LIC-15-0085, License Amendment Request 15-05; Application to Revise Technical Specification to Adopt TSTF-426, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiative 6B & 6C, Using the Consolidated Line Item.

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License Amendment Request 15-05; Application to Revise Technical Specification to Adopt TSTF-426, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiative 6B & 6C, Using the Consolidated Line Item.
ML15254A445
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 09/11/2015
From: Cortopassi L
Omaha Public Power District
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-15-0085
Download: ML15254A445 (28)
v • d • e


Text

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jjjjjjjj Omaha Public Power District 444 South t ffh Street Mall Omaha, NE 68102-2247 UC-15-0085 10 CFR 50.90 September 11, 2015 U. S. Nuclear Regular Commission Document Control Desk Washington, DC 20555 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

License Amendment Request (LAA) 15-05; Application to Revise Technical Specification to Adopt TSTF-426, "Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiative 6B & 6C, " Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, the Omaha Public Power District (OPPD), is submitting a request for an amendment to the Technical Specifications (TS) for Fort Calhoun Station (FCS) , Unit No. 1.

The proposed amendment would modify TS requirements to adopt the changes described in TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c." Attachment 1 provides a description and assessment 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 revised (clean) TS pages. Attachment 4 provides existing TS Bases pages marked up to show the proposed changes.

The proposed changes have been reviewed and approved by the Fort Calhoun Station Plant Operations Review Committee (PORC) and by the Nuclear Safety Review Board (NSRB).

OPPD requests approval of the proposed license amendment by August 31, 2016, with the amendment to be implemented within 90 days of issuance.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Nebraska official.

There are no regulatory commitments contained within this letter.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher at (402) 533-6894.

Employment with Equal Opportunity

U. S. Nuclear Regulatory Commission LIC-15-0085 Page2 I declare under penalty of perjury that the foregoing is true and correct. Executed on September 11, 2015.

Louis P. Cortopassi Site Vice President and CNO LPC/BRH/brh

Enclosure:

OPPD's Evaluation of the Proposed Change c: M. L. Dapas, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-15-0085 Enclosure Page 1 OPPD's Evaluation of the Proposed Change License Amendment Request (LAR) 15-05, Application to Revise Technical Specification to Adopt TSTF-426, "Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiative 68 & 6C," Using the Consolidated Line Item Improvement

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

Attachments: 1. Markup of Technical Specification Pages

2. Clean Technical Specification Pages
3. Markup of Technical Specification Bases Pages

LIC-15-0085 Enclosure Page2

1.0 DESCRIPTION

The Omaha Public Power District (OPPD) hereby requests an amendment to Fort Calhoun Station (FCS), Unit No. 1 Renewed Facility Operating License No. DPR-40, to adopt TSTF-426.

The proposed change provides a short Completion Time to restore an inoperable system for conditions under which the existing Technical Specifications (TS) require a plant shutdown. The proposed amendment is consistent with TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c."

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation OPPD has reviewed TSTF-426 Revision 5, and the model safety evaluation dated May 30, 2013 as part of the Federal Register Notice of Availability. This review included a review of the Nuclear Regulatory Commission (NRC) staff evaluation, as well as the information provided in TSTF-426, Revision 5, and the referenced Topical Report WCAP-16125-NP-A, Revision 2, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent plant Shutdown". As described in the subsequent paragraphs, OPPD has concluded that the justifications presented in the TSTF-426 proposal and the model safety evaluation prepared by the NRC staff are applicable to Fort Calhoun Station Unit No. 1 and justify this amendment for the incorporation of the changes to the FCS Technical Specifications.

2.2 Optional Changes and Variations Fort Calhoun is not proposing any technical variations or deviations from the TS changes described in TSTF-426-A, Revision 5 or the applicable parts of the NRC staff's model safety evaluation dated May 20, 2013. However, FCS is proposing the following administrative variations.

1. The FCS Technical Specifications utilize different numbering and titles than the Standard Technical Specifications on which TSTF-426 was based. The table below provides a cross-reference of those TS that are applicable for this application. These differences are administrative and do not affect the applicability of TSTF-426 to the FCS Technical Specifications.

