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#REDIRECT [[L-2011-380, License Amendment Request (LAR 194) Control Room Habitability TSTF-448 Response to NRC Questions and LAR 194 Changes]]
| number = ML11304A184
| issue date = 10/27/2011
| title = Turkey Point, Units 3 & 4 - License Amendment Request (LAR 194) Control Room Habitability TSTF-448 Response to NRC Questions and LAR 194 Changes
| author name = Kiley M
| author affiliation = Florida Power & Light Co
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000250, 05000251
| license number =
| contact person =
| case reference number = L-2011-380, TAC ME0004, TAC ME0005, TSTF-448
| document type = Letter
| page count = 23
| project = TAC:ME0004, TAC:ME0005
| stage = Other
}}
 
=Text=
{{#Wiki_filter:Florida Power & Light Company, 9760 S.W. 344 St. Homestead, FL 33035OCT 2 7 2011L-2011-380FPL. 10 CFR 50.90U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, D. C. 20555-0001Re: Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment Request (LAR 194)Control Room Habitability TSTF-448Responses to NRC Questions and LAR 194 Changes(TAC NOS. ME0004 AND ME0005)
 
==References:==
: 1) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-004), "LicenseAmendment Request (LAR 194) -Control Room Habitability TSTF-448, Accession No.ML102010386, July 16, 2010.2) Email from J. Paige (NRC) to Bob Tomonto (FPL), "Requests for Additional Information,"Accession No. ML 1 167A291, June 16, 2011.3) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2011-264), "LicenseAmendment Request (LAR 194) -Control Room Habitability TSTF-448 Requests forAdditional Information, System (TAC Nos. ME0004 and ME0005)," Accession No.ML11202A021, July 18, 2011.4) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2011-276), "SupplementalResponse Regarding LAR 194, Control Room Habitability TSTF-448, and Changes toTechnical Specification 3.7.5, Control Room Emergency Ventilation System (TAC Nos.ME0004 and ME0005)," Accession No. ML1 1215A013, August 1,2011.5) J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4, Issuance of AmendmentsRegarding Alternative Source Term (TAC Nos. ME 1624 and ME 1625)," Accession No.ML 110800666, June 23, 2011.6) Email from J. Paige to Bob Tomonto (FPL), "Acceptable Wording for TSTF-448, a.5"September 6, 20117) Email from J. Paige (NRC) to Bob Tomonto (FPL), "Requests for Additional Information,Round 2" Accession No. ML1 1273A003, September 29, 2011By letter L 2010-004 dated July 16, 2010 [Reference 1], Florida Power and Light (FPL) Companyrequested an amendment to Renewed Facility Operating Licenses DPR-31 and DPR-41 for TurkeyPoint Units 3 and 4 Technical Specifications (TS). The proposed amendment would modify the TSrequirements for Control Room Envelope Habitability in accordance with Technical SpecificationTask Force (TSTF) Change Traveler TSTF-448 Revision 3, "Control Room Habitability."On June 16, 2011, FPL received a Request for Additional Information (RAI) via email [Reference2] from the U.S. Nuclear Regulatory Commission (NRC) Project Manager, Mr. Jason Paige. TheRAI consisted of five questions pertaining to the License Amendment Request (LAR 194). Theresponses to these five questions were provided in FPL letter L-2011-264 dated July 18, 2011[Reference 3] and supplemented by FPL letter L-2011-276 dated August 1, 2011 [Reference 4]
Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Page 2 of 2License Amendment Request (LAR 194)Control Room Habitability TSTF-448Responses to NRC Questions and LAR 194 Changes(TAC NOS. ME0004 AND ME0005)which recognized the NRC's issuance of Amendments 244 and 240 for Alternative Source Term onJune 23, 2011 [Reference 5].On September 2, 2011, a telephone conference call was held between the NRC and FPL TurkeyPoint representatives regarding the responses provided. The NRC representatives included Mr.Jason Paige (NRC Turkey Point Project Manager) and Mr. Harold Walker of the NRC StaffContainment and Ventilation Branch.References 6 and 7 were sent by the NRC to FPL providing additional direction concerning theinformation needed from FPL. Attachment 1 to this letter provides revised responses to the NRCRAI questions. Attachments 2 and 3 provide proposed revisions to the Turkey Point TechnicalSpecifications and Bases as a result of the RAI questions and FPL responses with change bars toindicate the proposed changes.The Turkey Point Plant Nuclear Safety Committee has reviewed the proposed license amendmentchanges. In accordance with 10 CFR 50.91(b)(1), a copy of the proposed amendment changes isbeing forwarded to the State Designee for the State of Florida. The proposed changes have beenevaluated in accordance with 10 CFR 50.91(a)(1), using the criteria in 10 CFR 50.92(c). FPL hasreviewed the proposed no significant hazards consideration determination (NSHCD) published in theFederal Register as part of the CLIIP. FPL has concluded that the proposed NSHCD presented inthe Federal Register notice is applicable to Turkey Point Units 3 and 4 and is hereby incorporated byreference to satisfy the requirements of 10 CFR 50.91 (a). This submittal does not alter the NSHCDor environmental assessment.This submittal contains no new commitments and no revisions to existing commitments.Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto,Licensing Manager, at (305) 246-7327.I declare under penalty of perjury that the foregoing is true and correct.Executed on October 2"7 ,2011.Very truly yours,Michael KileyVice PresidentTurkey Point Nuclear PlantAttachments (2)cc: Regional Administrator, Region II, USNRCUSNRC Project Manager, Turkey Point Nuclear PlantSenior Resident Inspector, USNRC, Turkey Point Nuclear PlantMr. W. A. Passetti, Florida Department of Health Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment RequestControl Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)L-2011-380Attachment 1Page 1 of 4Attachment 1NRC Request for Additional Information -Round 2and FPL Responses Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 1License Amendment Request Page 2 of 4Control Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)NRC REQUEST FOR ADDITIONAL INFORMATION -ROUND 2 and FPL RESPONSESResponses