ML072050423
| ML072050423 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/12/2007 |
| From: | Polson K Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML072050423 (35) | |
Text
Keith J. Poison P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax 0 Constellation Energy*
Nine Mile Point Nuclear Station July 12, 2007 U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attention: Document Control Desk
Subject:
Nine Mile Point Nuclear Station Unit No. 2; Docket No. 50-4 10 Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Nine Mile Point Nuclear Station, LLC (NMPNS) is submitting a request for an amendment to the technical specifications (TS) for Nine Mile Point, Unit 2, renewed operating license No. NPF-69. The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3.
,Attachment (1) provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment (2) provides the existing TS pages marked up to show the proposed changes. Attachment (3) provides the existing TS Bases pages marked up to show the proposed changes.
NMPNS requests approval of the proposed License Amendment by July 31, 2008, with the amendment being implemented within the subsequent 60 days.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated New York state official.
" gizJZ
Document Control Desk July 12, 2007 Page 2 Should you have any questions regarding this submittal, please contact T. F. Syrell, Licensing Director, at (315) 349-5219.
Very truly yours, STATE OF NEW YORK TO WIT:
COUNTY OF OSWEGO I, Keith J. Polson, being duly sworn, state that I am Vice President-Nine Mile Point, and that I am duly authorized to execute and file this request on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.
Subscribed and sworn ,efore me, a Notary Public, in and for the State of New York and County of
& A this /2'dr'ayof . 2007.
WITNESS my Hand and Notarial Seal:
V-ýotary Public My Commission Expires: ___ _,____
SANDRA A. OSWALD Notary Public, State of New York No. 010S6032276 Qualified in Oswego County, KJP/JJD Commission Expires . 0/,"o Attachments: (1) Description and Assessment (2) Proposed License and Technical Specification Changes (Mark-Up)
(3) Proposed Technical Specification Bases Changes (Mark-Up) cc: M. J. David, NRC S. J. Collins, NRC Resident Inspector, NRC J. P. Spath, NYSERDA
ATTACHMENT (1)
DESCRIPTION AND ASSESSMENT Nine Mile Point Nuclear Station, LLC July 12, 2007
ATTACHMENT (1)
DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
The proposed amendment would modify technical specification (TS) requirements related to control room envelope habitability in TS 3.7.2, "Control Room Envelope Filtration (CREF) System," and TS Section 5.5, "Programs and Manuals."
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification change TSTF-448, Revision 3. The availability of this TS improvement was published in the FederalRegister on January 17, 2007, as part of the consolidated line item improvement process (CLIIP).
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Nine Mile Point Nuclear Station, LLC (NMPNS) has reviewed the safety evaluation (SE) dated January 17, 2007, as part of the CLIIP. This review included a review of the NRC staff's safety evaluation, as well as the information provided to support TSTF-448. NMPNS has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Nine Mile Point Nuclear Station, Unit 2 (NMP2) and justify this amendment for the incorporation of the changes to the NMP2 TS.
2.2 Optional Changes and Variations NMPNS is not proposing any variations or deviations (other than TS numbering) from the TS changes described in TSTF-448, Revision 3, or the applicable parts of the NRC staff's model safety evaluation dated January 17, 2007. The following parts of Section 3.0 of the model SE are applicable to NMP2: 3.1, 3.2, 3.3 Evaluation 1, 3.3 Evaluation 5, 3.3 Evaluation 6, and 3.4.
NMPNS is proposing the following changes from the new license condition described in the model license amendment request:
Items (a) and (b) of the license condition includes the phrase, "as stated in the [date] letter response to Generic Letter 2003-01," to indicate the correspondence utilized by the licensee to notify the NRC of the date of performance of tracer gas testing. NMPNS did not specify the exact date of tracer gas testing for NMP2 in any correspondence to the NRC related to Generic Letter 2003-01: the month and year of the testing was provided, but not the day of the month. Deletion of this phrase does not change the requirements of the proposed license condition.
