hazards Determination Analysis provided by NMPNS in Reference (a). A supplemental No Significant Hazards Analysis is included in Attachment 1. Attachment 2 provides a mark up of the existing TS pages showing both the initial change requested by Reference (a) and additional changes made in response to Reference (c). Attachment 3 provides the existing TS Bases pages marked up to show both the initially requested changes from Reference (a), as well as supplemental changes made to address Reference (c). The TS Bases changes are provided for information only and will be processed in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program." Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this submittal to the appropriate state representative. This submittal contains no regulatory commitments. Should you have any questions regarding the information in this submittal, please contact T. F. Syrell, Licensing Director, at (315) 349-5219. Very truly yours, STATE OF NEW YORK TO WIT: COUNTY OF OSWEGO I, Keith J. Polson, being duly sworn, state that I am Vice President-Nine Mile Point, and that I am duly authorized to execute and file this response on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable. Subscribed and sworn before me, a Notary Public in and for the State of New York and County of Oswego, this 8 4' day of 2008. WITNESS my Hand and Notarial Seal: _4-('2, LJI ' Notary Public SANDRA A. OSWALD Notary Public, State of New York My Commission My Expires: CmmisionExpies:No. in Oswego Count-O~OQualified 010S6032276 Camsion Expires -Veai5. Date KJP/JJD

Document Control Desk September 8, 2008 Page 3 Attachments: 1. Response to NRC Request for Additional Information

2. Proposed Technical Specification (TS) Changes (Marked Up Pages)

3. Proposed Technical Specification (TS) Bases Changes (Marked Up Pages) cc: S. J. Collins, NRC R. V. Guzman, NRC Resident Inspector, NRC J. P. Spath, NYSERDA

t ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Nine Mile Point Nuclear Station, LLC September 8, 2008

ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION This attachment provides the Nine Mile Point Nuclear Station, LLC (NMPNS) response to the request for additional information (RAI) documented in the NRC letter dated July 11, 2008. NRC Request, Limiting condition for operation (LCO) 3.7.3 requires each control room envelope AC subsystem to be operable or have operability. LCO 3.7.3, Condition A (two control room envelope AC subsytems inoperable with safety function maintained) specifies a plant condition for the LCO not met because both required systems are inoperable, yet functional. The concept of "safety function maintained" as separate and distinct from the concept of "operability" is not defined in the operating license TS. The NMP2 Bases describe the requirements implied by Condition A; however, Title 10 of the Code of Federal Regulations (10 CFR) section 50.36, states, in part, 'the bases .or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications." Therefore, TS requirements cannot be established by bases statements. The discovery of a degraded or nonconforming condition may call into question the operability of one or more LCO 3.7.3 control room envelope AC subsystem components. A subsequent determination of operability should be based on the 'licensee's "reasonable expectation" from the evidence collected, that the control room envelope AC subsystem are operable and that the operability determination will support that expectation. It should be noted that the standard of "reasonable expectation" is a high standard, and that there is no such thing as an indeterminate state of operability; structures, systems, and components are either operable or inoperable. Thus, a TS-required system cannot be both inoperable and maintain safety function. Please clarify TS 3.7.3, Condition A and B statements, regarding the indeterminate "functional" state of equipment that is required to be operable. NMPNS Response On July, 30, 2007, NMPNS submitted a license amendment request to adopt Technical Specification Task Force (TSTF) Traveler 477-A which would add an action statement for two inoperable control envelope room air conditioning (AC) subsystems to the Nine Mile Point Unit 2 (NMP2) Technical Specifications (TS) using the consolidated line item improvement process (References 1 and 2). As part of the request, NMPNS proposed a modification of the wording in TSTF-477-A to specify that the action would apply to two inoperable control room envelope AC systems "with safety function not maintained." This added wording was intended to conform the proposed change to the current NMP2 TS 3.7.3 which includes, as part of Condition A, "two control room envelope AC subsystems inoperable with safety function maintained." The existing Condition A was not proposed to be modified by the amendment request. The concept of "with safety function maintained" was added to TS 3.7.3 as part of the conversion to improved TSs (ITS). This change from the standard technical specifications was specifically reviewed .and approved by the NRC as shown in the excerpt from the Safety Evaluation for NMP2 TS Amendment 91 (Reference 3) below:

