RA-18-0001, Duke Energy Progress, LLC and Duke Energy Carolinas, LLC - License Amendment Application to Remove Heaters from Ventilation System Technical Specifications

Duke Energy Progress, LLC and Duke Energy Carolinas, LLC - License Amendment Application to Remove Heaters from Ventilation System Technical Specifications

ML18130A825
Person / Time
Site:	Mcguire, Catawba, Harris, Robinson, McGuire
Issue date:	05/10/2018
From:	Duke Energy Carolinas, Duke Energy Progress
To:	Office of Nuclear Reactor Regulation
Shared Package
ML18131A068	List: ML18130A807 RA-18-000, Duke Energy Progress, LLC and Duke Energy Carolinas, LLC - Submittal of License Amendment Application to Remove Heaters from Ventilation System Technical Specifications RA-18-0001, Duke Energy Progress, LLC and Duke Energy Carolinas, LLC - License Amendment Application to Remove Heaters from Ventilation System Technical Specifications
References
RA-18-0001
Download: ML18130A825 (53)

Text

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.11 Ventilation Filter Testing Program (VFTP} (continued)

ESF Ventilation System Penetration Flowrate Annulus Ventilation < 1% 8000 cfm Control Area Ventilation < 0.05% 2000 cfm Aux. Bldg. Filtered Exhaust (2 fans)(Unit 1) < 1% 45,700 cfm Aux. Bldg. Filtered Exhaust (2 fans)(Unit 2) < 1% 40,500 cfm Containment Purge (non-ESF) (2 fans) < 1% 21,000 cfm Fuel Bldg. Ventilation (non-ESF) < 1% 35,000 cfm

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 (N510-1980 for Auxiliary Building Filtered Exhaust) at the flowrate specified below +/- 10%.

ESF Ventilation System Penetration Flowrate Annulus Ventilation < 1% 8000 cfm Control Area Ventilation < 0.05% 2000 cfm Aux. Bldg. Filtered Exhaust (2 fans)(Unit 1) < 1% 45,700 cfm Aux. Bldg. Filtered Exhaust (2 fans)(Unit 2) < 1% 40,500 cfm Containment Purge (non-ESF) (2 fans) < 1% 21,000 cfm Fuel Bldg. Ventilation (non-ESF) < 1% 35,000 cfm

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at the temperature and relative humidity (RH) specified below.

ESF Ventilation System Penetration RH Temp.

Annulus Ventilation <4% 95% 30°c Control Area Ventilation < 0.95% 95% 30°c Aux. Bldg. Filtered Exhaust <4% 95%

Containment Purge (non-ESF) <4% 95%

Fuel Bldg. Ventilation (non-ESF) <4% 95% 89:f r--::7 y*--@~j

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 at the flowrate specified below+/- 10%.

(continued)

McGuire Units 1 and 2 5.5-10 Amendment No. 2371219

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program {VFTP} (continued)

ESF Ventilation System Delta P Flowrate Annulus Ventilation 6.0 in wg 8000 cfm Control Area Ventilation 5.0 in wg 2000 cfm Aux. Bldg. Filtered Exhaust (2 fans)(Unit 1) 6.0 in wg 45,700 cfm Aux. Bldg. Filtered Exhaust (2 fans)(Unit 2) 6.0 in wg 40,500 cfm Containment Purge (non-ESF) (2 fans) 6.0 in wg 21,000 cfm Fuel Bldg. Ventilation (non-ESF) 6.0 in wg 35,000 cfm

&.- Demonstrate that the heaters for each of the ESF systems dissipate the Yalue speoified below when tested in aeeordanee with ANSI N610 1976.

ESF Ventilation System ..

'Mattage @ eOO ~'

4 c Annulus Ventilation 43.0 +/- e.4 kV\/

Control Area Ventilation 10.0 .+/-. 1.0 kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.12 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in gas storage tanks or fed into the offgas treatment system, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure". The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures".

The program shall include:

a. The limits for concentrations of hydrogen and oxygen in the Waste Gas Holdup System and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion);

(continued)

McGuire Units 1 and 2 5.5-11 Amendment No. 237/219

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR} (continued)

14. DPC-NE-2009-P-A, 'Westinghouse Fuel Transition Report," (DPC Proprietary).

15. WCAP-12945-P-A, Volume 1 and Volumes 2-5, " Code Qualification Document for Best-Estimate Loss of Coolant Analysis," 0/::!.._ Proprietary).

16. DPC-NE-1005P-A, "Duke Power Nuclear Design Methodology Using CASMO-4/SIMULATE-3 MOX," (DPC Proprietary).

17. DPC-NE-1007-PA, "Conditional Exemption of the EOC MTC Measurement Methodology" (Duke and Westinghouse Proprietary).

18. WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," April 1995. (Westinghouse Proprietary).

19. WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO' ," July 2006. (Westinghouse Proprietary).

The COLR will contain the complete identification for each of the Technical Specifications referenced topical reports used to prepare the COLR (i.e., report number, title, revision number, report date or NRC SER date, and any supplements).

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SOM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Ventilation Systems t=ieater Failure Report

~

f or\/it.then a report is required by LCOs 3.6.10, "Annulus Ventilation System (IWS),"

LCO 3.7.Q, "Control Room Area Ventilation System (CRl\VS)," a report shall be submitted within the follo>1.i<<ing 30 days. The report shall outline tho reason f.or the inoperability and the planned actions to return the systems to OPERABLE status.

5.6.7 PAM Report When a report is required by LCO 3.3.3, "Post Accident Monitoring (PAM)

Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

(continued)

McGuire Units 1 and 2 5.6-4 Amendment Nos. 288/267

No change . Included for PLANT SYSTEMS information 3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION

3. 7 .6 Two independent Control Room Emergency Filtration System (CREFS) trains shall be OPERABLE.*

APPLICABILITY: a. MODES 1, 2, 3, and 4

b. MODES 5 and 6

c. During movement of irradiated fuel assemblies and movement of loads over spent fuel pools ACTION:

a. MODES 1, 2, 3 and 4:

---

NOTE---------

ln addition to the Actions below, perform Action c. if applicable.