Items (a) and (b) of the license condition discuss performing actions within specific time periods after the last "successful" tracer gas test. NMPNS is proposing to delete the word "successful" from these items. A tracer gas test was performed in August 2004, but the results of the test were not within the current licensing basis inleakage assumptions for NMP2 at the time of the test. An operability determination was completed demonstrating that when using alternative source term (AST) methodologies, the measured inleakage was acceptable. The operability determination is in accordance with the letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability," (ADAMS Accession No. ML040300694). No credit was taken in the operability determination for the use of any compensatory measures, e.g., KI tablets. As 1 of3
ATTACHMENT (1)
DESCRIPTION AND ASSESSMENT part of the resolution of Generic Letter 2003-01, "Control Room Habitability," NMPNS committed to submit a license amendment request to revise the current licensing bases to utilize AST methodologies. The AST license amendment request was submitted on May 31, 2007. As shown by the operability determination, once the AST methodologies are incorporated into the current licensing basis, the August 2004 tracer gas test would be considered "successful." As such, a new tracer gas test would not be required until August 2010, plus the allowance permitted by SR 3.0.2. The AST license amendment is expected to be implemented prior to the end of the six year period from the performance of the last tracer gas test. With this change to the proposed license condition, the revised SR 3.7.2.4 addressing tracer gas testing will be considered met upon implementation of the license amendment.
2.3 License Condition Re2arding Initial Performance of New Surveillance and Assessment Requirements NMPNS proposes the following as a license condition to support implementation of the proposed TS changes:
Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.2.4, in accordance with TS 5.5.13.c.(i), the assessment of CRE habitability as required by Specification 5.5.13.c.(ii),
and the measurement of CRE pressure as required by Specification 5.5.13.d, shall be considered met. Following implementation:
(a) The first performance of SR 3.7.2.4, in accordance with Specification 5.5.13.c.(i), shall be within the specified Frequency of 6 years plus the 18-month allowance of SR 3.0.2, as measured from August 20, 2004, the date of the most recent tracer gas test, or within the next 18 months if the time period since the most recent tracer gas test is greater than 6 years.
(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.13.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from August 20, 2004, the date of the most recent tracer gas test, or within the next 9 months if the time period since the most recent tracer gas test is greater than 3 years.
(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.13.d, shall be within 24 months, plus the 182 days allowed by SR 3.0.2, as measured from March 6, 2006, the date of the most recent successful pressure measurement test, or within the next 182 days if not performed previously.
3.0 REGULATORY ANALYSIS
3.1 No Si2nificant Hazards Consideration Determination NMPNS has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the FederalRegister as part of the CLIIP. NMPNS has concluded that the proposed NSHCD presented in the FederalRegisternotice is applicable to NMP2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.9 1(a).
3.2 Commitments There are no regulatory commitments made in conjunction with this application.
2 of 3
ATTACHMENT (1)
DESCRIPTION AND ASSESSMENT 4.0 ENVIRONMENTAL EVALUATION NMPNS has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007 as part of the CLUP. NMPNS has concluded that the staff s findings presented in that evaluation are applicable to NMP2 and the evaluation is hereby incorporated by reference for this application.
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ATTACHMENT (2)
NINE MILE POINT UNIT 2 PROPOSED LICENSE AND TECHNICAL, SPECIFICATION CHANGES (MARK-UP)
License Page 8
TS Pages 3.7.2-1 3.7.2-3 3.7.2-4 5.5-12 Nine Mile Point Nuclear Station, LLC July 12, 2007
(15) At the time any subject direct transfer is effected, NMP LLC shall enter or shall have entered into an intercompany credit agreement with Constellation Energy Group (CEG), Inc,, or New Controlled, whichever entity is the ultimate parent of NMP LLC at that time, in the form and on the terms represented in the Application for license transfer. Should New Controlled become the ultimate parent of NMP LLC following the direct transfer of the license to NMP LLC, NMP LLC shall enter or shall have entered into a substantially identical intercompany credit agreement with New Controlled at the time New Controlled becomes the ultimate parent; in such case, any existing intercompany credit agreement with CEG, Inc. may be canceled once the intercompany credit agreement with New Controlled is established. Except as otherwise provided above, NMP LLC shall take no action to void, cancel, or modify any intercompany credit agreement referenced above, without the prior written consent of the Director of the Office of Nuclear Reactor Regulation.
(16) Reactor Vessel Integrated Surveillance Program NMP LLC is authorized to revise the Updated Safety Analysis Report (USAR) to allow implementation of the Boiling Water Reactor Vessel and Internals Project reactor pressure vessel Integrated Surveillance Program as the basis for demonstrating compliance with the requirements of Appendix H to Title 10 of the Code of FederalRegulations, Part 50, "Reactor Vessel Material Surveillance Program Requirements," as set forth in the licensee's application dated January 9, 2004, and as
.. 4- supplemented on June 17, 2004.