Improved STS FCSTS Plant Shutdown TS 3.0.3 TS 2.0.1 General Requirements LCO Pressurizer TS 3.4.11 TS 2.1.6(5)

PO RVs CR Emergency Air TS 3.7.11 Control Room TS 2.12.1 Control Room Air Filtration Cleanup System Emergency Air Cleanup System - Operating Svstem (CREACS)

CR Emergency Air TS 3. 7 .12 Control Room TS 2.12.2 Control Room Air Temperature Emergency Air Temperature Conditioning System Svstem Control Svstem (CREATCS)

LI C-15-0085 Enclosure Page3

2. FCS TS 2.1. 7, "Pressurizer Operability," provides requirements for pressurizer heater operability. A change was approved in TSTF-426-A Revision 5 to address two groups of pressurizer heaters being inoperable. FCS is not pursuing a change to TS 2.1 .7. Since each TS change was evaluated separately in WCAP-16125-NP-A, Revision 2, failure to adopt this change will not have an impact on the acceptability of adopting the remaining changes which apply. This variation is administrative and does not affect the applicability of TSTF-426-A, Revision 5, to the FCS TS.
3. FCS TS 2.1.6(5) on pressurizer Power Operated Relief Valves action statements requirements are based on valves being inoperable due to excessive seat leakage or causes other than excessive seat leakage. NUREG-1432 action statements are based on whether the valves are inoperable and can be manually cycled or not, with excessive leakage being one potential reason for inoperability. It is proposed to revise the FCS TS wording to be consistent with NUREG-1432.
4. The FCS accident analyses do not credit containment spray for iodine removal. Therefore the TSTF-426-A Revision 5 changes for this system are not applicable. Since each TS change was evaluated separately in WCAP-16125-NP-A, Revision 2, failure to adopt this change will not have an impact on the acceptability of adopting the remaining changes which apply. This variation is administrative and does not affect the applicability of TSTF-426- A, Revision 5 to the FCS TS.
5. The FCS design does not include a Shield Building Exhaust Air Cleanup System (SBEACS),

Iodine Cleanup System (ICS) or Penetration Room Exhaust Air Cleanup System (PREACS),

Therefore the TSTF-426-A Revision 5 changes for those systems are not included. Since each TS change was evaluated separately in WCAP-16125-NP-A, Revision 2, failure to adopt these changes will not have an impact on the acceptability of adopting the remaining changes which apply. This variation is administrative and does not affect the applicability of TSTF-426- A, Revision 5 to the FCS TS.

2.3 Licensee Verifications OPPD confirms that plant procedures can establish temporary alternate means of control room cooling, as assumed in the justification of the proposed change to the Control Room Air Conditioning System.

The FCS Technical Specifications are not based on NUREG-1432, "Standard Technical Specifications, Combustion Engineering Plants." As stated in 3 above, OPPD proposes to modify the pressurizer Power Operated Relief Valve (PORV) Technical Specification 2.1.6(5) to contain wording similar to NUREG-1432 with regard to leaking and unisolable PORVs.

LIC-15-0085 Enclosure Page4

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration The Omaha Public Power District (OPPD) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment( s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed change provides a short Completion Time to restore an inoperable system for conditions under which the existing Technical Specifications require a plant shutdown to begin within one hour in accordance with Limiting Condition for Operation (LCO) 2.0.1. Entering into Technical Specification Actions is not an initiator of any accident previously evaluated. As a result, the probability of an accident previously evaluated is not significantly increased. The consequences of any accident previously evaluated that may occur during the proposed Completion Times are no different from the consequences of the same accident during the existing one hour allowance. As a result, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

No new or different accidents result from utilizing the proposed change. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change increase the time the plant may operate without the ability to perform an assumed safety function. The analyses in WCAP-16125-NP-A,

LIC-15-0085 Enclosure Pages "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent plant Shutdown," Revision 2, August 2010, demonstrated that there is an acceptably small increase in risk due to a limited period of continued operation in these conditions and that this risk is balanced by avoiding the risks associated with a plant shutdown. As a result, the change to the margin of safety provided by requiring a plant shutdown within one hour is not significant.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, OPPD concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL CONSIDERATION

A review of the proposed amendment has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22 (c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

LI C-15-0085 Enclosure, Attachment 1 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 Mark-up of Technical Specification Pages

[Word-processor mark-ups using "double underline/strikeouf' feature for "new text/deleted text respectively.}

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.1 Reactor Coolant System (continued) 2.1.6 Pressurizer and Main Steam Safety Valves (continued)

d. With both PORVs inoperable in Modes 4 or 5, depressurize and vent the RCS through at least a 0.94 square inch or larger vent within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