1. With one CREFS train inoperable for reasons other than an inoperable Control Room Envelope (CRE) boundary, restore the inoperable CREFS train to OPERABLE status within 7 days** or be in at least HOT STANDBY 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 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

2. With one or more CREFS trains inoperable due to inoperable CRE boundary:

a. Initiate action to implement mitigating actions immediately or be in at least HOT STANDBY 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 the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />;

b. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits and that CRE occupants are protected from hazardous chemicals and smoke or be in at least HOT STANDBY 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 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />;

c. Restore CRE boundary to OPERABLE within 90 days or be in at least HOT STANDBY 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 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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

• • The 'A' CREFS train is allowed to be inoperable for a total of 14 days only to allow for the implementation of design improvements on the 'A' Train ESW pump. The 14 days will be taken one time no later than October 29, 2016. During the period in which the 'A' Train ESW pump supply from the Auxiliary Reservoir or Main Reservoir is not available, Normal Service Water will remain available and in service to supply the 'A' Train ESW equipment loads until the system is ready for post maintenance testing. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Conditions described in HNP LAR submittal correspondence letter HNP-16-056.

SHEARON HARRIS - UNIT 1 3/4 7-14 Amendment No. 153

-- - ~ ~ - - -

No change. Included for PLANT SYSTEMS information 3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

b. MODES 5 and 6

---

NOTE------

ln addition to the Actions below, perform Action c. if applicable.

1. With one CREFS train inoperable for reasons other than an inoperable CRE boundary, restore the inoperable CREFS train to OPERABLE status within 7 days or immediately initiate and maintain operation of the remaining OPERABLE CREFS train in the recirculation mode.

2. With both CREFS trains inoperable for reasons other than an inoperable CRE boundary or with the OPERABLE CREFS train required to be in the recirculation mode by ACTION b.1., not capable of being powered by an OPERABLE emergency power source, immediately suspend all operations involving CORE ALTERATIONS or movement of irradiated fuel.

3. With one or more CREFS trains inoperable due to inoperable CRE boundary, immediately suspend all operations involving CORE AL TERATIONS or movement of irradiated fuel assemblies.

SHEARON HARRIS - UNIT 1 3/4 7-14a Amendment No. 153

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

c. During movement of irradiated fuel assemblies or movement of loads over spent fuel pools.

1. With one CREFS train inoperable for reasons other than an inoperable CRE boundary, restore the inoperable CREFS train to OPERABLE status within 7 days or immediately initiate and maintain operation of the remaining OPERABLE CREFS train in the recirculation mode; or immediately suspend movement of irradiated fuel.

2. With both CREFS trains inoperable for reasons other than an inoperable CRE boundary, or with the OPERABLE CREFS train required to be in the recirculation mode by Action c.1., not capable of being powered by an OPERABLE emergency power source, immediately suspend all operations involving movement of irradiated fuel assemblies or movement of loads over spent fuel pools.

3. With one or more CREFS trains inoperable due to inoperable CRE boundary, immediately suspend movement of irradiated fuel assemblies or movement of loads over spent fuel pools.

SURVEILLANCE REQUIREMENTS

4. 7 .6 Each CREFS train shall be demonstrated OPERABLE:

a. At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes with the heaters operating;

b. At the frequency specified in the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following significant painting, fire, or chemical release in any ventilation zone communicating with the system by:

1. Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Position C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is 4000 cfm +/- 10% during system operation when tested in accordance with ANSI N510-1980; and SHEARON HARRIS - UNIT 1 3/4 7-15 Amendment No. 4ae

PLANT SYSTEMS CONTROL ROOM EMERGENCY FILTRATION SYSTEM SURVEILLANCE REQUIREMENTS (CONTINUED)

2. Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C 6 b f R gulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide of S0.5% when tested at a temperature of 30°C and at a relative y 70% in accordance with ASTM D3803 -1989.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of S0.5% when tested at a temperature of 30°C and at a relative humidity of 70% in accordance with ASTM D3803-1989. ~

d. At the frequency specified in the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 5.1 inches water gauge while operating the system at a flow rate of 4000 cfm +/- 10%;

2. Verifying that, on either a Safety Injection or a High Radiation test signal, the system automatically switches into an isolation with recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks;

3. Deleted.

4. Verifying that the heaters dissipate 14

• 1.4 kW *Nhen tested in aooordanoe

~ ,,vith ANSI N510 1980; and

5. Deleted.

e. After each complete or partial replacement of a HEPA filter bank, by verifying that the unit satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 4000 cfm +/- 10%; and

f. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the cleanup system satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 4000 cfm +/- 10%.

g. Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

SHEARON HARRIS - UNIT 1 3/4 7-16 Amendment No. 4-54

PLANT SYSTEMS 3/4.7.7 REACTOR AUXILIARY BUILDING {RAB) EMERGENCY EXHAUST SYSTEM LIMITING CONDITION FOR OPERATION

3. 7. 7 Two independent RAB Emergency Exhaust Systems shall be OPERABLE.*

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a. With one RAB Emergency Exhaust System inoperable, restore the inoperable system to OPERABLE status within 7 days** or be in at least HOT STANDBY 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 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With two RAB Emergency Exhaust Systems inoperable due to an inoperable RAB Emergency Exhaust System boundary, restore the RAB Emergency Exhaust System boundary to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, be in at least HOT STANDBY within the next 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 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.7.7 Each RAB Emergency Exhaust System shall be demonstrated OPERABLE:

a. At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes v.<ith the heaters operating;

b. At the frequency specified in the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following significant painting, fire, or chemical release in any ventilation zone communicating with the system by:

1. Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the unit flow rate is 6800 cfm +/- 10% during system operation when tested in accordance with ANSI N510-1980;

2. Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodine penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of +G% in accordance with ASTM D3803-1989.

~

• The RAB Emergency Exhaust Systems boundary may be opened intermittently under administrative controls.

• • The 'A' Train RAB Emergency Exhaust System is allowed to be inoperable for a total of 14 days only to allow for the implementation of design improvements on the 'A' Train ESW pump. The 14 days will be taken one time no later than October 29, 2016. During the period in which the

'A' Train ESW pump supply from the Auxiliary Reservoir or Main Reservoir is not available, Normal Service Water will remain available and in service to supply the 'A' Train ESW equipment loads until the system is ready for post maintenance testing. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Conditions described in HNP LAR submittal correspondence letter HNP-16-056.