to the NRC Request for Additional Information (RAI) -Round 2 [Reference 7] areprovided below. The responses to the three RAI questions impact the previously submitted proposedTechnical Specification and Bases changes. These changes are provided in Attachments 2 and 3.NRC RAI Question No. 1: With respect to the agreed upon clarification, it is the NRCstaff's understanding that the typical use of the phrase, "testing on the staggered testbasis", refers to testing systems that contain two or more redundant trains of equipmentwhere the redundant trains are to be tested on a staggered test basis. However, inaccordance with your response to the staff's request for additional information dated July18, 2011, we understand that you will be testing redundant components of a single trainevery 36 months on a staggered test basis.You referred to Technical Specification (TS) Surveillance Requirement (SR) 4.7.5.d as thebasis for the Turkey Point yearly recirculation test. Currently, it appears that the onlypurpose of SR 4.7.5.d is to test the pressure drop across the HEPA filter and charcoalabsorber every 12 months at a flow rate of 1000 cfm +/- 10%. We believe it should be madeclear that SR 4.7.5.d has the additional functions of testing components on a staggered testbasis and measuring CRE pressure relative to external areas adjacent to the CRE boundary.It is not clear that measuring the flow rate and pressure drop every 12 months is consistentwith every 36 months on a staggered test basis (i.e. one component every 18 months).FPL RESPONSE/JUSTIFICATION: FPL agreed to clarify the staggered testing to beperformed in accordance with the NRC's request. The proposed Technical SpecificationProcedures and Program Section 6.8.4.k, as amended, provides this clarification.In addition, the proposed Technical Specification Surveillance Requirement 4.7.5.d has beenrevised to add the additional functions of testing components on a staggered test basis andmeasuring CRE pressure relative to external areas adjacent to the CRE boundary.TS Change: TS Surveillance Requirement 4.7.5.dCurrent TSd. At least once per 12 months by verifying that the pressure drop across the combined HEPAfilters and charcoal adsorber banks is less than 6 inches Water Gauge while operating thesystem at a flow rate of 1000 cfm +/- 10%**Proposed TSd.l At least once per 12 months by verifying that the pressure drop across the combined HEPAfilters and charcoal adsorber banks is less than 6 inches Water Gauge while operating thesystem at a flow rate of 1000 cfm +/- 10%* **;d.2 On a staggered test basis every 36 months, test the supply fans (trains A and B) andmeasure CRE pressure relative to external areas adjacent to the CRE boundary.See TS Surveillance Requirement 4.7.5.d.2 markup in Attachnment 2.
Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 1License Amendment Request Page 3 of 4Control Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)NRC RAI Ouestion No. 2: As committed during the September 2, 2011, call, provideacceptable language consistent with the intent of TSTF-448, Revision 3 regarding chemicaland smoke hazards. The suggested wording, "verify mitigating actions ensure CRE occupantradiological and chemical hazards will not exceed limits, and CRE occupants are protectedfrom smoke hazards," in the NRC staff's RAI dated June 16, 2011, is considered acceptable.FPL RESPONSE/JUSTIFICATION: FPL agreed to revise the wording as suggested by theNRC and therefore has revised proposed Technical Specification 3.7.5.b.TS Change: TS Action 3.7.5.bCurrent Proposed TS Action 3.7.5.b (Reference 3)".. verify mitigating actions ensure CRE occupants radiological exposures will not exceed limits,and CRE occupants are protected from chemical and smoke hazards..."Revised Proposed TS Action 3.7.5.b"...verify mitigating actions ensure CRE occupant radiological and chemical hazards will notexceed limits, and CRE occupants are protected from smoke hazards..."See TS Action 3.7.5.b markup in Attachment 2.NRC RAI Ouestion No. 3: Additionally, the reviewer suggested making the basis for TS3.7.5 consistent with the TS language... "...within 42 hrs" vs. "...within 12 hrs and in coldshutdown within the following 30 hours," and revise the a.5 language regarding specificallycalling out mitigating action (acceptable language in an email dated September 6,h).FPL RESPONSE/JUSTIFICATION: FPL agreed to review the basis language and make itconsistent with the TS language. Note the a.5 TS language does not include 42 hours; rather thehours allowed to be in hot standby (6 hours for one unit and 12 hours if both units are affected)and cold shutdown within the following 30 hours. Therefore, no change is proposed to action a.5.Additional TS ChangeTS Change: TS Action 3.7.5.a.5The changes to TS 3.7.5 Action a.5 proposed in FPL letter L-2011-276 [Reference 4] were revisedbased on the September 2, 2011 meeting and the specific language recommended in Reference 6.Current TSa.5 With the filter train inoperable, e.g., an inoperable filter, and/or two inoperable recirculationfans, and/or two inoperable recirculation dampers, immediately suspend all movement ofirradiated fuel, and, immediately, initiate action to implement mitigating actions, and, within24 hours, verify mitigating actions ensure control room occupant radiological exposures willnot exceed limits and, within 7 days, restore the filter train to OPERABLE status.
Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment RequestControl Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)L-2011-380Attachment 1Page 4 of 4Proposed TSa.5 With the filter train inoperable, e.g., an inoperable filter, and/or two inoperable recirculationfans, and/or two inoperable recirculation dampers, irmnediately suspend all movement ofirradiated fuel, and, immediately, initiate action to implement mitigating actions [e.g., use ofthe compensatory filtration unit is required to be immediately initiated], and, within 24hours, verify mitigating actions ensure control room occupant radiological exposures will notexceed limits and, within 7 days, restore the filter train to OPERABLE status.See TS Action 3.7.5.a.5 markup in Attachment 2.
Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment RequestControl Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)L-2011-380Attachment 2Page 1 of 8Attachment 2Technical Specification Markups Turkey Point Units 3 and 4 L-201 1-380Docket Nos. 50-250 and 50-251 Attachunent 2License Amendment Request Page 2 of 8Control Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)PLANT SYSTEMS3F4.7-5 CONTROL ROOM EMERGENCY VENTILATION SYSTEMLIMITING CONDITION FOR OPERATION3.7.5 The Control Room Emergency Ventilation System shall be OPERABL4eIfh:a. Three air handling units,b. Two of three condensing units,c. Two control room recirculation fans,d. Two recirculation dampers,e. One filter train,f. Two isolation dampers in the normal outside air intake duct,g- Two isolation dampers in the emergency outside air intake duct,h. Two isolation dampers in the kitchen area exhaust duct, andi. Two isolation dampers in the toilet area exhaust duct.APPUCABILITY: All MODES.ACTION:MODES 1, 2, 3 and 4-a.i With one air handling unit inoperable, immediately suspend all movement of irradiated fuel and.within 7 days, restore the inoperable air handling unit to OPERABLE status or be in at least HOTSTANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If thisACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLDSHUTDOW'N within the following 30 hours.a2 With two condensing units inoperable, immediately suspend all movement of irradiated fuel and,within 7 days, restore at least one of the inoperable condensing units to OPERABLE status or be inat least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hoursand in COLD SHUTDOWN within the following 30 hours.a.3 With one recirculation fan inoperable, immediately suspend all movement of irradiated fuel and,within 7 days, restore the inoperable fan to OPERABLE status or be in at least HOT STANDBYwithin the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTIONapplies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLDSHUTDOWN within the following 30 hours.t*-he Control Room Envelope (CRE) boundary may be opened intermittently under administntive contolTURKEY POINT- UNITS 3 & 4 314 7-16 AMENDMENT NOS. 244 AND 240 I Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attaclunent 2License Amendment Request Page 3 of 8Control Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND MEOO5)PLANT SYSTEMS3/4.7-5 CONTROL ROOM EMERGENCY VENTILATION SYSTEMLIMITING CONDITION FOR OPERATION (continued)a.4 With one recirculation damper inoperable, immediately suspend all movement of irradiated fuel and,within 7 days, restore the inoperable damper to OPERABLE status or place and maintain at leastone of the recirculation dampers in the open position and place the system, in recirculation mode-or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within thefollowing 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBYwithin 12 hours and in COLD SHUTDOWN within the following 30 hours.a.5 With the filter train inoperable, e.g., an inoperable filter, and/or two inoperable recirculation fans,andfor two inoperable recirculation dampers, Immediately suspend all movement of irradiated fuel,and, immediately, initiate action to implement mitigating actions and, within 24 hours, verifymitigating actions ensure control room occupant radiological e posures will not exceed limits and,within 7 days, restore the filtertrain, to OPERABLE status./Aith the above requirements not met, be in at least HOT ST/N DBY within the next 6 hours and inCOLD SHUTDOWN within the following 30 hours. If this A TION applies to both unitssimultaneously, be in HOT STANDBY within 12 hours an COLD SHUTDOWN within thefollowing 30 hours. i[e.e _ ire of the comperuatoi, filtration tuit is reqired to be immediatel mituted].a.6 With an inoperable damper in the normal outside air intake, immediately suspend all movement ofirradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or place andmaintain at least one of the pomral outside air intake isolation dampers in the closed position andplace the system in recirculation mode* or be in at least HOT STANDBY within the next 6 hoursand in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both unitssimultaneously, be in HOT STANDBY withn 12 hours and in COLD SHUTDOWN within thefollowing 30 hours.a.7 Wrth an inoperable damper In the emergency outside air intake, immediately suspend all movementof irradiated fuel andý, within 7 days, restore the inoperable damper to OPERABLE status or placeand maintain at least one of the emergency outside air intake isolation dampers in the openposition" or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN withinthe following 30 hours- If this ACTION applies to both units simultaneously, be in NOT STANDBYwithin 12 hours and in COLD SHUTDOWN within the following 30 hours.a.8 WIth an isolation damper inoperable in the kitchen area exhaust duct, immediately suspend allmovement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE statusor isolate the flow path" or be in at least HOT STANDBY within the next 6 hours and in COLDSHUTDOWN within the following 30 hours. If this ACTION applies to both, units simultaneously, bein HOT STANDBY within 12 hours and, in, COLD SHUTDOWN within the following 30 hours.a.9 Writh an isolation damper inoperable in the toilet area exhaust duct, immediately suspend allmovement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE statusor Isolate the flomw path- or be in at least HOT STANDBY within the next 6 hours and in COLDSHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, bein HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours."If action is Liken such that indefinite operation is permitted and the system is placed in recirculation mode,then movement of irradiated fuel may resume.TURKEY PO I NT -UNITS 3 & 4314 7-16aAMENDMENT NOS- 244 AND 240 Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment RequestControl Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)L-2011-380Attachment 2Page 4 of 8PLANT SYSTEMS3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEMLIMITING CONDITION FOR OPERATION (continued)MInsert 1ad>MODES 5 and 6: iraiaed limmediately]With the Control Room Emergency -ntilation System inoperab,, suspend all operations involvingCORE ALTERATIONS, movement of'fuel in the spent fuel pool, or positive reactivity changes. ThisACTION shall apply to both units simultaneously.SURVEILLANCE REQUIREMENTS4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:a. At least once per 12 hours by verifying that the control room air temperature is less than or equal to1201F;b. At least once per 31 days by initiating, from the control room, flow through the HEPA filters andcharcoal adsorbers and verifying that the system operates for at least 15 minutes***;c. At least once per 18 months or (1) after 720 hours of system operation, or (2) after any structuralmaintenance on the HEPA filter or charcoal adsorber housings, or (3) following exposure of thefilters to effluents from painting, fire, or chemical release in any ventilation zone communicating withthe system that may have an adverse effect on the functional capability of the system, or (4) aftercomplete or