D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70.
i) An exemption from the critically alarm requirements of 10 CFR Part 70.24 was granted in the Special Nuclear Materials License No. SNM-1 895 dated November 27, 1985. This exemption is described in Section 9.1 of Supplement 4 to the SER. This previously granted exemption is continued in this operating license.
ii) Exemptions to certain requirements of Appendix J to 10 CFR Part 50 are described in Supplements 3, 4, and 5 to the SER. These include (a) (this item left intentionally blank); (b)an exemption from the requirement of Option B of Appendix J, exempting main steam isolation valve measured leakage from the combined leakage rate limit of 0.6 La. (Section 6.2.6 of SSER 5)*; (c) an exemption from Option B of Appendix J, exempting the hydraulic control system for the reactor recirculation flow control valves from Type A and Type C leak testing (Section 6.2.6 of SSER 3);
The parenthetical notation following the discussion of each exemption denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the safety evaluation of the exemption is discussed.
i14 icnoMoNF0
INSERT 1 (17). Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.2.4, in accordance with TS 5.5.13.c.(i), the assessment of CRE habitability as required by Specification 5.5.13.c.(ii),
and the measurement of CRE pressure as required by Specification 5.5.13.d, shall be considered met. Following implementation:
(a) The first performance of SR 3.7.2.4, in accordance with Specification 5.5.13.c.(i), shall be within the specified Frequency of 6 years plus the 18-month allowance of SR 3.0.2, as measured from August 20, 2004, the date of the most recent tracer gas test, or within the next 18 months if the time period since the most recent tracer gas test is greater than 6 years.
(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.13.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from August 20, 2004, the date of the most recent tracer gas test, or within the next 9 months if the time period since the most recent tracer gas test is greater than 3 years.
(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.13.d, shall be within 24 months, plus the 182 days allowed by SR 3.0.2, as measured from March 6, 2006, the date of the most recent successful pressure measurement test, or within the next 182 days if not performed previously.
CREF System 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Control Room Envelope Filtration (CREF) System LCO 3.7.2 Two CREF subsystems shall be OPERABLE.
- - -NOTE- --- C )------------------------
The control room envelope. oundary may be opened intermittently under administrative control.
APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREF subsystem A.I Restore CREF 7 days inoperabled-.f,r . subsystem(s) to o,,-- i C~.*-,,4-', ,. OPERABLE status.
OR Two CREF subsystems inoperable, with safety function maintained.
g-B. 40CREF subsystems B. Restore ro inoperable due to inoperable 3 boundary to C21-4 h (;WS OPERABLE status.
boundary in MODES 1, 2, (203.
C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Associated Completion Time of Condition A or B AND not met in MODE 1, 2, or 3. C.2 Be in -MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)
Amendment 9 4 .r-9F-NMP2 3.7.2-1
-I1
INSERT 2 B. 1 Initiate action to implement Immediately mitigating actions.
AND B.2 Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.
AND
CREF System 3.7.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREF subsystems ---
NOTE----------
inoperable with safety LCO 3.0.3 is not applicable.
function not maintained ....................................
during movement of irradiated fuel assemblies in F.1 Suspend movement of Immediately in the secondary containment, irradiated fuel assemblies during CORE in the secondary ALTERATIONS, or during containment.
AND F.2 Suspend CORE Immediately ALTERATIONS.
AND F.3 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Operate each CREF subsystem for >1 continuous 31 days hour.
SR 3.7.2.2 Perform required CREF System filter testing in In accordance accordance with the Ventilation Filter Testing with the VFTP Program (VFTP).
SR 3.7.2.3 Verify each CREF subsystem actuates on an actual 24 months or simulated initiation signal.
(continued)
NMP2 3.7.2-3 Amendment 94-,-A J
INSERT 3 OR One or more CREF subsystems inoperable due to inoperable CRE boundary during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs.
CREF System 3.7.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.2.4 Verify com nations e ysem m s can intain positiv pressu of
> 8 inche water g ge rel ive to o side a osphere uring t emerg ncy ressuri ation mo of op ation an outsid air int e flow ate of 1500 cfm.