SHEARON HARRIS - UNIT 1 3/4 7-17 Amendment No. 4-ae

PLANT SYSTEMS REACTOR AUXILIARY BUILDING (RAB) EMERGENCY EXHAUST SYSTEM SURVEILLANCE REQUIREMENTS (CONTINUED)

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of +Go/o in accordance with ASTM 03803-1989. ~

d. At the frequency specified in the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber bank is less than 4.1 inches water gauge while operating the unit at a flow rate of 6800 cfm +/- 10%,

2. Verifying that the system starts on a Safety Injection test signal,

3. Verifying that the system maintains the areas served by the exhaust system at a negative pressure of greater than or equal to 1/8 inch water gauge relative to the outside atmosphere,

4. Verifying that the filter cooling bypass valve is locked in the balanced

~ position, and

5. Verifying that the heaters dissipate 40 :t 4 kVV when tested in accordance with ANSI N510 1980.

e. After each complete or partial replacement of a HEPA filter bank, by verifying that the unit satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the unit at a flow rate of 6800 cfm +/- 10%; and

f. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the unit satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the unit at a flow rate of 6800 cfm +/- 10%.

SHEARON HARRIS - UNIT 1 3/4 7-18 Amendment No. 454

REFUELING OPERATIONS 3/4.9.12 FUEL HANDLING BUILDING EMERGENCY EXHAUST SYSTEM LIMITING CONDITION FOR OPERATION 3.9.12 Two independent Fuel Handling Building Emergency Exhaust System Trains shall be OPERABLE.*

APPLICABILITY: Whenever irradiated fuel is in a storage pool.

ACTION:

a. With one Fuel Handling Building Emergency Exhaust System Train inoperable, fuel movement within the storage pool or crane operation with loads over the storage pool may proceed provided the OPERABLE Fuel Handling Building Emergency Exhaust System Train is capable of being powered from an OPERABLE emergency power source and is in operation and discharging through at least one train of HEPA filters and charcoal adsorber.

b. With no Fuel Handling Building Emergency Exhaust System Trains OPERABLE, suspend all operations involving movement of fuel within the storage pool or crane operation with loads over the storage pool until at least one Fuel Handling Building Emergency Exhaust System Train is restored to OPERABLE status.

c. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.12 The above required Fuel Handling Building Emergency Exhaust System trains shall be demonstrated OPERABLE:

a. At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes *Nith the heaters operating;

b. At the frequency specified in the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following significant painting, fire, or chemical release in any ventilation zone communicating with the system by:

1. Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the unit flow rate is 6600 cfm +/- 10% during system operation when tested in accordance with ANSI N510-1980.

• The Fuel Handling Building Emergency Exhaust System boundary may be opened intermittently under administrative controls.

SHEARON HARRIS - UNIT 1 3/4 9-14 Amendment No. 4ae

REFUELING OPERATIONS FUEL HANDLING BUILDING EMERGENCY EXHAUST SYSTEM SURVEILLANCE REQUIREMENTS (CONTINUED) 4.9.12 (Continued)

2. Verifying, within 31 days after r moval, that a laboratory analysis of a representative carbon sample btained in accordance with Regulatory Position C.6.b of Regulatory G ide 1.52, Revision 2, March 1978, has a methyl iodide penetration of_ .5% when tested at a temperature of 30°C and at a relative humidity of % in accordance with ASTM 03803-1989.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 7G% in accordance with ASTM 03803-1989. ~

d. At the frequency specified in the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber bank is not greater than 4.1 inches water gauge while operating the unit at a flow rate of 6600 cfm +/- 10%,

2. Verifying that, on a High Radiation test signal, the system automatically starts and directs its exhaust flow through the HEPA filters and charcoal adsorber banks,

3. Verifying that the system maintains the spent fuel storage pool area at a negative pressure of greater than or equal to 1/8 inch water gauge, relative to the outside atmosphere, during system operation at a flow rate of 6600 cfm +/- 10%,and

4. Deleted

~ 77 Verifying that the heaters dissipate 40 t 4 kW when tested in accordance

~ with ANSI N510 1980.

e. After each complete or partial replacement of a HEPA filter bank, by verifying that the unit satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the unit at a flow rate of 6600 cfm +/- 10%.

SHEARON HARRIS - UNIT 1 3/4 9-15 Amendment No. 4a4

No change. Included for information REFUELING OPERATIONS FUEL HANDLING BUILDING EMERGENCY EXHAUST SYSTEM I

SURVEILLANCE REQUIREMENTS (Cantinued) 4.9.12 (Continued)

f. After each complete or partial replacament of a charcoal adsorber bank. by verifying that the unit satisfies the fn-place penetration le*kage tasting acceptanc:1 criteria af less than O.OS: in accordance with ANSI N!l0-1980 far a halogenated hydT'ocarban "frigerant test gas while Ol'erating the unit at a flaw rate of 6600 c1m ~ 10:.

SHEARON HARRIS - UNIT 1 3/4 9-1&

~---.....- ****** ----**......-::*-.___...._,_,_----* -** * *--~-------,__.........,_~ -**-- -*

~

-~* . ---- . ~ *:. *--------.

FBACS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Fuel Building Air Cleanup System (FBACS)

LCO 3. 7 .11 The FBACS shall be OPERABLE and operating.

APPLICABILITY: During movement of irradiated fuel assemblies in the fuel building.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. The FBACS inoperable A.1 Suspend movement of Immediately during movement of irradiated fuel irradiated fuel assemblies assemblies in the fuel in the fuel building. building.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Operate the FBACS for ~ 15 continuous minutes-with 31 days the heaters operating automatically.

SR 3.7.11.2 Perform required FBACS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP (continued)

HBRSEP Unit No. 2 3.7-28 Amendment No. ~

No change. Included for Programs and Manuals information 5.5 5.5 Programs and Manuals 5.5.10 Secondary Water Chemistry Program (continued)

b. Procedures used to measure the critical parameters;

c. Requirements for the documentation and review of sample results;

d. Procedures which identify the administrative events and corrective actions required to return the secondary chemistry to its normal control band following an out of control band condition; and

e. Identification of the authority responsible for the interpretation of the sample results.

5.5.11 Ventilation Filter Testing Program {VFTP)

This program provides controls for implementation of the following required testing of Engineered Safety Feature (ESF) ventilation filter systems at the frequencies specified in Positions C.5 and C.6 of Regulatory Guide 1.52, Revision 2, March 1978, and conducted in general conformance with ANSI N510-1975 or N510-1980.

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows the specified penetration and system bypass leakage when tested in accordance with the referenced standard at the system flowrate specified below.

