ML060730331

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Draft Input for Revision 3 to STS Change Traveler TSTF-448, Control Room Habitability
ML060730331
Person / Time
Issue date: 03/10/2006
From:
Technical Specifications Task Force
To:
Office of Nuclear Reactor Regulation
Harbuck C, NRR/DIRS/301-415-3140
Shared Package
ML060730317 List:
References
Download: ML060730331 (100)
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{{#Wiki_filter:TSTF-448, Rev. 3, Draft Markup CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilation System (CREVS) LCO 3.7.10 Two CREVS trains shall be OPERABLE. 

  ---------------------------------------------NOTE--------------------------------------------   The control room envelope (CRE) boundary may be opened intermittently under administrative control.   --------------------------------------------------------------------------------------------------

APPLICABILITY: MODES 1, 2, 3, and 4, [5, and 6], [During movement of [recently] irradiated fuel assemblies]. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREVS train inoperable for reasons other than Condition B. A.1 Restore CREVS train to OPERABLE status. 7 days B. TwoOne or more CREVS trains inoperable due to

inoperable control room CRE boundary in MODE 1, 2, 3, or 4. B.1 Initiate action to implement mitigating actions. AND B.2 Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits. AND B.1 3 Restore control room CRE boundary to OPERABLE

status. Immediately 24 hours 60 days 24 hours BWOG STS 3.7.10-1 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREVS 3.7.10 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion

Time of Condition A or B not met in MODE 1, 2, 3, or 4. C.1 Be in MODE 3. AND C.2 Be in MODE 5. 6 hours 36 hours D. [ Required Action and associated Completion

Time of Condition A not

met [in MODE 5 or 6, or] during movement of [recently] irradiated fuel assemblies. D.1 --------------NOTE--------------- Place in emergency mode if automatic transfer to emergency mode

inoperable. ------------------------------------- Place OPERABLE CREVS train in emergency mode. OR D.2 Suspend movement of [recently] irradiated fuel assemblies. Immediately Immediately ] E. [ Two CREVS trains inoperable [in MODE 5 or 6, or] during movement of [recently] irradiated fuel assemblies. OR One or more CREVS trains inoperable due to an inoperable CRE boundary [in Mode 5 or 6, or] during movement of [recently] irradiated fuel assemblies. E.1 Suspend movement of [recently] irradiated fuel assemblies. Immediately ] BWOG STS 3.7.10-2 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREVS 3.7.10 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREVS trains inoperable during MODE 1, 2, 3, or 4 for reasons other than

Condition B. F.1 Enter LCO 3.0.3. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREVS train for [ 10 continuous hours with the heaters operating or (for system without heaters) 15 minutes]. 31 days SR 3.7.10.2 Perform required CREVS filter testing in accordance with the [Ventilation Filter Testing Program (VFTP)]. In accordance with the [VFTP] SR 3.7.10.3 Verify [each CREVS train actuates] [or the control room isolates] on an actual or simulated actuation

signal. [18] months SR 3.7.10.4 Verify one CREVS train can maintain a positive pressure of [0.125] inches water gauge relative to the adjacent [area] during the [pressurization] mode of operation at a flow rate of [3300] cfm. [18] months on a STAGGERED TEST BASIS SR 3.7.10.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program In accordance with the Control Room Envelope Habitability Program SR 3.7.10.5 [ Verify the system makeup flow rate is [270] and [330] cfm when supplying the the control room with outside air. 

 [18] months ]

BWOG STS 3.7.10-3 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 Containment Leakage Rate Testing Program (continued)

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.

5.5.17 Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, based on [the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer] including the following:

a. Actions to restore battery cells with float voltage < [2.13] V, and
b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

5.5.18 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented in accordance with the guidelines contained in Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, May 2003, Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release," Revision 1, December 2001. 

 [The following are exceptions to Regulatory Guide 1.196, Revision 0:
1.  ; and]
  [The following are exceptions to Regulatory Guide 1.197, Revision 0:
1.  ; and]
 [The following are exceptions to Regulatory Guide 1.78, Revision 1:
1.  ; and]

BWOG STS 5.5-14 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.18 Control Room Envelope Habitability Program (continued) The CRE Habitability Program shall ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely 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 occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of [5 rem whole body or its equivalent to any part of the body] [5 rem total effective dose equivalent (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 CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for assessing CRE habitability at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
d. Requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
e. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREVS, operating at the flow rate required by the VFTP, at a Frequency of [18] months on a STAGGERED TEST BASIS. The results shall be trended and compared to the pressure measurements at all locations taken during the previous CRE inleakage testing. These evaluations shall be used as part of an assessment of the CRE boundary between CRE inleakage tests.
f. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph d. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemical and smoke challenges must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

BWOG STS 5.5-15 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 BWOG STS 5.5-16 Rev. 3.0, 03/31/04 5.5 Programs and Manuals 5.5.18 Control Room Envelope Habitability Program (continued)

g. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c, d, and e, respectively.

TSTF-448, Rev. 3, Draft Markup CREVS B 3.7.10 BWOG STS B 3.7.10-1 Rev. 3.0, 03/31/04 B 3.7 PLANT SYSTEMS B 3.7.10 Control Room Emergency Ventilation System (CREVS) BASES BACKGROUND The CREVS provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity , hazardous chemicals, or smoke. 

[chemicals, or toxic gas].

The CREVS consists of two independent, redundant trains that recirculate and filter the air in the control room envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air . redundant, fan filter assemblies. Each CREVS filter train consists of a roughing filter, a water condensing unit, a high efficiency particulate air (HEPA) filter, and a charcoal filter for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system , train consists of a roughing filter, a high efficiency particulate air (HEPA) filter, and a charcoal filter. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit for normal and accident conditions. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected for normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program. The CREVS is an emergency system. Upon receipt of the activating signal(s), the normal CRE control room ventilation system is automatically shut down and the CREVS can be manually started. The roughing filters and water condensing units remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the HEPA and charcoal filters. A single CREVS train operating at a flow rate of [3300] cfm will pressurize the CRE control room with a 1.5 ft 2 LEAKAGE area to about 1/8 inch water gauge relative to all external areas adjacent to the CRE boundary. The CREVS operation in maintaining the CRE habitable is discussed in the FSAR, Section [9.4] (Ref. 1). TSTF-448, Rev. 3, Draft Markup B 3.7.10 BWOG STS B 3.7.10-2 Rev. 3.0, 03/31/04 CREVS BASES BACKGROUND (continued) The CREVS is designed to maintain a habitable environment in the CRE control room for 30 days of continuous occupancy after a Design Basis Accident (DBA), without exceeding a [5 rem whole body dose or its equivalent to any part of the body ] [5 rem total effective dose equivalent (TEDE)]. APPLICABLE The CREVS components are arr anged in redundant safety related SAFETY ventilation trains. The location of components and ducting within the ANALYSES control room envelope CRE ensures an adequate supply of filtered air to all areas requiring access. The CREVS provides airborne radiological protection for CRE occupants the control room operators as demonstrated by the CRE occupant control room accident dose analyses for the most limiting design basis loss of coolant accident fission product release presented in the FSAR, Chapter [15] (Ref. 2). The worst case single active failure of a CREVS component, assuming a loss of offsite power, does not impair the ability of the system to perform its design function. 

[ For this unit, there are no sources of toxic gases or chemicals that could be released to affect CRE control room habitability. ]

The CREVS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO Two independent and redundant CREVS trains are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other train. Total CREVS system failure , such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem to the control room operators 

[5 rem whole body or its equivalent to any part of the body] [5 rem TEDE]

to CRE occupants in the event of a large radioactive release. The Each CREVS train is considered OPERABLE when the individual components necessary to control operator limit CRE occupant exposure are OPERABLE in both trains. A CREVS train is considered OPERABLE when the associated:

a. Fan is OPERABLE, b. HEPA filter and charcoal absorber are not excessively restricting flow, and are capable of performing their filtration functions, and TSTF-448, Rev. 3, Draft Markup B 3.7.10 BWOG STS B 3.7.10-3 Rev. 3.0, 03/31/04 CREVS BASES LCO (continued)
c. Heater, demister, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In addition, the control room boundary, including the integrity of the walls, floors, ceilings, ductwork, and access doors, must be maintained within the assumptions of the design analys is. In order for the CREVS trains to be considered OPERABLE, the CRE boundary must be maintained such that CRE occupant dose from a large radioactive release does not exceed the calculated dose of the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke. The LCO is modified by a Note allowing the CRE control room boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly 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 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 operators in the CRE control room. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE control room isolation is indicated. APPLICABILITY In MODES 1, 2, 3, and 4, [5, and 6,] and during movement of [recently] irradiated fuel assemblies, the CREVS must be OPERABLE to ensure that the CRE control room will remain habitable during and following a DBA. During movement of [recently] irradiated fuel assemblies, the CREVS must be OPERABLE to cope with a release due to a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, CREVS is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)]. TSTF-448, Rev. 3, Draft Markup CREVS B 3.7.10 BWOG STS B 3.7.10-4 Rev. 3.0, 03/31/04 BASES ACTIONS A.1 With one CREVS train inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREVS train is adequate to perform the control room radiation protection function. However, the overall reliability is reduced because a failure in the OPERABLE CREVS train could result in loss of CREVS 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 train to provide the required capability. B.1 -----------------------------------REVIEWER'S NOT E-----------------------------------Adoption of Condition B is dependent on a commitment from the licensee to have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into Conditi on B. -------------------------------------------------------------------------------------------------- If the control room boundary is inoperable in MODE 1, 2, 3, or 4, the CREVS trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE control room boundary within 24 hours. During the period that the control room boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from p otential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour 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 hour Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary. B.1, B.2 and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE]), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is considered inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 60 days. TSTF-448, Rev. 3, Draft Markup CREVS B 3.7.10 BWOG STS B 3.7.10-5 Rev. 3.0, 03/31/04 BASES ACTIONS (continued) During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. The mitigating actions should also address maintaining temperature and relative humidity within limits, and physical security. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 60 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protec tive measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 60 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary. C.1 and C.2 In MODE 1, 2, 3, or 4, if the inoperable CREVS train or the CRE control room boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. [ D.1 and D.2 

 [In MODE 5 or 6, or] during movement of [recently] irradiated fuel assemblies, if the inoperable CREVS train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREVS train must immediately be placed in the emergency mode. This action ensures that the remaining train is OPERABLE, that no failures TSTF-448, Rev. 3, Draft Markup B 3.7.10    BWOG STS B 3.7.10-6  Rev. 3.0, 03/31/04  CREVS BASES  ACTIONS  (continued) preventing automatic actuation will occur, and that any active failure will

be readily detected. Required Action D.1 is modified by a Note indicating to place the system in the emergency mode if automatic transfer to emergency mode is inoperable. An alternative to Required Action D.1 is to immediately suspend activities that could release radioactivity that might require isolation of the CRE control room. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe

position. ] Required Action D.1 is modified by a Note indicating to place the system in the emergency mode if automatic transfer to emergency mode is inoperable. 

  [ E.1  [In MODE 5 or 6, or] during movement of [recently] irradiated fuel assemblies, when two CREVS trains are inoperable or with one or more CREVS trains inoperable due to an inoperable CRE boundary , action must be taken immediately to suspend activities that could release radioactivity that might require isolation of the CRE control room. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position. ]

F.1 If both CREVS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE control room boundary (i.e., Condition B), the CREVS may not be capable of performing the intended function and the unit is in a condition outside the accident analysis. Therefore, LCO 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 this system are not severe, testing each train once every month adequately checks this system. Monthly heater operations dry out any moisture that has accumulated in the charcoal because of humidity in the ambient air. [Systems with heaters must be operated for 10 continuous hours with the heaters energized. Systems without heaters need only be TSTF-448, Rev. 3, Draft Markup CREVS B 3.7.10 BWOG STS B 3.7.10-7 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) operated for 15 minutes to demonstrate the function of the system.] The 31 day Frequency is based on the known reliability of the equipment and the two train redundancy available. SR 3.7.10.2 This SR verifies that the required CREVS testing is performed in accordance with the [Ventilation Filter Testing Program (VFTP)]. The [VFTP] includes testing HEPA filter performance, charcoal absorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal. Specific test frequencies and additional information are discussed in detail in the [VFTP]. SR 3.7.10.3 This SR verifies that [each CREVS train starts] [or the control room isolates] and operates on an actual or simulated actuation signal. The Frequency of [18] months is based on industry operating experience and is consistent with the typical refueling cycle. The Frequency of [18] months is consistent with that specified in Reference

3. SR 3.7.10.4 This SR verifies the integrity of the control room enclosure and the assumed inleakage rates of the potentially contaminated air. The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify that the CREVS is functioning properly. During the emergency mode of o peration, the CREVS is designed to pressurize the control room [0.125] inches water gauge positive pressure, with respect to adjacent areas, to prevent unfiltered inleakage. The CREVS is designed to maintain this positive pressure with one train at a fl ow rate of [3300] cfm. This value includes [300]

cfm of outside air. The Frequency of [18] months on a STAGGERED TEST BASIS is consistent with industry practice and other filtration SRs. This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the CRE Habitability Program. The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA TSTF-448, Rev. 3, Draft Markup CREVS B 3.7.10 BWOG STS B 3.7.10-8 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) consequences is no more than [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE] and the CRE occupants are protected from hazardous chemicals and smoke. The CRE boundary is considered OPERABLE when unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Mitigating actions, or compensatory measures, are discussed in Regulatory Guide 1.196, Section 2.7.3, (Ref. 3) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 4). Temporary analytical methods may also be used as compensatory measures (Ref. 5). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status. SR 3.7.10.5 This SR verifies the CREVS can supply the CRE with outside air to meet the design requirement. The Frequency of [18] months is consistent with industry practice and other filtration SRs. REFERENCES 1. FSAR, Section [9.4].

2. FSAR, Chapter [15].
3. Regulatory Guide 1.196 1.52, Rev.
[2]. 4. NEI 99-03, "Control Room Habitability Assessment," March 2003 NUREG-0800, Section 6.4, Rev. 2, July 1981. 5. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2005, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

TSTF-448, Rev. 3, Draft Markup CREFS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Filtration System (CREFS) LCO 3.7.10 Two CREFS trains shall be OPERABLE. 

  ---------------------------------------------NOTE--------------------------------------------   The control room envelope (CRE) boundary may be opened intermittently under administrative control.   --------------------------------------------------------------------------------------------------

APPLICABILITY: MODES 1, 2, 3, 4, [5, and 6], During movement of [recently] irradiated fuel assemblies. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREFS train inoperable for reasons other than Condition B. A.1 Restore CREFS train to OPERABLE status. 7 days B. TwoOne or more CREFS trains inoperable due to inoperable control room CRE boundary in MODE 1, 2, 3, or 4. B.1 Initiate action to implement mitigating actions. AND B.2 Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits. AND B.1 3 Restore control room CRE boundary to OPERABLE

status. Immediately 24 hours 60 days 24 hours WOG STS 3.7.10-1 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREFS 3.7.10 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion

Time of Condition A or B not met in MODE 1, 2, 3, or 4. C.1 Be in MODE 3. AND C.2 Be in MODE 5. 6 hours 36 hours D. Required Action and associated Completion

Time of Condition A not

met [in MODE 5 or 6, or] during movement of

[recently] irradiated fuel assemblies. D.1 --------------NOTE-------------- 

[ Place in toxic gas protection mode if automatic transfer to toxic

gas protection mode is

inoperable. ] 

 -------------------------------------

Place OPERABLE CREFS train in emergency mode. OR D.2 Suspend movement of [recently] irradiated fuel assemblies. Immediately Immediately E. Two CREFS trains inoperable [in MODE 5

or 6, or] during movement of [recently] irradiated fuel assemblies. OR One or more CREFS trains inoperable due to an inoperable CRE boundary [in Mode 5 or 6, or] during movement of [recently] irradiated fuel assemblies. E.1 Suspend movement of [recently] irradiated fuel assemblies. Immediately WOG STS 3.7.10-2 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREFS 3.7.10 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREFS trains inoperable during MODE 1, 2, 3, or 4 for reasons other than

Condition B. F.1 Enter LCO 3.0.3. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREFS train for [ 10 continuous hours with the heaters operating or (for systems

without heaters) 15 minutes]. 31 days SR 3.7.10.2 Perform required CREFS filter testing in accordance with the [Ventilation Filter Testing Program (VFTP)]. In accordance

with [VFTP] SR 3.7.10.3 Verify each CREFS train actuates on an actual or simulated actuation signal. 

 [18] months SR  3.7.10.4 Verify one CREFS train can maintain a positive pressure of  [0.125] inches water gauge, relative to the adjacent [turbine building] during the pressurization mode of operation at a makeup flow rate of  [3000] cfm.   [18] months on a STAGGERED TEST BASIS SR 3.7.10.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program In accordance with the Control Room Envelope Habitability Program    WOG STS 3.7.10-3 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5    5.5 Programs and Manuals 5.5.16 Containment Leakage Rate Testing Program  (continued)
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.

