ML071500145

Proposed License Amendment Request, Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

ML071500145
Person / Time
Site:	North Anna
Issue date:	05/29/2007
From:	Gerald Bichof Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, NRC/NRR/ADRO
References
07-0361, TSTF-448, Rev 3
Download: ML071500145 (60)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 29,2007 U.S. Nuclear Regulatory Commission Serial No. 07-0361 Attention: Document Control Desk NL&OS/ETS RO Washington, D.C. 20555 Docket Nos. 50-3381339 License Nos. NPF-417 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2 IMPROVEMENT PROCESS Pursuant to 10 CFR 50.90, Dominion requests amendments, in the form of changes to the Technical Specifications to Facility Operating License Numbers NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3.

The availability of this TS improvement was announced in the Federal Register on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process (CLIIP). Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. The marked-up and proposed Technical Specifications pages are provided in Attachments 2 and 3, respectively. The associated marked-up Bases changes are provided in Attachment 4 for information only and will be implemented in accordance with the Technical Specification Bases Control Program and 10 CFR 50.59.

The proposed changes have been reviewed and approved by the Station Nuclear Safety and Operating Committee.

Dominion requests approval of the license amendments by October 31, 2007 with a 180-day implementation period to complete the development of a common Control Room Habitability Program for the Dominion nuclear plants.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the appropriate designated officials of Virginia.

Serial No. 07-0361 Docket Nos. 50-3381339 CRH TS Amendment Page 2 of 4 If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.

Very truly yours, Gerald T. Bischof u Vice President - Nuclear Engineering Attachments

1. Discussion of Change

2. Marked-up Technical Specifications Changes

3. Proposed Technical Specifications Pages

4. Marked-up Technical Specifications Bases Changes Commitments made in this letter: None

Serial No. 07-0361 Docket Nos. 50-3381339 CRH TS Amendment Page 3 of 4 cc: U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative lnnsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, Virginia 23060 Commissioner Bureau of Radiological Health 1500 East Main Street Suite 240 Richmond, Virginia 23218 Mr. J. T. Reece NRC Senior Resident Inspector North Anna Power Station Mr. S. P. Lingam NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852

Serial No. 07-0361 Docket Nos. 50-3381339 CRH TS Amendment Page 4 of 4 COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this J q F d a y of _A& , 2007.

My Commission Expires:

Notary Public (SEAL)

Attachment 1 (Serial No. 07-0360)

Discussion of Change North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Description and Assessment I.O DESCRIPTION The proposed amendment modifies the North Anna Power Station Units 1 and 2 Technical Specifications (TS) requirements related to control room envelope habitability.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved lndustrylTechnical Specification Task Force (TSTF) STS change TSTF-448, Revision 3.

The availability of this TS improvement was published in the Federal Register on January 17, 2007 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Virginia Electric and Power Company (Dominion) has reviewed the safety evaluation dated January 17, 2007 as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-448.

Dominion has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to North Anna Units 1 and 2 and justify this amendment for the incorporation of the changes to the North Anna Units 1 and 2 TS.

2.2 Optional Changes and Variations The following sections of the Model SE are applicable to North Anna design and current TS requirements.

Section 3.0 - TS 3.7.[10] [CREEVS] Evaluations 1, 4, and 6 are applicable to North Anna In addition, the North Anna plant design currently includes a pressurized Main Control RoomIEmergency Switchgear Room (MCRIESGR) design, which uses the Bottled Air System and the Emergency Ventilation System (EVS) to pressurize the MCRIESGR envelope. The North Anna TSs address the operability requirements for the EVS and MCRIESGR envelope boundary in three different specifications. Therefore, to incorporate TSTF-448, Revision 3, the specifications listed below will be modified.

3.7.10, Main Control RoomIEmergency Switchgear Room (MCRIESGR)

Emergency Ventilation System (EVS) 0 3.7.13, Main Control RoomIEmergency Switchgear Room (MCRIESGR) Bottled Air System 3.7.14 Main Control RoomIEmergency Switchgear Room (MCRIESGR)

Emergency Ventilation System (EVS) - During Movement of Recently Irradiated Fuel Assemblies

The following exception to the Section C.l and C.2 of Regulatory guide 1.I97 is being taken:

C.2.1 Licensing Bases -Vulnerability assessments for radiological, hazardous chemical and smoke, and emergency ventilation system testing were completed as documented in the UFSAR. The exceptions to the Regulatory Guides (RG) referenced in RG 1.196 (i.e., RG 1.52, RG 1.78, and RG 1.183), which were considered in completing the vulnerability assessments, are documented in the UFSARIcurrent licensing basis. Compliance with these RGs is consistent with the current licensing basis as described in the UFSAR.

This general exception does not affect the periodic testing and evaluation of the MCRIESGR envelope boundary. Periodic testing and evaluation of the MCRIESGR envelope boundary will be performed consistent with the regulatory positions described in Sections C.l and C.2 of RG 1.197. This exception identifies how the North Anna control room habitability licensing basis was developed, which is consistent with the intent of RG 1.196 and the regulatory guides referenced therein, but is not in verbatim compliance with the regulatory positions established in each RG. North Anna's commitment to the following regulatory guides is described in the following UFSAR Sections:

RG 1.52, Rev. 2, I978 - UFSAR 6.2.3 RG 1.78, Rev.0, 1974-UFSAR6.4.1.3.3 0 RG 1.95, Rev. 1, 1977 - UFSAR 6.4. I .3.3 RG 1.183, July 2000 - UFSAR 15.4 2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements Dominion proposes the following as a license condition to support implementation of the proposed TS changes:

Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of Main Control RoomIEmergency Switchgear Room (MCRIESGR) envelope unfiltered air inleakage as required by TS SR 3.7.10.4 in accordance with TS 5.5.16.c(i), the assessment of MCRIESGR envelope habitability as required by TS 5.5.16.c(ii), and the measurement of MCRIESGR envelope pressure as required by TS 5.5.16.d, shall be considered met. Following implementation:

(a) The first performance of SR 3.7.10.4 in accordance with Specification 5.5.16.c(i),

shall be within the specified frequency of 6 years plus the 18-month allowance of SR 3.0.2, as measured from September 21, 2003, the date of the most recent successful tracer gas test, as stated in the March 30, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of MCRIESGR envelope habitability, Specification 5.5.16.c(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from September 21, 2003, the date of the most recent successful tracer gas test, as stated in the March 31, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of MCRIESGR envelope pressure, Specification 5.5.16.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from February 27, 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Dominion has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

Dominion has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to North Anna Power Station Units I and 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

4.0 ENVIRONMENTAL EVALUATION Dominion has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007 as part of the CLIIP. Dominion has concluded that the staff's findings presented in that evaluation are applicable to North Anna Power Station Units 1 and 2 and the evaluation is hereby incorporated by reference for this application.

Attachment 2 (Serial No. 07-0360)

Marked-up Technical Specifications Changes North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance subject to the modified acceptance criteria is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

This license condition is effective as of its date of issuance.

f. U ~ o im~lementation n of Amendment No. XXX ado~tinaTSTF-448, Revision 3, the determination of Main Control RoomIEmeraencv Switchaear Room (MCRIESGR) envelo~eunfiltered air inleakaae as reauired bv TS SR 3.7.1 0.4 in accordance with TS 5.5.16.c(i), the assessment of MCRIESGR envelo~ehabitabilitv as reauired by S~ecification5.5.16.cW. and the measurement of MCRIESGR envelo~eDressure as reauired bv S~ecification5.5.1 6.d, shall be considered met. Followina im~lementation:

fi The first ~erformanceof SR 3.7.1 0.4 in accordance with Specification 5.5.1 6.c(i), shall be within the s~ecifiedfreauencv of 6 vears ~ l u the s 18-month allowance of SR 3.0.2. as measured from Se~tember21, 2003. the date of the most recent successful tracer aas test, as stated in the March 30, 2004 letter resDonse to Generic Letter 2003-01, or within the next 18 months if the time ~ e r i o dsince the most recent successful tracer aas test is areater than 6 vears.

(ii) The first ~erformanceof the ~eriodicassessment of MCRIESGR envelo~ehabitabilitv. S~ecification5.5.1 G.c(ii),

shall be within 3 vears. ~ l u the s 9-month allowance of SR 3.0.2, as measured from Se~tember21. 2003, the date of the most recent successful tracer aas test, as stated in the March 31, 2004 letter resDonse to Generic Letter 2003-01. or within the next 9 months if the time ~ e r i o dsince the most recent successful tracer aas test is areater than 3 vears.

Jiii) The first ~erformanceof the ~eriodicmeasurement of MCRIESGR envelo~eDressure, Soecification 5.5.1 6.d shall be within 18 months, ~ l u the s 138 davs allowed bv SR 3.0.2, as measured from Februarv 27, 2007, the date of the most recent successful oressure measurement test, or within 138 davs if not ~erformed~reviouslv.

NORTH ANNA - UNIT 1 Renewed License No. NPF-4

interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

This license condition is effective as of its date of issuance.

e. VEPCO may operate one lead test assembly containing advanced zirconium-based alloys for one cycle, to a lead rod burnup not exceeding 75,000 MWDIMTU, as described in the licensee's submittal dated February 11, 2002.

f. Uoon im~lementationof Amendment No. XXX ado~tinaTSTF-448, Revision 3, the determination of Main Control Room/Emeraencv Switchaear Room (MCRIESGR) envelo~eunfiltered air inleakaae as reauired bv TS SR 3.7.1 0.4 in accordance with TS 5.5.1 6.c(i), the assessment of MCRIESGR envelo~ehabitabilitv as reauired by S~ecification5.5.1 6.dii). and the measurement of MCRIESGR envelo~eDressure as reauired bv S~ecification5.5.1 6.d. shall be considered met. Followina im~lementation:

Ji) The first ~erformanceof SR 3.7.1 0.4 in accordance with S~ecification5.5.1 6.c(i), shall be within the s~ecifiedfreauencv of 6 vears ~ l u the s 18-month allowance of SR 3.0.2, as measured from Se~tember21 , 2003, the date of the most recent successful tracer aas test, as stated in the March 30, 2004 letter resDonse to Generic Letter 2003-01, or within the next 18 months if the time ~ e r i o dsince the most recent successful tracer aas test is areater than 6 vears.

lii) The first ~erformanceof the ~eriodicassessment of MCRIESGR envelo~ehabitabilitv, S~ecification5.5.1 G.c(ii),

shall be within 3 vears. ~ l u the s 9-month allowance of SR 3.0.2. as measured from Se~tember21. 2003. the date of the most recent successful tracer aas test, as stated in the March 31, 2004 letter resoonse to Generic Letter 2003-01. or within the next 9 months if the time Deriod since the most recent successful tracer aas test is areater than 3 vears.

liii) The first ~erformanceof the Deriodic measurement of MCRIESGR envelo~eDressure, S~ecification5.5.1 6.d shall be s 138 davs allowed bv SR 3.0.2. as within 18 months. ~ l u the measured from Februarv 27, 2007, the date of the most recent successful Dressure measurement test, or within 138 davs if not ~erformed~reviouslv.