(5) Two power-operated relief valves (PORVs) and their associated block valves shall be operable in Modes 1, 2, and 3.

a. With one or both PORV(s) inoperable because of excessive seat leakage and capable of being manually cycled, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV(s) to operable status or close the associated block valve(s) with power maintained to the block valve(s); otherwise, be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
b. With one PORV inoperable due to causes other than excessive seat leakage, and not capable of being manually cycled within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV to operable status or close its associated block valve and remove power from the block valve; restore the PORV to operable status within the following 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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

Not applicable when second PORV intentionally made inoperable.

c. With both PORVs inoperable due to causes other than excessive seat leakage and not capable of being manually cycled, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore at least one PORV to operable status or close both block valves, remove power from the block valves, and ~

LCO 2.5(1 ). auxiliary feedwater. is met and restore at least one PORV to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Otherwise be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

d. With one or both block valvefst inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore the block valvefst to operable status or place the associated PORVtst in the closed position. Restore at least GAe-tb.e...block valve to operable status within the next hour if both block valves are inoperable; restore the remaining inoperable block valve to operable *.vithin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.,.

Otherwise, be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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

Not applicable when second block valve intentionally made inoperable.

e. With both block valves inoperable. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> verifv LCO 2.5(1 ). auxiliarv feedwater. is met and restore at least one block valve to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Otherwise.

be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Basis The purpose of the two spring-loaded Pressurizer Safety Valves (PSV's) is to provide Reactor Coolant System (RCS) overpressure protection and thereby ensure that the Safety Limit for RCS pressure (i.e., 2750 psia) is not exceeded for analyzed accidents. The maximum RCS pressure transient for an

TECHNICAL SPECIFICATIONS analyzed accident is associated with a Loss of Load event<2>.

The TS 2.1.6( 1) lift settings are determined during Surveillance Testing in accordance with ASME Code test methods. The ASME Code requires that valves in steam service use steam as the test medium for establishing the setpoint. The +1%/-3% tolerance range specified in TS 2.1.6(1) applies to opening pressures determined during Surveillance Testing. When the valves are installed in the system, the presence of a water-filled loop seal at the valve inlets may result in in-situ actuation at a pressure that differs from the actuation pressure with steam at the inlet.

Comparative testing and analysis indicates that with a loop seal present, the opening pressure of these valves may be up to 1% lower than the opening pressure under normal test conditions.

Opening pressures below the specified setpoints are not a concern with respect to the safety limit for RCS pressure. The valves are set to a tolerance of +/-1% of setpoint using ASME Code 11 test methods before being returned to service after testing. This allows for some setpoint variance over the surveillance interval.

2.1 - Page 21 Amendment No. e4,14e,1§7,101 ,189,219,237

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System 2.12. 1 Control Room Air Filtration System - Operating Applicability Applies to the operational status of the control room air filtration system when the reactor coolant temperature Tcold ~ 210°F.

Objective To assure operability of equipment required to filter control room air following a Design Basis Accident.

Specification Two control room air filtration trains shall be OPERABLE.

Note------------------------------------------------------------

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

Required Actions (1) With one control room air filtration train inoperable for reasons other than (2),

restore the inoperable train to OPERABLE status within 7 days.

(2) With one or more control room air filtration trains inoperable due to inoperable CRE boundary:

a. initiate mitigating actions immediately, AND
b. verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, AND
c. restore CRE,boundary to OPERABLE status within 90 days.

(a) With tho roq1:1irod actions of (1) or (2) not mot, be in HOT SHUTDO'NN within 6 ho1:1rs and COLD SHUTDO'JVN 1Nithin tho following 36 ho1:1rs.

Note-------------------------------------------------------

Not applicable when second control room air filtration train intentionally made inoperable.

(3) With two control room air filtration trains inoperable for reasons other than (2),

enter LCO 2.0.1 immediately.

TECHNICAL SPECIFICATIONS

a. initiate mitigating actions immediately. AND
b. verify LCO 2.1.3. "Reactor Coolant Activity." is met within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. AND
c. restore at least one control room filtration train to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(4) With the required actions of (1 l. l2l. or (3) not met. be in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

2.12 - Page 1 Amendment No. 16,128,1a0,188, 257

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System 2.12.2 Control Room Air Conditioning System Applicability Applies to the operational status of the control room air conditioning system when the reactor coolant temperature Tcold ;;:: 210°F.

Objective To assure operability of equipment required to maintain air temperature within the control room following a Design Basis Accident.