ESF Ventilation Penetration System /Bypass Flowrate Reference Std Control Room <0.05% 3300 - 4150 ACFM Regulatory Guide Emergency 1.52, Revision 2, March 1978, C.5.a, C.5.c, C.5.d (using ANSI N510-1980)

Spent Fuel ~1% 11070- 13530 CFM ANSI N510-1975 Building Containment ~1% 31500- 38500 CFM ANSI N510-1975 Purge (continued)

HBRSEP 5.0-15 Amendment No. 214

No change. Included for Programs and Manuals information 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program (VFTP) (continued)

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows the specified penetration and system bypass leakage when tested in accordance with the referenced standard at the system flowrate specified below.

ESF Ventilation Penetration System /Bypass Flowrate Reference Std Control Room <0.05% 3300 - 4150 ACFM Regulatory Guide Emergency 1.52, Revision 2, March 1978, C.5.a, C.5.c, C.5.d (using ANSI N510-1980)

Spent Fuel ~1% 11070- 13530 CFM ANSI N510-1975 Building Containment ~1% 31500- 38500 CFM ANSI N510-1975 Purge (continued)

HBRSEP 5.0-16 Amendment No. 212

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program {VFTP} (continued)

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°) and the relative humidity specified below.

ESF Filter System Penetration RH Control Room S2.5% 70%

~

Emergency Spent Fuel Building S10% 0%

Containment Purge S10% 95%

(continued)

HBRSEP 5.0-17 Amendment No. 2-1-2

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program {VFTP) (continued)

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, and the charcoal adsorbers is less than the value specified below when tested at the system flowrate specified below.

ESF Filter System Delta P Flowrate Control Room ~3.4 inches 3300 - 4150 ACFM Emergency water gauge Spent Fuel <6inches 12300 CFM .+/-.10%

Building water gauge Containment <6inches 35000 CFM .+/-.10%

Purge water gauge Demonstrate that the heaters for the Spent Fuel Building ventilation filter system maintains the filter inlet air at s 70% relative humidity *Nhen tested in accordance with ASME N510 1975.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.12 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Decay Tanks, the quantity of radioactivity contained in The Waste Gas Decay Tanks and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The program shall include:

a. The limits for concentrations of hydrogen and oxygen in the Waste Gas Decay Tanks and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate (continued)

HBRSEP 5.0-18 Amendment No. 248

Attachment 2 PROPOSED TECHNICAL SPECIFICATION BASES PAGE MARKUPS (For Information Only)

No changes. Included AVS for information only B 3.6.10 B 3.6 CONTAINMENT SYSTEMS B 3.6.10 Annulus Ventilation System (AVS)

BASES BACKGROUND The AVS is required by 10 CFR 50, Appendix A, GDC 41, "Containment Atmosphere Cleanup" (Ref. 1), to ensure that radioactive materials that leak from the primary containment into the reactor building (secondary containment) following a Design Basis Accident (OBA) are filtered and adsorbed prior to exhausting to the environment.

The containment has a secondary containment called the reactor building, which is a concrete structure that surrounds the steel primary containment vessel. Between the containment vessel and the reactor building inner wall is an annulus that collects any containment leakage that may occur following a loss of coolant accident (LOCA) or rod ejection accident. This space also allows for periodic inspection of the outer surface of the steel containment vessel.

The AVS establishes a negative pressure in the annulus between the reactor building and the steel containment vessel. Filters in the system then control the release of radioactive contaminants to the environment.

The AVS consists of two separate and redundant trains. Each train includes a heater, prefilter/moisture separators, upstream and downstream high efficiency particulate air (HEPA) filters, an activated carbon adsorber section for removal of radioiodines, and a fan.

Ductwork, valves and/or dampers, and instrumentation also form part of the system. The prefilters/moisture separators function to remove large particles and entrained water droplets from the airstream, which reduces the moisture content. A HEPA filter bank upstream of the carbon adsorber filter bank functions to remove particulates and a second bank of HEPA filters follow the adsorber section to collect carbon fines. Only the upstream HEPA filter and the carbon adsorber section are credited in the analysis.

Catawba Units 1 and 2 B 3.6.10-1 Revision No. 3

AVS B 3.6.10 BASES BACKGROUND (continued)

Insert 1 A heater is included within each filter train to reduce the re tive humidity of the airstream, although no credit is taken in the safet~ nalysis. The heaters are not required for OPERABILITY since the c rbon laboratory tests are performed at 95% relative humidity, but ha been maintained in the system to provide additional margin (Ref. 6). ~ ee,~eR,..:fQf-~ ~

continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action.

The system initiates and maintains a negative air pressure in the reactor building annulus by means of filtered exhaust ventilation of the reactor building annulus following receipt of a safety injection (SI) signal. The system is described in Reference 2. The AVS reduces the radioactive content in the annulus atmosphere following a DBA. Loss of the AVS could cause site boundary doses, in the event of a DBA, to exceed the values given in the licensing basis.

APPLICABLE The AVS design basis is established by the consequences of the SAFETY ANALYSES limiting DBA, which is a LOCA. The accident analysis (Ref. 3) assumes that only one train of the AVS is functional due to a single failure that disables the other train. The accident analysis accounts for the reduction in airborne radioactive material provided by the remaining one train of this filtration system. The amount of fission products available for release from containment is determined for a LOCA.

The modeled A VS actuation in the safety analyses is based upon a worst case response time following an SI initiated at the limiting setpoint. The CANVENT computer code is used to determine the total time required to achieve a negative pressure in the annulus under accident conditions.

The response time considers signal delay, diesel generator startup and sequencing time, system startup time, and the time for the system to attain the required pressure.

The AVS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 4).

LCO In the event of a DBA, one AVS train is required to provide the minimum iodine removal assumed in the safety analysis. Two trains of the AVS must be OPERABLE to ensure that at least one train will operate, assuming that the other train is disabled by a single active failure.

Catawba Units 1 and 2 B 3.6.10-2 Revision No. a

AVS B 3.6.10 BASES APPLICABILITY In MODES 1, 2, 3, and 4, a OBA could lead to fission product release to containment that leaks to the reactor building. The large break LOCA, on which this system's design is based, is a full power event. Less severe LOCAs and leakage still require the system to be OPERABLE throughout these MODES. The probability and severity of a LOCA decrease as core power and Reactor Coolant System pressure decrease. With the reactor shut down, the probability of release of radioactivity resulting from such an accident is low.

In MODES 5 and 6, the probability and consequences of a OBA are low due to the pressure and temperature limitations in these MODES. Under these conditions, the AVS is not required to be OPERABLE.