    "ITS 3.7.3 ACTION A will allow a 30 day restoration time when both control room envelope AC subsystems are inoperable, provided the Control Room Envelope AC System safety function is 1 of4

ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION maintained. ... The NMP2 Control Room Envelope AC System design includes four air handling units. For the Control Room Envelope AC System to perform its design function, two air handling units are required. Two Control Room Envelope AC subsystems are provided with each system including two air handling units, both from the same electrical power division. Due to this design, when both subsystems are inoperable, the capability for the Control Room Envelope AC System to perform its design function may still exist. For example, if the Division 1 control room area and the Division 2 relay room air handling units are inoperable, sufficient components are operable for the Control Room Envelope AC System to meet its safety function (using the Division 2 control room area air handling unit and the Division 1 relay room air handling unit). Since this alignment is equivalent to having one control room envelope AC subsystem fully OPERABLE, the 30 day restoration time is acceptable, provided the Control Room Envelope AC System safety function is maintained. The 30 day restoration time is consistent to that allowed by NUREG-1434 and adopted in the ITS when one control room envelope AC subsystem is inoperable. In the current condition allowed by the CTS, the remaining OPERABLE subsystem will perform the Control Room Envelope AC System safety function, assuming no additional single failure. The proposed condition will still ensure the remaining OPERABLE components of the two subsystems can perform the Control Room Envelope AC System safety function, assuming no additional single failure. If the remaining components of the control room envelope AC subsystems cannot maintain the Control Room Envelope AC System safety function, then the'unit will be required to enter LCO 3.0.3 (if in MODE 1, 2, or 3), or the unit must suspend Core Alterations, handling irradiated fuel, and OPDRVs (if performing one of these evolutions), consistent with the current requirements. In addition, this concept is consistent with the ECCS Specification in NUREG-1430, NUREG-1431, and NUREG-1432, which allow multiple ECCS trains to be inoperable for the same length of time as is currently allowed for one train only, provided 100% of the flow equivalent to a single ECCS train is available." However, based upon the RAI and further discussions with the NRC staff, a revision to NMP2 TS 3.7.3 is proposed to remove the phrases "with safety function maintained" and "with safety function not maintained," while maintaining the same flexibility provided by the current TS (and the initially proposed adoption of TSTF-477-A). To accomplish this administrative change, similar Conditions are proposed separately for the two control room envelope areas (the Main Control Room area and the Relay Room area). Thus, proposed Condition A is for one Main Control Room area control room envelope AC subsystem inoperable, while Condition B is for one Relay Room area control room envelope AC subsystem inoperable. Similar paired conditions are proposed for two control room envelope AC subsystems inoperable in each area and for the required actions and completion times not being met during movement of recently irradiated fuel assemblies or OPDRVs (operations with the potential to drain the reactor vessel). Attachment 2 provides a mark up of the current TS 3.7.3 showing both the TST-477-A changes and the proposed administrative realignment in response to the RAI. Attachment 3 provides a similar mark up for the TS 3.7.3 Bases. The TS Bases changes are provided for information only and will be processed in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program." Because these administrative changes were not initially included with the license amendment request to adopt TSTF-477-A, a supplemental significant hazards determination for the administrative changes has been developed, below. 2 of 4

ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Supplemental Significant Hazards Consideration Nine Mile Point Nuclear Station, LLC (NMPNS) is requesting a revision to Nine Mile Point Unit 2 (NMP2) Technical Specification (TS) Section 3.7.3. This administrative revision would reword the existing TS to eliminate the phrases "with safety function maintained" and "with safety function not maintained" from the Conditions and Actions applicable when the Control Room Envelope Air Conditioning (AC) System is inoperable without changing' the current flexibility included in the TS Actions. A similar rewording is also made to the changes to TS 3.7.3 initially proposed for the adoption of Technical Specification Task Force (TSTF) Traveler 477-A. The proposed supplemental changes do not affect the overall Actions or Completion Times included in the TS (as modified by TSTF-477-A). NMPNS has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

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

Response: No. The proposed changes administratively revise the wording of TS 3.7.3, "Control Room Air Conditioning (AC) System," and do not change Actions or associated Completion Times currently included in the TS (as modified by TSTF-477-A). They do not impact any accident initiators, the ability to mitigate previously evaluated accidents, or the assumptions used in evaluating the radiological consequences of previously evaluated accidents. The proposed changes do not involve the addition or removal of any equipment, or any design changes to the facility. 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?