NMP2 3.7.2-4 Amendment
INSERT 4 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope Habitability Program
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 10 CFR 50 Appendix J Testing Program Plan (continued)
(b) For each door, leakage rate is < 5 scfh when the gap between the door seals is pressurized to
> 10 psig.
- e. The provisions of SR 3.0.3 are applicable to the 10 CFR 50 Appendix J Testing Program Plan.
NMP2 5.5-12 Amendment--
INSERT 5 5.5.13 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Envelope Filtration (CREF) 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 for the duration of the accident. The program shall include the following elements:
bRequirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
- c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.
- d. 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 subsystem of the CREF System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CRE boundary.
- e. 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 c. The unfiltered air inleakage limit for radiological challenges is the inieakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
- f. 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 and d, respectively.
ATTACHMENT (3)
PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP)
The current versions of the following Technical Specifications Bases pages have been marked-up by hand to reflect the proposed changes. These Bases Ipages are provided for information only and do not require NRC approval.
B 3.7.2-1 B 3.7.2-2 B 3.7.2-3 B 3.7.2-4 B 3.7.2-5 B 3.7.2-6 B 3.7.2-7 B 3.7.2-8 B 3.7.2-9 Nine Mile Point Nuclear Station, LLC July 12, 2007
CREF System B 3.7.2 B 3.7 PLANT SYSTEMS B 3.7.2 Control Room Envelope Filtration (CREF) System BASES BACKGROUND The CREF System provides a adio iogical y co rolle
,.en
- rom roml-0ch thuni can bosafeX o d rf lowi Des* n Basi A). The contro. room
.cv.n consists of all rooms and areas located in the main 6cgc)-* control room and relay room of the control building.
Included in the envelope are the main control room, relay room, instrument shop, training room, shift supervisor's office, lunch room, toilets, corridors, work release room, and HVAC equipment rooms (Ref. 1).
The safety related function of the CREF System used to control radiation exposure consists of two independent and redundant high efficiency air filtration subsystems for, treatment of recirculated air and outside supply air*" Each cCFF subsystem includes a control room outdoor air special filter train (CROASFT), which consists of an electric heater, a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section, a second HEPA filter, a filter booster fan, and the associated ductwork) v,-,,-*>r dampers6ý The electric heater is used to reduce the "
- idity of the air entering the filter train but, e-J3 is not required for CROASFT OPERABILITY. Prefilters and HEPA filters remove particulate matter dafm-ay be -`/.,*
radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay. Each subsystem also includes the necessary outside air intake(s) and two air conditioning units (fan portion only), one for the control room and one for the relay room. Each outside air intake is capable of providing 100% of the necessary makeup flow. Therefore, normally only one outside air intake is necessary. However, when the unit is in MODE 1, 2, or 3 with MSIV leakage > 15 scfh for any MSIV, both outside air intakes, including the capability to isolate the intakes, are necessary. Both outside air intakes are required in these conditions since the accident analysis assumes the most contaminated outside air intake is isolated 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the accident to ensure the dose to control room envelope personnel does not exceed the limit. The outside air intake that is not isolated continues to be capable of.
providing 100% of the necessary makeup flow. The two required outside air intakes are allowed to be common to both subsystems (since there are only two outside air (continued)
NMP2 B 3.7.2-1 Revision4ý--,-
INSERT B 1 protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.
INSERT B2 and a CRE boundary that limits the inleakage of unfiltered air.
INSERT B3 doors, barriers, and instrumentation.
CREF System B 3.7.2 BASES BACKGROUND intakes for the CREF System). Alternately, if MSIV leakage (continued) is > 15 scfh for any MSIV, an additional analysis may be performed to determine the "effective" MSIV leakage. The "effective" MSIV leakage is the individual MSIV leak rate when all four main steam lines are assumed to leak at the same rate, and the doses in the control room envelope are equivalent to those when the individual "as-left" valve leak rates are used. If the "effective" MSIV leakage is
< 15 scfh, then only one outside air intake is necessary.