ACTIONS With one AVS train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant AVS train and the low probability of a OBA occurring during this period. The Completion Time is adequate to make most repairs.

B.1 and B.2 With one or more AVS heaters inoperable, the heater must be restored to OPERABLE status within 7 days. Alternati"ely, a report must be initiated

'.*Jithin 7 days per Specification 5.6.6, which details the reason f.or the heater's inoperability and the corrective action required to return the heater to OPERABLE status.

Insert 1 - Move to Background conditions. Testing per ASTM 03803-1989 at 30°C and 95%

relative humidity ensures that the filter efficiency is unaffected by moisture.

Catawba Units 1 and 2 B 3.6.10-3 Revision No. 3

AVS B 3.6.10 BASES ACTIONS (continued)

~B.1 and 8.2 I IG.1 and G.2 I If the A VS train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.10.1 REQUIREMENTS Operating each AVS train from the control room with flow through the HEPA filters and carbon adsorbers ensures that all trains are OPERABLE and that all associated controls are functioning properly. Operation for ~

15 continuous minutes demonstrates OPERABILITY of the system.

Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for correction action. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.6.10.2 This SR verifies that the required AVS filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The AVS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 5). The VFTP includes testing HEPA filter performance, carbon adsorber efficiency, system flow rate, and the physical properties of the activated carbon (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

Catawba Units 1 and 2 B 3.6.10-4 Revision No. 3

No changes. Included AVS for information only B 3.6.10 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.10.3 The automatic startup on a safety injection signal ensures that each AVS train responds properly. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.6.10.4 The AVS filter cooling electric motor-operated bypass valves are tested to verify OPERABILITY. The valves are normally closed and may need to be opened from the control room to initiate miniflow cooling through a filter unit that has been shutdown following a OBA LOCA. Miniflow cooling may be necessary to limit temperature increases in the idle filter train due to decay heat from captured fission products. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.6.10.5 The proper functioning of the fans, dampers, filters, adsorbers, etc., as a system is verified by the ability of each train to produce the required system flow rate. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.6.10.6 The ability of the AVS train to produce the required negative pressure of at least -0.88 inch water gauge when corrected to elevation 564 feet ensures that the annulus negative pressure is at least -0.25 inch water gauge everywhere in the annulus. The -0.88 inch water gauge annulus pressure includes a correction for an outside air temperature induced hydrostatic pressure gradient of -0.63 inch water gauge. The negative Catawba Units 1 and 2 B 3.6.10-5 Revision No. 3

No changes. Included for CRAVS B 3.7.10 Information only.

B 3.7 PLANT SYSTEMS B 3. 7 .10 Control Room Area Ventilation System (CRAVS)

BASES BACKGROUND The CRAVS ensures that the Control Room Envelope (CRE) will remain habitable for occupants during and following all credible accident conditions. This function is accomplished by pressurizing the CRE to ~

1/8 (0.125) inch water gauge with respect to all surrounding areas, filtering the outside air used for pressurization, and filtering a portion of the return air from the CRE to clean up the control room environment.

The CRAVS consists of two independent, redundant trains of equipment.

Each train consists of:

• a pressurizing filter train fan (1CRA-PFTF-1 or 2CRA-PFTF-1)

• a filter unit ( 1CRA-PFT-1 or 2CRA-PFT-1) which includes moisture separator/prefilters, HEPA filters, and carbon adsorbers

• the associated ductwork, dampers/valves, controls, doors, and barriers Inherent in the CRAVS ability to pressurize the control room is the control room envelope boundary. 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. This area encompasses the control room, and may encompass the 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 the 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. These boundaries must be intact or properly isolated for the CRAVS to function properly.

Catawba Units 1 and 2 B 3.7.10-1 Revision No. 11

CRAVS B 3.7.10 BASES Testing per ASTM D3803-1989 at

- - - - - - - - - - - -- - - - - - -- - - -30°C and 95% relative humidity ensures that the filter efficiency is BACKGROUND (continued) unaffected by moisture.

The CRAVS can be operated either manu lly or automatically. Key operated selector switches located in the RE initiate operation of all train related CRAVS equipment. The sele ted train is in continuous operation. Outside air for pressurization a d makeup to the CRE is supplied from two independent intakes. T is outside air is mixed with return air from the CRE before being pass d through the filter unit. In the filter unit, moisture separator/prefilters rem ve any large particles in the air, and any entrained water droplets prese t. A HEPA filter bank upstream of the carbon adsorber filter bank functions to remove particulates and a second bank of HEPA fil rs follow the carbon adsorber to collect carbon fines. Only the u stream HEPA filters and carbon adsorber bank are credited in the a lysis. A heater is included within each filter train to reduce the relative umidity of the airstream, although no credit is taken in the safety ana sis. The heaters are not required for OPERABILITY since the carbon laboratory tests are performed at 95% relative humidity, but hav been maintained in the system to provide additional margin (Ref. 9). Operation for ~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action.

Upon receipt of an Engineered Safety Feature (ESF) signal, the selected CRAVS train continues to operate and the pressurizing filter train fan of the non-selected train is started. This assures control room pressurization, assuming an active failure of one of the pressurizing filter train fans.

The outside air for pressurization is continuously monitored for the presence of smoke, radiation, or chlorine by non-safety related detectors.

If smoke, radiation, or chlorine is detected in an outside air intake, an alarm is received within the CRE, alerting the operators of this condition.

The operator will take the required action to close the affected intake, if necessary, per the guidance of the Annunciator Response Procedures.

A single CRAVS train is capable of pressurizing the CRE to greater than or equal to 0.125 inches water gauge. The CRAVS is designed in accordance with Seismic Category 1 requirements. The CRAVS operation in maintaining the CRE habitable is discussed in the UFSAR, Sections 6.4 and 9.4.1 (Refs. 1 and 2).

The CRAVS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a OBA without exceeding a 5 rem total effective dose equivalent (TEDE).

Catawba Units 1 and 2 B 3.7.10-2 Revision No. -14

CRAVS B 3.7.10 BASES ACTIONS (continued)

In MODE 5 or 6, if the inoperable CRAVS train cannot be restored to OPERABLE status within the required Completion Time, or during movement of irradiated fuel assemblies, action must be taken to immediately place the OPERABLE CRAVS train in operation. This action ensures that the operating (or running) train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

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

Ll If both CRAVS trains are inoperable in MODE 1, 2, 3, or 4, for reasons other than Condition B, the CRAVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

G.1 and G.2

'Nith one or more CR.A.VS heaters inoperable, the heater must be restored to OPERABLE status within 7 days. Alternatively, a report must be initiated per Specification 5.e.e, ,.vhich details the reason for the heater's inoperability and the correcti,,e action required to return the heater to OPERABLE status.