Response: No. The proposed changes administratively revise the wording of TS 3.7.3, "Control Room Air Conditioning (AC) System," and do not change Actions or associated Completion Times currently included in the TS (as modified by TSTF-477-A). They do not involve a modification to the physical configuration of the plant (i.e., no new equipment will be installed) or involve a change in the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or introduce a new accident initiator, accident precursor, or failure mechanism. 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 a margin of safety?

Response: No. 3 of 4

ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION The proposed TS changes are administrative in nature. They do not involve a modification to the physical configuration of the plant (i.e., no new equipment will be installed) or change the methods governing normal plant operation. The proposed changes do not modify the safety limits or setpoints at which protective actions are initiated, and do not change the requirements governing operation or availability of safety equipment assumed to operate to preserve margins of safety. Therefore, the proposed changes do not involve a significant reduction in a margin of safety. Based on the above, NMPNS concludes that the proposed amendment does not involve a 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. REFERENCES

1. Letter from K. J. Poison (NMPNS) to Document Control Desk (NRC), dated July 30, 2007, Application for Technical Specification Change TSTF-477, Revision 3, "Add Action for Two Inoperable Control Room AC Subsystems" to the Technical Specifications Using Consolidated Line Item Improvement Process

2. Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-477-A, "Add Action for Two Inoperable Control Room AC Subsystems," Revision 3

3. Letter from G. S. Vissing (NRC) to J. H. Mueller (NMPC), dated February 15, 2000, Conversion to Improved Technical Specifications for the Nine Mile Point Nuclear Station Unit No. 2 - Amendment No. 91 to Facility Operating License No. NPF-69 (TAC No. MA3822) 4 of 4

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGES (MARKED UP PAGES) TS Pages 3.7.3-1 3.7.3-2 3.7.3-3 Nine Mile Point Nuclear Station, LLC September 8, 2008

Control Room Envelope AC System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Envelope Air Conditioning (AC) System / LCO 3.7.3 Two control room envelope AC subsystemsThall be OPERABLE-C4. 1%o;n Co,,.- -ol P-oo- are_- <L APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs). ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control room A. 1 Restore control room 30 days envelope AC subsystem, envelope AC inoperable. subsyste to OPERABLE status., env ope AC ubsyste ;o 4t'e- P1 r in erable ith safety r ,,, ot(e. f nction intained. 1*8. Required Action and Be in MODE 3. 12 hours Associated Completion Time of Condition A, ] AND not met in MODE 1 2 or 3. Be in MODE 4. 36 hours (continued) 6)c220T' -. 1 NMP2 3.7.3-1 Amendment 9-1-2&

INSERT 1 B. One control room B.1 Restore control room 30 days envelope AC subsystem envelope AC for the Relay Room subsystem for the area inoperable. Relay Room area to OPERABLE status. C. Two control room C.1 Verify control room Once per 4 hours envelope AC subsystems envelope Main Control for the Main Control Room area temperature Room area inoperable. <900 F. AND C.2 Restore one control 72 hours room envelope AC subsystem for the Main Control Room area to OPERABLE status. D. Two control room D.1 Verify control room Once per 4 hours envelope AC subsystems envelope Relay Room for the Relay Room area temperature area inoperable. < 90 0 F. AND D.2 Restore one control 72 hours room envelope AC subsystem for the Relay Room area to OPERABLE status.