The CROASFT portion of the safety related CREF System'is normally in standby, but the remaining portions of the CREF System (the outside air intakes and fan portion of the air conditioning units) are operated to maintain the(7CE o-en ope environment during normal operation7--Upon receipt o e initiation signal(s) (indicative of conditions that could result n radiation exposure to per*
Ol..........-o....ro.
o ye..e..e...... , the CREF System adtomatically switches to te emergency pressurization mode Sof operatio t ve.tinfiltration of contaminated air r 11 r;7.- into the- o ro oo enve pe. A system of, valves and__,
ampers redirects a lc(cccccctr*ro envetside 'airflow through the two CROASFTs. In addition, a portion of the control room air is recirculated through the CROASFTs. The air nditioning units (fan portion only) maintain<Z c,..
r positive pressure; the CROASFT booster fan only prvie the motive force to overcome the added resistance of the CROASFT being in service.
TheQREF System is designed to mainta incno m"
-loeenvinm for a 30 day continuous occupancy (i.e., consideringthe occupancy factors of NUREG-0800, Table 6.4-1, Ref. 2) after a DBA, while limiting the dosage to personnel to not more than 5 rem whole body or its equivalent to any part of the body. CREF System operation in maintaining the K rol 0 om
- e abitability is discussed in the USTo, Sections 6.4.1 an 9.4.1 (Refs. 3 and 4, respectively).
APPLICABLE The ability of theJCREF System to maintain the habitability SAFETY ANALYSES of the Co ýoldk<ooiinveDn~yeis an explicit assumption for the safety analyses presented in the USAR, Chapters 6 and 15 (Refs. 5 and 6, respectively). The emergency pressurization mode of the CREF System is assumed to operatefollawing a P0A*.
/Q1os-Kt 3c-oo nt acc'i 'ent, mai4 steam - hne bre, in cident and con ol rod o acci ent. he radiological oses to"Cpo ol roo enve o erso el as a NMP2 B 3.7.2-2 BRevision-q.
INSERT B4 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 during normal and accident conditions. 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.
INSERT B5 a habitable environment in the CRE
CREF System B 3.7.2 BASES APPLICABLE result of the various DBAs are summarized in Reference 6.
SAFETY ANALYSES No single active failure will cause the loss of outside or (continued) recirculated air from the 0m n e CZe
. -b' The CREF System satisfies Criterion 3 of Reference 7.
LCO Two redundant subsystems of the CREF System are required to be OPERABLE to ensure that at least one is available, IS-.
aa "
-u single'failure disables the other subsystem.
STota s- Iecould result in exceeding a dose of 5 reg(p tJ coffrros Toooin the event of a DBA.
Eieh<0eCREF4is considered OPERABLE when the individual components necessary to ontF1 o aorexposure are OPERABLE(?_:botfh -su ýsj. A subsystem is considered OPERABLE when its associa ed: r,
- a. CROASFT is OPERABLE;
- b. Air conditioning units (fan portion only) are OPERABLE (one for the control room and one for the relay room),,
including the ductwork, to maintain air circulation to and from the control room envelope; and
- c. Necessary outside air intake(s) a/re OPERABLE. When the unit is not in MODES 1, 2, and 3, or when the unit is in MODE 1, 2, or 3 with MSIV leakage < 15 scfh for each MSIV, only one outside air intake is necessary.
When the unit is in MODE 1, 2, or 3 with MSIV leakage
> 15 scfh for any MSIV, both outside air intakes, including the capability to isolate the intakes, are necessary and are allowed to be common to both subsystems. Alternately, if MSIV leakage is > 15 scfh for any MSIV, an additional analysis may be performed to determine the "effective" MSIV leakage. If the "effective" MSIV leakage is < 15 scfh, then only one outside air intake is necessary.
A CROASFT is considered OPERABLE when its associated filter booster fan is OPERABLE; HEPA filter and charcoal adsorber are not excessively restricting flow and are capable of performing their filtration functions; and ductwork, valves,(
and dampers are OPERABLE, and air circulation through the filter train can be maintained.
0 dition the c trol ro~* envelpe bou1rary mu(in be
(*a ~ntainec*, in ding the ~tgr* of t*( allsy'floors,)
(conti nued)
NMP2 B 3.7.2-3 Revi sion--4
INSERT B6 The CREF System provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release (Ref. 9). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Ref. 10).
A periodic offsite chemical survey and procedures for controlling onsite chemicals are essential elements of CRE protection against hazardous chemicals. Changes in offsite, mobile, and onsite hazardous chemical types or quantities are assessed in accordance with the Control Room Envelope Habitability Program. The assessments provide the necessary justification for not installing a toxic gas monitoring automatic isolation system.