NORTH ANNA - UNIT 2 Renewed License No. NPF-7

MCRIESGR EVS MODE 1 , 2 , 3 , and 4 3.7.10 3.7 PLANT SYSTEMS 3.7.1 0 Main Control RoomIEmergency Switchgear Room (MCRIESGR) Emergency Ventilation System (EVS) - Modes 1,2,3, and 4 L C 0 3.7.10 Two MCRIESGR EVS trains shall b e OPERABLE.

---

NOTE............................................

The MCRIESGR e n v e l o ~ eboundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required MCRIESGR A. 1 Restore MCWESGR EVS train 7 days EVS train inoperable& to OPERABLE status.

reasons other than Condition B.

6. %One or more reauired 6.1 Initiate action to imolernent lrnrnediatelv MCFUESGR EVS trains mitiaatina actions.

inoperable due to inoperable MCWESGR -

AND envelooe boundary.

B.2 Verifv mitiaatina actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure MCRIESGR envelo~e occueant exmsures to radioloaical. chemical. and smoke hazards will not exceed limits.

AND 6.43 Restore MCRIESGR envelooe boundary to OPERABLE status.

C. Required Action and C.l Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or I3 -

AND not met.

C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Two required MCRIESGR D.l Enter LC0 3.0.3. Immediately EVS trains inoperable for reasons other than Condition B.

North Anna Units 1 and 2 3.7.10-1 Amendments WXWl I

MCRIESGR EVS -Modes 1,2,3, and 4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1 0.1 Operate each required MCRIESGR EVS train for 31 days r 10 continuous hours with the heaters operating.

SR 3.7.10.2 Perform required MCRIESGR EVS filter testing in In accordance accordance with the Ventilation Filter Testing with the VFTP Program (VFTP).

SR 3.7.10.3 Not Used SR 3.7.10.4 Perform required MCRIESGR Envelo~eunfiltered In accordance air inleakaae testina in accordance with the with the MCRIESGR Envelo~eHabitabilitv Proaram. MCRIESGR Envelo~e Habitabilitv Proaram swa&RB TlEsxMX North Anna Units 1 and 2 Amendments &W224 I

MCRIESGR Bottled Air System 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Main Control RoomlEmergency Switchgear Room (MCRIESGR) Bottled Air System L C 0 3.7.13 Three MCRIESGR bottled air system trains shall be OPERABLE.

............................................. NOTE............................................

The MCRIESGR envelope boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of recently irradiated fuel assemblies.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required MCRIESGR A. 1 Restore MCRIESGR bottled 7 days bottled air system train air system train to OPERABLE inoperable for reasons status.

other than Condition B.

B. Twe One or more required B. 1 Initiate action to implement Immediately MCRIESGR bottled air mitiqatina actions.

system trains inoperable due to inoperable MCRIESGR envelope boundary in Mode 1,2, 3 B.2 Verifv mitiaatina actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 4. ensure MCRIESGR envelope occupant exposures to radioloqical, chemical, and smoke hazards will not exceed limits.

B.Q Restore MCRIESGR envelo~e boundary to OPERABLE status.

C Two or more required C. 1 Initiate action to implement Immediately MCRIESGR bottled air mitiqatina actions.

system trains inoperable in Mode I,2, 3 or4 for reasons other than Condition B. C.24 Restore at least two 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> MCRIESGR bottled air system trains to OPERABLE status.

North Anna Units 1 and 2 3.7.13-1 Amendments 3""'331

MCRIESGR Bottled Air System CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.l Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, or -

AND C not met in MODE 1, 2, 3, or 4. D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> E. Required Action and E.l Suspend movement of Immediately associated Completion recently irradiated fuel Time of Condition A, not assemblies.

met during movement of recently irradiated fuel assemblies.

Two or more required MCWESGR bottled air system trains inoperable during movement of recently irradiated fuel assemblies.

One or more reauired bottled air svstem trains ino~erabledue to an ino~erableMCWESGR envelo~eboundarv durinq movement of recentlv irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1 3.1 Verify each required MCRIESGR bottled air bank is 31 days pressurized to 2 2300 psig.

SR 3.7.1 3.2 Verify each required MCRIESGR bottled air bank 31 days manual valve not locked, sealed, or otherwise secured and required to be open during accident conditions is open.

SR 3.7.1 3.3 Verify each required MCRIESGR bottled air system 18 months train actuates on an actual or simulated actuation signal.

North Anna Units 1 and 2 3.7.1 3-2 Amendments &l&W+

MCRIESGR Bottled Air System 3.7.13 SURVEILLANCE REQUIREMENTS I I 1 SR 3.7.13.4 Verify two required MCRIESGR bottled air system 18 months on a trains can maintain a positive pressure of 2 0.05 STAGGERED inches water gauge, relative to the adjacent areas TEST BASIS for at least 60 minutes North Anna Units 1 and 2 Amendments 24QE3 1

MCRIESGR EVS During Movement of Recently lrradiated Fuel Assemblies 3.7.14 3.7 PLANT SYSTEMS 3.7.14 Main Control RoomIEmergency Switchgear Room (MCRIESGR) Emergency Ventilation System (EVS) - During Movement of Recently lrradiated fuel Assemblies L C 0 3.7.14 Two MCRIESGR EVS trains shall be OPERABLE.

............................................. NOTE............................................

The MCRIESGR envelope boundary may be opened intermittently under administrative control.

APPLICABILITY: During movement of recently irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required MCRIESGR A. 1 Restore MCRIESGR EVS train 7 days EVS train inoperablefor to OPERABLE status.

reasons other than inoperable MCRIESGR envelo~eboundary.

B. Required Action and B. 1 Suspend movement of Immediately associated Completion recently irradiated fuel Time of Condition A not assemblies.

met Two required MCRIESGR EVS trains inoperable.

One or more reauired MCRIESGR EVS trains inoperable due to inoperable MCRIESGR envelope boundary.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.14.1 Operate each required MCRIESGR EVS train for 210 31 days hours continuous hours with the heaters operating.

SR 3.7.14.2 Perform required MCRIESGR EVS filter testing in In accordance with the accordance with the Ventilation Filter Testing Program VFTP.

(VFTP).

North Anna Units 1 and 2 3.7.14-1 Amendments 234442 1

MCRIESGR EVS - During Movement of Recently Irradiated Fuel Assemblies 3.7.14

-- ~~--

SURVEILLANCE FREQUENCY 3.7.14.3 Perform reauired MCRIESGR envelooe In accordance with the unfiltered air inleakaae testina in accordance MCRIESGR Envelo~e with the MCRIESGR Envelooe Habitabilitv Habitabilitv Proaram Proaram.

\ICTD North Anna Units 1 and 2 Amendments 2WL42 I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Containment Leakage Rate Testing Program (continued)

d. Leakage Rate acceptance criteria are:

1. Prior to entering a MODE where containment OPERABILITY is required, the containment leakage rate acceptance criteria are:

~ 0 . 6 0Lafor the Type B and Type C tests on a Maximum Path Basis and 50.75 Lafor Type A tests.

During operation where containment OPERABILITY is required, the containment leakage rate acceptance criteria are:

< I .0 Lafor overall containment leakage rate and (0.60 Lafor the Type B and Type C tests on a Minimum Path Basis.

2. Overall air lock leakage rate testing acceptance criterion is (0.05 La when tested at SP,.

e. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

f. Nothing in these Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J.

5.5.16 Main Control RoomlEmergencv Switchgear Room (MCRIESGR) Envelope Habitabilitv Program A MCRIESGR Envelope Habitabilitv Program shall be established and implemented to ensure that MCWESGR envelope habitability is maintained such that, with an OPERABLE Emergencv Habitabilitv Svstem (i.e, MCRIESGR EVS and MCRIESGR Bottled Air Svstem), MCRIESGR envelope occupants can control the reactor safelv under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge.

The program shall ensure that adequate radiation protection is provided to permit access and occupancv of the MCRIESGR envelope under design basis accident conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent for the duration of the accident. The program shall include the following elements:

a. The definition of the MCWESGR envelope and the MCRIESGR envelope boundary.

b. Requirements for maintaining the MCRIESGR envelope boundarv in its desian condition includinq confiauration control and ~reventivemaintenance.

North Anna Units 1 and 2 5.5-1 5 Amendments XH-kl-2 I

Programs and Manuals 5.5 Program and Manuals 5.5.16 Main Control RoomlEmerqenc~Switchqear Room (MCRIESGR) Envelope Habitability Program (continued)

c. Requirements for (i) determining the unfiltered air inleakage past the MCRIESGR envelope into the MCRIESGR envelope in accordance with the testing methods and at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessinq MCRIESGR envelope habitabilitv at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197, Revision 0.

The following is an exce~tionto Section C.2 of Regulatorv Guide 1.197, Revision 0:

2.C.1 Licensing Bases - Vulnerability assessments for radiological, hazardous chemical and smoke, and emergency ventilation system testing were completed as documented in the UFSAR. The exceptions to the Regulatory Guides (RG) referenced in RG 1. I 96 (i.e.. RG 1.52, RG 1.78, and RG 1.183), which were considered in completing the vulnerability assessments, are documented in the UFSARIcurrent licensing basis. Compliance with these RGs is consistent with the current licensing basis as described in the UFSAR.

d. Measurement, at desiqnated locations, of the MCRIESGR envelope pressure relative to all external areas adiacent to the MCRIESGR envelope boundary during the pressurization mode of operation by one train of the MCRIESGR EVS, operating at the flow rate required by the VFTP, at a Frequencv of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the MCRIESGR envelope boundary.

e. The quantitative limits on unfiltered air inleakage into the MCRIESGR envelope. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakaqe limit for radiological challenges is the inleakage flow rate assumed in the licensinq basis analyses of desiqn basis accident consequences. Unfiltered air inleakaqe limits for hazardous chemicals must ensure that exposure of MCFUESGR envelope occupants to these hazards will be within the assum~tionsin the licensinq basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessinq MCRIESGR envelo~ehabitability, determining MCRIESGR envelope unfiltered inleakaqe, and measurinq MCRIESGR envelope pressure and assessing the MCFUESGR envelope boundary as required by paragraphs c and d, respectively.

North Anna Units 1 and 2 5.5-16 Amendments 234El2 1

Attachment 3 (Serial No. 07-0360)

Proposed Technical Specifications Changes North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance subject to the modified acceptance criteria is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

This license condition is effective as of its date of issuance.

f. Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of Main Control RoomIEmergency Switchgear Room (MCRIESGR) envelope unfiltered air inleakage as required by TS SR 3.7.10.4 in accordance with TS 5.5.16.c(i), the assessment of MCWESGR envelope habitability as required by Specification 5.5.16.c(ii), and the measurement of MCWESGR envelope pressure as required by Specification 5.5.16.d, shall be considered met.

Following implementation:

(i) The first performance of SR 3.7.10.4 in accordance with Specification 5.5.16.c(i), shall be within the specified frequency of 6 years plus the 18-month allowance of SR 3.0.2, as measured from September 21, 2003, the date of the most recent successful tracer gas test, as stated in the March 30, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(ii) The first performance of the periodic assessment of MCWESGR envelope habitability, Specification 5.5.1 6.c(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from September 21, 2003, the date of the most recent successful tracer gas test, as stated in the March 31, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(iii) The first performance of the periodic measurement of MCWESGR envelope pressure, Specification 5.5.16.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from February 27, 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

NORTH ANNA - UNIT 1 Renewed License No. NPF-4

(4) The licensee is authorized to receive from the Surry Power Station, Unit Nos. 1 and 2, possess, and store irradiated Surry Power Station fuel assemblies containing special nuclear material, enriched to not more than 4.1 percent by weight U-235, subject to the following conditions:

a. Surry Power Station fuel assemblies may not be placed in North Anna Power Station, Unit Nos. 1 and 2, reactors.

b. Irradiated fuel shipped to North Anna Power Station shall have been removed from the Surry Power Station reactors no less than 730 days prior to shipment.

c. No more than 500 Surry Power Station irradiated fuel assemblies shall be received for storage at the North Anna Power Station, Unit Nos. 1 and 2, spent fuel pool.