partial replacement of a filter bank by:TURKEY POINT -UNITS 3 & 43/4 7-16bAMENDMENT NOS. 244 AND 240 1 Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment RequestControl Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)L-2011-380Attachment 2Page 5 of 8SLURVE4I_ I ACF REOUIRFMENITS fConrir,"dl1) Verifyirg that the air deanp systemn satisfies the in-place pen etiation and bypassleakage testing acceptance criteria of greater than or eq.ial to 9g% DOP andhalogenated hydrocarbon removal at a system flow rate of t0D1 cfm +/-10%,"',2) Verifying, within 31 days afler removal, that a laboratory analysis ofa represertativecarbon sample obtained in accordance with Regulatory Position C.6.b of RegulatoryGuide 1.52, Revision 2. March 1978. and analyzed per ASTM D3803 -1989 at 300C and95% relatve humidity, meets the methyt iodide penetrali on criteria of lass than 2-5% orthe charcoal be r placed with charcoal that meets or exceeds the stated equuirenrenrt. and3) Verifying by a visual inspection the absence of foreign materials and gasktdeterioration'*.I At least once par 12 months by verifying that the pressure drop across the combined HEPA Otltersand clhacoal adsorber hbars is less than 5 inches Water Gauge while operating the systemat aflow rate of 1000 cfrn +/-10%-*°;//At Ileast once per 18 months by verifying [hat on a Containm'ent Phase WA I solation test signal thesystem automatically switches into the mode of operation, andAt least once per 18 rrnths by verifying operaility ofte kildlchan r, toilet area exhaust damperd.d-2 On a taggered rest every 36 months, teat the supply fans (trains A and B),and measure CREpressure relative to external areas adjacent to the G'RE boundary.g By performing required CRE unfiltered air inleakage testina in accordance with theControl Room Envelope Habitability ProgranL-As the mitigation actions of TS 3.7.5 Action a.5 may include the use of the connpensatoiy filtration unit, tie unitshall met the suivemlanog mqulrernents of TS 4.75.b, by rmanual Initiation from outside the room and TS4.7.5.c and d.TURKEY POINT -UNIIS 3 & 4V,4 717U I TAMENDMENT NOS. 244 AND 240 Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 2License Amendment Request Page 6 of 8Control Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)ADMINISTRATIVE CONTROLSPROCEDURES AND PROGRAMS (Continued)d. Provisions for SG tube inspections. Periodic SG tube inspections shall be performed.The number and portions of the tubes inspected and methods of inspection shall beperformed with the objective of detecting flaws of any type (e.g., volu metric flaws, axialand circumferential cracks) that may be present along the length of the tube, from thetube-to-tubesheet weld at the lube inlet to the tube-to-tubesheet weld at the lube outlet,and that may satisfy the applicable tube repair criteria. For Unit 3 through RefuelingOutage 25 and the next operating cycle, and for Unit 4 during Refueling Outage 25 andthe subsequent operating cycles until the next scheduled inspection, the portion of thetube below 17.28 inches from the top of the tubesheet is excluded from inspection. Thetube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements ofdV, d.2, and d.3 below, the inspection scope, inspection methods, and inspectionintervals shall be such as to ensure that SG tube integrity is maintained until the next SGinspection. An assessment of degradation shall be performed to determine the type andlocation of flaws to which the tube may be susceptible and, based on this assessment, todetermine which inspection methods need to be employed and at what locations.1. Inspect 100% of the tubes in each SG during the first refueling outage followingSG replacement.2. Inspect 100% of the.tubes at sequential periods of 120, 90, and, thereafter, 60effective full power months. The first sequential period shall be considered tobegin after the first inservice inspection of the SGs. In addition, inspect 50% ofthe tubes by the refueling outage nearest the midpoint of the period and theremaining 50% by the refueling outages nearest the end of the period. No SGshall operate for more than 48 effective full power months or two refuelingoutages (whichever is less) without being inspected.3. If crack indications are found in any portion of a SG tube not excluded above,then the next inspection for each SG for the degradation mechanism that causedthe crack indication shall not exceed 24 effective full power months or onerefueling outage (whichever is less). If definitive information, such as fromexamination of a pulled tube, diagnostic non-destructive testing, or engineeringevaluation indicates that a crack-like indication is not associated with a crack(s),then the indication need not be treated as a crack.e. Provisions for monitoring operational primary-secondary leakage.6.8.5 DELETEDTURKEY POINT -UNITS 3 & 46-18bAMENDMENT NOS.-24-1 AND 2,,6 Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 2License Amendment Request Page 7 of 8Control Room Habitability TSTF-448Requests for Additional Information(TAC NOS. ME0004 AND ME0005)INSERT 1b. With the Control Room Emergency Ventilation System inoperable due to aninoperable CRE boundary, immediately suspend all movement of irradiated fuel inthe spent fuel pool, and immediately initiate action to implement mitigating actions,and within 24 hours, verify mitigating actions ensure CRE occupant radiological andchemical hazards will not exceed limits, and CRE occupants are protected from smokehazards, and restore CRE boundary to OPERABLE status within 90 days, or:1. With the requirements not met be in at least HOT STANDBY within the next 6hours and in COLD SHUTDOWN within the following 30 hours.2. If this ACTION applies to both units simultaneously, be in HOT STANDBYwithin 12 hours and in COLD SHUTDOWN within the following 30 hours.INSERT 2k. Control Room Envelope Habitability ProgramA Control Room Envelope (CRE) Habitability Program shall be established andimplemented to ensure that CRE habitability is maintained such that, with anOPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupantscan control the reactor safely under normal conditions and maintain it in a safecondition following a radiological event, hazardous chemical release, or a smokechallenge. The program shall ensure that adequate radiation protection is provided topermit access and occupancy of the CRE under design basis accident (DBA) conditionswithout personnel receiving radiation exposures in excess of 5 rem total effective doseequivalent (TEDE) for the duration of the accident.The program shall include the following elements:a. The definition of the CRE and the CRE boundary.b. Requirements for maintaining the CRE boundary in its design conditionincluding configuration control and preventive maintenance.c. Requirements for (i) determining the unfiltered air inleakage past the CREboundary into the CRE in accordance with the testing methods and at theFrequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197,"Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors,"Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequenciesspecified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.
Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attaclhmnent 2License Amendment Request Page 8 of 8Control Room Habitability TSTF-448Requests for Additional Infonnation(TAC NOS. ME0004 AND ME0005)d. Measurement, at designated locations, of the CRE pressure relative to externalareas adjacent to the CRE boundary during the pressurization mode ofoperation of the CREVS, operating at the flow rate required by SurveillanceRequirement 4.7.5.d, at a Frequency of 18 months. Additionally, the supply fans(trains A and B) will be tested on a staggered test basis (defined in TechnicalSpecification definition 1.29 every 36 months. The results shall be trended andthe CRE boundary assessed every 18 months.e. The quantitative limits on unfiltered air inleakage into the CRE. These limitsshall be stated in a manner to allow direct comparison to the unfiltered airinleakage measured by the testing described in paragraph c. The unfiltered airinleakage limit for radiological challenges is the inleakage flow rate assumed inthe licensing basis analyses of DBA consequences. Unfiltered air inleakagelimits for hazardous chemicals must ensure that exposure of CRE occupants tothese hazards will be within the assumptions in the licensing basis.f. The provisions of Specification 4.0.2 are applicable to the Frequencies forassessing CRE habitability, determining CRE unfiltered inleakage, andmeasuring CRE pressure and assessing the CRE boundary as required byparagraphs c and d, respectively.
Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment RequestControl Room Habitability TSTF-448(TAC NOS. ME0004 AND ME0005)L-2011-380Attachment 3Page 1 of 9Attachment 3Technical Specification Bases Markups(Information Only)
Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 3License Amendment Request Page 2 of 9Control Room Habitability TSTF-448(TAC NOS. ME0004 AND ME0005)90': Ixed= TiP , Peta.geI 10!I Aflxmf'll O-ADM-536 Technical Specification Bases Control Program 6/14I1 IATTACHMENT I(Page 90 of 114)TECHNICAL SPECIFICATION BASES3/4.7.4 Uttihate Heat SinkThe limit on ultimate heat sink (UHS) temperature in conjunction with theSURVEILLANCE REQUIREMENTS of Technical Specification 3/4.7.2 will ensure thatsufficient cooling capacity Ls available either: (!) To provide, norial cooldown of thefacility, or (2) To mitigate the effects of accident conditions within acceptable limits.FPL has the option of monitoring the UHIS temperature by monitoring the temterature inthe ICW system piping going to the inlet of die CCW heat exchargers. Monitorinkg theUHS temperature after the IC(W but prior to CCW heat exchangers is cortsidered to beequivalent to temperature monitoring before the ICW pumps. The supply water leaving theICW pumps will be mixed and therefore, it will be representative of the bulk UMIStemperature to the (C(CW heat exchanger "The effects of the pamp heating on thesupply water are negligible due to low ICW head and high water volnie. Accordingly,monitoring the UH-IS temperature after the IC(W pumpsq but prior to the CCW heatexchangers providesan equivalent location for monitoring the UHS temperature.With the implementation of the. CCW heat exchanger performance, monitoring program, thelimiting UHS temperature can be treated xa a variable with an absolute upper himit of1O0"F without compromnsing any margin of safety. Demonstration of actual heatperfbrmance capability supports sstem operation with postulated canaltemperatures greater than 100'F. Therefore, an upper Technical Specificatilno limit oflenvelope (CREc.a3/4.7.5 control Room Emereencv Ventilation Sy-stem(The OP 'REkIjULTY of the Control Room Emergency V ntilation Svstemtnenure-s that:(I) he ambient air temperature does not exceed e albowaalbe temperature forcontdnuous-dut ra.tirg fbr the equipment and instmmen, cooled by this system, and(2) Trhe eontrol moilt will remain habitable for -during and following-. dibe --, ex c:tt ze:ajfita .The OPERABILITY of fit system in conjunction withSkontrol room design provisions is based on limiting the radiation exposure to personneloccupying the em.nrral rczn;f to 5 rcrns ar kof less whoe bc, iu_, inaln. Mtlimtht , nl4#C ffl P*9. lin1 o3pen~Aan uncontrolled release of radioactiity,hazardous chemicals or smoke.I Ia Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 3License Amendment Request Page 3 of 9Control Room Habitability TSTF-448(TAC NOS. ME0004 AND ME0005)1O2I Pa~eIrAprpcn-J DOa.:O-ADIM-536 Trclnical Specification Bases Control Program 6/14/1 IATTACH ME NT I(rage 91 of 114)dTECFLNICAL SPECIFICATION BASES3/4.7.5 (Conrid)Ithe vz Mtre fxltie a nt ~ pzat,2 w~za e4 u.its 6twoou of dthrccvilbl akit.~~i.L a 'fzac it:ut aperbz 4) 4:,o.zzalation haozalet and A~aze~te dznpzn o-abk. The easall .threAJI.s r zLz ata ntoceto i~ 4blz any iso A~Woui beov;l~bz o spp .a lto to uoo. ot Tezutatian tptor 1n seh; +-lttI---lieco~f~u.at~t; t.~td t sU7j~&t Tzluzal~pcztiztio op-ablty cg low ~robi' thSystem compoAents are odot subject to rapid deterioratior naving lifetimes of aay yearseven taider continuous flow cmonditionmn. Visual itnpection at{a operating oests providehuatrace of u ynter L and will early detection of conditions whih couldcause the :systen to NI or operate improperly. The fifters performance tesut prove thatfilters have been properly installed, that no deterioration or damage has occurred, and that:all components and subsystems operate properly. The in-shtu tests are pertformed inaccordance with the methodology and intent of ANSI N510 (1975) and provide assurancethat filter performance has not deteriorated below returned specification values due toaging, contamination, or other effects. Charcoal samples are tested using ASTMD3803- 1989 int accordance w'ith Generic Letter 99-02. The test conditions (30*C and 95%relative humrnidity) are as specified in