INSERT B7 CREF System failure, such as from a loss of both ventilation subsystems or from an inoperable CRE
- boundary, INSERT B8 whole body or its equivalent to any part of the body to the CRE occupants INSERT B9 limit CRE occupant INSERT B 10 In order for the CREF subsystems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.
CREF System B 3.7.2 BASES LCO (continued)
The LCO is modified by a Note allowing the oenv , 6-boundary to be opened intermittently under administrative controls.tFor entry and exit through the doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these control ,aonsistof stationing a dedicated J- g 2.
individual at the opening who is in continuous comnmunication withtj 0 " This individual will have a method to rapidly close the
- T 1-3 opening when a need for ~ r isolation is indicated.
APPLICABILITY In MODES 1, 2, and 3, the CREF System must be OPERABLE to
---, * - c tr2 opetor os e 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 CREF 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 movement of irradiated fuel assemblies in the secondary containment;
- b. During CORE ALTERATIONS; and
- c. During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS A.1 To-.:K F76 With one CREF subsystem inoperablidor with both CREF subsystems inoperable but the CREF System safety function maintained, the inoperable CREF subsystem(s) must be restored to OPERABLE status within 7 days. The CREF System safety function is maintained when the CREF System components equivalent to one CREF subsystem are (continued)
NMP2 B 3.7.2-4 Revision 0.
INSERT B 11 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.
INSERT B 12 should be proceduralized and INSERT B 13 operators in the CRE INSERT B 14 and to restore the CRE boundary to a condition equivalent to the design condition INSERT B 15 ensure that the CRE will remain habitable INSERT B 16 for reasons other than an inoperable CRE boundary
CREF System B 3.7.2 BASES ACTIONS OPERABLE. With the unit in this condition, the remaining (continued) OPERABLE CREF subsystem (or OPERABLE components in both subsystems) is adequate to perform theco rol om e protection function. However, the .overall reliability is reduced because aG failure in the OPERABLE subsystem (or remaining OPERABLE portions of the subsystems, as applicable) could result in loss of CREF System function. The 7 day Completion Time is based on the low probability-of aDBA occurring during this time period, and that the remaining subsystem (or components in both subsystems) can provide the required capabilities.
B 1
///
7 /
C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREF subsystem(s) orc--
, C. / r*-rr ve-tdbeboundary cannot be restored to OPERABLE status
- within thsCI Completion Time, the unit must be placed in a MODE that minimizeWisk. To achieve this status, the unit must be eq .: ,t-e-7 J3 placed in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging the unit systems.
(continued)
NMP2 B 3.7.2-5 M B3 Revision
&.4t
INSERT B 17 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), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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. 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 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 protective 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. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.
CREF System B 3.7.2 BASES ACTIONS D. 1, D.2.1, D.2.2, and D.2.3 (continued)
LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Entering LCO 3.0.3 while in MODE 1, 2, or 3 would require the unit to be shutdown, but would not require immediate suspension of movement of irradiated fuel assemblies. The Note to the ACTIONS, "LCO 3.0.3 is not applicable," ensures that the actions for immediate suspension of irradiated fuel assembly movement are not postponed due to entry into LCO 3.0.3.
During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, if the inoperable CREF subsystem(s) cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE components of the CREF subsystem(s) equivalent to a single CREF subsystem (e.g.,
the CROASFT and fan portion of the air conditioning units do not have to be powered from the same electrical division) may be placed in the emergency pressurization mode. This action ensures that the remaining subsystem (or components in both subsystems equivalent to a single CREF subsystem) is OPERABLE, that no failures that wouldprevent automatic actuation will occur, and that any active failure will be readily detected.
An alternative to Required Action D.1 is to immediately suspend activities that present a potential for releasing radioactivity that might e-) i atigoXofth'coeom yeA e- This placesthe unit in a condition that minimizes~prisk.
If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended.
(continued)
NMP2 B 3.7.2-6 Revision .1
INSERT B 18 the CREF System to be in the pressurization mode of operation.
CREF System B 3.7.2 BASES ACTIONS E. I (continued)
If both CREF subsystems are inoperable with the CREF System safety function not maintained in MODE 1, 2, or 3 for reasons other than an inoperabl -tr lrrn boundary (i.e., Condition B), the CREF 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, F.2, and F.3 LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Entering LCO 3.0.3 while in MODE 1, 2, or 3 would require the unit to be shutdown, but would not require immediate suspension of movement of irradiated fuel assemblies. The Note to the ACTIONS, "LCO 3.0.3 is not applicable," ensures that the actions for immediate suspension of irradiated fuel assembly movement are not postponed due to entry into LCO 3.0.3.