5.5.17 Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, based on [the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer] including the following:

a. Actions to restore battery cells with float voltage < [2.13] V, and
b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

5.5.18 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented in accordance with the guidelines contained in Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, May 2003, Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release," Revision 1, December 2001. 

 [The following are exceptions to Regulatory Guide 1.196, Revision 0:
1.  ; and]
  [The following are exceptions to Regulatory Guide 1.197, Revision 0:
1.  ; and]
 [The following are exceptions to Regulatory Guide 1.78, Revision 1:
1.  ; and]

WOG STS 5.5-15 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.18 Control Room Envelope Habitability Program (continued) The CRE Habitability Program shall ensure that CRE habitability is maintained such that, with an OPERABLE Contro l Room Emergency Filtration System (CREFS), CRE occupants can control the reactor safely 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 occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of [5 rem whole body or its equivalent to any part of the body] [5 rem total effective dose equivalent (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 CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for assessing CRE habitability at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
d. Requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
e. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS, operating at the flow rate required by the VFTP, at a Frequency of [18] months on a STAGGERED TEST BASIS. The results shall be trended and compared to the pressure measurements at all locations taken during the previous CRE inleakage testing. These evaluations shall be used as part of an assessment of the CRE boundary between CRE inleakage tests.
f. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph d. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemical and smoke challenges must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

WOG STS 5.5-16 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 WOG STS 5.5-17 Rev. 3.0, 03/31/04 5.5 Programs and Manuals 5.5.18 Control Room Envelope Habitability Program (continued)

g. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c, d, and e, respectively.

TSTF-448, Rev. 3, Draft Markup CREFS B 3.7.10 WOG STS B 3.7.10-1 Rev. 3.0, 03/31/04 B 3.7 PLANT SYSTEMS B 3.7.10 Control Room Emergency Filtration System (CREFS) BASES BACKGROUND The CREFS provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity , hazardous chemicals, or smoke. 

[chemicals, or toxic gas].

The CREFS consists of two independent, redundant trains that recirculate and filter the air in the control room envelope (CRE) air and a CRE boundary that limits the inleakage of unfiltered air. Each CREFS train consists of a prefilter or demister, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system, as well as demisters to remove water droplets from the air stream. A second

bank of HEPA filters follows the adsor ber section to collect carbon fines and provide s backup in case of failure of the main HEPA filter bank. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit for normal and accident conditions. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected for normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program. The CREFS is an emergency system, parts of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of the actuating signal(s), normal air supply to the CRE control room is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilters or demisters remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 10 hours 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 charcoal adsorbers.

TSTF-448, Rev. 3, Draft Markup CREFS B 3.7.10 WOG STS B 3.7.10-2 Rev. 3.0, 03/31/04 BASES BACKGROUND (continued) Actuation of the CREFS places the system in either of two separate states (emergency radiation state or toxic gas isolation state) of the emergency mode of operation, depending on the initiation signal. Actuation of the system to the emergency radiation state of the emergency mode of operation, closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the air within the CRE control room air through the redundant trains of HEPA and the charcoal filters. The emergency radiation state also initiates pressurization and filtered ventilation of the air supply to the CRE control room. Outside air is filtered, diluted with building air from the electrical equipment and cable spreading rooms, and added to the air being recirculated from the CRE control room. Pressurization of the CRE control room prevents minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas of the building adjacent to the CRE boundary. The actions taken in the toxic gas isolation state are the same, except that the signal switches control room ventilation the CREFS to an isolation alignment to prevent minimize any outside air from entering the CRE control room through the CRE boundary. The air entering the CRE control room is continuously monitored by radiation and toxic gas detectors. One detector output above the setpoint will cause actuation of the emergency radiation state or toxic gas isolation state, as required. The actions of the toxic gas isolation state are more restrictive, and will override the actions of the emergency radiation state. A single CREFS train operating at a flow rate of [3000] cfm will pressurize the CRE control room to about [0.125] inches water gauge relative to all external areas adjacent to the CRE boundary. The CREFS operation in maintaining the CRE control room habitable is discussed in the FSAR, Section [6.4] (Ref. 1). Redundant supply and recirculation trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally open isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The CREFS is designed in accordance with Seismic Category I

requirements. The CREFS is designed to maintain a habitable environment in the CRE the control room environment for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a [5 rem whole body dose or its equivalent to any part of the body ] [5 rem total effective dose equivalent (TEDE)]. TSTF-448, Rev. 3, Draft Markup B 3.7.10 WOG STS B 3.7.10-3 Rev. 3.0, 03/31/04 CREFS BASES APPLICABLE The CREFS components are arr anged in redundant, safety related SAFETY ventilation trains. The location of components and ducting within the ANALYSES control room envelope CRE ensures an adequate supply of filtered air to all areas requiring access. The CREFS provides airborne radiological protection for CRE occupants the control room operators, as demonstrated by the CRE occupant control room accident dose analyses for the most limiting design basis loss of coolant accident, fission product release presented in the FSAR, Chapter [15] (Ref. 2). The analysis of toxic gas releases demonstrates that the toxicity limits are

not exceeded in the CRE control room following a toxic chemical release, as presented in Reference 1. The worst case single active failure of a component of the CREFS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function. The CREFS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO Two independent and redundant CREFS trains are required to be OPERABLE to ensure that at least one is available assuming if a single active failure disables the other train. Total CREFS system failure , such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 r em to the control room operator [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE] to CRE occupants in the event of a large radioactive release. The Each CREFS train is considered OPERABLE when the individual components necessary to limit operator CRE occupant exposure are OPERABLE in both trains. A CREFS train is OPERABLE when the associated:

a. Fan is OPERABLE, b. HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions, and
c. Heater, demister, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors.

TSTF-448, Rev. 3, Draft Markup B 3.7.10 WOG STS B 3.7.10-4 Rev. 3.0, 03/31/04 CREFS BASES LCO (continued) In order for the CREFS trains to be considered OPERABLE, the CRE boundary must be maintained such that CRE occupant dose from a large radioactive release does not exceed the calculated dose of the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke. The LCO is modified by a Note allowing the CRE control room boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly 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 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 operators in the CRE control room. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE control room isolation is indicated. APPLICABILITY In MODES 1, 2, 3, 4, [5, and 6,] and during movement of [recently] irradiated fuel assemblies, the CREFS must be OPERABLE to ensure that the CRE will remain habitable control operator exposure during and following a DBA. In [MODE 5 or 6], the CREFS is required to cope with the release from the rupture of an outside waste gas tank. During movement of [recently] irradiated fuel assemblies, the CREFS must be OPERABLE to cope with the release from a fuel handling accident [involving handling recently irradiated fuel]. [The CREFS 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 [X] days), due to radioactive decay.] ACTIONS A.1 When one CREFS train is inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREFS train is adequate to perform the control room protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CREFS train could result in loss of CREFS 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 train to provide the required capability. TSTF-448, Rev. 3, Draft Markup CREFS B 3.7.10 WOG STS B 3.7.10-5 Rev. 3.0, 03/31/04 BASES ACTIONS (continued) B.1 -----------------------------------REVIEWER'S NOTE----------------------------------- Adoption of Condition B is dependent on a commitment from the licensee to have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into Condition B. 

--------------------------------------------------------------------------------------------------

If the control room boundary is inoperable in MODE 1, 2, 3, or 4, the CREFS trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE control room boundary within 24 hours. During the period that the control room boundary is 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, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour 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 hour Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary. B.1, B.2 and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE]), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is considered inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 60 days. During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. The mitigating actions should also address maintaining temperature and relative humidity within limits, and physical security. These mitigating

TSTF-448, Rev. 3, Draft Markup CREFS B 3.7.10 WOG STS B 3.7.10-6 Rev. 3.0, 03/31/04 BASES ACTIONS (continued) actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 60 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protec tive measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 60 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary. C.1 and C.2 In MODE 1, 2, 3, or 4, if the inoperable CREFS train or the CRE control room 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 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. D.1 and D.2 

 [In MODE 5 or 6, or] during movement of [recently] irradiated fuel assemblies, if the inoperable CREFS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CREFS train in the emergency mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE control room. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position. Required Action D.1 is modified by a Note indicating to place the system in the toxic gas protection mode if automatic transfer to the toxic gas protection mode is inoperable.

TSTF-448, Rev. 3, Draft Markup B 3.7.10 WOG STS B 3.7.10-7 Rev. 3.0, 03/31/04 CREFS BASES ACTIONS (continued) E.1 [In MODE 5 or 6, or] during movement of [recently] irradiated fuel assemblies, with two CREFS trains inoperable or with one or more CREFS trains inoperable due to an inoperable CRE boundary , action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the CRE control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position. F.1 If both CREFS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE control room boundary (i.e., Condition B), the CREFS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE SR 3.7.10.1REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. Monthly heater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air. [Systems with heaters must be operated for 10 continuous hours with the heaters energized. Systems without heaters need only be

operated for 15 minutes to demonstrate the function of the system.] The 31 day Frequency is based on the reliability of the equipment and the two train redundancy availability. SR 3.7.10.2 This SR verifies that the required CREFS testing is performed in accordance with the [Ventilation Filter Testing Program (VFTP)]. The

[VFTP] includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the [VFTP]. TSTF-448, Rev. 3, Draft Markup CREFS B 3.7.10 WOG STS B 3.7.10-8 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.7.10.3 This SR verifies that each CREFS train starts and operates on an actual

or simulated actuation signal. The Frequency of [18] months is based on industry operating experience and is consistent with the typical refueling cycle. The Frequency of [18] months is specified in Regulatory Guide 1.52 (Ref. 3). SR 3.7.10.4 This SR verifies the integrity of the control room enclosure, and the assumed inleakage rates of the potentially contaminated air. The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper functioning of the CREFS. During the emergency mode of operation, the CREFS is designed to pressurize the control room [0.125] inches water gauge positive pressure with respect to adjacent areas in order to prevent unfiltered inleakage. The CREFS is designed to maintain this positive pressure with one train at a makeup flow rate of [3000] cfm. The Frequency of [18] months on a STAGGERED TEST BASIS is consistent with the guidance pro vided in NUREG -0800 (Ref. 4). This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the CRE Habitability Program. The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE] and the CRE occupants are protected from hazardous chemicals and smoke. The CRE boundary is considered OPERABLE when unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Mitigating actions, or compensatory measures, are discussed in Regulatory Guide 1.196, Section 2.7.3, (Ref. 3) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 4). Temporary analytical methods may also be used as compensatory measures (Ref. 5). Options for restoring the CRE boundary to OPERABLE status include changing

TSTF-448, Rev. 3, Draft Markup CREFS B 3.7.10 WOG STS B 3.7.10-9 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status. REFERENCES 1. FSAR, Section [ 6 9.4]. 2. FSAR, Chapter [15].

3. Regulatory Guide 1.196 1.52, Rev.
[2]. 4. NEI 99-03, "Control Room Habitability Assessment," March 2003 NUREG-0800, Section 6.4, Rev. 2, July 1981. 5. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2005, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

TSTF-448, Rev. 3, Draft Markup CREACS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Cleanup System (CREACS) LCO 3.7.11 Two CREACS trains shall be OPERABLE. 

  ---------------------------------------------NOTE--------------------------------------------   The control room envelope (CRE) boundary may be opened intermittently under administrative control.   --------------------------------------------------------------------------------------------------

APPLICABILITY: MODES 1, 2, 3, 4, [5, and 6,] During movement of [recently] irradiated fuel assemblies. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREACS train inoperable for reasons other than Condition B. A.1 Restore CREACS train to OPERABLE status. 7 days B. TwoOne or more CREACS trains inoperable due to

inoperable control room CRE boundary in MODE 1, 2, 3, or 4. B.1 Initiate action to implement mitigating actions. AND B.2 Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits. AND B.1 3 Restore control room CRE boundary to OPERABLE

status. Immediately 24 hours 60 days 24 hours CEOG STS 3.7.11-1 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREACS 3.7.11 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion

Time of Condition A or B not met in MODE 1, 2, 3, or 4. C.1 Be in MODE 3. AND C.2 Be in MODE 5. 6 hours 36 hours D. Required Action and associated Completion

Time of Condition A not met [in MODES 5 and 6, or] during movement of

[recently] irradiated fuel assemblies. D.1 ---------------NOTE-------------- Place in toxic gas protection mode if automatic transfer to toxic

gas mode inoperable. ------------------------------------- Place OPERABLE CREACS train in

emergency radiation

protection mode. OR D.2 Suspend movement of [recently] irradiated fuel assemblies. Immediately Immediately E. Two CREACS trains inoperable [in MODES 5 and 6, or] during movement of [recently] irradiated fuel assemblies. OR One or more CREFS trains inoperable due to an inoperable CRE boundary [in Mode 5 or 6, or] during movement of [recently] irradiated fuel assemblies. E.1 Suspend movement of [recently] irradiated fuel assemblies. Immediately CEOG STS 3.7.11-2 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREACS 3.7.11 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREACS trains inoperable during MODE 1, 2, 3, or 4 for reasons other than

Condition B. F.1 Enter LCO 3.0.3. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Operate each CREACS train for [ 10 continuous hours with heaters operating or (for systems without heaters) 15 minutes]. 31 days SR 3.7.11.2 Perform required CREACS filter testing in accordance with [Ventilation Filter Testing Program (VFTP)]. In accordance

with the [VFTP] SR 3.7.11.3 Verify each CREACS train actuates on an actual or simulated actuation signal. 

 [18] months SR  3.7.11.4 Verify one CREACS train can maintain a positive pressure of  [0.125] inches water gauge, relative to the adjacent [area] during the emergency radiation state of the emergency mode of operation at a emergency ventilation fl ow rate of  [3000] cfm.   [18] months on a STAGGERED TEST BASIS SR 3.7.11.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program In accordance with the Control Room Envelope Habitability Program    CEOG STS 3.7.11-3 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5    5.5 Programs and Manuals 5.5.16 Containment Leakage Rate Testing Program  (continued)
2. Air lock testing acceptance criteria are:

a) Overall air lock leakage rate is [0.05 L a] when tested at P a. b) For each door, leakage rate is [0.01 L a] when pressurized to [ 10 psig].

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.

5.5.17 Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, based on [the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer] including the following

a. Actions to restore battery cells with float voltage < [2.13] V, and
b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

5.5.18 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented in accordance with the guidelines contained in Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, May 2003, Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release," Revision 1, December 2001. 

 [The following are exceptions to Regulatory Guide 1.196, Revision 0:
1.  ; and]
  [The following are exceptions to Regulatory Guide 1.197, Revision 0:
1.  ; and]

CEOG STS 5.5-14 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.18 Control Room Envelope Habitability Program (continued) 

[The following are exceptions to Regulatory Guide 1.78, Revision 1:
1.  ; and]

The CRE Habitability Program shall ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Air Cleanup System (CREACS), CRE occupants can control the reactor safely 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 occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of [5 rem whole body or its equivalent to any part of the body] [5 rem total effective dose equivalent (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 CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for assessing CRE habitability at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
d. Requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
e. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREACS, operating at the flow rate required by the VFTP, at a Frequency of [18] months on a STAGGERED TEST BASIS. The results shall be trended and compared to the pressure measurements at all locations taken during the previous CRE inleakage testing. These evaluations shall be used as part of an assessment of the CRE boundary between CRE inleakage tests.
f. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph d. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemical and smoke challenges must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

CEOG STS 5.5-15 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.18 Control Room Envelope Habitability Program (continued)

g. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c, d, and e, respectively.

CEOG STS 5.5-16 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREACS B 3.7.11 B 3.7 PLANT SYSTEMS B 3.7.11 Control Room Emergency Air Cleanup System (CREACS) BASES BACKGROUND The CREACS provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity , hazardous chemicals, or smoke. 

[chemicals, or toxic gas].

The CREACS consists of two independent, redundant trains that recirculate and filter the air in the control room envelope (CRE) air and a CRE boundary that limits the inleakage of unfiltered air. Each CREACS train consists of a prefilter and demister, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodine), and a fan. Ductwork, valves or

dampers, doors, barriers, and instrumentation also form part of the system, as do well as demisters that remove water droplets from the air stream. A second bank of HEPA filters follows the adsorber section to collect carbon fines and provides backup in case of failure of the main HEPA filter bank., and to back up the main HEPA filter bank if it fails. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit for normal and accident conditions. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected for normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program. The CREACS is an emergency system, part of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of the actuating signal(s), normal air supply to the CRE control room is isolated, and the stream of ventilation air is recirculated through the filter trains of the system. The prefilters and demisters remove any large particles in the air, and any entrained water droplets present to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 10 hours 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 charcoal adsorbers. CEOG STS B 3.7.11-1 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREACS B 3.7.11 BASES BACKGROUND (continued) Actuation of the CREACS places the system into either of two separate states of the emergency mode of operation, depending on the initiation signal. Actuation of the system to the emergency radiation state of the emergency mode of operation closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the air within the CRE control room air through the redundant trains of HEPA and charcoal filters. The emergency radiation state initiates pressurization and filtered ventilation of the air supply to the CRE control room. Outside air is filtered, [diluted with building air from the electrical equipment and cable spreading rooms,] and then added to the air being recirculated from the CRE control roo

m. Pressurization of the CRE control room prevents minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas of the building adjacent to the CRE boundary. The actions taken in the toxic gas isolation state are the same, except that the signal switches control room ventilation the CREACS to an isolation mode, preventing to minimize any outside air from entering the CRE control room through the CRE boundary. The air entering the CRE control room is continuously monitored by radiation and toxic gas detectors. One detector output above the setpoint will cause actuation of the emergency radiation state or toxic gas isolation state as required. The actions of the toxic gas isolation state are more restrictive, and will override the actions of the emergency radiation state.