Specification Two control room air conditioning trains shall be OPERABLE.

Required Actions (1) With one control room air conditioning train inoperable, restore the inoperable train to OPERABLE status within 30 days.

- - - - - - - - - - - - - - - - - - - - - - - - -f\IOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

f\lot applicable when second control room air conditioning train intentionally made inoperable.

(2) With two control room air conditioning trains inoperable. restore at least one train to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

t21 Qi With the required actions of (1) or (2) not met, be in HOT SHUTDOWf\I within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and COLD SHUTDOWf\I within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

(3) With t\vo oontrol room air oonditioning trains inoperable, enter LCO 2.0.1 immediately.

2.12 - Page 2 Amendment f\lo . .+88, 257

LIC-15-0085 Enclosure, Attachment 2 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 Clean Technical Specification Pages

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.1 Reactor Coolant System (continued) 2.1.6 Pressurizer and Main Steam Safety Valves (continued)

d. With both PORVs inoperable in Modes 4 or 5, depressurize and vent the RCS through at least a 0.94 square inch or larger vent within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

(5) Two power-operated relief valves (PORVs) and their associated block valves shall be operable in Modes 1 , 2, and 3.

a. With one or both PORV(s) inoperable and capable of being manually cycled, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV(s) to operable status or close the associated block valve(s) with power maintained to the block valve(s); otherwise, be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
b. With one PORV inoperable and not capable of being manually cycled within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV to operable status or close its associated block valve and remove power from the block valve; restore the PORV to operable status within the fallowing 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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

Not applicable when second PORV intentionally made inoperable.

c. With both PORVs inoperable and not capable of being manually cycled, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> close both block valves, remove power from the block valves, and verify LCO 2.5(1), auxiliary feedwater, is met, and restore at least one PORV to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Otherwise be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

d. With one block valve inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore the block valve to operable status or place the associated PORV in the closed position. Restore the block valve to operable status within the next 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Otherwise, be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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

Not applicable when second block valve intentionally made inoperable.

e. With both block valves inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> verify LCO 2.5(1), auxiliary feedwater, is met and restore at least one block valve to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Otherwise, be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Basis The purpose of the two spring-loaded Pressurizer Safety Valves (PSV's) is to provide Reactor Coolant System (RCS) overpressure protection and thereby ensure that the Safety Limit for RCS pressure (i.e., 2750 psia) is not exceeded for analyzed accidents. The maximum RCS pressure transient for an analyzed accident is associated with a Loss of Load event<2>.

2.1 - Page 21 Amendment No. 54,146,157,161 ,18Q,21Q,237

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2 .12 Control Room Ventilation System 2.12.1 Control Room Air Filtration System - Operating Applicability Applies to the operational status of the control room air filtration system when the reactor coolant temperature Tcold:::: 210°F.

Objective To assure operability of equipment required to filter control room air following a Design Basis Accident.

Specification Two control room air filtration trains shall be OPERABLE.

1\tote------------------------------------------------------------

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

Required Actions (1) With one control room air filtration train inoperable for reasons other than (2),

restore the inoperable train to OPERABLE status within 7 days.

(2) With one or more control room air filtration trains inoperable due to inoperable CRE boundary:

a. initiate mitigating actions immediately, AND
b. verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, Al\ID
c. restore CRE boundary to OPERABLE status within 90 days.

1\tote-------------------------------------------------------

Not applicable when second control room air filtration train intentionally made inoperable.

(3) With two control room air filtration trains inoperable for reasons other than (2),

a. initiate mitigating actions immediately, AND
b. verify LCO 2.1.3, "Reactor Coolant Activity," is met within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, AND
c. restore at least one control room filtration train to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(4) With the required actions of (1 ), (2), or (3) not met, be in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWl\I within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

2.12-Page1 Amendment No .. 15, 128, 130, 188, 257

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System 2.12.2 Control Room Air Conditioning System Applicability Applies to the operational status of the control room air conditioning system when the reactor coolant temperature Tcold ;:: 210°F.

Objective To assure operability of equipment required to maintain air temperature within the control room following a Design Basis Accident.

Specification Two control room air conditioning trains shall be OPERABLE.

Required Actions (1) With one control room air conditioning train inoperable, restore the inoperable train to OPERABLE status within 30 days.

- - - - - - - - - - - - - - - - - - - - - - - - -1\l()TE - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

l\lot applicable when second control room air conditioning train intentionally made inoperable.