the Generic Letter. Table I of the ASTM standardprovides the tolerances that must be met during the test tbr each test parameter. Thespecified methyl iodide penetration value is based on die assumptions used in theLOCA Analysi.3/4.7.6 SnubtxsAll snubbers are required OPERABLE to ensure that the structural integrity, of the ReactorCoolant Systetm and all other safety-related systerms is maintained during and following aseismic or other event initiating dynamic loads,The visual frequency is based upon maintaining a constant level of snubberprotection to each safety-related system during an earthquake or severe transmeltLTherefore, the required ittspectio interval varies inversely with the observed snubberfailures and is determined by the number of inoperable snubbers found during aninspection. Imspections performed before that interval has elapsed may be used as a newreference point to determine the next inspection. However, the results of such earlyinspections performed before the original required time interval has elapsed (nominal timeless 25,%') may not be used to lengthen the required in-section interval. Any inspectionwhose rezults require a shorter inspection hiterval will override the previous, scliedule.
Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 3License Amendment Request Page 4 of 9Control Room Habitability TSTF-448(TAC NOS. ME0004 AND ME0005)INSERT 3CRE to 5 rem. total effective dose equivalent (TEDE) for the duration of the accident. Theradiological limits are consistent with the requirements of 10 CFR Part 50.67. CRE occupantsare protection from chemical hazards in accordance with the limits of Regulatory Guide 1.78.INSERT 4The Control Room Emergency Ventilation System (CREVS) is considered to beOPERABLE (Ref: JPNPTNSENP-92-017) when 1) Three air handling units (AHUs)(three out of three) are operable, 2) Two condensing (air conditioning (A/C)) units (two outof three) are operable, 3) Two recirculation fans are operable, 4) Two recirculation dampersare operable, 5) One recirculation filter unit is operable, 6) Two normal outside air intakedampers are operable, 7) Two emergency outside air intake dampers are operable, 8) Twoisolation dampers (one motor-operated damper and one gravity backdraft damper) in thekitchen area exhaust duct are operable, and 9) Two isolation dampers (one motor-operateddamper and one gravity backdraft damper) in the toilet area exhaust duct are operable.The reason three AHUs are required is that in the event of a single failure, only two AHUswould be available to supply air to the suction of the recirculation filter and fan. This is theconfiguration tested to support Technical Specification operability for flow through theemergency charcoal filter unit. Taking one AHU out of service renders the system incapableof operating in accordance with the tested configuration assuming an accident and a singlefailure, i.e., only one air handling unit available instead of the two assumed in the analysis.Any one of the three condensing (A/C) units is capable of maintaining control roomequipment within environmental limits for temperature and humidity. Thus, onecondensing unit can be taken out of service without impacting the ability of CREVS toaccomplish its intended function under single failure conditions.The LCO actions allow inoperability of the redundant active CREVS components (oneAHU, two condensing units, one recirculation fan, one recirculation damper, one normaloutside air intake damper, and/or one emergency outside air intake damper) for a period ofup to 7 days consistent with the approach provided in the Westinghouse StandardTechnical Specifications and based on the low probability of occurrence of a Design BasisAccident (DBA) challenging the Control Room Habitability during this time period and thecontinued capability of the remaining operable system components to perform the requiredCREVS safety function. When the motor-operated isolation damper in a kitchen or toiletarea exhaust duct becomes inoperable, the damper is required to be restored to operabilitywithin 7 days or a damper in the flow path be closed (either the motor-operated damper orits associated manual isolation damper) until it can be restored to operability. This 7 dayAOT is predicated on continued operability of its associated gravity backdraft damper.When one damper in the normal outside air intake is inoperable, it can either be restoredwithin 7 days or one of the two in-series dampers closed and CREVS run in recirculationmode. When one recirculation damper is inoperable, it can either be restored or one of thetwo paralleled dampers opened and the CREVS run in recirculation mode. With one or both Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 3License Amendment Request Page 5 of 9Control Room Habitability TSTF-448(TAC NOS. ME0004 AND ME0005)emergency outside air intake dampers inoperable, they can either be restored or openedwithout adversely impacting the normal or emergency mode of operation. (See TSA 03-03-025-024 for evaluation). The placement of the dampers in their "fail-safe" position in lieu ofrestoration is allowed as the dampers fail "as-is" in the event of loss of offsite power (except forthe emergency outside air intake dampers which go to their emergency "open" position) andare in their emergency mode position in the event of receipt of an emergency actuation signal.As indicated in LCO footnote, if an action is taken such that indefinite operation ispermitted (a.4, a.6, a.7, a.8, a.9) and the system is placed in recirculation mode, thenmovement of irradiated fuel is allowed. Although still technically in the Action due tocomponent inoperability, system configuration, as modified, satisfies the design requirementto support system emergency operation with ability to withstand a single active