A single CREACS train operating at a flow rate of [3000] cfm will pressurize the CRE control room to about [0.125] inches water gauge relative to all external areas adjacent to the CRE boundary , and provides an air exchange rate in excess of 25% per hour. The CREACS operation in maintaining the CRE con trol room habitable is discussed in the FSAR, Section [9.4] (Ref. 1). Redundant supply and recirculation trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally open isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The CREACS is designed in accordance with Seismic Category I requirements. The CREACS is designed to maintain a habitable environment in the CRE t he control room environment for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a [5 rem whole body dose or its equivalent to any part of the body ] [5 rem total effective dose equivalent (TEDE)]. CEOG STS B 3.7.11-2 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREACS CEOG STS B 3.7.11-3 Rev. 3.0, 03/31/04 B 3.7.11 BASES (continued) APPLICABLE The CREACS components are a rranged in redundant safety related SAFETY ventilation trains. The location of components and ducting within the ANALYSES control room envelope CRE ensures an adequate supply of filtered air to all areas requiring access. The CREACS provides airborne radiological protection for CRE occupants the control room operators, as demonstrated by the CRE occupant control room accident dose analyses for the most limiting design basis loss of coolant accident fission product release presented in the FSAR, Chapter [15] (Ref. 2). The analysis of toxic gas releases demonstrates that the toxicity limits are not exceeded in the CRE control room following a toxic chemical release, as presented in Reference 1. The worst case single active failure of a component of the CREACS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function. The CREACS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO Two independent and redundant trains of the CREACS are required to be OPERABLE to ensure that at least one is available, assuming if that a single active failure disables the other train. Total CREACS system failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in a control room operator receiving exceeding a dose in excess of of [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE] to CRE occupants 5 rem in the event of a large radioactive release. The Each CREACS train is considered OPERABLE when the individual components necessary to control operator limit CRE occupant exposure are OPERABLE in both trains. A CREACS train is considered OPERABLE when the associated:

a. Fan is OPERABLE, b. HEPA filters and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functions, and
c. Heater, demister, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors.

TSTF-448, Rev. 3, Draft Markup CREACS CEOG STS B 3.7.11-4 Rev. 3.0, 03/31/04 B 3.7.11 BASES LCO (continued)In order for the CREACS trains to be considered OPERABLE, the CRE boundary must be maintained such that CRE occupant dose from a large radioactive release does not exceed the calculated dose of the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke. The LCO is modified by a Note allowing the CRE control room boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly 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 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 operators in the CRE control room. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE control room isolation is indicated. APPLICABILITY In MODES 1, 2, 3, and 4, [5, and 6,] and during movement of [recently] irradiated fuel assemblies, the CREACS must be OPERABLE to ensure that the CRE will remain habitable limit operator exposure during and following a DBA. In MODES [5 and 6], the CREACS is required to cope with the release from a rupture of an outside waste gas tank. During movement of [recently] irradiated fuel assemblies, the CREACS must be OPERABLE to cope with the release from a fuel handling accident. [Due to radioactive decay, CREACS is only required to cope with fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days).] ACTIONS A.1 With one CREACS train inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREACS subsystem is adequate to perform control room radiation protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CREACS train could result in loss of CREACS function. The 7 day Completion Time is based on the low probability of a TSTF-448, Rev. 3, Draft Markup CREACS B 3.7.11 BASES ACTIONS (continued) DBA occurring during this time period, and the ability of the remaining train to provide the required capability. B.1 -----------------------------------REVIEWER'S NOTE

Adoption of Condition B is dependent on a commitment from the licensee to have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into Condition B. 

--------------------------------------------------------------------------------------------------

If the control room boundary is inoperable in MODES 1, 2, 3, and 4, the CREACS trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE control room boundary within 24 hours. During the period that the control room boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from potentia l hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour 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 hour Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary. B.1, B.2 and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE]), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is considered inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 60 days. During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose CEOG STS B 3.7.11-5 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREACS B 3.7.11 BASES ACTIONS (continued) of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. The mitigating actions should also address maintaining temperature and relative humidity within limits, and physical security. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 60 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protec tive measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 60 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary. C.1 and C.2 In MODE 1, 2, 3, or 4, if If the inoperable CREACS or the CRE control room boundary cannot be restored to OPERABLE status within the associated Completion Time in MODE 1, 2, 3, or 4, the unit must be placed in a MODE that minimizes the accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. D.1 and D.2 Required Action D.1 is modified by a Note indicating to place the system in the emergency radiation protection mode if the automatic transfer to emergency mode is inoperable. In MODE 5 or 6, or during movement of [recently] irradiated fuel assemblies, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CREACS train must be immediately placed in the emergency mode of operation. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure will be readily detected. CEOG STS B 3.7.11-6 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREACS CEOG STS B 3.7.11-7 Rev. 3.0, 03/31/04 B 3.7.11 BASES ACTIONS (continued) An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of

the CRE control room. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies to a safe position. Required Action D.1 is modified by a Note indicating to place the system in the toxic gas protection mode if the automatic transfer to the toxic gas protection mode is inoperable. E.1 When [in MODES 5 and 6, or] during movement of [recently] irradiated fuel assemblies, with two CREACS trains inoperable or with one or more CREACS trains inoperable due to an inoperable CRE boundary , action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE control room. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position. F.1 If both CREACS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE control room boundary (i.e., Condition B), the CREACS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE SR 3.7.11.1REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system. Monthly heater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air. [Systems with heaters must be operated for 10 continuous hours with the heaters energized. Systems without heaters need only be operated for 15 minutes to demonstrate the function of the system.] The 31 day Frequency is based on the known reliability of the equipment, and the two train redundancy available. TSTF-448, Rev. 3, Draft Markup CREACS B 3.7.11 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.7.11.2 This SR verifies that the required CREACS testing is performed in accordance with the [Ventilation Filter Testing Program (VFTP)]. The [VFTP] includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the [VFTP]. SR 3.7.11.3 This SR verifies each CREACS train starts and operates on an actual or simulated actuation signal. The Frequency of [18] months is based on industry operating experience and is consistent with the typical refueling cycle. The Frequency of [18] months is consistent with that specified in Reference 3. SR 3.7.11.4 This SR verifies the integrity of the control room enclosure and the assumed inleakage rates of potentially contaminated air. The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper function of the CREACS. During the emergency radiation state of the emergency mode of operation, the CREACS is designed to pressurize the control room [0.125] inches water gauge positive pressure with respect to adjacent areas in order to prevent unfiltered inleakage. The CREACS is designed to maintain this positive pressure with one train at an emergency ventilation flow rate of [3000] cfm. The Frequency of [18] months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800, Section 6.4 (Ref. 4). This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the CRE Habitability Program. The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE] and the CRE occupants are protected from hazardous chemicals and smoke. The CRE boundary is CEOG STS B 3.7.11-8 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup CREACS B 3.7.11 CEOG STS B 3.7.11-9 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) considered OPERABLE when unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Mitigating actions, or compensatory measures, are discussed in Regulatory Guide 1.196, Section 2.7.3, (Ref. 3) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 4). Temporary analytical methods may also be used as compensatory measures (Ref. 5). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status REFERENCES 1. FSAR, Section [ 6 9.4]. 2. FSAR, Chapter [15].

3. Regulatory Guide 1.196 1.52, Rev.
[2]. 4. NEI 99-03, "Control Room Habitability Assessment," March 2003 NUREG-0800, Section 6.4, Rev. 2, July 1981. 5. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2005, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

TSTF-448, Rev. 3, Draft Markup 

[MCREC] System 3.7.4   3.7   PLANT SYSTEMS 3.7.4 [Main Control Room Environmental Control (MCREC)] System LCO  3.7.4  Two [MCREC] subsystems shall be OPERABLE. 
  ---------------------------------------------NOTE--------------------------------------------

The main control room envelope (CRE) boundary may be opened intermittently under administrative control. -------------------------------------------------------------------------------------------------- APPLICABILITY: MODES 1, 2, and 3, During movement of [recently] irradiated fuel assemblies in the [secondary] containment, During operations with a potential for draining the reactor vessel (OPDRVs). ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One [MCREC] subsystem inoperable for reasons other than Condition B. A.1 Restore [MCREC] subsystem to OPERABLE

status. 7 days B. TwoOne or more 

[MCREC] subsystems inoperable due to

inoperable control room CRE boundary in MODE 1, 2, or 3. B.1 Initiate action to implement mitigating actions. AND B.2 Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits. AND B.1 3 Restore control room CRE boundary to OPERABLE status. Immediately 24 hours 60 days 24 hours BWR/4 STS 3.7.4-1 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup 

[MCREC] System

3.7.4 ACTIONS

(continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion

Time of Condition A or B

not met in MODE 1, 2, or 3. C.1 Be in MODE 3. AND C.2 Be in MODE 4. 12 hours 36 hours D. Required Action and associated Completion

Time of Condition A not met during movement of

[recently] irradiated fuel assemblies in the [secondary] containment or during OPDRVs. 

 --------------------NOTE------------------- LCO 3.0.3 is not applicable. ------------------------------------------------

D.1 ---------------NOTE-------------- [ Place in toxic gas protection mode if

automatic transfer to toxic

gas protection mode is inoperable. ] ------------------------------------- Place OPERABLE [MCREC] subsystem in [pressurization] mode. OR D.2.1 Suspend movement of [recently] irradiated fuel assemblies in the

[secondary] containment. AND D.2.2 Initiate action to suspend OPDRVs. Immediately Immediately Immediately E. Two [MCREC] subsystems inoperable

in MODE 1, 2, or 3 for reasons other than

Condition B. E.1 Enter LCO 3.0.3. Immediately BWR/4 STS 3.7.4-2 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup 

[MCREC] System

3.7.4 ACTIONS

(continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two [MCREC] subsystems inoperable during movement of

[recently] irradiated fuel assemblies in the

[secondary] containment or during OPDRVs. OR One or more [MCREC] subsystems inoperable due to inoperable CRE boundary during movement of [recently] irradiated fuel assemblies in the [secondary] containment or during OPDRVs. 

  --------------------NOTE------------------- LCO 3.0.3 is not applicable. ------------------------------------------------

F.1 Suspend movement of [recently] irradiated fuel assemblies in the [secondary] containment. AND F.2 Initiate action to suspend OPDRVs. Immediately Immediately BWR/4 STS 3.7.4-3 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup 

[MCREC] System

3.7.4 SURVEILLANCE

REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Operate each [MCREC] subsystem for [ 10 continuous hours with the heaters operating or (for systems without heaters) 15 minutes]. 31 days SR 3.7.4.2 Perform required [MCREC] filter testing in accordance with the [Ventilation Filter Testing Program (VFTP)]. In accordance

with the [VFTP] SR 3.7.4.3 Verify each [MCREC] subsystem actuates on an actual or simulated initiation signal. 

 [18] months SR  3.7.4.4 [ Verify each [MCREC] subsystem can maintain a positive pressure of  [0.1] inches water gauge relative to the [turbine building] during the [pressurization] mode of operation at a flow rate of  [400] cfm.   [18] months on a STAGGERED TEST BASIS
]   SR 3.7.4.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program In accordance with the Control Room Envelope Habitability Program    BWR/4 STS 3.7.4-4 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5    5.5 Programs and Manuals 5.5.13 Primary Containment Leakage Rate Testing Program (continued)
1. Containment leakage rate acceptance criterion is 1.0 L a. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 L a for the Type B and C tests and [< 0.75 L a for Option A Type A tests] [ 0.75 L a for Option B Type A tests].
2. Air lock testing acceptance criteria are:

a) Overall air lock leakage rate is [0.05 L a] when tested at P a. b) For each door, leakage rate is [0.01 L a] when pressurized to [10] psig.

e. The provisions of SR 3.0.3 are applicable to the Primary 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.

5.5.14 Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, based on [the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer] of the following:

a. Actions to restore battery cells with float voltage < [2.13] V, and
b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

5.5.15 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented in accordance with the guidelines contained in Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, May 2003, Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release," Revision 1, December 2001. 

 [The following are exceptions to Regulatory Guide 1.196, Revision 0:
1.  ; and]

BWR/4 STS 5.5-13 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Control Room Envelope Habitability Program (continued) 

  [The following are exceptions to Regulatory Guide 1.197, Revision 0:
1.  ; and]
 [The following are exceptions to Regulatory Guide 1.78, Revision 1:
1.  ; and] The CRE Habitability Program shall ensure that CRE habitability is maintained such that, with an OPERABLE [Main Control Room Environmental Control (MCREC) System], CRE occupants can control the reactor safely 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 occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of [5 rem whole body or its equivalent to any part of the body] [5 rem total effective dose equivalent (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 CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for assessing CRE habitability at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
d. Requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
e. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS, operating at the flow rate required by the VFTP, at a Frequency of [18] months on a STAGGERED TEST BASIS. The results shall be trended and compared to the pressure measurements at all locations taken during the previous CRE inleakage testing. These evaluations shall be used as part of an assessment of the CRE boundary between CRE inleakage tests.

BWR/4 STS 5.5-14 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 BWR/4 STS 5.5-15 Rev. 3.0, 03/31/04 5.5 Programs and Manuals 5.5.15 Control Room Envelope Habitability Program (continued)

f. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph d. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemical and smoke challenges must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
g. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c, d, and e, respectively.

TSTF-448, Rev. 3, Draft Markup MCREC B 3.7.4 BWR/4 STS B 3.7.4-1 Rev. 3.0, 03/31/04 B 3.7 PLANT SYSTEMS B 3.7.4 [Main Control Room Environmental Control (MCREC)] System BASES BACKGROUND The [MCREC] System provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. radiologically controlled environment from which the unit can be safely operated following a Design Basis Accident (DBA). The safety related function of [MCREC] System includes two independent and redundant high efficiency air filtration subsystems for emergency treatment of recirculated air or outside supply air and a CRE boundary that limits the inleakage of unfiltered air. Each [MCREC] subsystem consists of a demister, an electric heater, a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section, a

second HEPA filter, a booster fan, an air handling unit (excluding the condensing unit), and the associated ductwork, dampers, doors, barriers, and instrumentation. ductwork and dampers. Demisters remove water droplets from the airstream. Prefilters and HEPA filters remove particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit for normal and accident conditions. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected for normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program. The [MCREC] System is a standby syst em, parts of which also operate during normal unit operations to maintain the CRE control room environment. Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to CRE occupants control room personnel), the [MCREC] System automatically switches to the pressurization mode of operation to prevent infiltration of contaminated air into the CRE control room. A system of dampers

TSTF-448, Rev. 3, Draft Markup B 3.7.4 BWR/4 STS B 3.7.4-2 Rev. 3.0, 03/31/04 MCREC BASES BACKGROUND (continued) isolates the CRE, control room, and a part of the recirculated air is routed through either of the two filter subsystems. Outside air is taken in at the normal ventilation intake and is mixed with the recirculated air before being passed through one of the charcoal adsorber filter subsystems for removal of airborne radioactive particles. The [MCREC] System is designed to maintain a habitable environment in the CRE the control room environment for a 30 day continuous occupancy after a DBA without exceeding [5 rem whole body dose or its equivalent to any part of the body ] [5 rem total effective dose equivalent (TEDE)]. A single [MCREC] subsystem operating at a flow rate of [400] cfm will pressurize the CRE control room to about [0.1] inches water gauge relative to all external areas adjacent to the CRE boundary to minimize to prevent infiltration of air from all surrounding areas adjacent to the CRE boundary surrounding bui ldings. [MCREC] System operation in maintaining CRE control room habitability is discussed in the FSAR, Chapters [6] and [9], (Refs. 1 and 2, respectively). APPLICABLE The ability of the [MCREC] System to maintain the habitability of the SAFETY CRE co ntrol room is an explicit assumption for the safety analyses ANALYSES presented in the FSAR, Chapters [6] and [15] (Refs. 1 and 3, respectively). The pressurization mode of the [MCREC] System is assumed to operate following a loss of coolant accident design basis accident (DBA), fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)], main steam line break, and control rod drop accident, as discussed in the FSAR, Section [6.4.1.2.2] (Ref. 4). The radiological doses to CRE occupants control room personnel as a result of the various DBAs are summarized in Reference 3. No single active or passive failure will cause the loss of outside or recirculated air from the CRE control room. The [MCREC] System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO Two redundant subsystems of the [MCREC] System are required to be OPERABLE to ensure that at least one is available, assuming if a single active failure disables the other subsystem. Total [MCREC] s System failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE] to CRE occupants of 5 rem to the control room operators in the event of a DBA. TSTF-448, Rev. 3, Draft Markup B 3.7.4 BWR/4 STS B 3.7.4-3 Rev. 3.0, 03/31/04 MCREC BASES LCO (continued) The Each [MCREC] subsystem System is considered OPERABLE when the individual components necessary to control operator limit CRE occupant exposure are OPERABLE in both subsystems. A subsystem is considered OPERABLE when its associated:

a. Fan is OPERABLE, b. HEPA filter and charcoal adsorbers are not excessively restricting flow and are capable of performing their filtration functions, and
c. Heater, demister, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors. In order for the [MCREC] subsystems to be considered OPERABLE, the CRE boundary must be maintained such that CRE occupant dose from a large radioactive release does not exceed the calculated dose of the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke. The LCO is modified by a Note allowing the CRE main control room boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly 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 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 operators in the main CREcontrol room. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for main CRE control room isolation is indicated. APPLICABILITY In MODES 1, 2, and 3, the [MCREC] System must be OPERABLE to ensure that the CRE will remain habitable control operator exposure during and following a DBA, since the DBA could lead to a fission product

release. In MODES 4 and 5, the probability and consequences of a DBA are reduced because of the pressure and temperature limitations in these MODES. Therefore, maintaining the [MCREC] System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated: TSTF-448, Rev. 3, Draft Markup B 3.7.4 BWR/4 STS B 3.7.4-4 Rev. 3.0, 03/31/04 MCREC BASES APPLICABILITY (continued)

a. During operations with potential for draining the reactor vessel (OPDRVs) and
b. During movement of [recently] irradiated fuel assemblies in the [secondary] containment. [Due to radioactive decay, the MCREC

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 [X] days).] ACTIONS A.1 With one [MCREC] subsystem inoperable, for reasons other than an inoperable CRE boundary, the inoperable [MCREC] subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE [MCREC] subsystem is adequate to perform control room radiation protection. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced [MCREC] System capability. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities. B.1 -----------------------------------REVIEWER'S NOTE----------------------------------- Adoption of Condition B is dependent on a commitment from the licensee to have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into Condition B. 