(5) Environmental Protection Plan The Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 197, is hereby incorporated in the renewed license.

The licensee shall operate the facility in accordance with the Environmental Protection Plan.

D. Fire Protection VEPCO shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility and as approved in the SER dated February 1979 subject to the following provision:

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

E. Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approvedphysical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Millstone, North Anna and Surry Power Stations' Security Plan, Training, and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program" with revisions submitted through May 15, 2006.

NORTH ANNA - UNIT 1 Renewed License No. NPF-4

F. Updated Final Safety Analysis Report (1) The licensee's Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d), as revised on July 25, October 1, November 4, and December 2, 2002, describes certain future inspection activities to be completed before the period of extended operation. The licensee shall complete these activities no later than April 1, 2018, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

(2) The Updated Final Safety Analysis Report supplement as revised on July 25, October 1, November 4, and December 2,2002, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

G. This renewed license is effective as of the date of issuance and shall expire at midnight on April 1, 2038.

FOR THE NUCLEAR REGULATORY COMMISSION Samuel J. Collins, Director Office of Nuclear Reactor Regulation Attachments:

1. Appendix A, Technical Specifications

2. Appendix B, Environmental Protection Plan Date of Issuance: March 20, 2003 NORTH ANNA - UNIT 1 Renewed License No. NPF-4

interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

This license condition is effective as of its date of issuance.

e. VEPCO may operate one lead test assembly containing advanced zirconium-based alloys for one cycle, to a lead rod burnup not exceeding 75,000 MWDIMTU, as described in the licensee's submittal dated February 11, 2002.

f. Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of Main Control RoomIEmergency Switchgear Room (MCRIESGR) envelope unfiltered air inleakage as required by TS SR 3.7.10.4 in accordance with TS 5.5.1 6.c(i), the assessment of MCWESGR envelope habitability as required by Specification 5.5.16.c(ii), and the measurement of MCWESGR envelope pressure as required by Specification 5.5.16.d, shall be considered met.

Following implementation:

The first performance of SR 3.7.1 0.4 in accordance with Specification 5.5.16.c(i), shall be within the specified frequency of 6 years plus the 18-month allowance of SR 3.0.2, as measured from September 21, 2003, the date of the most recent successful tracer gas test, as stated in the March 30, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

The first performance of the periodic assessment of MCWESGR envelope habitability, Specification 5.5.1 G.c(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from September 21, 2003, the date of the most recent successful tracer gas test, as stated in the March 31, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(iii) The first performance of the periodic measurement of MCWESGR envelope pressure, Specification 5.5.16.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from February 27, 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

NORTH ANNA - UNIT 2 Renewed License No. NPF-7

(4) The licensee is authorized to receive from the Surry Nuclear Power Station, Unit Nos. 1 and 2, possess, and store irradiated Surry Power Station fuel assemblies containing special nuclear material, enriched to not more than 4.1 percent by weight U-235, subject to the following conditions:

a. Surry Power Station fuel assemblies may not be placed in North Anna Power Station, Unit Nos. 1 and 2, reactors.

b. Irradiated fuel shipped to North Anna Power Station shall have been removed from the Surry Power Station reactors no less than 730 days prior to shipment.

c. No more than 500 Surry Power Station irradiated fuel assemblies shall be received for storage at the North Anna Power Station, Unit Nos. 1 and 2, spent fuel pool.

(5) Environmental Protection Plan The Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 178, is hereby incorporated in the renewed license.

The licensee shall operate the facility in accordance with the Environmental Protection Plan.

D. Fire Protection VEPCO shall implement and maintain in effect all provisions of the approved fire protection program as described in the licensee's Updated Final Safety Analysis Report for the facility and as approved in the SER dated February 1979 subject to the following provision:

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

E. Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approvedphysical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Millstone, North Anna and Surry Power Stations' Security Plan, Training, and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program" with revisions submitted through May 15, 2006.

NORTH ANNA - UNIT 2 Renewed License No. NPF-7

F. Updated Final Safety Analysis Report (1) The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on July 25, October 1, November 4, and December 2, 2002, describes certain future inspection activities to be completed before the period of extended operation. The licensee shall complete these activities no later than August 21, 2020, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

(2) The Updated Final Safety Analysis Report supplement as revised on July 25, October 1, November 4, and December 2,2002, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

G. This renewed license is effective as of the date of issuance and shall expire at midnight on August 21, 2040.

FOR THE NUCLEAR REGULATORY COMMISSION Samuel J. Collins, Director Office of Nuclear Reactor Regulation Attachments:

1. Appendix A, Technical Specifications

2. Appendix B, Environmental Protection Plan Date of Issuance: March 20, 2003 NORTH ANNA - UNIT 2 Renewed License No. NPF-7

MCR/ESGR EVS-MODES 1, 2, 3, and 4 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Mai n C o n t r o l Room/Emergency Swi tchgear Room (MCRIESGR) Emergency V e n t i l a t i o n System (EVS)-MODES 1, 2, 3, and 4 LC0 3.7.10 Two MCRIESGR EVS t r a i n s s h a l l be OPERABLE.

- - - - - - - --- - - NOTE- - - - - - - - - - - - -

The MCRIESGR envel ope boundary may be opened in t e r m i t t e n t l y under admi n i s t r a t i ve c o n t r o l . I APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One r e q u i r e d MCRIESGR A. 1 Restore MCRIESGR EVS 7 days EVS t r a i n i n o p e r a b l e t r a i n t o OPERABLE f o r reasons o t h e r than status.

C o n d i t i o n B.

6. One o r more r e q u i r e d 6.1 I n i t i a t e action t o Immedi ate1 y MCRIESGR EVS t r a i n s implement m i t i g a t i n g i n o p e r a b l e due t o actions .

inoperabl e MCR/ESGR envel ope boundary.

8.2 Verifymitigating a c t i o n s ensure MCR/ESGR envelope occupant exposures t o r a d i 01 o g i c a l ,

chemical , and smoke hazards w i l l n o t exceed l i m i t s .

B. 3 Restore MCRIESGR 90 days envelope boundary t o OPERABLE s t a t u s .

I N o r t h Anna U n i t s 1 and 2

MCR/ESGR EVS-MODES 1, 2, 3, and 4 3.7.10 ACT IONS CONDITION I REQUIRED ACT ION I COMPLETION TIME C. Required A c t i o n and C.l Be i n MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> a s s o c i a t e d Completion Time o f C o n d i t i o n A -

AND o r B n o t met.

C.2 Be i n MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Two r e q u i r e d MCR/ESGR D. 1 E n t e r LC0 3.0.3. Immediately EVS t r a i n s inoperabl e f o r reasons o t h e r than C o n d i t i o n B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each r e q u i r e d MCR/ESGR EVS t r a i n 3 1 days f o r 2 10 continuous hours w i t h t h e heaters operating .

SR 3.7.10.2 Perform r e q u i r e d MCR/ESGR EVS f i 1t e r I n accordance t e s t i n g i n accordance w i t h t h e V e n t i l a t i o n w i t h VFTP F i 1t e r T e s t i n g Program (VFTP) .

SR 3.7.10.3 Not Used SR 3.7.10.4 Perform r e q u i r e d MCRIESGR Envel ope I n accordance u n f i 1t e r e d a i r i n l e a k a g e t e s t i n g i n with the accordance w i t h t h e MCR/ESGR Envelope MCRIESGR Habi t a b i 1 it y Program. Envelope Habi t a b i 1 it y Program N o r t h Anna U n i t s 1 and 2 3.7.10-2

MCR/ESGR B o t t l e d A i r System 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Mai n C o n t r o l Room/Emergency Swi t c h g e a r Room (MCRIESGR) B o t t l ed A i r System LC0 3.7.13 Three MCRIESGR b o t t l e d a i r system t r a i n s s h a l l be OPERABLE.

The MCR/ESGR envelope boundary may be opened i n t e r m i t t e n t l y I under a d m i n i s t r a t i v e c o n t r o l .

APPLICABILITY: MODES 1, 2, 3, and 4, D u r i n g movement o f r e c e n t l y ir r a d i a t e d f u e l assembl ies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One r e q u i r e d MCR/ESGR A. 1 Restore MCRIESGR 7 days b o t t l e d a i r system b o t t l e d a i r system t r a i n inoperabl e f o r t r a i n t o OPERABLE reasons o t h e r than status.

C o n d i t i o n B.

B. One o r more r e q u i r e d B.l I n i t i a t e action t o Immedi a t e 1y MCR/ESGR b o t t l ed a i r implement m i t i g a t i n g system t r a i n s actions.

i n o p e r a b l e due t o i n o p e r a b l e MCR/ESGR envelope boundary i n MODE 1, 2, 3, o r 4. 3.2 Verifymitigating 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a c t i o n s ensure MCRIESGR envelope occupant exposures t o r a d i 01 o g i c a l ,

chemical , and smoke hazards w i 11 n o t exceed 1 i m i t s .

AND

- I

( c o n t i nued)

N o r t h Anna U n i t s 1 and 2

MCR/ESGR B o t t l ed A i r System 3.7.13 ACT IONS CONDITION REQUIRED ACTION COMPLETION TIME B . ( c o n t i nued) 8.3 Restore MCR/ESGR 90 days envelope boundary t o OPERABLE s t a t u s .

C. Two o r more r e q u i r e d C.l I n i t i a t e action t o Immedi a t e 1y MCR/ESGR b o t t l e d a i r implement m i t i g a t i n g system t r a i ns actions.

i n o p e r a b l e i n MODE 1, 2, 3, o r 4 f o r reasons o t h e r than I

C o n d i t i o n B. C.2 Restore a t l e a s t two 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> I MCR/ESGR b o t t l ed a i r system t r a i n s t o OPERABLE s t a t u s .

D. Required A c t i o n and D.l BeinMODE3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> a s s o c i a t e d Completion Time o f C o n d i t i o n A, B AND o r C n o t met i n MODE 1, 2, 3, o r 4. D.2 Be i n MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> N o r t h Anna U n i t s 1 and 2

MCRIESGR B o t t l e d A i r System 3.7.13 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Required A c t i o n and E.l Suspend movement o f Imrnedi ate1y associ a t e d Completion recently irradiated Time o f Condi t i on A f u e l assembl ies.

n o t met d u r i n g movement o f r e c e n t l y irradiated fuel assembl ies.

Two o r more r e q u i r e d MCR/ESGR b o t t 1ed a i r system t r a i n s inoperable during movement o f r e c e n t 1y irradiated fuel assembl ies.