Control Room Envelope AC System 3.7.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME Required Action and NOTE ---------- associated Completion LCO 3.0.3 is not applicable. Time of Condition A not met during movement of recently Place OPERABLE Immediately irradiated fuel assemblies A control in the secondary room envelope AC containment or during subsystem~ s)_____ OPDRVs. Jeq v to ae js' e ntrol/oom I mmed 4 Vate ly,'e enve p e A/ subs tem in operation-OR 4.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment. AND 2 Initiate action to Immediately suspend OPDRVs. mal 2 r (continued) NMP2 3.7.3-2 Amendment 94-425-,

INSERT 2 G. Required Action and NOTE ---------- -------- associated Completion LCO 3.0.3 is not applicable. Time of Condition B not met during movement of recently G.1 Place OPERABLE Immediately irradiated fuel assemblies control room envelope in the secondary AC subsystem for containment or during the Relay Room OPDRVs. area in operation. OR G.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment. AND G.2.2 Initiate action to Immediately suspend OPDRVs.

Control Room Envelope AC System 3.7.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME

                                                                           -NOTE LCO 3.0.3 is not applicable.

Z,.* T con ol roo H fX. Suspend movement of Immediately movement of recently recently irradiated fuel irradiated fuel assemblies assemblies in the in the secondary secondary containment or during containment. OPDRVs. 4 AND 44

                                                                                                    /

rej"-,r Ac0 4; Initiate action to Immediately o~'f VI4t5oo -c4<- suspend OPDRVs. C6 _,F o..a on

&f,,:÷.+ ," C o,.-.D r~o SURVEILLANCE REQUIREMENTS SURVEILLANCE                                         FREQUENCY SR 3.7.3.1         Verify each control room envelope AC                           24 months subsystem has the capability to remove the assumed heat load,,6r- the-vMor) '>,,4rol Fo-0w 0,-MIC.

NMP2 3.7.3-3 Amendment -I

ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION (TS) BASES CHANGES (MARKED UP PAGES) Bases Pages B 3.7.3-1 B 3.7.3-2 B 3.7.3-3 B 3.7.3-4 B 3.7.3-5 B 3.7.3-6 Nine Mile Point Nuclear Station, LLC September 8, 2008

                                    -~              Control Room Envelope AC System B 3.7.3 B 3.7   PLANT SYSTEMS B 3.7.3   Control Room Envelope Air Conditioning (AC)      System BASES BACKGROUND         The control room envelope AC portion of the Control Building Heating, Ventilation, and Air Conditioning (HVAC) System (hereafter referred to as the Control Room Envelope AC System) provides temperature control for the control room envelope following isolation of the control room envelope.

The Control Room Envelope AC System consists of two independent, redundant subsystems that provide cooling of recirculated and outside air makeup control room envelope air. Each subsystem consists of two air conditioning units (one for th4&hftrol roonafrnd one for the relay roorif-U'r "ce-control building chilled water subsystem (which provides cooling water to the cooling coils of the two air conditioning units), ductwork, dampers, and instrumentation and controls to provide for control room envelope temperature control. Each air conditioning unit includes an air filter assembly, cooling coil, and fan. Each control building chilled water subsystem includes a hermetic centrifugal water chiller, chilled water pump, expansion tank, controls, piping, and valves. The Control Room Envelope AC System is designed to provide a controlled environment under both normal and accident conditions. A single subsystem provides the required temperature control to maintain a suitable control room envelope environment for a sustained occupancy of 37 persons. The design conditions for the control room envelope environment are 75°F and 50% relative humidity. The Control Room Envelope AC System operation in maintaining the control room envelope temperature is discussed in the USAR, Sections 6.4 and 9.4.1 (Refs. I and 2, respectively). APPLICABLE The design basis of the Control Room Envelope AC System is SAFETY ANALYSES to maintain the control room envelope temperature for a 30 day continuous occupancy following isolation of the control room envelope. The Control Room Envelope AC System components are arranged in redundant safety related subsystems. During emergency operation, the Control Room Envelope AC System maintains a habitable environment and ensures the OPERABILITY of (continued) NMP2 B 3.7.3-1 I

                                                           'Control Room Envelope AC System B 3.7.3 BASES APPLICABLE           components in the control room envelope., A single active SAFETY ANALYSES     failure of a component of the Control Room Envelope AC (continued)       System, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