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If the main control room boundary is inoperable in MODE 1, 2, or 3, the MCREC subsystems cannot perform their intended functions. Actions must be taken to restore an OPERABLE main control room boundary within 24 hours. During the period that the main control room boundary is 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, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour 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 hour Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems wi th the main control room boundary TSTF-448, Rev. 3, Draft Markup MCREC B 3.7.4 BWR/4 STS B 3.7.4-5 Rev. 3.0, 03/31/04 BASES ACTIONS (continued) B.1, B.2 and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE]), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is considered inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 60 days. During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. The mitigating actions should also address maintaining temperature and relative humidity within limits, and physical security. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 60 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protec tive measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 60 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary. C.1 and C.2 In MODE 1, 2, or 3, if the inoperable [MCREC] subsystem or the CRE control room boundary cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. TSTF-448, Rev. 3, Draft Markup MCREC B 3.7.4 BWR/4 STS B 3.7.4-6 Rev. 3.0, 03/31/04 BASES ACTIONS (continued) D.1, D.2.1 and D.2.2 The Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving [recently] irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of [recently] irradiated fuel assemblies is not sufficient reason to require a reactor shutdown. During movement of [recently] irradiated fuel assemblies in the [secondary] containment or during OPDRVs, if the inoperable [MCREC] subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE [MCREC] subsystem may be placed in the pressurization mode. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected. Required Action D.1 is modified by a Note alerting the operator to [place the system in the toxic gas protection mode if the toxic gas automatic transfer capability is inoperable]. An alternative to Required Action D.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the CRE control room. This places the unit in a condition that minimizes risk. If applicable, movement of [recently] irradiated fuel assemblies in the [secondary] containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended. E.1 If both [MCREC] subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable CRE control room boundary (i.e., Condition B), the [MCREC] System may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately. TSTF-448, Rev. 3, Draft Markup B 3.7.4 BWR/4 STS B 3.7.4-7 Rev. 3.0, 03/31/04 MCREC BASES ACTIONS (continued) F.1 and F.2 The Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving [recently] irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of [recently] irradiated fuel assemblies is not sufficient reason to require a reactor shutdown. During movement of [recently] irradiated fuel assemblies in the [secondary] containment or during OPDRVs, with two [MCREC] subsystems inoperable or with one or more [MCREC] subsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the CRE control room. This places the unit in a condition that minimizes risk. If applicable, movement of [recently] irradiated fuel assemblies in the [secondary] containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, actions must be initiated

immediately to suspend OPDVRs OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended. SURVEILLANCE SR 3.7.4.1REQUIREMENTS This SR verifies that a subsystem in a standby mode starts on demand and continues to operate. Standby systems should be checked periodically to ensure that they start and function properly. As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system. Monthly heater operation dries out any moisture that has accumulated in the charcoal as a result of humidity in the ambient air. [Systems with heaters must be operated for 10 continuous hours with the heaters energized. Systems without heaters need only be

operated for 15 minutes to demonstrate the function of the system.] Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available.

TSTF-448, Rev. 3, Draft Markup MCREC B 3.7.4 BWR/4 STS B 3.7.4-8 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.7.4.2 This SR verifies that the required [MCREC] testing is performed in accordance with the [Ventilation Filter Testing Program (VFTP)]. The [VFTP] includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the [VFTP]. SR 3.7.4.3 This SR verifies that on an actual or simulated initiation signal, each [MCREC] subsystem starts and operates. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.5 overlaps this SR to provide complete testing of the safety function. The Frequency of [18] months is based on industry operating experience and is consistent with the typical refueling cycle. The [18] month Frequency is specified in Reference

5. [ SR 3.7.4.4 This SR verifies the integrity of the control room enclosure and the assumed inleakage rates of potentially contaminated air. The control room positive pressure, with respect to potentially contaminated adjacent areas (the turbine building), is periodically tested to verify proper function of the [MCREC] System. During the emergency mode o f operation, the [MCREC] System is designed to slightly pressurize the control room [0.1] inches water gauge positive pressure with respect to the turbine building to prevent unfiltered inleakage. The [MCREC] System is designed to maintain this positive pressure at a flow rate of [400] cfm to the control room in the pressurization mo de. The Frequency of

[18] months on a STAGGERED TEST BASIS is consistent with industry practice and other filtration systems SRs. 

] SR 3.7.4.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the CRE Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than [5 rem whole body or its equivalent to any TSTF-448, Rev. 3, Draft Markup MCREC B 3.7.4 BWR/4 STS B 3.7.4-9 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) part of the body] [5 rem TEDE] and the CRE occupants are protected from hazardous chemicals and smoke. The CRE boundary is considered OPERABLE when unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Mitigating actions, or compensatory measures, are discussed in Regulatory Guide 1.196, Section 2.7.3, (Ref. 5) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 6). Temporary analytical methods may also be used as compensatory measures (Ref. 7). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status. REFERENCES 1. FSAR, Chapter [6].

2. FSAR, Chapter [9].
3. FSAR, Chapter [15].
4. FSAR, Section [6.4.1.2.2].
5. Regulatory Guide 1.196 1.52, Rev.
[2]. 6. NEI 99-03, "Control Room Habitability Assessment," March 2003
7. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2005, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

TSTF-448, Rev. 3, Draft Markup [CRFA] System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 [Control Room Fresh Air (CRFA)] System LCO 3.7.3 Two [CRFA] subsystems shall be OPERABLE. 

  ---------------------------------------------NOTE--------------------------------------------   The control room envelope (CRE) boundary may be opened intermittently under administrative control.   --------------------------------------------------------------------------------------------------

APPLICABILITY: MODES 1, 2, and 3, During movement of [recently] irradiated fuel assemblies in the [primary or secondary containment], During operations with a potential for draining the reactor vessel (OPDRVs). ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One [CRFA] subsystem inoperable for reasons other than Condition B. A.1 Restore [CRFA] subsystem to OPERABLE status. 7 days B. TwoOne or more [CRFA] subsystems inoperable due to inoperable control room CRE boundary in MODE 1, 2, or 3. B.1 Initiate action to implement mitigating actions. AND B.2 Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits. AND B.1 3 Restore control room CRE boundary to OPERABLE

status. Immediately 24 hours 60 days 24 hours BWR/6 STS 3.7.3-1 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup [CRFA] System

3.7.3 ACTIONS

(continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion

Time of Condition A or B

not met in MODE 1, 2, or 3. C.1 Be in MODE 3. AND C.2 Be in MODE 4. 12 hours 36 hours D. Required Action and associated Completion

Time of Condition A not met during movement of

[recently] irradiated fuel assemblies in the [primary or secondary containment] or during OPDRVs. --------------------NOTE------------------- LCO 3.0.3 is not applicable. ------------------------------------------------ D.1 ---------------NOTE-------------- [ Place in toxic gas protection mode if

automatic transfer to toxic

gas protection mode is inoperable. ] ------------------------------------- Place OPERABLE [CRFA] subsystem in [isolation]

mode. OR D.2.1 Suspend movement of [recently] irradiated fuel assemblies in the [primary and secondary containment]. AND D.2.2 Initiate action to suspend OPDRVs. Immediately Immediately Immediately E. Two [CRFA] subsystems inoperable in MODE 1, 2, or 3 for reasons other

than Condition B. E.1 Enter LCO 3.0.3. Immediately BWR/6 STS 3.7.3-2 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup [CRFA] System

3.7.3 ACTIONS

(continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two [CRFA] subsystems inoperable during movement of [recently] irradiated fuel assemblies in the [primary or secondary containment] or during OPDRVs. OR One or more [CRFA] subsystems inoperable due to inoperable CRE boundary during movement of [recently] irradiated fuel assemblies in the [primary or secondary] containment or during OPDRVs. --------------------NOTE------------------- LCO 3.0.3 is not applicable. ------------------------------------------------ F.1 Suspend movement of [recently] irradiated fuel assemblies in the [primary and secondary

containment]. AND F.2 Initiate action to suspend OPDRVs. Immediately Immediately BWR/6 STS 3.7.3-3 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup [CRFA] System

3.7.3 SURVEILLANCE

REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each [CRFA] subsystem for [ 10 continuous hours with the heaters operating or (for systems without heaters) 15 minutes]. 31 days SR 3.7.3.2 Perform required [CRFA] filter testing in accordance with the [Ventilation Filter Testing Program (VFTP)]. In accordance with the [VFTP] SR 3.7.3.3 Verify each [CRFA] subsystem actuates on an actual or simulated initiation signal. 

 [18] months SR 3.7.3.4 [ Verify each [CRFA] subsystem can maintain a positive pressure of  [  ] inches water gauge relative to [adjacent buildings] during the [isolation]

mode of operation at a flow rate of [ ] cfm. [18] months on a STAGGERED TEST BASIS 

]   SR 3.7.4.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program In accordance with the Control Room Envelope Habitability Program    BWR/6 STS 3.7.3-4 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5    5.5 Programs and Manuals 5.5.13 Primary Containment Leakage Rate Testing Program (continued)
f. Nothing in these Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J.

5.5.14 Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, based on [the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer] of the following:

a. Actions to restore battery cells with float voltage < [2.13] V, and
b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

5.5.15 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented in accordance with the guidelines contained in Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, May 2003, Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release," Revision 1, December 2001. 

 [The following are exceptions to Regulatory Guide 1.196, Revision 0:
1.  ; and]
 [The following are exceptions to Regulatory Guide 1.197, Revision 0:
1.  ; and]
 [The following are exceptions to Regulatory Guide 1.78, Revision 1:
1.  ; and]

The CRE Habitability Program shall ensure that CRE habitability is maintained such that, with an OPERABLE [Main Control Room Environmental Control (MCREC) System], CRE occupants can control the reactor safely 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 occupancy of BWR/6 STS 5.5-13 Rev. 3.0, 03/31/04 TSTF-448, Rev. 3, Draft Markup Programs and Manuals 5.5 BWR/6 STS 5.5-14 Rev. 3.0, 03/31/04 5.5 Programs and Manuals 5.5.15 Control Room Envelope Habitability Program (continued) the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of [5 rem whole body or its equivalent to any part of the body] [5 rem total effective dose equivalent (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 CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for assessing CRE habitability at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
d. Requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Regulatory Guide 1.197, Revision 0.
e. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFS, operating at the flow rate required by the VFTP, at a Frequency of [18] months on a STAGGERED TEST BASIS. The results shall be trended and compared to the pressure measurements at all locations taken during the previous CRE inleakage testing. These evaluations shall be used as part of an assessment of the CRE boundary between CRE inleakage tests.
f. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph d. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemical and smoke challenges must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
g. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c, d, and e, respectively.

TSTF-448, Rev. 3, Draft Markup [CRFA] System B 3.7.3 BWR/6 STS B 3.7.3-1 Rev. 3.0, 03/31/04 B 3.7 PLANT SYSTEMS B 3.7.3 [Control Room Fresh Air (CRFA)] System BASES BACKGROUND The [CRFA] System provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. radiologically controlled environment from which the unit can be safely operated following a Design Basis Accident (DBA). The safety related function of the [CRFA] System used to control radiation exposure consists of two independent and redundant high efficiency air filtration subsystems for treatment of recirculated air or outside supply air and a CRE boundary that limits the inleakage of unfiltered air. Each [CRFA] subsystem consists of a demister, an electric heater, a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section, a second HEPA filter, a fan, and the associated ductwork, dampers, doors, barriers, and instrumentation. ductwork and dampers. Demisters remove water droplets from the airstream. Prefilters and HEPA filters remove particulate matter that may be radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing

time for decay. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit for normal and accident conditions. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected for normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program. In addition to the safety related standby emergency filtration function, parts of the [CRFA] System are operated to maintain the CRE control ro om environment during normal operation. Upon receipt of the initiation signal(s) (indicative of conditions that could result in radiation exposure to CRE occupants control room personnel), the [CRFA] System automatically switches to the isolation mode of operation to prevent infiltration of contaminated air into the CRE control room. A system of dampers isolates the CRE control room , and CRE control room air flow is recirculated and processed through either of the two filter subsystems. TSTF-448, Rev. 3, Draft Markup B 3.7.3 BWR/6 STS B 3.7.3-2 Rev. 3.0, 03/31/04 [CRFA] System BASES BACKGROUND (continued) The [CRFA] System is designed to maintain a habitable environment in the CRE the control room environment for a 30 day continuous occupancy after a DBA, without exceeding a [5 rem whole body dose or its equivalent to any part of the body ] [5 rem total effective dose equivalent (TEDE)]. [CRFA] System operation in maintaining CRE the control room habitability is discussed in the FSAR, Sections [6.5.1] and [9.4.1] (Refs. 1 and 2, respectively). APPLICABLE The ability of the [CRFA] System to maintain the habitability of the SAFETY CRE control room is an explicit assumption for the safety analyses ANALYSES presented in the FSAR, Chapters [6] and [15] (Refs. 3 and 4, respectively). The isolation mode of the [CRFA] System is assumed to operate following a loss of coolant accident design basis accident (DBA), main steam line break, fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)], and control rod drop accident. The radiological doses to CRE occupants control room personnel as a result of the various DBAs are summarized in Reference 4. No single active or passive failure will cause the loss of outside or recirculated air from the CRE control room. The [CRFA] System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO Two redundant subsystems of the [CRFA] System are required to be OPERABLE to ensure that at least one is available, assuming if a single active failure disables the other subsystem. Total [CRFA] s System failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE] to CRE occupants of 5 rem to the control room operators in the event of a DBA. The Each [CRFA] subsystem System is considered OPERABLE when the individual components necessary to control operator limit CRE occupant exposure are OPERABLE in both subsystems. A subsystem is considered OPERABLE when its associated:

a. Fan is OPERABLE, b. HEPA filter and charcoal adsorber are not excessively restricting flow and are capable of performing their filtration functions, and
c. Heater, demister, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

TSTF-448, Rev. 3, Draft Markup B 3.7.3 BWR/6 STS B 3.7.3-3 Rev. 3.0, 03/31/04 [CRFA] System BASES LCO (continued) In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors. In order for the [CRFA] subsystems to be considered OPERABLE, the CRE boundary must be maintained such that CRE occupant dose from a large radioactive release does not exceed the calculated dose of the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke. The LCO is modified by a Note allowing the CRE control room boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly 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 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 operators in the CRE control room. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE control room isolation is indicated. APPLICABILITY In MODES 1, 2, and 3, the [CRFA] System must be OPERABLE to ensure that the CRE will remain habitable control operator exposure during and following a DBA, since the DBA could lead to a fission product

release. In MODES 4 and 5, the probability and consequences of a DBA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the [CRFA] System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:

a. During operations with a potential for draining the reactor vessel (OPDRVs) and
b. During movement of [recently] irradiated fuel assemblies in the [primary or secondary containment]. [Due to radioactive decay, the CRFA 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 [X] days).]