I One o r more r e q u i r e d b o t t l e d a i r system t r a i n s inoperabl e due t o an i n o p e r a b l e MCR/ESGR envelope boundary d u r i ng movement o f r e c e n t 1y irradiated fuel assembl ies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 V e r i f y each r e q u i r e d MCRIESGR b o t t l e d a i r 3 1 days bank i s p r e s s u r i z e d t o 2 2300 p s i g .

SR 3.7.13.2 V e r i f y each r e q u i r e d MCR/ESGR b o t t l e d a i r 31 days bank manual v a l v e n o t locked, sealed, o r o t h e r w i s e secured and r e q u i r e d t o be open d u r i n g a c c i d e n t c o n d i t i o n s i s open.

N o r t h Anna U n i t s 1 and 2 3.7.13-3

MCRIESGR B o t t l ed A i r System 3.7.13 SURVE ILLANCE REQlJ I REMENTS SURVEILLANCE ( FREQUENCY SR 3.7.13.3 V e r i f y each r e q u i r e d MCR/ESGR b o t t l e d a i r 18 months system t r a i n actuates on an a c t u a l o r simul a t e d a c t u a t i o n s i g n a l .

SR 3.7 .13.4 V e r i f y two r e q u i r e d MCR/ESGR b o t t l e d a i r 18 months on a system t r a i n s can m a i n t a i n a p o s i t i v e STAGGERED TEST pressure o f 2 0.05 inches water gauge, BAS I S r e 1 a t i ve t o t h e a d j a c e n t areas f o r a t 1e a s t 60 minutes.

N o r t h Anna U n i t s 1 and 2

MCR/ESGR EVS-Duri ng Movement o f Recently I r r a d i a t e d Fuel Assembl ies 3.7.14 3.7 PLANT SYSTEMS 3.7.14 Mai n C o n t r o l Room/Emergency Swi tchgear Room (MCRIESGR) Emergency V e n t i 1a t i on System (EVS)-During Movement o f Recently I r r a d i a t e d Fuel Assembl ies LC0 3.7.14 Two MCR/ESGR EVS t r a i n s s h a l l be OPERABLE.

- - - - - - - - - - - - NOTE- - - - - - - - - - - - -

The MCRIESGR envelope boundary may be opened i n t e r m i t t e n t l y under a d m i n i s t r a t i v e c o n t r o l . I APPLICABILITY: D u r i n g movement o f r e c e n t l y i r r a d i a t e d f u e l assembl ies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One r e q u i r e d MCRIESGR A.l Restore MCRIESGR EVS 7 days EVS t r a i n inoperabl e t r a i n t o OPERABLE f o r reasons o t h e r than status.

i n o p e r a b l e MCR/ESGR envel ope boundary.

B. Required A c t i o n and B.l Suspend movement o f Immedi ate1 y a s s o c i a t e d Compl e t i on r e c e n t l y ir r a d i a t e d Time o f C o n d i t i o n A f u e l assembl ies.

n o t met.

Two r e q u i r e d MCRIESGR EVS t r a i ns inoperabl e.

I One o r more r e q u i r e d MCR/ESGR EVS t r a i n s i n o p e r a b l e due t o i n o p e r a b l e MCRIESGR envelope boundary.

N o r t h Anna U n i t s 1 and 2

MCRIESGR EVS-Duri ng Movement o f Recently I r r a d i a t e d Fuel Assembl ies 3.7.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE 1 FREQUENCY SR 3.7.14.1 Operate each r e q u i r e d MCRIESGR EVS t r a i n 31 days f o r 2 10 continuous hours w i t h t h e h e a t e r s operating .

SR 3.7.14.2 Perform r e q u i r e d MCRIESGR EVS f i 1t e r I n accordance t e s t i n g i n accordance w i t h t h e Venti 1a t i on w i t h VFTP F i 1t e r T e s t i ng Program (VFTP) .

SR 3.7.14.3 Perform r e q u i r e d MCR/ESGR envelope I n accordance u n f i 1t e r e d a i r i n l e a k a g e t e s t i n g i n with the accordance w i t h t h e MCRIESGR Envelope MCRIESGR Habi t a b i 1it y Program. Envelope Habi t a b i 1 it y Program N o r t h Anna U n i t s 1 and 2

Programs and Manual s 5.5 5.5 Programs and Manuals 5.5.15 Contai nment Leakage Rate T e s t i nq Program ( c o n t i nued)

d. Leakage Rate acceptance c r i t e r i a a r e :

1. P r i o r t o e n t e r i n g a MODE where containment OPERABILITY i s r e q u i r e d , t h e containment leakage r a t e acceptance c r i t e r i a are:

I0.60 La f o r t h e Type B and Type C t e s t s on a Maximum Path B a s i s and I0.75 La f o r Type A t e s t s .

D u r i n g o p e r a t i on where containment OPERABILITY is r e q u i red, t h e containment leakage r a t e acceptance c r i t e r i a a r e :

I 1.0 La f o r o v e r a l l containment leakage r a t e and I 0.60 La f o r t h e Type B and Type C t e s t s on a Minimum Path B a s i s .

2. O v e r a l l a i r l o c k leakage r a t e t e s t i n g acceptance c r i t e r i o n i s I0.05 La when t e s t e d a t 2 Pa.

e. The p r o v i s i o n s o f SR 3.0.3 a r e a p p l i c a b l e t o t h e Containment Leakage Rate T e s t i n g Program.

f. N o t h i n g i n these Technical S p e c i f i c a t i o n s s h a l l be c o n s t r u e d t o m o d i f y t h e t e s t i n g Frequencies r e q u i r e d by 10 CFR 50, Appendix J.

5.5.16 Main C o n t r o l Room/Emergency Swi t c h g e a r Room (MCR/ESGR) Envel ope Habi t a b i 1 it y Program A MCRIESGR Envelope Habi t a b i 1it y Program s h a l l be e s t a b l ished and imp1 emented t o ensure t h a t MCRIESGR envelope habi t a b i 1 it y is m a i n t a i n e d such t h a t , w i t h an OPERABLE Emergency Habi t a b i 1 it y System (i.e., MCRIESGR EVS and MCRIESGR B o t t l e d A i r System), MCRIESGR envelope occupants can c o n t r o l t h e r e a c t o r s a f e l y under normal c o n d i t i o n s and m a i n t a i n i t i n a s a f e c o n d i t i o n f o l l o w i n g a r a d i o 1 o g i c a l event, hazardous chemical r e 1 ease, o r a smoke chal 1enge. The program s h a l l ensure t h a t adequate r a d i a t i o n p r o t e c t i o n i s p r o v i d e d t o p e r m i t access and occupancy o f t h e MCRIESGR envel ope under design b a s i s a c c i d e n t c o n d i t i o n s w i t h o u t (continued)

N o r t h Anna U n i t s 1 and 2 5.5-15

Programs and Manual s 5.5 5.5 Programs and Manuals 5.5.16 Main C o n t r o l Room/Emergency Swi t c h g e a r Room Envelope Habi t a b i 1 it y 1

personnel r e c e i v i n g r a d i a t i o n exposures i n excess o f 5 rem t o t a l e f f e c t i v e dose e q u i v a l e n t f o r t h e d u r a t i o n o f t h e a c c i d e n t . The program s h a l l i n c l u d e t h e f o l l owing elements:

a. The d e f i n i t i o n o f t h e MCRIESGR envelope and t h e MCRIESGR envelope boundary.

b. Requirements f o r m a i n t a i n i n g t h e MCRIESGR envelope boundary i n i t s d e s i g n c o n d i t i o n i n c l u d i n g c o n f i g u r a t i o n c o n t r o l and p r e v e n t i v e mai ntenance.

c. Requirements f o r ( i ) d e t e r m i n i n g t h e u n f i 1t e r e d a i r in l eakage p a s t t h e MCRIESGR envelope i n t o t h e MCRIESGR envelope i n accordance w i t h t h e t e s t i n g methods and a t t h e Frequencies s p e c i f i e d i n S e c t i o n s C . l and C.2 o f R e g u l a t o r y Guide 1.197, "Demonstrati ng C o n t r o l Room Envel ope I n t e g r i t y a t Nucl e a r Power Reactors," R e v i s i o n 0, May 2003, and ( i i ) assessing MCRIESGR envelope habi t a b i 1 it y a t t h e Frequencies speci f i ed i n S e c t i o n s C . l and C.2 o f R e g u l a t o r y Guide 1.197, R e v i s i o n 0.

The f o l l o w i n g i s an e x c e p t i o n t o S e c t i o n C.2 o f R e g u l a t o r y Guide 1.197, R e v i s i o n 0:

2 .C. 1 L i c e n s i n g Bases - Vul n e r a b i 1it y assessments f o r r a d i o 1o g i c a l , hazardous chemi c a l and smoke, and emergency v e n t i 1a t i o n system t e s t i n g were completed as documented i n t h e UFSAR. The e x c e p t i o n s t o t h e Regul a t o r y Guides (RG) r e f e r e n c e d i n RG 1.196 (i.e., RG 1.52, RG 1.78, and RG l . l 8 3 ) , which were c o n s i d e r e d i n compl e t i ng t h e v u l n e r a b i 1it y assessments, a r e documented i n t h e UFSARIcurrent 1icensi ng b a s i s. Compl iance w i t h t h e s e RGs i s c o n s i s t e n t w i t h t h e c u r r e n t l i c e n s i n g b a s i s as d e s c r i b e d i n t h e UFSAR.

d. Measurement, a t designated l o c a t i o n s , o f t h e MCRIESGR envelope p r e s s u r e r e l a t i v e t o a l l e x t e r n a l areas a d j a c e n t t o t h e MCRIESGR envel ope boundary d u r i n g t h e p r e s s u r i z a t i o n mode o f o p e r a t i on by one t r a i n o f t h e MCRIESGR EVS, o p e r a t i n g a t t h e f l o w r a t e r e q u i r e d by t h e VFTP, a t a Frequency o f 18 months on a STAGGERED TEST BASIS. The r e s u l t s s h a l l be t r e n d e d and used as p a r t o f t h e 18 month assessment o f t h e MCRIESGR envelope boundary.

( c o n t i nued)

N o r t h Anna U n i t s 1 and 2 5.5-16

Programs and Manual s 5.5 5.5 Programs and Manuals 5.5.16 Main C o n t r o l RoomlEmergency Swi tchgear Room Envelope Habi t a b i 1 it y Program (MCRIESGR) (continued)

e. The q u a n t i t a t i v e l i m i t s on u n f i l t e r e d a i r i n l e a k a g e i n t o t h e MCR/ESGR envelope. These l i m i t s s h a l l be s t a t e d i n a manner t o a1 1ow d i r e c t compari son t o t h e u n f i 1t e r e d a i r in l eakage measured by t h e t e s t i n g d e s c r i b e d i n paragraph c. The u n f i 1t e r e d a i r in l eakage 1i m i t f o r r a d i 01 o g i c a l chal 1enges i s t h e in l eakage f l o w r a t e assumed i n t h e 1 i c e n s i n g b a s i s analyses o f design b a s i s a c c i d e n t consequences. U n f i 1t e r e d a i r in l eakage 1 i m i t s f o r hazardous chemicals must ensure t h a t exposure o f MCRIESGR envelope occupants t o these hazards w i l l be w i t h i n t h e assumptions i n t h e 1icensing b a s i s .

f. The p r o v i s i o n s o f SR 3.0.2 a r e a p p l i c a b l e t o t h e Frequencies f o r assessing MCR/ESGR envelope habi t a b i 1it y , d e t e r m i n i n g MCRIESGR envelope u n f i l t e r e d inleakage, and measuring MCRIESGR envelope pressure and assessing t h e MCRIESGR envelope boundary as r e q u i r e d by paragraphs c and d, r e s p e c t i v e l y .