Redundant detectors and controls are provided for control room envelope temperature control. The Control Room Envelope AC System is designed in accordance with Seismic Category I requirements. The Control Room Envelope AC System is capable of removing sensible and latent heat loads from the control room envelope, including consideration of equipment heat loads and personnel occupancy requirements to ensure equipment OPERABILITY. The Control Room Envelope AC System satisfies Criterion 3 of Reference 3. LCO Two independent and redundant subsystems of the Control Room Envelope AC System are required to be OPERABLEto ensure that at least one is available, assuming a single failuree-r -P'4 disables the other subsystem. Total system failure could /%a:, . result in the equipment operating temperature exceeding , limits. a. 9,,,, *1

                                                                                                      -/ 61 r,   , ",4

• g The Control Room Envelope AC System is considered OPERABLE when the individual components necessary to maintain the 4-ý5control room envelope temperat'ur eare OPERABLE in both C : a~k Co'-rAt' subsystems These components include th91 C8'hntrol roomand relay roorr air conditioning units (cooling coils and fans only), the control building chilled water subsystems, ductwork, dampers, and associated instrumentation and fr~ ~m controls. In addition, during conditions in MODES other than MODES 1, 2, and 3 when the Control Room Envelope AC System is required to be OPERABLE (e.g., during operations with a potential for draining the reactor vessel (OPDRVs)), the necessary portions of the SW System and Ultimate Heat Sink capable of providing cooling to the hermetic centrifugal water chillers are part of the OPERABILITY requirements covered by this LCO.

APPLICABILITY In MODE 1, 2, or 3, the Control Room Envelope AC System must be OPERABLE to ensure that the control room envelope temperature will not exceed equipment OPERABILITY limits following control room envelope isolation. In MODES 4 and 5, the probability and consequences of a Design Basis Accident are reduced due to the pressure and (continued) NMP2 B 3.7.3-2 Revision A1-2

Control Room Envelope AC System B 3.7.3 BASES APPLICABILITY temperature limitations in these MODES. Therefore, maintaining (continued) the Control Room Envelope AC System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:

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

b. During movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the Control Room Envelope AC System is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours).

ACTIONS A._1 M0k.'y1C0r4fc,1 rluoý" cArcc% one control room enveli futiorn i maint ' ed we 'rthe Contr/YRoom F__1velope Aq/ " ysem ompor nts equi alenU~o orW control=:;Q 08~4 -:~.' uti u~ ngefunction. stem~n the perform es n room ofJ control 6 e cition s al

• p *air'con ubs*te envelope However, the overall reliability is reduced because a single loss of the control room envelope air con'itioning function.

The 30 day Completion Time is based on the low probability of an event occurring requiring control roomenvelope isubyte failre tha te remaining subsystem atin corn*ai*

                                                                                -o     ents E T3can                   provide the required protection, and the availa bility of alterna e cooling methods.

6.1 andJ2 In MODE 1, 2, or 3, ifthe inoperable control room envelope AC subsystem cannot be restored to OPERABLE status within the associate Completion Time, the unit must be placed in a MODE that minimizes risk. To achieve this status the unit (continued) NMP2 B 3.7.3-3 Revision ,-26 -(A!4-2*,

INSERT BI B. 1 With one control room envelope AC subsystem inoperable for the Relay Room area, the inoperable control room envelope AC subsystem for the Relay Room area must be restored to OPERABLE status within 30 days. With the unit in this condition, the remaining OPERABLE. control room envelope AC subsystem for the Relay Room area is adequate to perform the control room envelope air conditioning function for the Relay Room area. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of the control room envelope air conditioning function in the Relay Room area. The 30 day Completion Time is based on the low probability of an event occurring requiring control room envelope isolation, the consideration that the remaining subsystem can provide the required protection, and the availability of alternate cooling methods. C.1 and C.2 If both control room envelope AC subsystems for the Main Control Room area are inoperable, the Control Room Envelope AC System may not be capable of performing its intended function. Therefore, the control room envelope Main Control Room area temperature is required to be monitored to ensure that temperature is being maintained low enough that equipment in the Main Control Room area of the control room envelope is not adversely affected. With the Main Control Room area temperature of the control room envelope being maintained within the temperature limit of <901F (Reference 2), 72 hours is allowed to restore a Main Control Room area control room envelope subsystem to OPERABLE status. This Completion Time is reasonable considering that the Main Control Room area control room envelope temperature is being maintained within limits and the low probability of an event occurring requiring control room envelope isolation.