TSTF-448, Rev. 3, Draft Markup [CRFA] System B 3.7.3 BWR/6 STS B 3.7.3-4 Rev. 3.0, 03/31/04 BASES ACTIONS A.1 With one [CRFA] subsystem inoperable, for reasons other than an inoperable CRE boundary, the inoperable [CRFA] subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE [CRFA] subsystem is adequate to perform control room radiation protection. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of [CRFA] System function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities. B.1 -----------------------------------REVIEWER'S NOTE-----------------------------------Adoption of Condition B is dependent on a commitment from the licensee to have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into Condition B. 

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If the control room boundary is inoperable in MODE 1, 2, or 3, the CRFA subsystems cannot perform their intended functions. Actions must be taken to restore an OPERABLE control room boundary within 24 hours. During the period that the control room boundary is 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, toxic chemicals, smoke, temperature and relative humidity, and physical securi ty. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour 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 hour Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary. B.1, B.2 and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE]), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is considered inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 60 days.

TSTF-448, Rev. 3, Draft Markup [CRFA] System B 3.7.3 BWR/6 STS B 3.7.3-5 Rev. 3.0, 03/31/04 BASES ACTIONS (continued) During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. The mitigating actions should also address maintaining temperature and relative humidity within limits, and physical security. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 60 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protec tive measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 60 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary. C.1 and C.2 In MODE 1, 2, or 3, if the inoperable [CRFA] subsystem or the CRE control room boundary cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. D.1, D.2.1 and D.2.2 The Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving [recently] irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of [recently] irradiated fuel assemblies is not sufficient reason to require a reactor shutdown. TSTF-448, Rev. 3, Draft Markup [CRFA] System B 3.7.3 BWR/6 STS B 3.7.3-6 Rev. 3.0, 03/31/04 BASES ACTIONS (continued) During movement of [recently] irradiated fuel assemblies in the [primary or secondary containment] or during OPDRVs, if the inoperable [CRFA] subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE [CRFA] subsystem may be placed in the isolation mode. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected. Required Action D.1 is modified by a Note alerting the operator to [place the system in the toxic gas protection mode if the toxic gas, automatic transfer capability is inoperable]. An alternative to Required Action D.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the CRE control room. This places the unit in a condition that minimizes risk. If applicable, movement of [recently] irradiated fuel assemblies in the [primary and secondary containment] must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended. E.1 If both [CRFA] subsystems are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable CRE control room boundary (i.e., Condition B), the [CRFA] System may not be capable of performing the intended function and the unit is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately. F.1 and F.2 The Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving [recently] irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of [recently] irradiated fuel assemblies is not sufficient reason to require a reactor shutdown. TSTF-448, Rev. 3, Draft Markup B 3.7.3 BWR/6 STS B 3.7.3-7 Rev. 3.0, 03/31/04 [CRFA] System BASES ACTIONS (continued) During movement of [recently] irradiated fuel assemblies in the [primary or secondary containment] or during OPDRVs, with two [CRFA] subsystems inoperable or with one or more [CRFA] subsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the CRE control room. This places the unit in a condition that minimizes risk. If applicable, movement of [recently] irradiated fuel assemblies in the [primary and secondary containment] must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended. SURVEILLANCE SR 3.7.3.1REQUIREMENTS This SR verifies that a subsystem in a standby mode starts on demand and continues to operate. Standby systems should be checked periodically to ensure that they start and function properly. As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system. Monthly heater operation dries out any moisture accumulated in the charcoal from humidity in the ambient air. [Systems

with heaters must be operated for 10 continuous hours with the heaters energized. Systems without heaters need only be operated for 15 minutes to demonstrate the function of the system.] Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available. SR 3.7.3.2 This SR verifies that the required CRFA testing is performed in accordance with the [Ventilation Filter Testing Program (VFTP)]. The [VFTP] includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the [VFTP]. TSTF-448, Rev. 3, Draft Markup [CRFA] System B 3.7.3 BWR/6 STS B 3.7.3-8 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.7.3.3 This SR verifies that each [CRFA] subsystem starts and operates on an actual or simulated initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.5 overlaps this SR to provide complete testing of the

safety function. The Frequency of [18] months is based on industry operating experience and is consistent with the typical refueling cycle. The [18] month Fre quency is specified in Reference

5. SR 3.7.3.4 This SR verifies the integrity of the control room enclosure and the assumed inleakage rates of potentially contaminated air. The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper function of the [CRFA] System. During the emergency mode of operation, the [CRFA] System is designed to slightly pressurize the control room to [0.1]

inches water gauge positive pressure with respect to adjacent areas to prevent unfiltered inleakage. The [CRFA] System is designed to maintain this positive pressure at a flow rate of [500] cfm to the control room in the isolation mode. The Frequency of [18] months on a STAGGERED TEST BASIS is consistent with industry practice and other filtration system SRs. This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the CRE Habitability Program. Unfiltered air inleakage into the CRE greater than the amount assumed in the licensing basis consequence anal yses for design basis accidents results in the CRE boundary being inoperable when control room habitability is not maintained (i.e., accident dose is greater than licensing basis consequence analyses calculated dose, which can be no greater than [5 rem whole body or its equivalent to any part of the body] [5 rem TEDE] or the control room occupants are not protected from hazardous chemicals or smoke.) However, when unfiltered air inleakage is greater than assumed in the licensing basis accident consequence analyses, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Mitigating actions, or compensatory measures, are discussed in Regulatory Guide 1.196, Section 2.7.3, (Ref. 5) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 6). Temporary analytical methods may TSTF-448, Rev. 3, Draft Markup [CRFA] System B 3.7.3 BWR/6 STS B 3.7.3-9 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) also be used as compensatory measures (Ref. 7). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status. REFERENCES 1. FSAR, Section [6.5.1].

2. FSAR, Section [9.4.1].
3. FSAR, Chapter [6].
4. FSAR, Chapter [15].
5. Regulatory Guide 1.196 1.52, Rev. [2]. 6. NEI 99-03, "Control Room Habitability Assessment," March 2003
7. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2005, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694.).

Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 1 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 1 Revise Condition A to exclude Condition B. Spec 3.7.10

Condition A Spec 3.7.10

Condition A Spec 3.7.11

Condition A Spec 3.7.4 Condition A Spec 3.7.3 Condition A 2 Revise Condition B to apply to one, as well as two, control room envelope (CRE) emergency ventilation systems (CREEVS) made inoperable due to an inoperable CRE

boundary. Spec 3.7.10

Condition B Spec 3.7.10

Condition B Spec 3.7.11

Condition B Spec 3.7.4 Condition B Spec 3.7.3 Condition B 3 Add a required action (RA) to initiate action to

implement mitigating

actions immediately. Spec 3.7.10 RA B.1 Spec 3.7.10 RA B.1 Spec 3.7.11 RA B.1 Spec 3.7.4 RA B.1 Spec 3.7.3 RA B.1 4 Add the word "envelope" and use the acronym CRE in place of "control room" (except for plant-specific name for the CREEVS). Spec 3.7.10 LCO Note Condition B RAs B.2 & B.3 Spec 3.7.10 LCO Note Condition B RAs B.2 & B.3 Spec 3.7.11 LCO Note Condition B RAs B.2 & B.3 Spec 3.7.4 LCO Note Condition B RAs B.2 & B.3 Spec 3.7.3 LCO Note Condition B RAs B.2 & B.3 5 Add a RA to verify, within 24 hours, that mitigating actions ensure CRE

occupant exposures to radiological, chemical, and smoke hazards will not exceed limits. Spec 3.7.10 RA B.2 Spec 3.7.10 RA B.2 Spec 3.7.11 RA B.2 Spec 3.7.4 RA B.2 Spec 3.7.3 RA B.1 Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 2 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 6 Re-number STS RA B.1 as RA B.3 Spec 3.7.10 RA B.3 Spec 3.7.10 RA B.3 Spec 3.7.11 RA B.3 Spec 3.7.4 RA B.3 Spec 3.7.3 RA B.3 7 Add a new condition to Condition E that states, "One or more CREEVS trains inoperable due to an inoperable CRE boundary [in Mode 5 or 6, or] during movement of [recently] irradiated fuel assemblies." Spec 3.7.10

Condition E second condition Spec 3.7.10

Condition E second condition Spec 3.7.11

Condition E second condition Not Applicable Not Applicable 8 Add phrase "[in MODE 5 or 6, or]" to Conditions D and

E. Spec 3.7.10 Condition D Condition E first condition Not Applicable Not Applicable Not Applicable Not Applicable 9 Add a new condition to Condition F that states, "One or more CREEVS subsystems inoperable due to inoperable CRE boundary during movement of [recently] irradiated fuel assemblies in the [[primary or] secondary] containment

or during OPDRVs. Not Applicable Not Applicable Not Applicable Spec 3.7.4 Condition F second condition Spec 3.7.3 Condition F second condition 10 Delete differential pressure surveillance requirement (SR). Spec 3.7.10 SR 3.7.10.4 Spec 3.7.10 SR 3.7.10.4 Spec 3.7.11 SR 3.7.11.4 Spec 3.7.4 SR 3.7.4.4 Spec 3.7.3 SR 3.7.3.4

Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 3 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 11 Add a new surveillance requirement that states, "Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program." Spec 3.7.10 SR 3.7.10.4 Spec 3.7.10 SR 3.7.10.4 Spec 3.7.11 SR 3.7.11.4 Spec 3.7.4 SR 3.7.4.4 Spec 3.7.3 SR 3.7.3.4 12 Replace "irradiate" with "irradiated" for editorial

correction. Not Applicable Spec 3.7.10 Condition E first condition Not Applicable Not Applicable Not Applicable 13 Add a CRE Habitability Program specification. Spec 5.5.18 Spec 5.5.18 Spec 5.5.18 Spec 5.5.15 Spec 5.5.15 14 Replace "[, chemicals, or toxic gas]." with ", hazardous chemicals, or

smoke." B 3.7.10 Background ¶-1 B 3.7.10 Background ¶-1 B 3.7.11 Background ¶-1 Not Applicable Not Applicable 15 Revise to be consistent with PWR STSs. Not Applicable Not Applicable Not Applicable B 3.7.4 Background ¶-1 B 3.7.3 Background ¶-1 16 Clarify that the CREEVS includes the CRE boundary. B 3.7.10 Background ¶-2, Sentence 1 B 3.7.10 Background ¶-2, Sentence 1 B 3.7.11 Background ¶-2, Sentence 1 B 3.7.4 Background ¶-2, Sentence 1 B 3.7.3 Background ¶-2, Sentence 1 17 Revise to be more consistent with other PWR

STSs. B 3.7.10 Background ¶-2, Sentences 1 & 2 Not Applicable Not Applicable Not Applicable Not Applicable Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 4 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 18 Add system acronym to modify "train" for clarification. B 3.7.10 Background ¶-2, Sentence 2 B 3.7.10 Background ¶-2, Sentence 2 B 3.7.11 Background ¶-2, Sentence 2 B 3.7.4 Background ¶-2, Sentence 2 B 3.7.3 Background ¶-2, Sentence 2 19 Add sentence to clarify that 'doors and barriers' also form part of the CREVS. B 3.7.10 Background ¶-2, Sentence 3 Not Applicable Not Applicable Not Applicable Not Applicable 20 Revise sentence to clarify that 'doors and barriers'

also form part of the CREEVS. Not Applicable B 3.7.10 Background ¶-2, Sentence 3 B 3.7.11 Background ¶-2, Sentence 3 Not Applicable Not Applicable 21 Revise sentence to clarify that 'doors, barriers, and instrumentation' also form part of the CREEVS. Not Applicable Not Applicable Not Applicable B 3.7.4 Background ¶-2, Sentence 2 B 3.7.3 Background ¶-2, Sentence 2 22 Replace "provide" with "provides" for editorial correction. Not Applicable B 3.7.10 Background ¶-2, Sentence 4 Not Applicable Not Applicable Not Applicable 23 Replace "do" with "well as" for consistency and editorial

correction. Not Applicable Not Applicable B 3.7.11 Background ¶-2, Sentence 3 Not Applicable Not Applicable 24 Replace ", and to back up the main HEPA filter bank if it fails" with "and provides backup in case of failure of

the main HEPA filter bank" for consistency with WOG STSs. Not Applicable Not Applicable B 3.7.11 Background ¶-2, Sentence 4 Not Applicable Not Applicable Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 5 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 25 Add a new paragraph that generally describes the

CRE and its boundary. B 3.7.10 Background ¶-3 B 3.7.10 Background ¶-3 B 3.7.11 Background ¶-3 B 3.7.4 Background ¶-3 B 3.7.3 Background ¶-3 26 Replace 'control room' with 'CRE.' B 3.7.10 Background ¶-4, Sentence 2 ¶-5, Sentence 1 ¶-6, Sentence 1 B 3.7.10 Background ¶-4, Sentence 2 ¶-5, Sentence 3 ¶-6, Sentences 1, 2, & 3 ¶-7, Sentence 1 ¶-8, Sentences 1 & 2 B 3.7.11 Background ¶-4, Sentence 2 ¶-5, Sentence 3 ¶-6, Sentences 1, 2, & 3 ¶-7, Sentence 1 ¶-8, Sentences 1 & 2 B 3.7.4 Background ¶-4, Sentences 1, 2, & 3 ¶-5, Sentences 2 & 3 B 3.7.3 Background ¶-4, Sentences 1, 2, & 3 ¶-5, Sentence 2 27 Replace "control room personnel" with "CRE occupants" for consistent terminology. Not Applicable Not Applicable Not Applicable B 3.7.4 Background ¶-4, Sentence 2 B 3.7.3 Background ¶-4, Sentence 2 28 Replace "control room air" with the air within the

CRE. Not Applicable B 3.7.10 Background ¶-5, Sentence 2 B 3.7.11 Background ¶-5, Sentence 2 Not Applicable Not Applicable 29 Remove phrase "with a 1.5 ft 2 LEAKAGE area" for consistency with other PWR STSs. B 3.7.10 Background ¶-5, Sentence 1 Not Applicable Not Applicable Not Applicable Not Applicable 30 Add phrase "in maintaining the CRE habitable" to modify the word "operation"

for clarity. B 3.7.10 Background ¶-5, Sentence 2 Not Applicable Not Applicable Not Applicable Not Applicable Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 6 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 31 Revise sentence as follows: Pressurization of the CRE control room prevents minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas of the building adjacent to the CRE boundary. Not Applicable B 3.7.10 Background ¶-6, Sentence 2 B 3.7.11 Background ¶-6, Sentence 2 Not Applicable Not Applicable 33 Replace "prevent" with "minimize any," or

"preventing" with "to

minimize any." Not Applicable B 3.7.10 Background ¶-6, Sentence 3 B 3.7.11 Background ¶-6, Sentence 3 Not Applicable Not Applicable 34 Add "through the CRE boundary" to the end of the sentence. Not Applicable B 3.7.10 Background ¶-6, Sentence 3 B 3.7.11 Background ¶-6, Sentence 3 Not Applicable Not Applicable 35 Replace "control room ventilation" with "the CREEVS" for clarity. Not Applicable B 3.7.10 Background ¶-6, Sentence 3 B 3.7.11 Background ¶-6, Sentence 3 Not Applicable Not Applicable 36 Add "CREEVS" to clarify what system the "single train" belongs to. B 3.7.10 Background ¶-5, Sentence 1 B 3.7.10 Background ¶-8, Sentence 1 B 3.7.11 Background ¶-8, Sentence 1 Not Applicable Not Applicable Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 7 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 37 Add the flow rate criterion from the deleted CRE pressurization-flow SR, and stipulate that the minimum pressure criterion is "relative to all external areas adjacent to the CRE

boundary." B 3.7.10 Background ¶-5, Sentence 1 B 3.7.10 Background ¶-8, Sentence 1 B 3.7.11 Background ¶-8, Sentence 1 B 3.7.4 Background ¶-5, Sentence 2 Not Applicable 38 Revise sentence as follows: A single [MCREC]

subsystem operating at a flow rate of [400] cfm will pressurize the CRE control room to about [0.1] inches water gauge relative to all external areas adjacent to the CRE boundary to minimize to prevent infiltration of air from all surrounding areas adjacent to the CRE boundary surrounding buildings. Not Applicable Not Applicable Not Applicable B 3.7.4 Background ¶-5, Sentence 2 Not Applicable 39 No changes Not Applicable B 3.7.10 Background ¶-9 B 3.7.11 Background ¶-9 Not Applicable Not Applicable 40 Add phrase "habitable environment in" following word "maintain." B 3.7.10 Backgound ¶-6, Sentence 1 Not Applicable Not Applicable Not Applicable Not Applicable Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 8 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 41 Replace "the control room environment" with "a habitable environment in the