N o r t h Anna U n i t s 1 and 2

Attachment 4 (Serial No. 07-0360)

Marked-up Technical Specifications Bases Changes (For Information Only)

North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

MCRJESGR EVS-Modes 1,2,3, and 4 B 3.7.10 B 3.7 PLANT SYSTEMS B 3.7.1 0 Main Control RoomIEmergency Switchgear Room (MCRIESGR) Emergency Ventilation System (EVS)-Modes 1, 2, 3, and 4 BASES BACKGROUND The MCRIESGR Emergency Habitability System (EHS) provides a protected environment from which qwaW+occuDants can control the unit following an uncontrolled release of radioactivity, hazardous chemical, or smoke. The MCRIESGR EHS consists of the MCRIESGR bottled air system (LC0 3.7.1 3) and the MCRIESGR EVS (LC0 3.7.1 0 and LCO 3.7.1 4).

The MCRIESGR EVS consists of -four 100% capacity redundant trains /2 per unit) that can filter and recirculate air inside the MCWESGR envelope or supply filtered air to the MCRIESGR envelope, and a MCRIESGR boundarv that limits the inleakaae of unfiltered a. Each train consists of a heater, demister filter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity .

(principally iodines), and a fan. Ductwork, valves, dampers, doors, barriers I and instrumentation also form part of the system. One EVS train is capable of performing the safety function of supplying filtered outside-air kx peswk&w. The two , n r l n l ? n n r l r \ n ) M C R I E S G R EVS trains on the accident unit can actuate automatically in recirculation. Either of these trains be aligned to provide filtered outside air kx

. . can alsoappropriate.

-when *Either train from the other unit can be manually actuated to provide filtered outside air approximately 60 minutes after the event. &:: EVS S H o w e v e r , dDue to the location of the air intake for 1-HV-F-41, it can not be used to satisfy the I

requirements of LC0 3.7.1 0. Two of the three remaining trains (1-HV-F-42, 2-HV-F-41, and 2-HV-F-42) are required for independence and redundancy.

The MCRIESGR envelo~eis the area within the confines of the MCRIESGR envelo~eboundarv that contains the swaces that control room occu~ants inhabit to control the unit durina normal and accident conditions. This area encomDasses the control room, and mav encomDass other non-critical areas to which freauent ~ersonnelaccess or continuous occupancv is not necessarv in the event of an accident. The MCRIESGR envelope is protected durina normal operation, natural events, and accident conditions.

The MCRIESGR envelo~eboundarv is the combination of walls, floor, roof, ductina. doors, ~enetrationsand eaubment that ~hvsicallvform the MCRIESGR envelo~e.The OPERABILITY of the MCRIESGR envelope boundarv must be maintained to ensure that the inleakaae of unfiltered air into the MCRIESGR envelo~ewill not exceed the inleakaae assumed in the licensina basis analvsis of desian basis accident (DBA) conseauences to MCRIESGR envelo~eoccuwants. The MCRIESGR envelo~eand its boundarv are defined in the MCRIESGR envelope Habitabilitv Proaram.

North Anna Units 1 and 2 B 3.7.10-1 Revision 23

MCRIESGR EVS-Modes 1 ,2,3, and 4 B 3.7.10 BASES BACKGROUND Upon receipt of the actuating signal(s), normal air supply to and exhaust (continued) from the MCRJESGR envelope is isolated, two trains of MCRJESGR EVS actuate to recirculate air, and airflow from the bottled air banks maintains a positive pressure in the MCRIESGR envelope.

-Approximately 60 minutes after actuation of the MCRIESGR bottled air system, a single MCRIESGR EVS train is manually actuated to provide filtered outside air to the MCRJESGR envelope through HEPA filters and charcoal a d s o r b e r s v . The demisters I remove any entrained water droplets present, to prevent excessive moisture loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the heaters on, reduces moisture buildup on the HEPA filters and adsorbers. Both the demister and heater are important to the effectiveness of the HEPA filters and charcoal adsorbers.

Pressurization of the MCRIESGR envelope minimizes infiltration of unfiltered air throuah the MCRIESGR envelope boundarv from u t h e surroundina areas adjacent to the K R I E S G R envelope boundarv.

A single train of the MCRJESGR EVS, o~eratinaat a flow rate of < 1100 cfm,-will pressurize the MCRJESGR envelope to 2 0.04 inches water gauge relative to external areas adjacent to the MCRJESGR envelo~e boundary. The MCRJESGR EHS operation in maintaining the MCRJESGR envelope habitable is discussed in the UFSAR, Section 6.4 (Ref. 1).

Redundant MCRJESGR EVS supply and recirculation trains provide the required -filtration should an excessive drop 1 develop across the other filter train. Normally closed isolation dampers are arranged in series pairs so that the failure of one damper to open will not result in an inability of the system to perform the function based on the presence of the redundant train. The MCRJESGR EHS is designed in accordance with Seismic Category I requirements. The actuation signal will only start the MCRIESGR EVS trains for the affected unit. Requiring two of the three MCRJESGR EVS trains provides redundancy, assuring that at least one train is available to be realigned to provide filtered outside air.

The MCRJESGR EHS is designed to maintain a habitable environment in the S

- MCRJESGR envelo~efor 30 days of continuous occupancy after a DBA without exceeding the control room North Anna Units 1 and 2 B 3.7.1 0-2 Revision 2Q

MCR/ESGR EVS-Modes 1,2,3, and 4 B 3.7.1 0 BASES BACKGROUND operator dose limits of 10 CFR 50, Appendix A, GDC-19 (Ref. 3) for (continued) alternative source terms.

APPLICABLE The MCRIESGR EVS components are arranged in redundant, safety SAFETY ANALYSIS related ventilation trains. The location of most components and ducting within the MCRIESGR envelope ensures an adequate supply of filtered air to all areas requiring access. The MCRIESGR EHS provides airborne radiological protection for the -MCRIESGR enveloee occueants, as demonstrated by the ee&whemMCR/ESGR enveloee accident dose analyses for the most limiting design basis accident fission product release presented in the UFSAR, Chapter 15 (Ref. 2). This accident analysis assumes that at least one train is aligned *to erovide . .filtered outside air e c m h t w to ~ the MCRIESGR enveloee pwwwakm approximately 60 minutes after actuation of bottled air, but does not take any credit for automatic start of the trains in the recirculation mode or any filtration of recirculated air. Since, the MCRIESGR EVS train associated with 1-HV-F-41 can not be used to provide filtered outside air #e+Nta&

-(due

. . to the location of its air intake with respect to Vent Stack 6)it can not be used to satisfy the requirements of LC0 3.7.1 0.

The North Anna UFSAR describes eotentiallv hazardous chemicals stored onsite in auantities areater than 100 Ib. These include hvdroaen, sulfuric acid. sodium hvdroxide, hvdrazine, ethanolamine, and sodium hveochlorite.

Evaluations for accidental release of these chemicals indicate that the worst-case concentrations at the control room intake would be expected to be less than their reseective toxicitv limit. (Refs 1 and 4) The assessment assumed no action beina taken bv the control room oDerator (i.e.. normal or emeraencv sueelv svstem remains o~eratina).

In the event of firelsmoke external to the MCRIESGR enveloee, eaui~ment and erocedures are available to maintain habitabilitv of the control room.

Smoke detectors are installed in the return ducts to the MCR Air-Handlinq Units (AHU), in the near vicinitv of the ESGR AHUs, and in the MCRIESGR EVS sueelv ducts, as well as other numerous locations in the ESGRs and MCR. Smoke detectors are also installed in the MCRIESGR chiller rooms, which are ventilated with air from the Turbine Buildina, and the Mechanical Eaui~mentrooms. If smoke is detected, the MCRIESGR normal and EVS sueelv can be manuallv isolated. The fire reseonse erocedures provide direction for removina smoke from the MCR or ESGRs. (Ref. 5)

The worst case single active failure of a component of the MCRIESGR EVS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

The MCRIESGR EVS-MODES 1, 2, 3, and 4 satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).,

North Anna Units 1 and 2 B 3.7.1 0-3 Revision 2Q

MCRIESGR EVS-Modes 1 , 2 , 3 , and 4 B 3.7.10 BASES LC0 Two independent and redundant MCRIESGR EVS trains are required to be OPERABLE to ensure that at least one train is available to be manually aligned to -provide filtered outside air to the MCRIESGR (

envelope, if a single active failure disables one of the two required OPERABLE trains. Total system failure, such as from a loss of both EVS trains or from an inoperable MCRIESGR envelope boundarv, could result in exceeding the control room operator dose limits of 10 CFR 50, Appendix A, GDC-19 (Ref. 3) for alternative source terms, in the event of a large radioactive release.

The MCRJESGR EVS-MODES 1,2,3, and 4 is considered OPERABLE when the individual components necessary to limit q w a W MCRIESGR envelope occupant exposure are OPERABLE in the two required trains of the MCRIESGR EVS-MODES 1, 2, 3, and 4. 1-HV-F-41 can not be used to satisfy the requirements of LC0 3.7.1 0.

An MCRIESGR EVS train is OPERABLE when the associated:

a.Fan is OPERABLE; b.Demister filters, HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; and

c. Heater, ductwork, valves, and dampers are OPERABLE, and air flow can be maintained.

The MCRJESGR EVS is shared by Unit 1 and Unit 2.

In order for the MCRIESGR EVS trains to be considered OPERABLE, the MCRIESGR envelope boundarv must be maintained such that the MCRIESGR envelope occupant dose from a larae radioactive release does not exceed the calculated dose in the licensina basis conseauence analvses for DBAs, and that MCRIESGR envelooe occupants are protected from hazardous chemicals and smoke.

The LC0 is modified by a Note allowing the MCRJESGR envelope boundary to be opened intermittently under administrative controls. This Note onlv applies to openinas in the MCRIESGR envelope boundarv that can be rapidlv restored to the desian condition, such as doors, hatches, floor ~ l u a sand

, access panels. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the ooerators in the

~~W~E~IMCRIESGRenvelope. This individual will have a method to rapidly close the opening and restore the MCRIESGR envelope boundarv to acondition eauivalent to the desian condition when a need for MCRIESGR isolation is indicated.

North Anna Units 1 and 2 B 3.7.1 0-4 Revision 2Q

MCRIESGR EVS-Modes 1,2,3, and 4 B 3.7.10 BASES APLICABILITY In MODES 1,2,3, and 4, MCRIESGR EVS must be OPERABLE ensure that the MCRIESGR e n v e l o ~ ewill remain habitable eeeW p d u r i r ~ and g following a DBA.

ACTIONS -

A. 1 When one required MCRIESGR EVS train is inoperable for reasons other than an inoperable MCRIE3GR envelope boundarv, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining required OPERABLE MCRIESGR EVS train is adequate to perform the MCRIESGR envelope occ:ueant protection function. However, the overall reliability is reduced becal~sea stqkfailure in the required OPERABLE EVS trains could result in loss of MCRIESGR EVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining trains to provide the required capability.