During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, with two CREF subsystems inoperable with the CREF Sys tem safety function not maintained,,action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the (ýtr ,o eel . This places the unit in a condition that minimizerisk. 1 .- C/-,i If applicable, CORE ALTERATIONS and movement of 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 OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.
NMP2 B 3.7.2-7 Revisionn.--
INSERT B 19 or with one or more CREF subsystems inoperable due to an inoperable CRE boundary,
CREF System B 3.7.2 BASES SURVEILLANCE SR 3.7.2.1 REQUIREMENTS Operating (from the control room) each CREF subsystem for >_1 continuous hour ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, filter booster or air conditioning unit fan or motor failure, or excessive vibration can be detected for corrective action. In addition, it is not necessary to operate all components of a single subsystem simultaneously for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period. It is acceptable to operate the fan portion of the air conditioning unit(s) of one subsystem with the CROASFT of the other subsystem, such that the CROASFTs and fan portion of the air conditioning units are each operated for 1 continuous hour. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.
SR 3.7.2.2 This SR verifies that the required CROASFT testing is performed in accordance with Specification 5.5.7, "Ventilation Filter Testing Program (VFTP)." The CROASFT filter tests are in accordance with Regulatory Guide 1.52 (Ref. 8). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test gequencies and additional information are discussed in detail in the VFTP.
SR 3.7.2.3 This SR verifies that each CREF subsystem starts and operates on an actual or simulated initiation signal. This SR also includes ensuring the air conditioning units (fan portion only) start on a low flow signal after the appropriate time delay. The LOGIC SYSTEM FUNCTIONAL TEST in LCO .3.3.7.1, "Control Room Envelope Filtration (CREF)
System Instrumentation," overlaps this SR to provide complete testing of the safety function. Operating experience has shown that these components normally pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was found to be acceptable from a reliability standpoint.
(continued)
NMP2 B 3.7.2-8 Revision G-+-zt*J
CREF System B 3.7.2 BASES SURVEILLANCE SR 3.7.2.4 REQUIREMENTS (continued) This SR rifies the integrit,//of the control room nvelope and t assume inleakage rates o potentially contami ted air. The c trol roo nvelope positive ressure, with respec to potentially co aminated adjacen areas, is periodically ested to verify ,roper frction of the C System. The SR re uires all combi ations of the CREF System to e verified. This can e met by dete ning (by test) the worst comb* ation of the air cond" ioning units (fy. portion only),
then testing te worst combination the air conditi oning units (fan portion onl with each CROAS During the epmergency
(
pressurz tion mode of operatio , the CREF Sys .m is designed to slight] pressurize the contro oom envelopeto >0.125 inche /water gauge positive pressure wit respect to outsi.e atmosphere tg/prevent un Itered inleakage. The/' REF System iydesigned to mai,ntain this
.ositive pressure at an tside air intake-"ow rate of <1500 cfm to the/
control room envelop ein the emergenyc pressurization/node.
Compliance with ths SR is demonst ted by measur2 ment of the pressure in the c trol room and re y room, which are representat e of adequate positi e pressure in bot elevations of t control room envelope. T Frequency of 2 months on a S AGGERED T T BASIS is cnsistent with ind try practice and other filtratio system SRs./
REFERENCES 1. USAR, Section 6.4.2.1.
- 2. NUREG-0800, Table 6.4-1.
- 3. USAR, Section 6.4.1.
- 4. USAR, Section 9.4.1.
- 5. USAR, Chapter 6.
- 6. USAR, Chapter 15.
- 8. Regulatory Guide 1.52, Revision 2, March 1978.
NMP2 B 3.7.2-9 Revision G.9-
INSERT B20 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 Control Room Envelope Habitability Program.
The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem whole body or its equivalent to any part of the body and the. CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the 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. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 11) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 12). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 13). 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.
INSERT B21
- 9. USAR, Section 2.2.3.1.3.
- 10. USAR, Section 9.4..
- 12. NEI 99-03, "Control Room Habitability Assessment," June 2001.
- 13. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).