(2) With two control room air conditioning trains inoperable, restore at least one train to ()PERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(3) With the required actions of (1) or (2) not met, be in H()T SHUTD()Wl\I within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and COLD SHUTDOWl\I within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

2.1 2 - Page 2 Amendment l\lo. +88, 257

LIC-15-0085 Enclosure, Attachment 3 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 Mark-up of Technical Specification Bases Pages For Information Only

[Word-processor mark-ups using "double underline/strikeout" feature for "new text/deleted texf' respectively.}

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.1 Reactor Coolant System (continued) 2.1.6 Pressurizer and Main Steam Safety Valves (continued)

The TS 2.1.6(1) lift settings are determined during Surveillance Testing in accordance with ASME Code test methods. The ASME Code requires that valves in steam service use steam as the test medium for establishing the setpoint. The +1%/-3% tolerance range specified in TS 2.1.6(1) applies to opening pressures determined during Surveillance Testing. When the valves are installed in the system, the presence of a water-filled loop seal at the valve inlets may result in in-situ actuation at a pressure that differs from the actuation pressure with steam at the inlet. Comparative testing and analysis indicates that with a loop seal present, the opening pressure of these valves may be up to 1% lower than the opening pressure under normal test conditions. Opening pressures below the specified setpoints are not a concern with respect to the safety limit for RCS pressure. The valves are set to a tolerance of +/-1% of setpoint using ASME Code test methods before being returned to service after testing. This allows for some setpoint variance over the surveillance interval.

The power-operated relief valves (PORVs) operate to relieve RCS pressure below the setting of the pressurizer code safety valves. These relief valves have remotely operated block valves to provide a positive shutoff capability should a relief valve become inoperable. The electrical power for both the relief valves and the block valves is capable of being supplied from an emergency power source to ensure the ability to seal this possible RCS leakage path.

Wijh the PORV inoperable and capable of being manually cycled. either the PORV must be restored or the flow path isolated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The block valve should be closed but power must be maintained to the associated block valve. since removal of power would render the block valve inoperable. Although the PORV may be designated inoperable. it may be able to be manually opened and closed and in this manner can be used to perform its function. PORV inoperability may be due to seat leakage. instrumentation problems. automatic control problems. or other causes that do not prevent manual use and do not create a possibility for a small break LOCA. For these reasons, the block valve may be closed but the Action requires power be maintained to the valve. This Condition is only intended to permit operation of the plant for a limited period of time not to exceed the next refueling outage (MODE 5) so that maintenance can be performed on the PORVs to eliminate the problem condition. The PORVs should normally be available for automatic mitigation of overoressure events and should be returned to OPERABLE status orior to entering startup (MODE 2).

Action statements (5}b. and c. include the removal of power from a closed block valve to preclude any inadvertent opening of the block valve at a time the PORV may not be closed due to maintenance.

However, the applicability requirements of the LCO to operate with the block valve(s) closed with power maintained to the block valve(s) are only intended to permit operation of the plant for a limited period of time not to exceed the next refueling shutdown (Mode 5), so that maintenance can be performed on the PORV(s) to eliminate the seat leakage condition.

If both PORVs are inoperable and not capable of being manually cycled, it is necessarv to isolate the flow path by closing and removing the power to the associated block valves within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and to restore at least one PORV within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The Condition is modified by a Note stating it is not applicable if the second PORV train is intentionally declared inoperable. The Condition does not apply to voluntarv removal of redundant systems or components from service. The Condition is applicable if one PORV is inoperable for any reason and the second PORV is discovered to be inoperable. or if both PORVs are discovered to be inoperable at the same time.

In the event of a loss of feedwater. the PORVs would be used to remove core heat. In order to minimize the consequences of a loss of feedwater while two PORVs are inoperable. Action statement (5)c requires that LCO 2.5(1) on auxiliary feedwater. be met to ensure AEW is available. The inoperability of two PORVs during the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time has been shown to be acceptable based on the infrequent use of the Required Action and the smallincremental effect on plant risk <Ref.