B. 1 If the unfiltered inleakaae of potentiallv contaminated air past the MCRIESGR envelope boundarv and into the MCRIESGR envelope can result in MCRIESGR envelo~eoccupant radioloaical dose areater than the calculated dose of the licensina basis analvses of DBA conseauences jallowed to be up to 5 rem Total Effective Dose Eaulivalent), or inadeauate protection of MCRIESGR envelope occupants from hazardous chemicals or smoke, the MCRIESGR envelope boundarv is inoperable. Actions must be taken to restore an OPERABLE MCRIESGR enveloee boundarv within 90 davs. Durina the period that the MCRIESGR envelope boundarv is considered inoperable, action must be initiated to implement mitiaatinq actions to lessen the effect on MCRIESGR envelope occueants from the potential hazards of a radioloaical or chemical event or a challenae from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verifv that in the event of a DBA, the mitiaatina actions will ensure that MCRIESGR envelope occupant radioloaical exposures will not exceed the calculated dose of the licensina basis analvses of DBA conseauences, and that MCRIESGR envelope occupants are protected from hazardous chemicals and smoke.

These mitiaatina actions he., actions that are taken to offset the conseauences of the inoeerable MCRIESGR envelo~eboundarv) should be meplanned for imelementation ueon entrv into the condition. reaardless of whether entrv is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Com~letion Time is reasonable based on the low probabilitv of a DBA occurrina durinq this time period. and the use of mitiaatina actions. The 90 dav Completion Time is reasonable based on the determination that the mitiaatina actions will ensure protection of MCRIESGR envelope occueants within analvzed limits while limitina the ~robabilitvthat MCRIESGR envelope occupants will have to implement protective measures that mav adverselv affect their abilitv to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition. the 90 dav Com~letionTime is a reasonable time to diaanose, plan and ~ossiblvrepair, and test most problems with the MCRIESGR envelo~eboundarv.

North Anna Units 1 and 2 B 3.7.1 0-5 Revision 2Q

MCRlESGR EVS-Modes 1,2,3, and 4 B 3.7.10 BASES ACTIONS (continued)

C 4

'?

') Q

-1 M1r\"

\"'ym9 P p C.l and C.2 In MODE 1, 2, 3, or 4, if the inoperable required MCRIESGR EVS train or the inoperable MCRIESGR envelo~eboundary cannot be restored to I OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

When two required MCRIESGR EVS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable MCRIESGR envelo~e I boundary (i.e., Condition B), the MCRIESGR EVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LC0 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on the MCRIESGR EVS are not too severe, testing each required train once every month provides an adequate check of this system. Monthly heater operations dry out any moisture accumulated in the charcoal and HEPA filters from humidity in the ambient air. Each required train must be operated for 210 continuous hours with the heaters energized. The 31 day Frequency is based on the reliability of the equipment and the one train redundancyav4kbMy. I North Anna Units 1 and 2 B 3.7.1 0-6 Revision 20

MCRIESGR EVS-Modes 1 , 2 , 3, and 4 B 3.7.10 SURVEILLANCE SR 3.7.10.2 REQUIREMENTS This SR verifies that the required MCRIESGR EVS testing is performed in (continued) accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing the performance of the demister filter, HEPA filter,charcoal adsorber efficiency, minimum and maximum flow rate, and thephysical properties of the activated charcoal. Specific test Frequencies andadditional information are discussed in detail in the VFTP.

Not Used This SR verifies the OPERABILITY of the MCRIESGR envelope boundarv bv testing for unfiltered air inleakage past the MCRIESGR envelope boundarv and into the MCRIESGR envelope. The details of the testing are specified in the MCWESGR Envelope Habitabilitv Program.

The MCRIESGR envelope is considered habitable when the radiological dose to MCWESGR envelope occupants calculated in the licensing basis analvses of DBA consequences is no more than 5 rem TEDE and the MCRIESGR envelope occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the MCRIESGR envelope is no greater than the flow rate assumed in the licensing basis analvses 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 MCRIESGR envelope boundarv to OPERABLE status provided mitigatina actions can ensure that the MCRIESGR envelope remains within the licensing basis habitabilitv limits for the occupants following an accident. Compensatory measures are discussed in Regulatorv Guide 1.196, Section C.2.7.3, (Ref.

6) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F

{Ref. 7). These com~ensatorvmeasures mav also be used as mitigating actions as required bv Required Action B.2. Temporarv analvtical methods mav also be used as compensatorv measures to restore OPERABILITY

{Ref. 8). Options for restorinq the MCRIESGR envelope boundarv to OPERABLE status include changina the licensing basis DBA consequence analvsis, repairing the MCRIESGR envelope boundarv, or a combination of these actions. Dependinq upon the nature of the problem and the corrective action, a full scope inleakaqe test mav not be necessarv to establish that the MCRIESGR envelope boundarv has been restored to OPERABLE status.

North Anna Units 1 and 2 B 3.7.10-7 Revision 2Q

MCRIESGR EVS-Modes 1 , 2 , 3 , and 4 B 3.7.10 SURVEllANCE . . ..

REQUIREMENTS (continued)

REFERENCES 1.- UFSAR, Section 6.4.

2 . U F S A R , Chapter 15.

3. 10 CFR 50, Appendix A.

4. Control Room Habitabilitv Studv (Supplement to 1980 Onsite Control Room Habitabilitv Studv - North Anna Power Station Units 1 and 2, January 1 9 8 2 ) W E C W,Kcn:. 2, ~~

5. Letter from L. N. Hartz (Virqinia Electric and Power Companv) to UNSRC, dated March 31, 2004, Response to Generic Letter 2003-01 Control Room Habitabilitv Control Room testing and Technical Information.

6. Renulatow Guide 1.196 7 .NEI 99-03, "Control Room Habitabilitv Assessment," June 2001.

8 Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated Januarv 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitabilitv." (ADAMS Accession No. ML040300694).

North Anna Units 1 and 2 B 3.7.1 0-8 Revision 2-0

MCRIESGR Bottled Air System B 3.7.13 B 3.7 PLANT SYSTEMS B 3.7.13 Main Control Room1Emergenc:y Switchgear Room (MCRIESGR) Bottled Ai r System BASES BACKGROUND The MCRIESGR Emergency Habitability System (EHS) provides a protected environment from which occupants q w a t w s c a n control the unit following an uncontrolled release of radioactivity, hazardous chemical, or smoke. The MCRIESGR EHS consists of the MCRIESGR bottled air system (LC0 3.7.13) and the MCRIESGR Emergency Ventilation System (EVS) (LC0 3.7.1 0 and LC0 3.7.1 4).

The MCRIESGR bottled air system consists of four trains of bottled air lined up to provide air to the MCR/ESGR envelope and a MCRIESGR envelope boundarv that limits the inleakaae of unfiltered air. wbm4h.e

.- The air is provided via four trains which feed a common header, supply in^ air to the Unit 1 and Unit 2 ESGRs. The header is also capable of being aligned to supply air directly to the MCR. Each train is provided air by one of the bottled air banks. Unit 1 and Unit 2 each provide two trains of bottled air. Two bottled air trains are capable of providing dry air of breathing quality to maintain a positive interior pressure in the MCRIESGR envelope for Unit 1 and Unit 2 for a period of one hour following a Design Basis Accident (DBA).

The MCRIESGR envelope is the area within the confines of the MCR/ESGR envelope boundarv that contains the spaces that control room occupants inhabit to control the unit durina normal and accident conditions. This area encompasses the control room, and mav encompass other non-critical areas to which freauent personnel access or continuous occupancv is not necessarv in the event of an accident.

The MCRIESGR envelope is wotected durina normal operation, natural events. and accident conditions. The MCRIESGR envelo~e boundarv is the combination of walls, floor, roof, ductina. doors, penetrations and eaui~mentthat ~hvsicallvform the MCRIESGR envelope. The OPERABILITY of the MCRIESGR envelope boundarv must be maintained to ensure that the inleakaae of unfiltered air into the MCRIESGR envelope will not exceed the inleakaae assumed in the licensina basis analvsis of DBA conseauences to MCRIESGR envelope occupants. The MCRIESGR envelope and its boundarv are defined in the MCRIESGR Envelope Habitabilitv Proaram.

In MODES 1, 2, 3, or 4, upon receipt of the actuating signal(s), normal air supply to and exhaust from the MCRIESGR envelope is isolated, two trains of MCRIESGR EVS actuate to recirculate air, and airflow from the bottled air banks maintains a positive pressure in the MCRIESGR envelope. In case of a fuel handling accident (FHA) in the fuel building, automatic actuation of bottled air is possible. A FHA in containment can not cause an automatic actuation of bottled air., but

- - - - ~ - - -

manual actuation can be initiated. After 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> of decay, actuation I North Anna Units 1 and 2 B 3.7.1 3-1 Revision 20

MCRIESGR Bottled Air System B 3.7.13 BASES BACKGROUND (continued)

MCRIESGR EVS train is manually actuated to provide filtered outside air to the MCRIESGR envelope through high efficiency . . particulate air (HEPA) filters and charcoal adsorbers-.

Pressurization of the MCRJESGR envelope ptwer+%minimizes I

infiltration of unfiltered air from the areas adjacent to the MCRIESGR envelope boundarv.

Two trains of the MCRIESGR bottled air system will pressurize the MCRIESGR envelope to > 0.05 inches water gauge. The MCRIESGR EHS operation in maintaining the MCRIESGR envelope habitable is discussed in the UFSAR, Section 6.4 (Ref. 1).

The MCRIESGR EHS is designed in accordance with Seismic Category I requirements.

I The MCR/ESGR EHS is designed to maintain a habitable environment in the MCRIESGR envelope for 30 days of continuous occupancy after a DBA without exceeding the control room operator dose limits of 10 CFR 50, Appendix A, GDC-19, (Ref. 2) alternative source terms.

I I

APPLICABLE The MCRIESGR bottled air system is arranged in redundant, SAFETY ANALYSES safety related trains providing pressurized air from the required bottled air banks to maintain a habitable environment in the MCRIESGR envelope.

The MCRIESGR EHS provides airborne radiological protection for the MCRIESGR envelo~eoccu~ants-, as I demonstrated by the control room accident dose analyses for the most limiting design basis accident fission product release presented in the UFSAR, Chapter 15 (Ref. 4). I The North Anna UFSAR describes potentiah hazardous chemicals stored onsite in auantities areater than 100 Ib. These include hvdroaen, sulfuric acid, sodium hvdroxide. hvdrazine, ethanolamine, and sodium hv~ochlorite. Evaluations for accidental release of these chemicals indicate that the worst-case concentrations at the control room intake would be ex~ectedto be less than their res~ectivetoxicity limit. (Refs 1 and 5) The assessment assumed no action beina taken bv the control room operator (i.e., normal or emeraencv s u ~ ~svstem lv remains operatinu.