Catawba Units 1 and 2 B 3.7.10-6 Revision No. 44

CRAVS B 3.7.10 BASES ACTIONS (continued)

The heaters do not affest OPERABILITY of the GRAVS filter trains because carbon adsorber efficiency testing is performed at 30°G and 96% relative humidity. The assident analysis shows that site boundary and sontrol room operator radiation doses are within 10 GFR 60.67 limits during a DBA LOGA under these sonditions.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. Operation for;;:: 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for correction action. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.7.10.2 This SR verifies that the required CRAVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CRAVS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 5).

The VFTP includes testing the performance of the HEPA filter and carbon adsorber efficiencies and the physical properties of the activated carbon.

Specific test Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.10.3 This SR verifies that each CRAVS train starts and operates on an actual or simulated actuation signal. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

Catawba Units 1 and 2 B 3.7.10-7 Revision No. 44

ABFVES B 3.7.12 B 3.7 PLANT SYSTEMS B 3. 7 .12 Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)

BASES BACKGROUND The ABFVES consists of two independent and redundant trains. Each train consists of a heater demister section and a filter unit section. The heater demister section consists of a prefilter/moisture separator (to remove entrained water droplets) and an electric heater (to reduce the relative humidity of air entering the filter unit). The filter unit section consists of a prefilter, an upstream HEPA filter, an activated carbon adsorber (for the removal of gaseous activity, principally iodines), a downstream HEPA, and a fan. The downstream HEPA filter is not credited in the accident analysis, but serves to collect carbon fines.

Ductwork, valves or dampers, and instrumentation also form part of the system. Following receipt of a safety injection (SI) signal, the system isolates non safety portions of the ABFVES and exhausts air only from the Emergency Core Cooling System (ECCS) pump rooms.

The ABFVES is normally aligned to bypass the system HEPA filters and carbon adsorbers. During emergency operations, the ABFVES dampers are realigned to the filtered position, and fans are started to begin filtration. During emergency operations, the ABFVES dampers are realigned to isolate the non-safety portions of the system and only draw air from the ECCS pump rooms, as well as the Elevation 522 pipe chase, and Elevation 543 and 560 mechanical penetration rooms.

The ABFVES is discussed in the UFSAR, Sections 6.5, 9.4, 14.4, and 15.6 (Refs. 1, 2, 3, and 4, respectively) since it may be used for normal, as well as post accident, atmospheric cleanup functions. The heaters are not required for OPERABILITY, since the laboratory test of the carbon is performed at 95% relative humidity, but have been maintained in the system to provide additional margin u:u:~"17 Testing per ASTM D3803-1989 at 30°C and 95%

relative humidity ensures that the filter efficiency is unaffected by moisture.

Catawba Units 1 and 2 B 3.7.12-1 Revision No. +

ABFVES B 3.7.12 BASES ACTIONS (continued) hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 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 compensatory measures. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the ECCS pump rooms pressure boundary.

C.1 and C.2 If the ABFVES train or ECCS pump rooms pressure boundary cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1 and D.2 With one or more ABFVES heaters inoperable, the heater must be restored to OPERABLE status within 7 days. Alternatively, a report must be initiated per Speoifioation 5.6.6, which details the reason for the heater's inoperability and the correcti>Je action required to return the heater to OPERABLE status.

The heaters do not affect OPER.'\BI LIT¥ of the ABFVES filter trains because carbon adsorber efficiency testing is performed at ao 0 c and 953/4 relative humidity. The accident analysis shows that site boundary radiation doses are within 10 CFR 50.67 limits during a OBA LOCA under these oonditions.

SURVEILLANCE SR 3.7.12.1 REQUIREMENTS Systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once a month provides an adequate check on this system. Operation for~ 15 continuous minutes Catawba Units 1 and 2 B 3.7.12-4 Revision No. 7

FHVES B 3.7.13 B 3.7 PLANT SYSTEMS B 3.7.13 Fuel Handling Ventilation Exhaust System (FHVES)

BASES BACKGROUND The FHVES filters airborne radioactive particulates from the area of the fuel pool following a fuel handling accident. The FHVES, in conjunction with other normally operating systems, also provides environmental control of temperature and humidity in the fuel pool area.

The FHVES consists of two independent and redundant trains with two filter units per train. Each filter unit consists of a heater, prefilters/moisture separators, high efficiency particulate air (HEPA) filters, an activated carbon adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, and instrumentation also form part of the system. The upstream HEPA filter bank functions to remove particulates and is credited in the safety analysis. A second bank of HEPA filters follows the adsorber section to collect carbon fines. The downstream HEPA filters are not credited in the analysis. A heater is included within each filter unit to reduce the relative humidity of the airstream. The heaters are not required for Testing per ASTM OPERABILITY, since the carbon laboratory tests are performed at 95%

03803-1989 at 30°C relative humidity, but have been maintained in the system to provide and 95% relative L--~~~~~~-trt-iRt:!~ttt.. The system initiates filtered ventilation of the fuel handling building following receipt of a high radiation signal.

humidity ensures that the filter efficiency is The FHVES train does not actuate on any Engineered Safety Feature unaffected by moisture. Actuation System signal. One train is required to be in operation whenever recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) is being moved in the fuel handling building. The operation of one train of FHVES ensures, if a fuel handling accident occurs, ventilation exhaust will be filtered before being released to the environment. The prefilters/moisture separators remove any large particles in the air, and any entrained water droplets present.

The FHVES is discussed in the UFSAR, Sections 6.5, 9.4, and 15. 7 (Refs. 1, 2, and 3, respectively) because it may be used for normal, as well as atmospheric cleanup functions after a fuel handling accident in the spent fuel pool area.

Catawba Units 1 and 2 B 3.7.13-1 Revision No. §

FHVES B 3.7.13 BASES ACTIONS (continued)

With the movement of recently irradiated fuel in the fuel handling building, two trains of FHVES are required to be OPERABLE and one in operation.

The movement of recently irradiated fuel must be immediately suspended, if one or more trains of FHVES are inoperable or one is not in operation. This does not preclude the movement of an irradiated fuel assembly to a safe position. This action ensures that a fuel handling accident with unacceptable consequences could not occur.