INSERT BI (cont) D.1 and D.2 If both control room envelope AC subsystems for the Relay Room area are inoperable, the Control Room Envelope AC System may not be capable of performing its intended function. Therefore, the control room envelope Relay Room area temperature is required to be monitored to ensure that temperature is being maintained low enough that equipment in the Relay Room area of the control room envelope is not adversely affected. With the Relay Room area temperature of the control room envelope being maintained within the temperature limit of <900 F (Reference 2), 72 hours is allowed to restore a Relay Room area control room envelope subsystem to OPERABLE status. This Completion Time is reasonable considering that the Relay Room area control room envelope temperature is being maintained within limits and the low probability of an event occurring requiring control room envelope isolation.

Control Room Envelope AC System B 3.7.3 BASES ACTIONS X.1 and,'.2 (continued) must be placed in at least MODE 3 within 12 hours and in MODE 4 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.

                   ,1*1, '.21   nd,9.2.2 The Required Actions of Condition, are modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODES 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODES 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if Required Action A. 1 cannot be com leted within the required Completion Time, the OPERABLE~xrn-nmpod tsOontrol room envelope AC su sstem ) quival t o singe-con ol room egelopeAe'l u s em .g., the ontro building c illed water ubsystyn /* ('FI C*,",/ la*a air co;ditionin units o o be tored fro th me el rical d* ision) ay be placed immediately in oon. Co ) ~ os'co', J3isoth

              /'in    ac S/~syst3.i4£ln ion ensures tat the remaining 1;,rlnlsubsyste (or      ompon envjeJ*.a,,/ *ts Z;mtol.o suys'te,)is OPERABLE, that no failures that would prevent actua ion wI occur, and that any active failure will be readily detected.

An alternative to Required Action.l is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room envelope. This places the unit in a condition that minimizes risk. (continued) NMP2 B 3 7.3-4 Revisinn 0 ,f- !A-{,'

Control Room Envelope AC System B 3.7.3 BASES ACTIONS .1 .1, andS'.2.2 (continued) If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended. If hcontrol roo envelope A subsystem ae inoperab/ the Control)Room Envelo 'e AC Syste h~t safety functijy not The Required Actions of Condition...are modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODES 4 or 5, LCO 3.0.3

  *"4"
     , -*. "      would not
             "--LE,'vegp*(C    specify ystem  o any   ,,aaction.

cla If moving afe/funerfion t nthrecently irradiated fuel lintainedato assemblies while in MODES 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. During movement of recently irradiated fuel assemblies in the Sroh envelo e subs stems in alel th the ntrol Ioomt must be taken o imme iaLey suspend activities that present a potential for releasing radioactivity that might require isolation of the control om e nvelop h ace the unit in a condition that minimizes risk. (continuedl NMP2 B 3.7.3-5 Revision .Q-26 'A-12 i INSERT B2 G.1, G.2.1, and G.2.2 The Required Actions of Condition G are modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODES 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODES 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblips would not be a sufficient reason to require a reactor shutdown. During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if Required Action B.1 cannot be completed within the required Completion Time, the OPERABLE control room envelope AC subsystem for the Relay Room area may be placed immediately in operation. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent actuation will occur, and that any active failure will be readily detected. An alternative to Required Action G.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room envelope. This places the unit in a condition that minimizes risk. If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended. INSERT B3 if Required Actions of Condition C or Condition D cannot be met within the required Completion Times,

Control Room Envelope AC System B 3.7.3 BASES ACTIONS ,l andjP.2 (continued) If applicable, handling of recent!y irradiated fuel in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended. SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control r+4m Pnvln.-.. f'4cYr heat load assumed in the safety analyses( The SR consists C,,,,-,o I ,., of a combination of testing and calculation. The 24 month , - Frequency is appropriate since significant degradation of r the Control Room Envelope AC System is not expected over this time period. * (er REFERENCES 1. USAR, Section 6.4.

2. USAR, Section 9.4.1.

3. 10 CFR 50.36(c)(2)(ii).

NMP2 B 3.7.3-6 Revision (A2-}}