In the event of firelsmoke external to the MCRIESGR envelo~e, eaui~mentand ~roceduresare available to maintain habitabilitv of the control room. Smoke detectors are installed in the return ducts to the MCR Air-Handlina Units (AHU), in the near vicinitv of the ESGR AHUs, and in the MCRIESGR EVS s u ~ ~ducts, l v as well as other numerous North Anna Units 1 and 2 B 3.7.1 3-2 Revision 20

MCRIESGR Bottled Air System B 3.7.1 3 BASES APPLICABLE locations in the ESGRs and MCR. Smoke detectors are also installed SAFETY ANALYSES in the MCRJESGR chiller rooms. which are ventilated with air from the (continued) Turbine Buildina, and the Mechanical Eaui~mentrooms. If smoke is detected, the MCRJESGR normal and EVS s u ~ p l vcan be manually isolated. The fire response erocedures provide direction for removinq smoke from the MCR or ESGRs.(Ref. 6)

The worst case single active failure of a component of the MCRIESGR bottled air system, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

The MCRIESGR bottled air system satisfies Criterion 3 of 10 CFR 50.36(~)(2)(ii).

Three independent and redundant MCRJESGR bottled air system trains are required to be OPERABLE to ensure that at least two are available assuming a single failure disables one train. Total system failure, such as from a loss of two reauired bottled air svstem trains or from an inoperable MCRIESGR enveloee boundarv, could result in exceeding the control room operator dose limits of 10 CFR 50, Appendix A, GDC-19 (Ref. 2) for alternative source terms, in the event of a large radioactive release.

I Each %MCR/ESGR bottled air system train is considered OPERABLE when the individual components necessary to limit I

~~W~BFMCRJESGR enveloee occupant exposure are OPERABLE-iR I

A MCRIESGR bottled air system train is OPERABLE when:

a. One OPERABLE bottled air bank of 69 bottles is in service;

b. A flow path, including associated valves and piping, is OPERABLE; and

c. The common exhaust header is OPERABLE.

The MCRIESGR bottled air system trains are shared by Unit 1 and Unit 2.

In order for the MCRJESGR EVS trains to be considered OPERABLE, the MCRJESGR envelope boundarv must be maintained such that the MCRJESGR envelope occupant dose from a larae radioactive release does not exceed the calculated dose in the licensina basis conseauence analvses for DBAs, and that MCRJESGR enveloee occupants are protected from hazardous chemicals and smoke.

The L C 0 is modified by a Note allowing the MCRIESGR enveloee boundary to be opened intermittently under administrative controls.

I North Anna Units 1 and 2 B 3.7.1 3-3 Revision 2Q

MCRIESGR Bottled Air System B 3.7.1 3 BASES LC0 This Note onlv applies to openinas in the MCRIESGR envelope (continued) boundarv that can be rauidlv restored to the desian condition. such as doors, hatches, floor ~ l u a sand , access panels. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be ~6cedurali;ed and consist of stationinga dedicated individual at the opening who is in continuous communication with the n-n)--'operators in the MCRIESGR envelope. This individual will have a method to rapidly close the openingand restore the MCRIESGR envelope to a condition eauivalent to the desian condition when a need for MCRIESGR envelope isolation is indicated.

APPLICABILITY In MODES 1, 2,3, and 4, and during movement of recently irradiated fuel assemblies, MCRIESGR bottled air system must be OPERABLE to ensure that the MCRIESGR envelope will remain habitable &

-wing and following a DBA. I During movement of recently irradiated fuel assemblies, the MCRIESGR bottled air system must be OPERABLE to respond to the release from a fuel handling accident involving handling recently irradiated fuel. The MCRIESGR bottled air 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 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />), due to radioactive decay.

ACTIONS -A. I I

When one required MCRIESGR bottled air system train is inoperable, for reasons other than an ino~erableMCRIESGR envelope boundarv, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining required OPERABLE MCRIESGR bottled air system trains are adequate to perform the MCRIESGR envelope occupant protection function. However, the I overall reliabilitv is reduced because a sinale failure in one of the remaining required OPERABLE trains codd result in loss of MCRIESGR bottled air system function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining trains to provide the required capability.

If the unfiltered inleakaae of ~otentiallvcontaminated air past the MCRIESGR envelope boundarv and into the MCRIESGR envelope can result in MCRIESGR envelope occupant radioloaical dose areater than the calculated dose of the licensina basis analvses of DBA conseauences (allowed to be up to 5 rem Total Effective Dose Eaulivalent), or inadeauate protection of MCRIESGR envelope occupants from hazardous North Anna Units 1 and 2 B 3.7.1 3-4 Revision 20

MCRIESGR Bottled Air System B 3.7.13 BASES ACTIONS chemicals or smoke, the MCRIESGR envelo~eboundarv is (continued) inoperable. Actions must be taken to restore an OPERABLE MCRIESGR envelope boundarv within 90 davs.

Durina the period that the MCRIESGR envelope boundarv is considered inoperable, action must be initiated to implement mitiaatina actions to lessen the effect on MCRlESGR envelope occupants from the potential hazards of a radioloaical Or chemical event or a challenae from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verifv that in the event of a DBA, the mitiaatina actions will ensure that MCRIESGR envelo~eoccuDant radioloaical exposures will not exceed the calculated dose of the licensina basis analvses of DBA conseauences, and that MCRIESGR envelope occupants are protected from hazardous chemicals and smoke. These mitiaatinq actions (i.e., actions that are taken to offset the conseauences of the inoperable MCRIESGR envelope boundarv) should be ~ r e p h n e for d implementation w o n entrv into the condition. reaardless of whether entrv is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probabilitv of a DBA occurrina durinq this time period, and the use of mitiaatina actions. The 90 day Completion Time is reasonable based on the determination that the mitiaatina actions will ensure ~rotectionof MCRIESGR envelope occupants within analvzed limits while limitina the ~robabilitvthat MCRJESGR envelo~eoccupants will have to implement protective measures that mav adverselv affect their abilitv to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 dav Com~letionTime is a reasonable time to diaanose. plan and Dossiblv re~air,and test most ~roblemswith the MCRIESGR envelope boundarv.

If the M C R

. . C E? A /nn 1 - 9 w, C. I When two or more required trains of the MCRIESGR bottled air system are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable MCRIESGR boundary (i.e., Condition B), action must be taken to restore at least two of the required MCRJESGR bottled air North Anna Units 1 and 2 B 3.7.1 3-5 Revision 2 9

MCRIESGR Bottled Air System B 3.7.13 BASES ACTIONS system trains to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the period (continued) that two or more required trains of the MCRIESGR bottled air svstem are inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from potential hazards such as radioactive contamination. Preplanned measures should be available to-address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is a typically reasonable time to diagnose, plan, restore, and possibly repair, and test most problems with the MCRIESGR bottled air system, such as repressurizing the system after an inadvertent actuation.

D.1 and D.2 In MODE 1, 2, 3, or 4, if the inoperable required MCRIESGR bottled air system trains or the inoperable MCRIESGR boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

During movement of recently irradiated fuel assemblies, if the required inoperable MCRIESGR bottled air system train cannot be restored to OPERABLE status within the required Completion Time, *two or more required MCRIESGR bottled air system trains are inoperable, or one or more bottled air svstem trains ino~erabledue to an inooerable MCRIESGR envelo~eboundarv, action must be taken to immediately suspend activities that could result in a release of radioactivity that might require isolation of the MCRIESGR envelope. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

SURVEILLANCE SR 3.7.1 3.1 REQUIREMENTS This SR verifies that each required MCRIESGR bottled air bank is at the proper pressure. This ensures that when combined with the required number of OPERABLE air bottles, the minimum required air flow will be maintained to ensure the required MCRIESGR envelope pressurization for approximately 60 minutes when the MCRIESGR bottled air system is actuated. The 31 day Frequency is based on engineering judgement.

This SR verifies that the proper number of MCRIESGR air bottles are in service, with one bank of 69 air bottles in each required train. This North Anna Units 1 and 2 B 3.7.1 3-6 Revision 20

MCRIESGR Bottled Air System B 3.7.13 BASES SURVEILLANCE SR 3.7.13.2 (continued)

REQUIREMENTS SR requires verification that each bottled air bank manual valve not (continued) locked, sealed, or otherwise secured and required to be open during accident conditions is open. This SR helps to ensure that the bottled air banks required to be OPERABLE to pressurize the MCRIESGR boundary are in service. The 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. This SR does not apply to valves that are locked, sealed, or otherwise secured in the open position, since these were verified to be in the correct position prior to locking, sealing, or securing.

This SR verifies that each required MCRIESGR bottled air system train actuates by verifying the flow path is opened and that the normal air supply to and exhaust from the MCRIESGR envelope is isolated on an actual or simulated actuation signal. The Frequency of 18 months is consistent with performing this test on a refueling interval basis.

This SR verifies, by pressurizing the MCRIESGR envelope, the integrity of the MCRIESGR envelope, and the assumed inleakage rates of the potentially contaminated air. The MCRIESGR envelope positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper functioning of the MCRIESGR bottled air system. During the emergency mode of operation, the MCRIESGR bottled air system is designed to pressurize the MCRIESGR envelope to

> 0.05 inches water gauge positive pressure with respect to adjacent areas in order to prevent unfiltered inleakage. The MCRIESGR bottled air system is designed to maintain this positive pressure with two trains for at least 60 minutes. Testing two trains at a time at the Frequency of 18 months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800 (Ref. 3).

REFERENCES 1. UFSAR, Section 6.4.

2. 10 CFR 50, Appendix A.

3. NUREG-0800, Rev. 2, July 1981

4. UFSAR, Chapter 15

5. Control Room Habitabilitv Studv (Supplement to 1980 Onsite Control Room Habitabilitv Study - North Anna Power Station Units 1 and 2, Januarv 1982)

6. Letter from L. N. Hartz (Virginia Electric and Power Company) to UNSRC, dated March 31, 2004, Response to Generic Letter 2003-01 Control Room Habitabilitv Control Room testing and Technical Information.

North Anna Units 1 and 2 B 3.7.13-7 Revision 20

MCRIESGR EVS-During Movement of Recently Irradiated Fuel Assemblies B.3.7.14 B 3.7 PLANT SYSTEMS B 3.7.14 Main Control RoomIEmergency Switchgear Room (MCRIESGR) Emergency Ventilation System (EVS)-During Movement of Recently lrradiated Fuel Assemblies BACKGROUND The MCRIESGR Emergency Habitability System (EHS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The MCRIESGR EHS consists of the MCRIESGR bottled air system (LC0 3.7.13) and the MCRIESGR EVS (LC0 3.7.10 and LC0 3.7.14).

I The MCRIESGR EVS -consists of four independent, redundant trains that can filter and recirculate air inside the MCRIESGR I

envelope, or supply filtered air to the MCWESGR envelopeand MCRIESGR boundarv that limits the inleakaqe of unfiltered air. Each train consists of a heater, demister filter, a high efficiency particulate air I

(HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves and dampers, doors, barriers and instrumentation also form part of the I system. One EVS train is capable of performing the safety function of supplying filtered outside.-rai There is no restriction on the use of 1-HV-F-41 in the recirculation mode. However, dBue to the location of the air intake for 1-HV-F-41, it can not be used to satisfy the requirements of LC0 3.7.14 to supplv filtered outside air. Two of the I three remaining trains (1-HV-F-42, 2-HV-F-41, and 2-HV-F-42) are required for independence and redundancy. I The MCRIESGR envelope is the area within the confines of the MCRIESGR envelope boundarv that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions . This area encompasses the control room, and mav encomDass other non-critical areas to which frequent personnel access or continuous occupancv is not necessarv in the event of an accident. The MCRIESGR envelope is protected durinq normal operation, natural events, and accident conditions. The MCRIESGR envelope boundarv is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that phvsically form the MCWESGR envelope. The OPERABILITY of the MCRIESGR envelope boundarv must be maintained to ensure that the inleakage of unfiltered air into the MCWESGR envelope will not exceed the inleakage assumed in the licensing basis analvsis of design basis accident (DBA) consequences to MCRIESGR envelope occupants. The MCRIESGR envelope and its boundarv are defined in the MCRIESGR Envelope Habitabilitv Program.