B.1 and B.2

'Nith one or more FHVES heaters inoperable, the heater must be restored to OPERABLE status within 7 days. Alternatively, a report must be initiated per Specification 5.6.6, >Nhich details the reason for the heater's inoperability and the corrective action required to return the heater to OPERABLE status.

The heaters do not affect OPERABILITY of the FHVES filter trains ao c because carbon adsorber efficiency testing is perf:ormed at 0 and 95% relati>.<e humidity. The accident analysis sho>.vs that site boundary radiation doses are within 10 CFR 50.67 limits during a fuel handling accident under these conditions.

SURVEILLANCE SR 3.7.13.1 REQUIREMENTS With the FHVES train in service, a periodic monitoring of the system for proper operation should be checked on a routine basis to ensure that the system is functioning properly. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.7.13.2 Systems should be checked periodically to ensure that they function properly. Operation for~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

Catawba Units 1 and 2 B 3.7.13-3 Revision No. G

No changes. Included Containment Penetrations for information only. B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During movement of recently irradiated fuel assemblies (i.e., fuel assemblies that have occupied part of a critical reactor core within the previous 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) within containment, a release of fission product radioactivity within containment will be restricted from escaping to the environment when the LCO requirements are met. In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LCO 3.6.1, "Containment." In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. Since there is no potential for containment pressurization, the Appendix J leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained within the acceptance criteria of 10 CFR 50.67 and Regulatory Guide 1.183. Additionally, the containment provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment. During movement of recently irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LCO be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 unit operation in accordance with LCO 3.6.2, "Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of unit shutdown when containment closure is not required, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for Catawba Units 1 and 2 B 3.9.3-1 Revision No. 4

Containment Penetrations B 3.9.3 BASES BACKGROUND (continued) extended periods when frequent containment entry is necessary. During movement of recently irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain closed.

The requirements for containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted from escaping to the environment. The closure restrictions are sufficient to restrict fission product radioactivity release from containment due to a fuel handling accident involving recently irradiated fuel during refueling.

The Containment Purge Exhaust System includes two trains. Purge air is exhausted from the containment through the Containment Purge Exhaust System to the unit vent where it is monitored for radioactivity level by the unit vent monitor prior to release to the atmosphere. The Containment Purge Exhaust System consists of two 50 percent capacity filter trains and fans. There is one purge exhaust duct penetration through the Reactor Building wall from the annulus area. There are three purge exhaust penetrations through the containment vessel, two from the upper compartment and one from the lower compartment. Two normally closed isolation valves at each penetration through the containment vessel provide containment isolation. One normally closed isolation damper at the Reactor Building wall provides annulus isolation.

The upper compartment purge exhaust ductwork is arranged to draw exhaust air into a plenum around the periphery of the refueling canal, effecting a ventilation sweep of the canal during the refueling process.

The lower compartment purge exhaust ductwork is arranged so as to sweep the reactor well during the refueling process.

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on at least one side. Isolation may be achieved by an OPERABLE automatic isolation valve, or by a manual isolation valve, blind flange, or equivalent.

Equivalent isolation methods must be approved and may include use of a Insert 5 material that can provide a temporary, atmospheric pressure, ventilation barrier for the other containment penetrations during recently irradiated fuel movements.

APPLICABLE During movement of recently irradiated fuel assemblies within SAFETY ANALYSES containment, the most severe radiological consequences result from a fuel handling accident involving recently irradiated fuel. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 1). Fuel handling accidents, analyzed in Reference 2, include Catawba Units 1 and 2 B 3.9.3-2 Revision No. 4

No changes. Included Containment Penetrations for information only. B 3.9.3 BASES APPLICABLE SAFETY ANALYSES (continued) dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.6, "Refueling Cavity Water Level," and the minimum decay time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without containment closure capability ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are within the guideline values specified in 10 CFR 50.67 and Regulatory Guide 1.183.

Containment penetrations satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3).

LCO This LCO limits the consequences of a fuel handling accident involving handling recently irradiated fuel in containment by limiting the potential escape paths for fission product radioactivity released within containment.

The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except for penetrations exhausting through an OPERABLE Containment Purge Exhaust System HEPA filter and carbon adsorber during movement of recently irradiated fuel assemblies.

APPLICABILITY The containment penetration requirements are applicable during movement of recently irradiated fuel assemblies within containment because this is when there is a potential for the limiting fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6.1. In MODES 5 and 6, when movement of recently irradiated fuel assemblies within containment is not being conducted, the potential for a limiting fuel handling accident does not exist. Therefore, under these conditions no requirements are placed on containment penetration status.

During movement of recently irradiated fuel assemblies, ventilation system and radiation monitor availability (as defined by NUMARC 91-06) should be assessed, with respect to filtration and monitoring of releases from the fuel. Following shutdown, radioactivity in the RCS decays fairly rapidly.

The goal of maintaining ventilation system and radiation monitor availability is to reduce doses even further below that provided by the natural decay, and to avoid unmonitored releases.

A single normal or contingency method to promptly close primary or secondary containment penetrations exists. Such prompt methods need Catawba Units 1 and 2 B 3.9.3-3 Revision No. 4

- ~ - ~ - - - -- --- -

Containment Penetrations B 3.9.3 BASES APPLICABILITY (continued) not completely block the penetration or be capable of resisting pressure.

The purpose is to enable ventilation systems to draw the release from a postulated fuel handling accident in the proper directions such that it can be treated and monitored.

ACTIONS A.1 and A.2 If the containment equipment hatch, air locks, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere is not in the required status, the unit must be placed in a condition where the isolation function is not needed. This is accomplished by immediately suspending movement of recently irradiated fuel assemblies within containment. Performance of these actions shall not preclude completion of movement of a component to a safe position.

8.1 and 8.2 Containment Purge Exhaust System Insert 5 - Move to

Background

Testing per ASTM 03803-1989 at 30°C and 95% relative humidity

_ _ _ _ _ _ _ _ _ _ _ _ ensures that the filter efficiency is unaffected by moisture.

SURVEILLANCE SR 3.9.3.1 REQUIREMENTS This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open purge and exhaust valves will demonstrate that the valves are exhausting through an OPERABLE Containment Purge Exhaust System HEPA Filter and carbon adsorber.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

Catawba Units 1 and 2 B 3.9.3-4 Revision No. 4

Containment Penetrations B 3.9.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.9.3.2 Operation for~ 15 continuous minutes demonstrates ootiA\:Jw s--howl'.'S-\Mtt:l--tA10-+~tEWs...e~roo~. The Surveillance OPERABILITY of the F uency is based on operating experience, equipment reliability, and system. Periodic operation plant risk and is controlled under the Surveillance Frequency Control ensures that blockage, fan Program.

or motor failure, or excessive vibration can be detected for corrective SR 3.9.3.3 action.