CRE." Not Applicable B 3.7.10 Background ¶-10, Sentence 1 B 3.7.11 Background ¶-10, Sentence 1 B 3.7.4 Background ¶-5, Sentence 1 B 3.7.3 Background ¶-5, Sentence 1 42 Put "5 rem whole body dose or its equivalent to any part of the body" in brackets, and add "[5 rem total effective dose equivalent (TEDE)]" at the end. B 3.7.10 Backgound ¶-6, Sentence 1 B 3.7.10 Background ¶-10, Sentence 1 B 3.7.11 Background ¶-10, Sentence 1 B 3.7.4 Background ¶-5, Sentence 2 B 3.7.3 Background ¶-5, Sentence 2 43 Split first paragraph in Applicable Safety Analyes (ASA) section to match

CEOG STSs. B 3.7.10 ASA B 3.7.10 ASA Not Applicable Not Applicable Not Applicable 44 Replace "control room envelope" with "CRE." B 3.7.10 ASA ¶-1, Sentence 2 B 3.7.10 ASA ¶-1, Sentence 2 B 3.7.11 ASA ¶-1, Sentence 2 Not Applicable Not Applicable 45 Replace "the control room operators" with "CRE

occupants" B 3.7.10 ASA ¶-2, Sentence 1 B 3.7.10 ASA ¶-2, Sentence 1 B 3.7.11 ASA ¶-2, Sentence 1 Not Applicable Not Applicable 46 Replace "control room accident" with "CRE

occupant." B 3.7.10 ASA ¶-2, Sentence 1 B 3.7.10 ASA ¶-2, Sentence 1 B 3.7.11 ASA ¶-2, Sentence 1 Not Applicable Not Applicable 47 Remove "loss of coolant." B 3.7.10 ASA ¶-2, Sentence 1 B 3.7.10 ASA ¶-2, Sentence 1 B 3.7.11 ASA ¶-2, Sentence 1 Not Applicable Not Applicable Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 9 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 48 Replace "control room" with "CRE." B 3.7.10 ASA ¶-4, Sentence 1 B 3.7.10 ASA ¶-3, Sentence 1 B 3.7.11 ASA ¶-3, Sentence 1 B 3.7.4 ASA ¶-1, Sentence 1 ¶-1, Sentence 4 B 3.7.3 ASA ¶-1, Sentence 1 ¶-1, Sentence 4 49 Replace "loss of coolant accident" with "design basis accident (DBA)." Not Applicable Not Applicable Not Applicable B 3.7.4 ASA ¶-1, Sentence 2 B 3.7.3 ASA ¶-1, Sentence 2 50 Replace "control room personnel" with "CRE occupants." Not Applicable Not Applicable Not Applicable B 3.7.4 ASA ¶-1, Sentence 3 B 3.7.3 ASA ¶-1, Sentence 3 51 no changes B 3.7.10 ASA ¶-3 and ¶-5 B 3.7.10 ASA ¶-4 and ¶-5 B 3.7.11 ASA ¶-4 and ¶-5 B 3.7.4 ASA ¶-2 B 3.7.3 ASA ¶-2 52 Replace "assuming [that]" with "if" for consistency with BWOG STSs. Not Applicable B 3.7.10 LCO ¶-1, Sentence 1 B 3.7.11 LCO ¶-1, Sentence 1 B 3.7.4 LCO ¶-1, Sentence 1 B 3.7.3 LCO ¶-1, Sentence 1 53 Clarify that "a single failure" means a single "active" failure. B 3.7.10 LCO ¶-1, Sentence 1 B 3.7.10 LCO ¶-1, Sentence 1 B 3.7.11 LCO ¶-1, Sentence 1 B 3.7.4 LCO ¶-1, Sentence 1 B 3.7.3 LCO ¶-1, Sentence 1 54 Revise sentence to state that an inoperable CRE boundary could also result in CRE occupant exposures

exceeding limits. B 3.7.10 LCO ¶-1, Sentence 2 B 3.7.10 LCO ¶-1, Sentence 2 B 3.7.11 LCO ¶-1, Sentence 2 B 3.7.4 LCO ¶-1, Sentence 2 B 3.7.3 LCO ¶-1, Sentence 2 Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 10 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 55 Revise sentence by bracketing "5 rem" and

adding "dose" language

used in Background section. B 3.7.10 LCO ¶-1, Sentence 2 B 3.7.10 LCO ¶-1, Sentence 2 B 3.7.11 LCO ¶-1, Sentence 2 B 3.7.4 LCO ¶-1, Sentence 2 B 3.7.3 LCO ¶-1, Sentence 2 56 Replace "to the control room operator" with "to CRE occupants." B 3.7.10 LCO ¶-1, Sentence 2 B 3.7.10 LCO ¶-1, Sentence 2 B 3.7.11 LCO ¶-1, Sentence 2 B 3.7.4 LCO ¶-1, Sentence 2 B 3.7.3 LCO ¶-1, Sentence 2 57 Revise sentence to address one train or subsystem. B 3.7.10 LCO ¶-2, Sentence 1 B 3.7.10 LCO ¶-2, Sentence 1 B 3.7.11 LCO ¶-2, Sentence 1 B 3.7.4 LCO ¶-2, Sentence 1 B 3.7.3 LCO ¶-2, Sentence 1 58 Replace "control operator" with "limit CRE occupant" for consistency with BWOG STSs. Not Applicable B 3.7.10 LCO ¶-2, Sentence 2 B 3.7.11 LCO ¶-2, Sentence 2 B 3.7.4 LCO ¶-2, Sentence 2 B 3.7.3 LCO ¶-2, Sentence 2 59 Replace "operator" with CRE occupant." B 3.7.10 LCO ¶-2, Sentence 2 Not Applicable Not Applicable Not Applicable Not Applicable 60 Replace paragraph with a more detailed description of the role of the CRE

boundary in determining

CREEVS operability. B 3.7.10 LCO ¶-3 B 3.7.10 LCO ¶-3 B 3.7.11 LCO ¶-3 B 3.7.4 LCO ¶-3 B 3.7.3 LCO ¶-3 61 Replace "[main] control room" with "CRE." B 3.7.10 LCO ¶-4, Sentences 1, 4, & 5 B 3.7.10 LCO ¶-4, Sentences 1, 4, & 5 B 3.7.11 LCO ¶-4, Sentences 1, 4, & 5 B 3.7.4 LCO ¶-4, Sentences 1, 4, & 5 B 3.7.3 LCO ¶-4, Sentences 1, 4, & 5 Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 11 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 62 Add sentence to clarify application of the LCO Note. B 3.7.10 LCO ¶-4, Sentence 2 B 3.7.10 LCO ¶-4, Sentence 2 B 3.7.11 LCO ¶-4, Sentence 2 B 3.7.4 LCO ¶-4, Sentence 2 B 3.7.3 LCO ¶-4, Sentence 2 63 Clarify the administrative controls required by the

LCO Note. B 3.7.10 LCO ¶-4, Sentences 4 & 5 B 3.7.10 LCO ¶-4, Sentences 4 & 5 B 3.7.11 LCO ¶-4, Sentences 4 & 5 B 3.7.4 LCO ¶-4, Sentences 4 & 5 B 3.7.3 LCO ¶-4, Sentences 4 & 5 64 Clarify the basis for the applicability of the CREEVS. B 3.7.10 Applicability ¶-1, Sentence 1 B 3.7.10 Applicability ¶-1, Sentence 1 B 3.7.11 Applicability ¶-1, Sentence 1 B 3.7.4 Applicability ¶-1, Sentence 1 B 3.7.3 Applicability ¶-1, Sentence 1 65 Revise to match Actions Condition A. B 3.7.10 Actions A.1 ¶-1, Sentence 1 B 3.7.10 Actions A.1 ¶-1, Sentence 1 B 3.7.11 Actions

A.1 ¶-1, Sentence 1 B 3.7.4 Actions A.1 ¶-1, Sentence 1 B 3.7.3 Actions

A.1 ¶-1, Sentence 1 66 Remove Reviewer's Note and Bases for replaced Required Action B.1 B 3.7.10 Actions B.1, B.2, & B.3 B 3.7.10 Actions B.1, B.2, & B.3 B 3.7.11 Actions B.1, B.2, & B.3 B 3.7.4 Actions B.1, B.2, & B.3 B 3.7.3 Actions B.1, B.2, & B.3 67 Add Bases for revised Actions Condition B, and new Required Actions B.1, B.2, and B.3. B 3.7.10 Actions B.1, B.2, & B.3 ¶-1 & 2 B 3.7.10 Actions B.1, B.2, & B.3 ¶-1 & 2 B 3.7.11 Actions B.1, B.2, & B.3 ¶-1 & 2 B 3.7.4 Actions B.1, B.2, & B.3 ¶-1 & 2 B 3.7.3 Actions B.1, B.2, & B.3 ¶-1 & 2 68 Revise sentence to be consistent with other STSs. Not Applicable Not Applicable B 3.7.11 Actions C.1 & C.2 ¶-1, Sentence 1 Not Applicable Not Applicable Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 12 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 69 Move Bases for the Note for RA D.1 from the first to third paragraph of discussion, for consistency with WOG STS.Add "the" to WOG STS

paragraph. B 3.7.10 Actions D.1 & D.2 ¶-1 ¶-3 B 3.7.10 Actions D.1 & D.2 ¶-3, Sentence 1 B 3.7.11 Actions

D.1 & D.2 ¶-1 ¶-3 Not Applicable Not Applicable 70 Replace "control room" with "CRE." B 3.7.10 Actions C.1 and C.2 ¶-1, Sentence 1 D.1 & D.2 ¶-2, Sentence 1 E.1 ¶-1, Sentence 1 F.1 ¶-1, Sentence 1 B 3.7.10 Actions C.1 & C.2 ¶-1, Sentence 1 D.1 & D.2 ¶-2, Sentence 1 E.1 ¶-1, Sentence 1 F.1 ¶-1, Sentence 1 B 3.7.11 Actions C.1 & C.2 ¶-1, Sentence 1 D.1 & D.2 ¶-3, Sentence 1 E.1 ¶-1, Sentence 1 F.1 ¶-1, Sentence 1 B 3.7.4 Actions C.1 & C.2 ¶-1, Sentence 1 D.1 & D.2 ¶-4, Sentence 1 E.1 ¶-1, Sentence 1 F.1 & F.2 ¶-2, Sentence 1 B 3.7.3 Actions C.1 & C.2 ¶-1, Sentence 1 D.1 & D.2 ¶-4, Sentence 1 E.1 ¶-1, Sentence 1 F.1 & F.2 ¶-2, Sentence 1 71 Replace "MODE in which the LCO does not apply" with "MODE that minimizes

accident risk" to be consistent with other STSs. B 3.7.10 Actions C.1 and C.2 Sentence 1 Not Applicable Not Applicable Not Applicable Not Applicable 72 Revise Bases to address second Actions Condition, "one or more CREEVS trains [subsystems] inoperable due to an inoperable CRE boundary." B 3.7.10 Actions

E.1 ¶-1, Sentence 1 B 3.7.10 Actions

E.1 ¶-1, Sentence 1 B 3.7.11 E.1 ¶-1, Sentence 1 B 3.7.4 Actions F.1 & F.2 ¶-2, Sentence 1 B 3.7.3 Actions F.1 & F.2 ¶-2, Sentence 1 Control Room Envelope Habitability Systems Standard Technical Specification Improvements Page 13 of 13 List of Changes Made by TSTF-448, Revision 3, Draft Markup Revised Specification (Spec), Bases Section, Paragraph (¶-#), or Sentence # of NUREG-Change Number Description 1430 1431 1432 1433 1434 73 Correct spelling error for "OPDRVs." Not Applicable Not Applicable Not Applicable B 3.7.4 Actions F.1 & F.2 ¶-3, Sentence 3 Not Applicable 74 no changes B 3.7.10 SR 3.7.10.1 SR 3.7.10.2 B 3.7.10 SR 3.7.10.1 SR 3.7.10.2 B 3.7.11 SR 3.7.11.1 SR 3.7.11.2 B 3.7.4 SR 3.7.4.1 SR 3.7.4.2 B 3.7.3 SR 3.7.3.1 SR 3.7.3.2 75 Replace Bases sentence for the Frequency. B 3.7.10 SR 3.7.10.3 ¶-1, Sentence 2 B 3.7.10 SR 3.7.10.3 ¶-1, Sentence 2 B 3.7.11 SR 3.7.11.3 ¶-1, Sentence 2 B 3.7.4 SR 3.7.4.3 ¶-1, Sentence 3 B 3.7.3 SR 3.7.3.3 ¶-1, Sentence 3 76 Replace Bases for CRE differential pressure test with inleakage test. B 3.7.10 SR 3.7.10.4 B 3.7.10 SR 3.7.10.4 B 3.7.10 SR 3.7.11.4 B 3.7.4 SR 3.7.4.4 B 3.7.3 SR 3.7.3.4 77 Replace "Regulatory Guide 1.52" with "Regulatory

Guide 1.196." B 3.7.10 Reference 3 B 3.7.10 Reference 3 B 3.7.11 Reference 3 B 3.7.4 Reference 5 B 3.7.3 Reference 5 78 Replace "NUREG-800" with "NEI 99-03." B 3.7.10 Reference 4 B 3.7.10 Reference 4 B 3.7.11 Reference 4 B 3.7.4 Reference 6 B 3.7.3 Reference 6 79 Reference NRC letter on compensatory measures. B 3.7.10 Reference 5 B 3.7.10 Reference 5 B 3.7.11 Reference 5 B 3.7.4 Reference 7 B 3.7.3 Reference 7 80 Correct error. Not Applicable B 3.7.10 Reference 1 B 3.7.11 Reference 1 Not Applicable Not Applicable 81 Add missing Bases. B 3.7.10 SR 3.7.10.5 Not Applicable Not Applicable Not Applicable Not Applicable

SAFETY EVAL UATION B Y THE OF FICE OF NUCL EAR R EACTOR REGUL ATION RELATE D TO AM ENDM ENT NO. TO FACIL ITY OPER ATING LI CENS E NO. [N PF-XX]AND AMENDMENT NO. TO FACILITY OPERATING LICENSE NO. [NPF-YY] [NAME OF LICENSEE] [NAME OF FACILITY] DOCKET NOS. 50-[X XX] AND 50-[YYY]

1.0 INTRODU

CTION By appli cation dated [ ] as supple mented by l etters dated[ and 

], [Name of Licens ee] (the lice nsee) requeste d chan ges to th e Techn ical Speci ficatio ns (TSs) for the [Name of Faci lity].The supplements dated [ and ], provided additional information that clarif ied the application, did not expand the scope of the application as originally noticed, and did not chang e the staff's original prop osed no signi ficant hazards consideratio n determinatio n as publi shed in the Federa l Regi ster on [Date (PM/L A wi ll fil l in FR in formatio n)] (XX FR XXXX).In NRC Generi c Letter 2003-01 (Reference 1), li censees w ere alerted to findings at facili ties that existi ng technical specification surveill ance requirements for th e [Control Ro om Envelo pe Emergency Venti lation Sy stem (CREEVS

)] may not be adequate. Speci fically, the results of ASTM E741 (Reference 2) tracer gas tests to measure control room env elope (CRE) unfiltered inleakage at facil ities ind icated that the differential press ure survei llance i s not a reli able method for demonstrating CRE boundary o perability. Licensees were requeste d to address e xisting TSs as follow s: Provi de con firmatio n that your techni cal sp ecific ation s ver ify th e inte grity [i.e., operabili ty] of the CRE [boundary], an d the assumed [u nfiltered] inl eakage rates of poten tiall y con tamina ted ai r. If yo u curre ntly have a differe ntial pressu re surveill ance requirement to demonstrate CRE 

[boundary]

integrity, prov ide the basis for yo ur con clusi on tha t it re mains adequa te to d emonstr ate CR E inte grity in light of the ASTM E741 testing results. If you conclu de that you r differential pressu re surv eill ance r equire ment is no lo nger ad equate, prov ide a sched ule for: 1) rev isin g the su rvei llan ce requi rement in y our tec hnica l spe cifica tion t o reference an accep table surve illance methodology (e.g., A STM E741), a nd 2)making any neces sary modificati ons to you r CRE [bound ary] so that c ompliance with y our new su rveilla nce requirement can be demonstrated. If your facility does not curre ntly hav e a technica l specificati on survei llance requirement for your CRE integrity , explai n how an d at what frequency you confirm your CRE integrity and why this is adequate to demonst rate CRE integr ity. To promote standardi zation an d to minimiz e the resources that woul d be needed to create and process plan t-specific amendment applicatio ns in respon se to the conc erns describe d in the generic letter, the industry and the NRC proposed rev isions to C RE habitabi lity sy stem requirements contai ned in the improved sta ndard technic al specificati ons (STSs), NURE Gs-1430 t o 1434 , usin g the STS change trave ler pr ocess. This e ffort culm inate d in R evis ion 3 to traveler TSTF-448 , "Control Roo m Habitabil ity," wh ich the NRC staff approved on [month d d, 200 6].Consistent w ith the trav eler as in corporated into NUREG-143x x, the li censee propose d revisi ng action and s urveill ance requirements i n [Specificati on 3.7.10, "Con trol Room Env elope Emergen cy Ve ntila tion S ystem (CREE VS),"] and ad ding a new admin istrat ive contro ls pro gram, [Specification 5.5.18, "CRE H abitabili ty Program."] The purpo se of the changes i s to ensure tha t CRE bounda ry operabi lity is maintained and verified through effective surv eillance and programmatic requirements, a nd that appropri ate remedial actions are ta ken in the ev ent of an inopera ble CRE boun dary.2.0 REGUL ATORY E VALUA TION 2.1 Control Room and Control Room Envel ope Regula tory Gu ide 1.196, "Contro l Roo m Habi tabil ity a t Light-wate r Nucl ear Po wer R eactor s,"Revisio n 0, May 2003, (Reference