North Anna Units 1 and 2 B 3.7.14-1 Revision 28

MCRIESGR EVS-During Movement of Recently Irradiated Fuel Assemblies B.3.7.14 BASES BACKGROUND In case of a Design Basis Accident (DBA), during movement of (continued) recently irradiated fuel assemblies, an automatic (signal from the fuel building radiation monitors) or manual actuation of airflow from the bottled air banks is required. Actuation of airflow from the bottled air banks also automatically isolates the MCRIESGR envelope to maintain positive pressure in the MCRIESGR envelope and I automatically starts all available EVS trains in recirculation mode.

I v i e d air system, a single MCRIESGR EVS train is manually actuated or aligned to provide filtered outside air to the MCRIESGR envelope through HEPA filters and charcoal adsorbers for pressurization. ke r I lI\I C A 1

-The demisters remove any entrained water droplets present in the air, to prevent excessive moisture loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the heaters on, reduces moisture buildup on the HEPA filters and adsorbers. Both the demister and heater are important to the effectiveness of the HEPA filters and charcoal adsorbers.

Pressurization of the MCRIESGR envelope ptee&eminimize infiltration of unfiltered air from the areas adjacent to the envelope.

A single train of the MCRIESGR EVS will pressurize the MCRIESGR envelope to > 0.04 inches water gauge. The MCRIESGR EHS operation in maintaining the MCRIESGR envelope habitable is discussed in the UFSAR, Section 6.4 (Ref. 1).

Redundant MCRIESGR EVS supply trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally closed isolation dampers are arranged in series pairs so that the failure of one damper to open will not result in an inability of the system to perform the function based on the presence of the redundant train. The MCRIESGR EHS is designed in accordance with Seismic Category I requirements.

The MCRIESGR EHS is designed to maintain& a habitable environment in the MCRIESGR e n v e l o ~ e e c w & w mfor 30 days of continuous occupancy after a DBA without exceeding the control room operator dose limits of 10 CFR 50, Appendix A, GDC-19 (Ref.

2) for alternative source terms.

APPLICABLE The MCRIESGR EVS components are arranged in redundant, SAFETY ANALYSIS safety related ventilation trains. The location of most components and ducting within the MCRIESGR envelope ensures an adequate supply of filtered air to all areas requiring access. The MCRIESGR EHS provides airborne radiological protection for the e&wtwm I North Anna Units 1 and 2 B 3.7.1 4-2 Revision 33

MCRIESGR EVS-During Movement of Recently lrradiated Fuel Assemblies B.3.7.14 BASES APPLICABLE epe&ssMCR/ESGR envelope occu~ants,as demonstrated by the SAFETY ANALYSIS GwM-FwwMCR/ESGR envelope accident dose analyses for the (continued) most limiting design basis accident fission product release presented in the UFSAR, Chapter 15 (Ref. 4).

The North Anna UFSAR describes potentiallv hazardous chemicals stored onsite in quantities greater than 100 Ib. These include hydrogen, sulfuric acid, sodium hvdroxide, hvdrazine, ethanolamine, and sodium hvpochlorite. Evaluations for accidental release of these chemicals indicate that the worst-case concentrations at the control room intake would be expected to be less than their respective toxicitv limit. .(Refs. 1 and 5) The assessment assumed no action being taken bv the control room operator (i.e., normal or emergencv SUDP~Vsvstem remains operatinq.

In the event of firelsmoke external to the MCRIESGR envelo~e, equipment and procedures are available to maintain habitabilitv of the control room. Smoke detectors are installed in the return ducts to the MCR Air-Handling Units (AHU), in the near vicinitv of the ESGR AHUs, and in the MCWESGR EVS supplv ducts, as well as other numerous locations in the ESGRs and MCR. Smoke detectors are also installed in the MCRIESGR chiller rooms, which are ventilated with air from the Turbine Building, and the Mechanical Eauipment rooms. If smoke is detected, the MCWESGR normal and EVS supplv can be manuallv isolated. The fire response procedures provide direction for removinq smoke from the MCR or ESGRs.(Ref. 9)

The worst case single active failure of a component of MCRIESGR EVS, assuming a loss of offsite power, does not (continued) impair the ability of the system to perform its design function.

The MCRIESGR EVS-During Movement of Recently lrradiated Fuel Assemblies satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LC0 Two independent and redundant MCRIESGR EVS trains are required to be OPERABLE to ensure that at least one is available if aswmga single active failure disables the other train. Total system failure such as from a loss of both required ventilation trains or from an inoperable MCRIESGR envelope boundan/, could result in exceeding the control room operator dose limits of 10 CFR 50, AppendixA, GDC-19 (Ref. 2), for alternative source terms in the event of a large radioactive release.

&he MCRIESGR EVS-During Movement of Recently lrradiated Fuel Assemblies train is considered OPERABLE when the individual components necessary to limit ~WW~~FMCRIESGR occupant exposure are OPERABLE.&

An MCRIESGR EVS train is OPERABLE when the associated:

a. Fan is OPERABLE; North Anna Units Iand 2 B 3.7.14-3 Revision 20

MCRIESGR EVS-During Movement of Recently Irradiated Fuel Assemblies B.3.7.14 BASES I nn LLU (continued) b Demister filters, HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; and

c. Heater, ductwork, valves, and dampers are OPERABLE, and air flow can be maintained.

The MCRIESGR EVS is shared by Unit 1 and Unit 2.

In order for the MCRIESGR EVS trains to be considered OPERABLE, the MCRIESGR envelope boundary must be maintained such that the MCRIESGR envelope occupant dose from a larae radioactive release does not exceed the calculated dose in the licensing basis conseauence analyses for DBAs, and that MCRIESGR envelope occupants are protected from hazardous chemicals and smoke.

The LC0 is modified by a Note allowing the MCRIESGR envelope boundarv to be o~enedintermittentlv under administrative controls.

This ~ o f onlye applies to openings h the MCRIESGR envelope boundary that can be rapidly restored to the desiqn condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in-continuous communication with the amtwMemoperators in the MCRIESGR envelope. This individual will have a method to rapidly close the opening and restore the MCRIESGR envelope boundary to a condition equivalent to the design condition when a need for MCRIESGR isolation is indicated.

APPLICABILITY During movement of recently irradiated fuel assemblies, MCRIESGR EVS-During Movement of Recently lrradiated Fuel Assemblies must be OPERABLE to r r n n ) m l n s u r e that the MCRIESGR envelope will remain habitable during and following a DBA.

During movement of recently irradiated fuel assemblies, the MCRIESGR EVS must be OPERABLE to respond to the release from a fuel handling accident involving handling recently irradiated fuel.

The MCRIESGR EVS 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 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />),

due to radioactive decay.

Regarding the MCRIESGR EVS, it should be noted that they are required to be OPERABLE by other LCOs in other MODES.

North Anna Units 1 and 2 B 3.7.1'4-4 Revision 28

MCRIESGR EVS-During Movement of Recently Irradiated Fuel Assemblies B.3.7.14 BASES ACTIONS -

A. 1 When one required MCRIESGR EVS train is inoperable, for reasons other than an ino~erableMCRIESGR envelo~eboundarv, action must be taken to restore OPERABLE status within 7 days. In this Condition, I

the remaining required OPERABLE MCRIESGR EVS train is adequate to perform the MCRIESGR occupant protection function. However, the overall reliability is reduced because a single failure in the required OPERABLE MCRIESGR EVS train could result in loss of MCRIESGR EVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining trains to provide the required capability.

B.1 During movement of recently irradiated fuel assemblies, if the required inoperable MCRIESGR EVS train cannot be restored to OPERABLE status within the required Completion TimeL+ two required MCRIESGR EVS trains are inoperable, or one or more MCRIESGR EVS trains are ino~erabledue to an ino~erableMCRIESGR envelo~eboundarv action must be taken to immediately suspend activities that could result in a release of radioactivity that might require isolation of the MCRIESGR envelope. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position. I SURVEILLANCE SR 3.7.14.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on the MCRIESGR EVS are not too severe, testing each required train once every month provides an adequate check of this system. Monthly heater operations dry out any moisture accumulated in the charcoal and HEPA filters from humidity in the ambient air. Each required train must be operated for > 10 continuous hours with the heaters energized.

The 31 day Frequency is based on the reliability of the equipment and the one train redundancy availability.

SR 3.7.1 4.2 This SR verifies that the required MCRIESGR EVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing the performance of the demister filter, HEPA filter, charcoal adsorber efficiency, minimum and maximum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP. I SR 3.7.1 4.3 This SR verifies the OPERABILITY of the MCRIESGR envelo~eboundarv bv testina for unfiltered air inleakaae rsast the MCRIESGR envelo~e boundarv and into the MCRIESGR envelo~e.The details of the testinq are s~ecifiedin the MCRIESGR Envelo~eHabitabilitv Proaram North Anna Units 1 and 2 B 3.7.14-5 Revision XI

MCRIESGR EVS-During Movement of Recently Irradiated Fuel Assemblies 0.3.7.14 BASES SURVEILLANCE The MCRIESGR envelo~eis considered habitable when the REQUIREMENTS radioloaical dose to MCRIESGR envelo~eoccuDants calculated in (continued) the licensina basisanalvses of DBA conseauences is no more than 5 rem Total Effective Dose Eaulivalent and the MCRIESGR envelo~e occu~antsare Protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inteakaae into the MCRIESGR envelo~eis no areater than the flow rate assumed in the licensinq basis analvses of DBA conseauences. When unfiltered air inleakaae is areater than the assumed flow rate. Condition B must be entered.

Reauired Action B reauires sus~endinathe movement of recentlv irradiated fuel assemblies immediatelv to reduce the risk of exPosure to the MCR/ESGR envelo~eoccwants durina a fuel handinq accident REFERENCES 1. UFSAR, Section 6.4.

2. 10 CFR 50, Appendix A.

3. NUREG-0800, Rev. 2, July 1981,

4. UFSAR, Chapter 15.

5. Control Room Habitabilitv Studv (Su~~lernent to 1980 Onsite Control Room Habitabilitv Studv - North Anna Power Station Units 1 and 2, Januarv 1982)

6. Reaulatorv Guide 1.196

7. NEI 99-03, "Control Room Habitabilitv Assessment," June 2001 8 Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30.2004. "NEI Draft White Pa~er.Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitabilitv."

JADAMS Accession No. ML040300694).

9 Letter from L. N. Hartz (Virainia Electric and Power C o m ~ a n v to )

UNSRC, dated March 31,2004, R e s ~ o n s eto Generic Letter 2003-01 Control Room Habitabilitv Control Room testina and Technical Information North Anna Units 1 and 2 B 3.7.14-6 Revision 2Q