~

2.1 - Page 22 Amendment No. aQ,47,a4 ,14e,101 ,18Q,224 ,227

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.1 Reactor Coolant System (continued) 2.1.6 Pressurizer and Main Steam Safety Valves (continued)

If both block valves are inoperable. it is necessarv to restore at least one block valve to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The Condition is modified by a Note stating it is not applicable if the second block valve is intentionally declared inoperable. The Condition does not apply to voluntarv removal of redundant systems or components from service. The Condition is only applicable if one block valve is inoperable for any reason and the second block valve is discovered to be inoperable. or if both block valves are discovered to be inoperable at the same time. In the event of a loss of feedwater. the PORVs would be used to remove core heat. In order to minimize the consequences of a loss of feedwater while two block valves are inoperable. Action statement (5)e requires that LCO 2.5(1) on auxiliarv feedwater be verified to be met within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The inoperability of two block valves during the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time has been shown to be acceptable based on the infrequent use of the Required Actions and the small incremental effect on plant risk <Ref.5).

To determine the maximum steam flow, the only other pressure relieving system assumed operational is the main steam safety valves. Conservative values for all systems parameters, delay times and core moderator coefficients are assumed. Overpressure protection is provided to portions of the reactor coolant system which are at the highest pressure considering pump head, flow pressure drops and elevation heads.

If no residual heat were removed by any of the means available, the amount of steam which could be generated at safety valve lift pressure would be less than half of the capacity of one safety valve. This specification, therefore, provides adequate defense against overpressurization when the reactor is subcritical.

Performance of certain calibration and maintenance procedures on safety valves requires removal from the pressurizer. Should a safety valve be removed, either operability of the other safety valve or maintenance of at least one nozzle open to atmosphere will assure that sufficient relief capacity is available. Use of plastic or other similar material to prevent the entry of foreign material into the open nozzle will not be construed to violate the "open to atmosphere" provision, since the presence of this material would not significantly restrict the discharge of reactor coolant.

The total relief capacity of the ten main steam safety valves is 6.606 x 106 lb/hr. If, following testing, the as found setpoints are outside +/-1 % of nominal nameplate values, the valves are set to within the

+/-1% tolerance. The main steam safety valves were analyzed for a total loss of main feedwater flow while operating at 1500 Mwt<3>to ensure that the peak secondary pressure was less than 1100 psia, the ASME Section Ill upset pressure limit of 10% greater than the design pressure. At the power of 1500 MWt, sufficient relief valve cagacity is available to prevent overpressurization of the steam system on loss-of-load conditions.<> These analyses are based on a minimum of four-of-five operable main steam safety valves on each main steam header.

The power-operated relief valve low setpoint will be adjusted to provide sufficient margin, when used in conjunction with Technical Specification Sections 2.1.1 and 2.3, to prevent the design basis pressure transients from causing an overpressurization incident. Limitation of this requirement to scheduled cooldown ensures that, should emergency conditions dictate rapid cooldown of the reactor coolant system, inoperability of the low temperature overpressure protection system would not prove to be an inhibiting factor. The effective full flow area of an open PORV is 0.94 in 2

  • Removal of the reactor vessel head provides sufficient expansion volume to limit any of the design basis pressure transients. Thus, no additional relief capacity is required.

References (1) Article 9 of the 1968 ASME Boiler and Pressure Vessel Code, Section Ill (2) USAA, Section 14.9 (3) USAA, Section 14. 10 (4) USAA, Sections 4.3.4, 4.3.9.5 (5) WCAP-16125-NP-A. "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown." Revision 2. August 2010.

2.1 - Page23Amendment No. :39,47,64,146,101,189,224,227

2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System Bases 2.12 Control Room Ventilation System The control room ventilation system (CRVS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The CRVS contains two independent, redundant control room air filtration trains that filter the air in the control room envelope (CRE), two independent, redundant air conditioning units that circulate and cool the air in the CRE, and a CRE boundary that limits the inleakage of unfiltered air.

The CRE is the area within the confines of the CRE boundary that control room occupants inhabit to control the unit during 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 during 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 (OBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

Actuation of the CRVS 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 through the redundant trains of HEPA and charcoal filters. The emergency radiation state also initiates filtered ventilation of the outside air supply to the CRE.

The actions taken in the toxic gas isolation state are similar, except that the signal switches the CRVS to an isolation mode, minimizing outside air entering the CRE through the CRE boundary. Toxic gas is monitored at the outside air intake duct.

Actuation of the system to toxic gas protection mode trips CRVS fans and isolates the outside air dampers. The CRVS is then placed in recirculation mode. In recirculation mode, the filter trains are bypassed.

Fire and smoke detection is provided at the outlet of the recirculation fans to protect against smoke developed from sources in the outside air stream or from sources inside the control room. As in toxic gas protection mode, CRVS fans are tripped and the outside air dampers are isolated.