4) uses the term "c ontrol room env elope (CRE

)" in additi on to the term "control room" and defines each term as foll ows: Control Room The plant area, defined in the facility l icensing basi s, in wh ich actions can be taken to ope rate th e pla nt safel y und er norm al co nditi ons an d to mainta in the reacto r in a safe co nditi on dur ing acc ident situa tions. It enc omp ass es t he in str ume nta tio n a nd con tro ls nec ess ary for a s afe shutdown o f the plant and typicall y inclu des the criti cal document reference file, computer room (if used as a n integral part of the emergency respon se plan), shi ft supervisor's office, operator w ash room and kitchen, and other critica l areas to w hich frequent personn el access or con tinuo us occ upanc y may be ne cessar y in the ev ent of a n acci dent.Control Room The plant area, defined in the facility l icensing basi s, that in the event of an Envelope emergency, can b e isolated from the plant areas and the env ironment exter nal to the CR E. This area i s serv ed by an eme rgency vent ilati on sy stem, with the intent of maintai ning the habi tability of the control ro om. This area encompasses the control room, and may encompas s other non-cri tical areas to which frequent personnel a ccess or conti nuous occupa ncy is n ot necess ary i n the e vent of an ac ciden t.Regulatory Gui de 1.197, "Demon strating Control Room Envel ope Integrity A t Nuclear Po wer Reactors," Rev ision 0, M ay 2003 (R eference 5), also contains these definitions, but uses the term CR E to me an bot h. Thi s is b ecause the pr otecte d env ironme nt prov ided for oper ators varies w ith the nucl ear power facility. At some facilitie s this env ironment is l imited to the control room; a t other s, it i s the C RE. In this safety eval uatio n, con sisten t wi th the propos ed cha nges to the STSs, the CR E will be used to designate both. F or consistency , facilities should use the term CRE wi th an appropri ate facility-specific definiti on derive d from the above CRE definiti on. 2.2[Contro l Roo m Env elope Emergen cy Ve ntila tion S ystem (CREE VS)]The [CR EEVS] prov ides a prote cted e nvir onment from wh ich o perato rs can contro l the unit, during airborne challenges from radioactivi ty, hazard ous chemical s, and fire by products, such as fire suppressi on agents and smo ke, during both normal and accide nt condition s.The [CREEVS] i s designed to maintain a h abitable e nvironment i n the control room envelo pe for 30 day s of c onti nuou s oc cupa ncy after a De sign Bas is A cci dent (DB A) w itho ut ex ceed ing a[5 rem whol e body do se or its equi valent to any part of the body] [5 rem to tal effective dos e equiv alent (TEDE)].The [CREEVS] c onsists of two redundant trai ns [subsystems], each capabl e of maintainin g the habitabil ity of the CR E. The [CREEV S] is consi dered operabl e when th e indiv idual compon ents n ecessa ry to limit opera tor ex posure are op erabl e in b oth tra ins [s ubsy stems]. A[CREEVS] tra in [subsys tem] is consid ered operabl e when th e associated

!Fan is ope rable;!High efficiency particulat e air (HEPA) filters and charcoal adsorbe rs are not excessively restricting flow , and are capa ble of performing their filtration function s;!Heater, demister, d uctwork, val ves, and d ampers are OPERA BLE, and ai r circulatio n can be maintaine d; and!CRE b ounda ry is opera ble (t he si ngle b ounda ry su pports both t rains [subsy stems]).The CRE boun dary is co nsidered ope rable wh en the measured unfiltered air inleakage is l ess than or equal to the inleakag e value assumed by the licensing basis analyses of design basis accident con sequences to CR E occupants.

2.3 Regula

tions Appl icabl e to Co ntrol Room H abita bili ty In Appendix A, "General D esign Criteria for Nuclear Po wer Plan ts," to 10 CFR Part 50,"Domestic Lice nsing of Productio n and Util ization Faciliti es," General D esign Criteria (GDC) 1, 3, 4, 5, and 1 9 apply to CRE habi tability. A summary of these GDCs follow s.!GDC 1, "Quality Standards an d Records," requi res that structures, s ystems, and compon ents (S SCs) i mportan t to sa fety be desi gned, fab ricate d, erec ted, an d teste d to quality stan dards commensurate with the importance of the sa fety functions performed. !GDC 3, "Fire Protec tion," requir es SSC s impo rtant to safety be de signed and l ocated to minimize the effects of fires and ex plosions.!GDC 4, "Envi ronmen tal an d Dyn amic E ffects Des ign Ba ses," r equire s SSC s impo rtant to safety to be de signed to accommod ate the effects of and to b e compatible with the environmenta l conditi ons associate d with n ormal operatio n, maintenance, testing, and postul ated a ccide nts, i nclud ing lo ss-of-co olant accid ents (L OCAs). !GDC 5, "Sharin g of Structures, Syste ms, and Componen ts," requires that SS Cs important to safety not be shared among nuc lear pow er units unl ess it can b e shown that such sharing will not significantly impair their ability to perfor m their safety fun ctions, including, in the event o f an accident i n one unit, the orderly shutdown and cooldow n of the remainin g units.!GDC 19, "Control Room," requires tha t a control roo m be provid ed from which actions can be taken to operate the nuclear reactor safely u nder normal co nditions an d to maintain the reactor in a s afe condition under accide nt condition s, includi ng a LOCA. Adequate radiation protection is to be prov ided to permi t access and o ccupancy o f the control room u nder accident con ditions w ithout personn el receiv ing radiation exposures in excess of specified values.Prior to inc orporation of TSTF-448, Revisio n 3, the STS requi rements addressi ng control room habitabil ity resid ed only in the follow ing CRE v entilation system speci fications: NURE G-1430, TS 3.7.10, "C ontrol Room E mergency Venti latio n Sys tem (CR EVS);" NURE G-1431, TS 3.7.10, "C ontrol Room E mergency Filt ration Syst em (CRE FS);" NURE G-1432, TS 3.7.11, "C ontrol Room E mergency Air C leanu p Sys tem (CR EACS);" NUREG-1433, TS 3 .7.4, "[Main Control Ro om Environ mental Control (MCREC)] System;" and NURE G-1434, TS 3.7.3, "[Co ntrol Room F resh A ir (CR FA)] S ystem." In these speci fications, the su rveilla nce requirement ass ociated w ith demonstratin g the operabili ty of the CRE boundary re quires verify ing that one [CR EEVS] train [subsystem] can mai nta in a p osi tiv e p res sur e o f $ [0.125] inche s water gauge, rel ative to th e adjacent [turbi ne bui ld in g] d uri ng t he pre ssu riz ati on mod e o f op era tio n a t a make up flo w r ate of # [3000] cfm.Facilities that pressurize the CRE during the emer gency mode of operation of the [CREEVS] have simila r surveilla nce req uireme nts. Ot her fa cilities t hat do not pressur ize the CRE have only a sy stem flo w rat e crit erion for the emergenc y mode of oper ation. Regar dless , the re sults of ASTM E741 (Reference 2) tracer gas tests to measure C RE unfiltered inleakage at facil ities indicated th at the differential pressure surv eillance (or the alterna tive surv eillance at non-pressu riza tion fa cili ties) is no t a rel iabl e metho d for de monstra ting CR E boun dary operab ilit y. That is, lice nsees were able to ob tain differential pressure and flow measurements sati sfying the SR limits even though unfiltered inleak age was determined to exceed the value assumed in the safety anal yses.In addition to an inad equate survei llance requi rement, the action requirements of these specifications were ambi guous regarding CRE boundary operabili ty in the event CRE unfiltered inleakage is found to exceed the analy sis assumptio

n. The ambiguity stemmed from the vi ew that the CRE boundary may be considered operable but degr aded in this condition, and that it woul d be d eemed i nopera ble o nly if calc ulate d radi ologi cal e xpos ure li mits for CRE o ccupan ts exce eded a lice nsing b asis l imit; e.g., as s tated i n GDC-1 9, ev en w hile credi ting co mpensa tory measures.NRC A dmini strati ve Le tter 98-10, "D ispos ition ing of Tec hnica l Spe cifica tions That Ar e Insufficient to Assure Plant Safety

," (AL 98-10) state s that " the di scovery o f an improper or inade quate TS val ue or r equire d acti on is consi dered a degra ded or nonco nforming condi tion,"which i s defined in [NRC Inspecti on Manua l Chapter 99 00; see lates t guidance in RIS 2005-20 (Refe renc e 3)]. Imp osi ng ad mini stra tiv e co ntro ls i n res pons e to an i mpro per o r in adeq uate TS is con sider ed an accept able short-t erm corr ectiv e acti on. The [NRC] staff ex pects t hat, follow ing the impos ition of admi nistra tive contro ls, an amendm ent to the [i nadequ ate] TS, wit h approp riate justifi catio n and schedu le, w ill be sub mitted in a t imely fashio n."Licen sees th at hav e found unfil tered i nleaka ge in e xcess of the l imit a ssumed in th e safety analyses and have yet to eith er reduce the i nleakage below the limit o r establish a higher bounding li mit through re-anal ysis, hav e implemented compensatory a ctions to ens ure the safety of CRE occupa nts, pe nding final resol ution of the c ondit ion, c onsis tent w ith RI S 2005-20. How eve r, ba sed on GL 200 3-01 and AL 9 8-10 , the staff exp ects eac h li cens ee to prop ose TS changes that i nclud e a su rvei llan ce to p eriod ical ly me asure CRE u nfilte red in leakage in or der to satisfy 10 CF R 50.36(c)(3), w hich requires a facility' s TSs to incl ude survei llance requi rements, which i t defines as "requi rements relating to test, calibra tion, or insp ection to ass ure that the necessary quality of systems and comp onents is maintained, that f acility operation will be within safety limit s, and that li miting conditi ons for operation will be met." (Emph asis a dded.)The NR C staff al so ex pects fa cili ties t o prop ose un ambiguo us reme dial actio ns, con sisten t wi th 10 CFR 50.36 (c)(2), for the c ondit ion o f not mee ting th e limi ting co nditi on for o perati on (LC O) due to an inoperable CRE boundary. The action requirem ents should specify a reasonable comple tion t ime to restore conforma nce to the LC O before requiri ng a faci lity to be shut d own. This co mpleti on time shoul d be b ased o n the b enefits of impl ementi ng miti gating a ction s to ensure CRE occupant safety and sufficient time to resolve most problems anti cipated w ith the CRE bounda ry, whi le minimiz ing the chance that operators i n the CRE w ill need to use mitigating actions during accid ent conditio ns.2.4 Adoption of TSTF-448 , Revisi on 3, by [faci lity name] Adoption of TSTF-448 , Revisi on 3, wi ll assure th at the facility 's TS limiti ng condition for operation (LCO) fo r the [CREEVS] is met by demonstrating unfiltered leakag e into the CRE is within limit; i.e., th e operabil ity of the CR E boundary. In support of thi s surveil lance, wh ich spec ifie s a r ela tiv ely lon g tes t in terv al (freque ncy) of 6 yea rs, TS TF-44 8 al so a dds TS administrativ e controls to assure the hab itability of the CRE betw een performances of the ASTM E741 test. In addition, adoption of T STF-448 will establish clearly stated and reasonable required actions in the event CRE unfiltered inleakage is found to exceed the analysis assumption. The changes made by TST F-448 to the STS requirem ents for the [CREEVS] and the CRE boundary co nform to 10 CFR 50 .36(c)(2) and 10 CFR 50.36(c)(3). Their adoptio n will better assure that [fac ility name]'s CRE will remain habitable during normal operation and design basis accid ent co nditi ons. Th ese ch anges a re, the refore, a ccepta ble fro m a regul atory stand point.3.0 TECHNI CAL E VALUA TION The NRC staff revie wed the p roposed changes against the corres ponding changes made to the STSs by TSTF-44 8, Rev isio n 3, w hich the NR C staff ha s found to sati sfy app lica ble re gulato ry requirements, as des cribed abov e in Secti on 2.0. [The emergency operational mode of the [CREE VS] at [facil ity n ame] [pr essuri zes] [isol ates b ut doe s not p ressur ize] the CR E to minimize unfiltered air inleakage.] The propo sed changes are consistent w ith this des ign. 3.1 Proposed Cha nges The p ropo sed amen dmen t wo uld sten gthen CRE hab itab ili ty TS requ irem ents by chan ging TS[3.7.10 , CREE VS] an d addi ng a ne w TS a dmini strati ve co ntrols program on CR E habi tabil ity. Accompanyi ng the proposed TS changes are app ropriate conforming tec hnical cha nges to the TS Bases. The pr oposed r evision to t he Bases a lso include s editor ial and adm inistra tive changes to refl ect ap plic able changes to the corres pondi ng STS B ases, w hich were made to improve cl arity, conform w ith the late st information and references, correct factual errors, and achieve more consistency among the ST S NUREGs. [Except for plant specif ic differences, all]of these changes are consistent w ith STSs as rev ised by TSTF-448, Revi sion 3.The NRC staff compared the proposed TS ch anges to the STSs and the STS markups and evaluations in TSTF-448. [Th e staff verif ied that differen ces from the ST Ss were adequately justified on the basis of plant-specific design or ret ention of current licensing basis.] The NRC staff also review ed the propose d changes to the TS Bases for consi stency w ith the STS Ba ses and th e pla nt-spe cific d esign a nd li censi ng base s, alt hough a pprov al of th e Base s is n ot a condition for a ccepting the prop osed amendment. Howeve r, TS 5.5.[11], "TS Base s Control Program," provide s assurance tha t the licens ee has establ ished and will maintain the adequacy of the Bases.

3.2 Editorial

Changes The li censee propo sed ed itori al ch anges to TS [3.7.10, "C REEVS ,"] to e stabl ish st andard terminology, su ch as "control room envel ope (CRE)" i n place of "contro l room," exce pt for the plant-specific name for the [CREE VS], and "radi ological, ch emical, and smoke hazards (or chall enges)" in pl ace of v ariou s phra ses to descri be the haza rds tha t CRE occupa nts are protected from by th e [CREEVS]. 

[The license e also propo sed to correct a typographical error by replac ing "irradiate" with "irra diated" in TS 3.7.10 Condi tion E.]  These changes improv e the usabi lity and qu ality of the p resent ation of the TS s, hav e no i mpact o n safety , and t herefore , are acceptable.

3.3 TS [3.7.10, CREEVS] < Evaluation 1 - for facil ities that ha ve adopted the 

[CREEVS] T S LCO Note an d Actio n B of TSTF-287, R ev. 5 >The li censee propo sed to revi se the actio n requi rements of TS [3.