failure.When the filter train is inoperable, e.g., the filter is inoperable, and/or two recirculationfans are inoperable, and/or two recirculation dampers are inoperable, all movement of fuelin the spent fuel pool is required to be immediately suspended and mitigating actions, e.g.,use of compensatory filtration unit, are required to be immediately initiated, and, within 24hours, the mitigating actions are required to be verified to be in place to ensure the controlroom occupant radiological exposures will not exceed limits, e.g., the compensatoryfiltration unit is placed into service, and, within 7 days, the inoperable filter train isrequired to be restored to OPERABLE status. The 24 hour allowance is reasonable basedon the low probability of a DBA occurring during this time period, and the use ofmitigating actions, i.e., compensatory filtration unit. The 7 day AOT is reasonable basedon the determination that the mitigating actions will ensure protection of Control Roomoccupants within analyzed limits. In addition, the 7 day AOT is a reasonable time todiagnose, plan, repair, and test most problems with the inoperable filter train.The compensatory filtration unit is designed as a manual, safety-related, Seismic Class Ibackup to the installed system with the same functional and operational capabilities as theinstalled filter train. In addition, the unit is surveillance tested in accordance with the samerequirements as those imposed on the installed filter train per TS 4.7.5.b, c, and d exceptthat the requirements of TS 4.0.1 -4.0.4 do not apply to the compensatory unit as it is notincluded in CREVS LCO.Regarding exposure of the filters to effluents that may have an adverse effect on thefunctional capability of the system, painting, fire, or chemical releases are considered "notcommunicating" with the HEPA filter or adsorber if the system is not in operation, theisolation dampers for the system are closed, and there is no pressure differential across thefilter housing. This provides reasonable assurance that air is not passing through thefilters and adsorbers.In addition, the CREVS includes the emergency outside air intakes, located beyond thesoutheast and northeast corners of the Auxiliary Building. The CREVS emergency outsideair intakes are considered OPERABLE when: 1) both flow paths are available, 2) havebalanced intake flow rates and 3) a flow path capable of drawing outside makeup air from Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 3License Amendment Request Page 6 of 9Control Room Habitability TSTF-448(TAC NOS. ME0004 AND ME0005)only the analyzed intake locations. The alternative source term radiological analysesassume both emergency outside air intake flow paths are available with parallel dampersensuring outside makeup air can be drawn through both intake locations during a designbasis accident and a single active failure. These analyses rely on a provision in RegulatoryGuide 1.194 Section 3.3.2 that allows a reduction in the atmospheric dispersion factors(X/Qs) for dual intake arrangements with balanced flow rates to one half of the morelimiting X/Q value provided the two intakes are not within the same wind direction windowfor each release / receptor location. Accordingly, any maintenance on the emergencyoutside intake dampers or associated duct work that would prevent the CREVS fromaccomplishing these functions would require entering action statement a.7. The provisionsof LCO 3.0.6 apply to the surveillance testing required to demonstrate operability of theemergency intake flow paths.INSERT 5Turkey Point Units 3 and 4 share a common CRE. The CRE is the area within the confines ofthe CRE boundary that contains the spaces that control room occupants inhabit to control theunits during normal and accident conditions. This area encompasses the control room,including the control room offices, rack area, kitchen and lavatory, and the mechanicalequipment room (MER) located below the control room. The MER contains the CREVSequipment. The CRE is protected during normal operation, natural events, and accidentconditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors,penetrations, and equipment that physically form the CRE. The OPERABILITY of the CREboundary must be maintained to ensure that the inleakage of unfiltered air into the CRE willnot exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA)consequences, and that CRE occupants are protected from hazardous chemicals and smoke.The CRE and its boundary are defined in the Control Room Envelope Habitability Program.The location of CREVS components and ducting within the CRE ensures an adequate supplyof filtered air to all areas requiring access. The CREVS filter train provides airborneradiological protection for the CRE occupants, as demonstrated by occupant dose analyses forthe most limiting design basis accident fission product release presented in the UFSAR,Chapter 14.The CREVS provides protection from and chemical hazards as well as protecting the CREoccupants from smoke hazards. The CREVS pressurizes the CRE relative to external areasadjacent to the CRE boundary. The analysis of hazardous chemical releases for NUREG-0737Item III.D.3.4, "Control Room Habitability Requirement," and the subsequent reanalysisincluded in PC/M 06-004, "Addition of Unit 5 to the Turkey Point Site," for new chemicalrelease hazards demonstrate that the toxicity limits of Regulatory Guide 1.78 are not exceededin the CRE following a hazardous chemical release. Therefore, neither automatic nor manualactuation of the CREVS is required for an analyzed hazardous chemical release. The analysisof a smoke challenge demonstrates that it will not result in the inability of the CRE occupantsto control the reactors either from the control room or from the alternate shutdown panels.
Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 3License Amendment Request Page 7 of 9Control Room Habitability TSTF-448(TAC NOS. ME0004 AND ME0005)In order for the CREVS to be considered OPERABLE, the CRE boundary must bemaintained such that the CRE occupant dose from a large radioactive release does not exceedthe calculated dose in the licensing basis consequence analyses for DBAs, and that CREoccupants are protected from hazardous chemicals and smoke. With respect to radiologicalemergencies, the CREVS is designed as a single filtration train that is capable of automaticallystarting under accident conditions to initiate CRE pressurization and filtration, assuming theoccurrence of a single active damper or supply fan failure. For other emergencies that couldaffect the CRE environment, the CREVS is capable of manual actuation.The LCO is modified by a Note allowing the CRE boundary to be opened intermittently underadministrative controls. This Note only applies to openings in the CRE boundary that can berapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels.For entry and exit through doors, the administrative control of the opening is performed bythe person(s) entering or exiting the area. For other openings, these controls should beproceduralized and consist of stationing a dedicated individual at the opening who is incontinuous communication with the operators in the CRE. This individual will have a methodto rapidly close the opening and to restore the CRE boundary to a condition equivalent to thedesign condition when a need for CRE isolation is indicated.The CREVS must be OPERABLE to ensure that the CRE will remain habitable to limitoperator exposure during and following a DBA. Since the CREVS and CRE are common toboth Turkey Point Units 3 and 4, the ACTION requirements are applicable to both unitssimultaneously, and must be applied according to each unit's operational MODE.If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into theCRE can result in CRE occupant radiological dose greater than the calculated dose of thelicensing basis analyses of DBA consequences (allowed to be up to 5 rem total effective doseequivalent -TEDE) or inadequate protection of CRE occupants from hazardous chemicals orsmoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLECRE boundary within 90 days when in MODE 1, 2,3, or 4.During the period that the CRE boundary is considered inoperable in MODE 1, 2, 3, or 4,immediately initiate action to implement mitigating actions to lessen the effect on CREoccupants from the potential hazards of a radiological or chemical event or a challenge fromsmoke. Actions must be taken within 24 hours to verify that in the event of a DBA, themitigating actions will ensure that CRE occupant radiological exposures will not exceed thecalculated dose of the licensing basis analyses of DBA consequences, and that CRE occupantsare protected from hazardous chemicals and smoke. Previous surveys of offsite and onsitechemicals identified that no hazardous chemicals present a hazard to control roomhabitability. Therefore, the mitigating action for chemical hazards may verify that thechemical hazards analyses are current and require no toxic gas protection for the CREoccupants. These mitigating actions (i.e., actions that are taken to offset the consequences ofthe inoperable CRE boundary) should be preplanned for implementation upon entry into thecondition, regardless of whether entry is intentional or unintentional. The 24 hour allowableoutage time (AOT) is reasonable based on the low probability of a DBA occurring during this Turkey Point Units 3 and 4 L-2011-380Docket Nos. 50-250 and 50-251 Attachment 3License Amendment Request Page 8 of 9Control Room Habitability TSTF-448(TAC NOS. ME0004 AND ME0005)time period, and the use of mitigating actions. The 90 day AOT is reasonable based on thedetermination that the mitigating actions will ensure protection of CRE occupants withinanalyzed limits while limiting the probability that CRE occupants will have to implementprotective measures that may adversely affect their ability to control the reactors and maintainthem in a safe shutdown condition in the event of a DBA. In addition, the 90 day AOT is areasonable time to diagnose, plan and possibly repair, and test most problems with the CREboundary.In MODE 1, 2, 3, or 4, if the inoperable CREVS or the CRE boundary cannot be restored toOPERABLE status within the associated required AOT, the unit must be placed in a MODEthat minimizes the accident risk. To achieve this status, the unit must be placed in at leastMODE 3 (HOT STANDBY) within 6 hours, and in MODE 5 (COLD SHUTDOWN) within 36hours. If the inoperability applies to both units simultaneously, be in MODE 3 within 12hours, and in MODE 5 within 42 hours. The AOTs are reasonable, based on operatingexperience, to reach the required unit conditions from full power conditions in an orderlymanner and without challenging unit systems.In MODE 5 or 6, with the CREVS inoperable for an inoperable CRE boundary or for otherreasons, action must be taken immediately to suspend all operations that could result in arelease of radioactivity that might require isolation of the CRE, such as movement ofirradiated fuel. This places the unit in a condition that minimizes the accident risk. This doesnot preclude the movement of fuel to a safe position. These ACTION requirements apply toboth units simultaneously.Surveillance Requirement (SR) 4.7.5.f verifies the OPERABILITY of the CRE boundary bytesting for unfiltered air inleakage past the CRE boundary and into the CRE. The details ofthe testing are specified in the Control Room Envelope Habitability Program.The CRE is considered habitable when the radiological dose to CRE occupants calculated inthe licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CREoccupants are protected from hazardous chemicals and smoke. SR 4.7.5.f verifies that theunfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensingbasis analyses of DBA consequences. When unfiltered air inleakage is greater than theassumed flow rate, ACTION b must be entered (ACTION c must also be entered with a unit inMODE 5 or 6). ACTION b allows time to restore the CRE boundary to OPERABLE statusprovided mitigating actions are taken while in MODES 1-4, that ensures that the CRE remainswithin the licensing basis habitability limits for the occupants following an accident.Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, whichendorses, with exceptions, NEI 99-03 (June 2001), Section 8.4 and Appendix F. Thesecompensatory measures may also be used as mitigating actions as required by ACTION b.Temporary analytical methods may also be used as compensatory measures to restoreOPERABILITY, as discussed in a letter from Eric J. Leeds (NRC) to James W. Davis (NEI)dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process andAlternative Source Terms in the Context of Control Room Habitability" (ADAMS AccessionNo. ML040300694). Options for restoring the CRE boundary to OPERABLE status include Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment RequestControl Room Habitability TSTF-448(TAC NOS. ME0004 AND ME0005)L-2011-380Attachment 3Page 9 of 9changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or acombination of these actions. Depending upon the nature of the problem and the correctiveaction, a full scope inleakage test may not be necessary to establish that the CRE boundary hasbeen restored to OPERABLE status.
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