2.12- Page 3 Amendment No. +88, 257

2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System Bases (Continued) 2.12 Control Room Ventilation System (Continued)

The radiation monitoring system provides an airborne radiation monitor (RM-065),

which starts after a ventilation isolation actuation signal (VIAS) to verify control room habitability following a design basis accident. The air entering the CRE is continuously monitored by toxic gas detectors. One detector output above the setpoint will cause actuation of the toxic gas isolation state. The actions of the toxic gas isolation state are more restrictive, and will override the actions of the emergency radiation state.

The CRVS 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. 3).

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. 4).

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

The CRVS satisfies Criterion 3 of 10 CFR 50.36(d)(2)(ii).

2.12.1 Control Room Air Filtration System - Operating Each control room air filtration system (CRAFS) train contains a heater and 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 that remove water droplets from the air stream. A second bank of HEPA filters follows the adsorber section to collect carbon fines and provides back-up in case of failure of the main HEPA filter bank.

The CRAFS is an emergency system, part of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of a VIAS, normal air supply to the CRE is diverted to the filter trains, and the stream of ventilation air is recirculated through the filter trains of the system. The demisters remove any entrained water droplets present to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 1O 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.

2.12- Page 4 Amendment No. +88, 257

2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System Bases (Continued) 2.12.1 Control Room Air Filtration System - Operating (Continued)

Outside air is filtered, and then added to the air being recirculated from the CRE.

Pressurization of the CRE minimizes infiltration of unfiltered air though the CRE boundary from all the surrounding areas adjacent to the CRE boundary.

A single CRAFS train operating at a flow rate of s 1000 cfm will pressurize the CRE to about 0.125 inches water gauge relative to external areas adjacent to the CRE boundary, and provides an air exchange rate in excess of 60% per hour. The CRAFS operation in maintaining the CRE habitable is discussed in USAA, Section 9.1O (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. However, the recirculation duct does not require redundant dampers to meet single failure proof criteria. Damper PCV-6682 meets the acceptance criteria for the damper repair option described in Standard Review Plan 6.4, Appendix A. A release of radioactivity requires PCV-6682 to open, should PCV-6682 fail to open, it can be repaired or repositioned open before control room doses exceed the allowable limits of General Design Criterion 19. The CRAFS is designed in accordance with Seismic Category 1 requirements.

The CRAFS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (OBA) without exceeding a 5 rem total effective dose equivalent (TEDE). The CRAFS components are arranged in redundant, safety related ventilation trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access.

The CRAFS provides airborne radiological protection for the CRE occupants as demonstrated by the CRE occupant dose analyses for the most limiting design basis accident fission product release presented in the USAA, Section 14.15 (Ref. 2).

2.12- Page 5 Amendment No. 257 I

2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System Bases (Continued) 2.12.1 Control Room Air Filtration System - Operating (Continued)

Two independent and redundant trains of the CRAFS are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other train.

Total system failure, such as from a loss of both filtration trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem TEDE to the CRE occupants in the event of a large radioactive release.

Each CRAFS train is considered OPERABLE when the individual components necessary to limit CRE occupant exposure are OPERABLE. A CRAFS 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 function, and
c. Heater, demister, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In order for the CRAFS 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 in 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 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 the operators in the CRE. 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 isolation is indicated.

APPLICABILITY With the reactor coolant temperature Tcold ;:::: 210°F, the CRAFS must be OPERABLE to ensure that the CRE will remain habitable during and following a OBA.

2.12- Page 6 Amendment No. 257 I

2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System Bases (Continued) 2.12.1 Control Room Air Filtration System - Operating (Continued)

ACTIONS (1)

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

(2)a, (2)b, and (2)c 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 OBA consequences (allowed to be up to 5 rem TEDE), 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 OBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of OBA 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 OBA 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 OBA. 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.

2.12- Page 7 Amendment No. 257 I

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System Bases (Continued) 2.12.1 Control Room Air Filtration System - Operating (Continued)

(3)

'J'Jith reactor coolant tomporat1:1ro Too14 ?i: 210°F, if tho inoperable CRAFS or CRE bo1:1ndary cannot be restored to OPERABLE stat1:1s Nithin tho roq1:1irod Completion 1

Time, tho 1:1nit m1:1st be placed in a MODE that minimizes tho accident risk. To achio¥o this stat1:1s, tho 1:1nit m1:1st be placed in at least MOT SMUTDO\"IN within 6 ho1:1rs, and in COLD SMUTDOWN within 36 ho1:1rs. Tho allm*1od Completion Times are reasonable, based on operating oxporionco, to roach tho req1:1irod 1:1nit conditions from f1:1ll power conditions in an orderly manner and witho1:1t challenging 1:1nit systems.