7.10, "CREE VS,"] t o acknowledge th at an inope rable CRE boundary, d epending upon the locatio n of the associa ted degradation, could cause jus t one, instead of both [CREEVS] [t rains] to be inoperable. This is accomp lish ed by revi sing C ondit ion A to ex clude Condi tion B , and r evis ing Co nditi on B to address one o r more [CREEVS ] [trains], as foll ows: Condition A One [CREEVS] [train] inoperable f or reasons other than Condition B. Condition B One or m ore [CR EEVS] [train s] ino perabl e due to ino perabl e CRE bound ary in M ODE 1, 2, [or] 3[, or 4].This change clarifies how to apply the action requ irements in the event just one [CREEVS] [train] is una ble to ensure CRE occupa nt safety wi thin lice nsing basis l imits because of an inoperable CRE bound ary. It enha nces the usab ility o f Conditions A and B w ith a presenta tion that is more con sistent wi th the intent o f the existin g requirements. This cha nge is an administrativ e change becaus e it neithe r reduces nor i ncreases the ex isting action requirements, and, the refore, is acceptab le.The li censee propo sed to repla ce ex istin g Requi red Ac tion B.1, "Re store c ontrol room b ounda ry to OPER ABLE status," whi ch has a 24-h our Co mpleti on Time , wi th Requ ired A ction B.1, to immediately initiate action to imp lement mitigatin g actions; Requi red Action B .2, to verify, within 24 hours, that i n the even t of a DBA, CRE occupant radi ological ex posures wi ll not ex ceed the calcu lated dose of the l icens ing ba sis an alys es of DB A cons equence s, and that C RE occ upants are protected fr om hazardous chemicals and smoke; and Required Action B.3, to restor e CRE boundary to OPERABLE s tatus withi n 60 days.The 24-hour Compl etion Time is reasonable b ased on the l ow probab ility o f a DBA occurri ng during this time period, and the use of mitigating actions. The 60 day Completion Time is reasonable based on the determinat ion that the mitigating actions will ensure protection of CRE occupa nts w ithin anal yze d limi ts wh ile l imiti ng the p robabi lity that C RE occ upants wil l hav e to implement protec tive measure s that may ad versely affect their abili ty to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 60 day Completion Tim e is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary. Therefore, proposed Ac tion B is acceptable. < End of Eval uation 1 >< Evaluatio n 2 - for facil ities that ha ve not yet adopted the [CREEVS] TS LCO Note and Action B of TSTF-287, Rev. 5 >The licensee proposed to e stablish ne w action requirements in TS [3.7.10, "CREEV S,"] for an inoperable CRE boundary. Currently, if one [CREEVS] [train] is determined to be inoperable due to an i noperable C RE boundary , existin g Action A w ould appl y and require restoring the [train] (and the CRE bounda ry) to operab le status in 7 days. If two [trains] are determined to be inope rable due to an in operab le CR E boun dary, exi sting A ction [E] sp ecifie s no ti me to re store the [trains] (and the CRE bo undary) to o perable status , but requires i mmediate entry into the shutdown a ctions of LCO 3.0.3. These exi sting Actions a re more restrictiv e than wo uld be appropriate i n situations for which C RE occupant implementation of compensatory measures or mitigating actions would temporarily afford adequate CRE occ upant protectio n from postulated airborne haz ards. To account for such situatio ns, the lice nsee proposed to revise the action require ments to add a new Condi tion B , "One o r more [CREE VS] [tr ains] inop erabl e due to inope rable CRE b ounda ry in MODE 1, 2, [or] 3[, or 4]." New Actio n B w ould allo w 60 days to restore the CRE boundary (and conseq uently, the affect ed [CREEVS] [trains]) to operab le status, prov ided that mi tigati ng acti ons ar e immed iatel y imp lement ed and wit hin 2 4 hour s are verified to e nsure, that in the event o f a DBA, CRE occupant radi ological ex posures wi ll not exceed the calculated dose of the li censing basis analyse s of DBA conseque nces, and that CRE occupan ts are protected from hazardous ch emicals and smoke.The 24 hour Co mpletion Time i s reasonable based on the low pro bability of a DBA occu rring during this time period, and the use of mitigating actions. The 60 day Completion Time is reasonable based on the determinat ion that the mitigating actions will ensure protection of CRE occupa nts w ithin anal yze d limi ts wh ile l imiti ng the p robabi lity that C RE occ upants wil l hav e to implement protec tive measure s that may ad versely affect their abili ty to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 60 day Completion Tim e is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary. There fore, proposed Acti on B is ac ceptable.To distinguish new Cond ition B from the existing co ndition for one 

[CREEVS] [tra in] inopera ble, Condition A is revi sed to state, "One

[CREEVS] [trai n] inoperabl e for reasons other than Condition B." To distinguish new Condition B from the existing condition for two [CREEVS] [tr ains] inop erab le, Co ndit ion [E] (r enum bere d as Co ndit ion [F]) is revis ed to stat e, "T wo[CREEVS] [trai ns] inoperabl e during M ODE 1, 2, [or] 3[, o r 4] for reasons othe r than Condition B." The changes to existing C onditions A and [E] are l ess restrictiv e because the se Condi tions wil l no l onger a pply in th e eve nt one or tw o [CRE EVS] [trains] are i nopera ble d ue to an inoperable CRE boundary during unit operation in Mode 1, 2, [or] 3[, or 4]. This is acceptable because the new Action B establishes adequate re medial measures in this condi tion. With the ad ditio n of a n ew C ondit ion B , exi sting C ondit ions B, C, D , and E are re-des ignate d C, D, E, an d F, resp ectively.The licensee also proposed to modif y the [CREEVS] LCO by adding a note allowing the CRE boundary to be opened intermittently under administ rative controls. As stated in the LCO Bases , this Note "only appl ies to openi ngs in the CR E boun dary that ca n be ra pidl y res tored t o the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the a dministrativ e control of the opening is p erformed by the pe rson(s) entering or exitin g the area. For o ther openings, the se controls sh ould be pro ceduraliz ed and consi st of statio ning a dedi cated indi vidu al at the op ening who is in conti nuous commun icati on w ith operat ors in the CR E. Thi s ind ivi dual wil l hav e a meth od to r apidl y cl ose th e open ing an d to restore the CRE boundary to a conditi on equival ent to the desi gn condition when a n eed for CRE isolat ion is indica ted." The allowanc e of thi s note is ac ceptab le becaus e the adm inistra tive controls w ill ensu re that the open ing wil l be quickly sealed to maintain the validi ty of the licensing b asis analy ses of DBA cons equences.< End of Eval uation 2 >< Evaluation 3 - for B&W CREVS TS >The existing TS 3.7.10 condition f or two control room emerg ency ventilation system (CREVS) trains inoperable during ref ueling, Condition E, is revised to also apply during plant operation in Modes 5 and 6. It w ill state, "Tw o CREVS tra ins inope rable [in M ODE 5 or 6, or] during movement of [rece ntly] irradiated fuel assemblies." This change clarifies the applicability of this condition for d ual unit faci lities w hen the uni t is in M ode 5 or 6, a nd the other un it is movi ng[recently] i rradiated fuel a ssemblies. Si milarly, C ondition D , for failing to meet Ac tion A duri ng moveme nt of [re centl y] ir radia ted fuel assemb lies , is re vise d to al so app ly i n Mo des 5 and 6. These changes are administrativ e because th ey only clarify the intended ap plicabil ity of the exis ting co nditi ons, a nd are , there fore, acc eptabl e. Requ ired A ction s D.2 a nd E.1 , to immediately suspend mov ement of [recently ] irradiated fuel assemblie s, ensures that a fuel handling accident cannot occur while the unit is in these conditions. W ith only one CREVS train inoperable , Required Acti on D.1 speci fies an alterna tive to i mmediately suspending fuel movement; it requi res immediatel y placi ng the operable CREVS trai n in its e mergency operating alignment , or mode, to minimize the chance the train will fail to properly switch to this mode if called upon in re sponse to a fuel handling ac cident, or othe r airborne ha zards challenge. < End of Eval uation 3 > < Evaluation 4 - for B&W, CE, a nd W [CREEVS] T Ss >The li censee propo sed to add a new actio ns con ditio n to TS 3.7.1[0] that s tates, "One or more[CREEVS] trai ns inoperabl e due to an inoperable CRE bound ary [in M ode 5 or 6, o r] during movement of [rece ntly] irradiated fuel assemblies." The specified Required Action f or this condition is the same as for propose d Condition E, and thus the new condition is stated in Condition E using the l ogical conne ctor "OR" in acco rdance wi th the STS w riter's guide. The practical res ult of this prese ntation is th e same as spec ifying two separately numbered action s condi tions. It's adva ntage i s avo idin g havi ng an a dditi onal number ed row in th e Acti ons ta ble. This actions c ondition i s needed bec ause proposed Action B w ill onl y apply in Mod es 1, 2, 3, and 4. As s uch, this cha nge will ensure that the Actions tabl e continues to specify a condition for an inoperable CRE boundary during Modes 5 and 6 and during ref ueling. Therefo re, this change is admi nistrative and acceptabl e.< End of Eval uation 4 > < Evaluation 5 - for BWR4 and BWR6 [CREEVS ] TSs >The li censee propo sed to add a new actio ns con ditio n to TS 3.7.[4] that s tates, "One or more[CREEVS] su bsystems ino perable due to an inop erable CRE boundary during movement of[recently] i rradiated fuel a ssemblies i n the [[primary or] secondary ] containment or during OPDRVs." The spe cified Required Actions for thi s condition are the same a s for existin g Condition F, and thus the new con dition is stated in C ondition F using the lo gical connecto r"OR" in accorda nce with the STS wri ter's guide. The p ractical resu lt of this presen tation is the same as speci fying two sep arately nu mbered actions conditions. It's adva ntage is avo iding having an additional numbered row in the Acti ons table. Thi s actions con dition is needed because proposed Action B will only apply in M odes 1, 2, 3, and 4. As such, this change will ensure that th e Acti ons ta ble c ontin ues to speci fy a co nditi on for a n ino perabl e CRE bound ary during refueling an d OPDRVs. There fore, this change i s administrati ve and ac ceptable.< End of Eval uation 5 >< Evalu ation 6 - for facil ities that h ave a CRE p ressur iz ation survei llan ce req uireme nt >In the [emergenc y radiation state] of operation, the [CREEVS] isolates unfiltered ventilation air supply intakes, filters the em ergency ventilation air supply to the CRE, and pressurizes the CRE to mini mize unfilt ered a ir in leakage past t he CR E boun dary. The li censee propo sed to dele te the CRE pres surization surveil lance requiremen t (SR). This SR requires veri fying that one [CREEVS] [trai n][subsystem], ope rating in the [e mergency radiati on state], can mai ntain a pre ssu re o f $ [0.125] inche s water gauge, rel ative to th e adjacent [turbi ne buildi ng] during the pre ssu riz ati on mod e o f op era tio n a t a make up flo w r ate of # [3000] cfm. Th e deletion of this SR is propo sed because measurements of unfiltere d air leakage i nto the CRE at numerous reactor facilities demon strated that a basic assumpt ion of this SR, an essentially leak-tight CRE boundary, w as incorrect for most facilities. Hence, meeting thi s SR by achievi ng the required CRE p ressur e is n ot nec essari ly a concl usiv e ind icati on of CR E boun dary leak ti ghtness , i.e., CRE bounda ry operabi lity. In its response to GL 2003-01, [da ted month, dd, y yyy], th e licensee reported that it had determined that the [facili ty name] CRE pressuriza tion survei llance, SR 3.7.[10].[4], w as inadequate to demonstrate the operabili ty of the CRE boundary, a nd proposed to replace it with an inleakage measur ement SR and a CRE Habitability Program in TS Section 5.5, in accordanc e with th e approved version of TSTF-448. Based on the adoptio n of TSTF-448, the lice nsee's propo sal to del ete SR 3.7.[10].[4] is acceptabl e.< End of Eval uation 6 >The proposed CRE inleakage me asurement SR states, "Perform req uired CRE unfiltered air inleakage testin g in accordance with the Control Ro om Envelo pe Habitabi lity Program." The CRE Habi tability Program TS, proposed TS 5.5.[18], requires th at the program incl ude"Requirements f or determining the unf iltered air inleakage past the CRE boundary into the CRE in ac cordan ce wi th the testin g method s and at the Frequen cies s pecifi ed in Regul atory Guide 1.197, R evision 0." This guida nce references AS TM E 741 (R eference 2) as an accept able method for asce rtaini ng the u nfilte red le akage in to the CRE. The li censee has[, howeve r, not] proposed to follow th is method. [The NR C staff review ed the lic ensee's prop osed alternativ e method for measurin g CRE inle akage to ensure it meets the criteri a for such methods give n in R G 1.197.] [Insert plant-spec ific techni cal evalua tion by the s taff of the alternative meth od.] [The NRC staff finds that th e proposed al ternative meth od is adequate for satisfying the criter ia of RG 1.197.] Ther efore, the propos ed CRE inleakage measuremen t SR is acceptabl e.3.4 TS 5.5.[18], CRE H abitabili ty Program The pro posed admin istrat ive contro ls pro gram TS, i n combi natio n wi th SR 3.7.[10].[4], a re intended to ensure the operability of the CRE boundary, which as part of an operable [CREEVS] w ill ensu re that CRE h abitabili ty is main tained such that CRE occu pants can con trol the r eact or sa fely und er no rmal con diti ons and main tain it i n a s afe c ondi tion foll owi ng a radiological event, hazardous chemical release, or a smo ke challenge. The prog ram shall ensure that ade quate radiation protection i s provide d to permit acce ss and occupa ncy of the CRE under d esign basis a ccident (DBA) conditions without personnel rec eiving radi ation exposures i n excess o f [5 rem whole body or i ts equivale nt to any p art of the body] [5 rem total eff ective dos e equivale nt (TE DE)] f or the du ration o f the ac cident. The prop osed adm inistra tive controls program TS i s consistent w ith the model program TS in TSTF-448. The model program TS re quires a CRE Habitability Program to be established and implem ented in accord ance w ith th e guid elin es con taine d in R egulat ory Gu ide 1.196, "Contro l Roo m Habi tabil ity at Light-Water Nuclear Pow er Reactors," Rev ision 0, M ay 2003, R egulatory Guid e 1.197,"Demonstrating Contro l Room Env elope Integrity at Nuclear Power Re actors," Revi sion 0, M ay 2003, and Re gulatory Guide 1.78, "Eval uating the Habi tability of a Nuclear P ower Pla nt Control Room During a Postulated H azardous C hemical Rel ease," Revi sion 1, Dec ember 2001. The licensee's proposed TS c ontains [no] [th e followi ng] exception s to these guide lines.[Insert plant-spec ific evalu ation of li censee's proposed ex ceptions.]The proposed ad ministrativ e controls pro gram TS requires that the program include the following e lements: [plant-s pecific] definiti ons of CRE and CRE bound ary; requirements for CRE configuration control and preventiv e maintenance; requirements for period ically assessing CRE habitability and measuring unfiltered air inleak age; requirem ents for measur ing CRE pressure wi th respect to al l areas adjac ent to the CRE boundary at designated l ocations for use in assessi ng the CRE bou ndary betw een inlea kage tests; and the quanti tative li mits on unfiltered inleakag

e. The licensee has proposed to establish a TS that requires a CRE Habit abil ity P rogram th at con tains these eleme nts. The staff find s such a progr am wi ll en sure the operabil ity of the CR E boundary and habita bility of the CRE. Therefore, TS 5.5.[18], whi ch is consistent with the model program T S approved by the NRC staff in TSTF-4 48, Rev. 3, is acceptable.

4.0 STATE

C ONSUL TATION In accordance w ith the Commiss ion's regula tions, the [Name of State] State official was notifi ed of th e prop osed i ssuanc e of the amendm ent. The State official had [n o] comme nts. [If comment s wer e prov ided, they shoul d be a ddress ed her e].5.0 ENVIR ONME NTAL C ONSIDE RATION The amen dments change a requi rement with respe ct to i nstal latio n or us e of a fac ilit y component loca ted withi n the restricted area as define d in 10 C FR Part 20. The NRC staff has determined that the amendments i nvolve no significant increase in the amounts, and no significant chang e in the types, of any effluents that may be released offs ite, and that there is no significant i ncrease in i ndividu al or cumula tive occup ational rad iation ex posure. The Commission ha s previou sly issu ed a proposed finding that the a mendments inv olve no signifi cant h azard s cons idera tion, and th ere ha s been no pu blic commen t on su ch find ing (XX FR XXXX). Accordingly , the amendments mee t the eligibi lity cri teria for categorical exclusi on set forth in 10 C FR 51.22(c)(9). P ursuant to 10 C FR 51.22(b) no environmen tal impact statement or env ironmental as sessment need b e prepared i n connection with the issuance o f the amendments.

6.0 CONCL

USION The Com missi on has concl uded, based on the consi derati ons di scusse d abov e, that: (1) th ere is reasonabl e assurance tha t the health and safety of the p ublic w ill not b e endangered by operation i n the proposed manner, (2) such activiti es wil l be condu cted in compl iance w ith the Commission's regulations, a nd (3) the iss uance of the amend ments wil l not be i nimical to the common defense and security or to the health and safety of the p ublic.

7.0 REFERENCES

1.NRC Generic Letter 2003-01, "C ontrol Room H abitabili ty," dated Jun e 12, 2003, (GL 200 3-01).2.ASTM E 74 1 - 00, "Standa rd Test Method for Determining Ai r Change in a Single Zon e by Mean s of a Tra cer Gas Dilu tion," 2000, (ASTM E741).3.NRC Regulatory Issue Summary 2005-20: Revision to Guidance Formerly Contained in NRC Generic Letter 91-18," Information to Licensee s Regarding Two NRC Inspecti on Manual Sections on Resolution of Degraded and N onconforming Condi tions and on Operabi lity ," date d Sept ember 2 6, 200 5 (RIS 2005-20). 4.Regulatory Gui de 1.196, "Con trol Room Hab itability at Light-Water Nuclear Pow er Reactors," dated May 20 03.5.Regulatory Gui de 1.197, "Demon strating Control Room Envel ope Integrity a t Nuclear Po wer Reactors," Rev ision 0, M ay 2003.6.NEI 99-03, Re vision 1, "Control Ro om Habitabil ity Assess ment Guidance" d ated March 200 3. Princ ipal Contri butor: Date:}}

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