If both CRAFS trains are inoperable with reactor coolant temperature Tcold =:: 210°F for reasons other than an inoperable CRE boundary (i.e., Condition 2), tho CRAFS may not be capable of performing tho intended f1:1nction and tho 1:1nit is in a condition 01:1tsido tho accident analyses. Therefore, LCO 2.0.1 m1:1st be entered immediately. at least one train must be returned to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Condition is modified by a Note stating it is not applicable if the second CRAFS train is intentionally declared inoperable. The Condition does not apply to voluntary removal of redundant systems or components from service. The Condition is only applicable if one train is inoperable for any reason and the second train is discovered to be inoperable. or if both trains are discovered to be inoperable at the same time. During the period that the CRAFS trains are inoperable actions must be initiated to implement mitigating actions to lessen the effect on CRE occupants from potential hazards while both trains of CRAFS are inoperable. In the event of a OBA. the mitigating actions will reduce the consequences of radiological exposures to the CRE occupants Specification 2.1.3. "Reactor Coolant Activity." allows limited operation with the reactor coolant system (RCS) activity significantly greater than the LCO limit. This presents a risk to the plant operator during an accident when all CRAFS trains are inoperable.

Therefore. it must be verified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the LCO 2. 1.3 is met. This Required Action does not require additional RCS sampling beyond that normally required by LCO 2. 1.3.

At least one CRAFS train must be returned to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Completion Time is based on Reference 5 which demonstrates that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is acceptable based on the infrequent use of the Required Action and the small incremental effect on plant risk.

If the inoperable CRAFS or CRE boundary cannot be restored to OPERABLE status

within the associated Completion Time. 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 HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. and in COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable. based on operating experience. to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit svstems.

2.12.2 Control Room Air Conditioning System The control room air conditioning system is required to ensure the control room temperature will not exceed equipment OPERABILITY requirements. The reactor protective system panels and the engineered safety features panels were designed for, and the instrumentation was tested at, 120°F. The temperature inside the control cabinets is at most 15°F warmer than the temperature of the control room due to heat produced by the electronic circuitry. Therefore, the temperature of the control room will not affect OPERABILITY of the control cabinets as long as it doesn't exceed 105°F.

During non-emergency operation, the control room temperature may be maintained by using Component Cooling Water (CCW). During design basis accident conditions, the CCW isolation valves to air conditioning units (VA-46A and VA-468) are automatically closed on a VIAS. This prevents CCW that has been heated by components following a design basis accident from adding heat to the control room . When VIAS is in override, closing these valves maintains the OPERABILITY of the associated air conditioning unit.

2.12- Page 8 Amendment No. 257

2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Ventilation System Bases (Continued) 2.12.2 Control Room Air Conditioning System {Continued)

With the reactor coolant temperature Tcold ~ 210°F, two trains of the control room air conditioning system are required to be OPERABLE. If one train is inoperable it shall be restored to OPERABLE status within 30 days. In this condition the remaining train is adequate to maintain the control room temperature. 'Nith both trains inoperable, tho control room air oonditioning system may not be capable of performing its intended funotion and LCO 2.0.1 rnust be entered immediately. If two trains of the control room air conditioning system are inoperable. at least one train must be returned to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Condition is modified by a Note stating it is not applicable if the second control room air conditioning train is intentionally declared inoperable. The Condition does not apply to voluntarv removal of redundant systems or components from service. The Condition is only applicable if one train is inoperable for any reason and the second train is discovered to be inoperable. or if both trains are discovered to be inoperable at the same time. The Completion Time is based on Reference 5 which demonstrates that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is acceptable based on the infrequent use of the Required Action and the small incremental effect on plant risk.

References (1) USAA Section 9.10 (2) USAA Section 14. 15 (3) USAA Section 14.23 (4) Engineering Analysis (EA)-FC-01-013, "Effects of Secondary Environment Resulting from a Fire Event" (5) WCAP-16125-NP-A. "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown."

Revision 2. August 2010.

2.12-Page 9 Amendment No. 257

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