This SR verifies that the required testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The Containment Purge Exhaust System filter tests are in accordance with Reference 4. The VFTP includes testing HEPA filter performance, carbon adsorbers efficiency, system flow rate, and the physical properties of the activated carbon (general use and following specific operations). Specific test Frequencies and additional information are discussed in detail in the VFTP.

REFERENCES 1. UFSAR, Section 15.7.4.

2. NUREG-0800, Section 15.7.4, Rev. 1, July 1981.

3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

4. Regulatory Guide 1.52 (Rev. 2).

5. 10 CFR 50.67, Accident source term.

6. Regulatory Guide 1.183 (Rev. 0).

7. Catawba Nuclear Station License Amendments 90/84 for Units 1/2, August 23, 1991.

Catawba Units 1 and 2 B 3.9.3-5 Revision No. 4

AVS B 3.6.10 B 3.6 CONTAINMENT SYSTEMS B 3.6.10 Annulus Ventilation System (AVS)

BASES BACKGROUND The AVS is required by 10 CFR 50, Appendix A, GDC 41, "Containment Atmosphere Cleanup" (Ref. 1), to ensure that radioactive materials that leak from the primary containment into the reactor building (secondary containment) following a Design Basis Accident (OBA) are filtered and adsorbed prior to exhausting to the environment.

The containment has a secondary containment called the reactor building, which is a concrete structure that surrounds the steel primary containment vessel. Between the containment vessel and the reactor building inner wall is an annulus that collects any containment leakage that may occur following a loss of coolant accident (LOCA) or rod ejection accident. This space also allows for periodic inspection of the outer surface of the steel containment vessel.

The AVS establishes a negative pressure in the annulus between the reactor building and the steel containment vessel. Filters in the system then control the release of radioactive contaminants to the environment.

Reactor building OPERABILITY is required to ensure retention of primary containment leakage and proper operation of the AVS.

The AVS consists of two separate and redundant trains. Each train includes a heater, mechanical demister, a prefilter/ moisture separator, upstream and downstream high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of radioiodines, and a fan. Ductwork, valves and/or dampers, and instrumentation also form part of the system. The heaters and mechanical demisters function to reduce the moisture content of the airstreamlto less than 70% relati*re I IhuFAidity. lA second bank of HEPA filters follows the adsorber section to collect carbon fines and provide backup in case of failure of the main HEPA filter bank. Only the upstream HEPA filter and the charcoal adsorber section are credited in the analysis. The system initiates and maintains a negative air pressure in the reactor building annulus by means of filtered exhaust ventilation of the reactor building annulus following receipt of a Phase B isolation signal. The system is described in Reference 2.

The prefilters remove large particles in the air, and the moisture separators remove entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal absorbers. Heaters are included McGuire Units 1 and 2 B 3.6.10-1 Revision No. 46G

AVS B 3.6.10 BASES BACKGROUND (continued) Insert 1 to reduce the relative humidity of the airstrea . Operation for > 16 continuous minutes etemonstrates OPERABILITY of the system. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The mechanical demisters cool the air to keep the charcoal beds from becoming too hot due to absorption of fission product.

The AVS reduces the radioactive content in the annulus atmosphere following a OBA. Loss of the A VS could cause site boundary doses, in the event of a OBA, to exceed the values given in the licensing basis.

APPLICABLE The AVS design basis is established by the consequences of the limiting SAFETY ANALYSES OBA, which is a LOCA. The accident analysis (Ref. 3) assumes that only one train of the AVS is functional due to a single failure that disables the other train. The accident analysis accounts for the reduction in airborne radioactive material provided by the remaining one train of this filtration system. The amount of fission products available for release from containment is determined for a LOCA.

The modeled AVS actuation in the safety analyses is based upon a worst case response time following a Phase B isolation signal initiated at the limiting setpoint. The total response time, from exceeding the signal setpoint to attaining the negative pressure of 0.5 inch water gauge in the reactor building annulus, is 22 seconds. The pressure then goes to -3.5 inches water within 48 seconds after the start signal is initiated. At this point the system switches into its recirculation mode of operation and pressure may increase to -0.5 inches water within 278 seconds but will not go above -0.5 inches water. This response time is composed of signal delay, diesel generator startup and sequencing time, system startup time, and time for the system to attain the required pressure after starting.

The AVS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 4).

LCO In the event of a OBA, one AVS train is required to provide the minimum particulate iodine removal assumed in the safety analysis. Two trains of the AVS must be OPERABLE to ensure that at least one train will operate, assuming that the other train is disabled by a single active failure.

McGuire Units 1 and 2 B 3.6.10-2 Revision No. 4-aO

AVS B 3.6.10 BASES APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could lead to fission product release to containment that leaks to the reactor building. The large break LOCA, on which this system's design is based, is a full power event. Less severe LOCAs and leakage still require the system to be OPERABLE throughout these MODES. The probability and severity of a LOCA decrease as core power and Reactor Coolant System pressure decrease. With the reactor shut down, the probability of release of radioactivity resulting from such an accident is low.

In MODES 5 and 6, the probability and consequences of a OBA are low due to the pressure and temperature limitations in these MODES. Under these conditions, the AVS is not required to be OPERABLE.

ACTIONS With one AVS train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant AVS train and the low probability of a OBA occurring during this period. The Completion Time is adequate to make most repairs.

B.1 and B.2 VVith one or FAore /'.V-S heaters inoperaele, the heater must ee restored to OPERABLE status *.vithin 7 days. /\lternaUvely, a report must be initiated within 7 days in aooordanoe with Speoifioation 6.6.6, \*thioh details the reason for the heater's inoperaeility and the oorreotive action required to return the heater to OPERABLE status.

Insert 1 - Move to Backoround The ea ers o not a ect ITV of the A VS filter train because charcoal adsorber efficiency testing is performed at 30°C and 95%

relative humidity. The aooident analysis shows that site boundary radiation doses are within 10 GFR 60.67 (Ref. 6) liFAits during a DB/\

LOGA under these conditions .

~ B. 1 and B. 2 I I..----------------.

G.1 and G.2 I If the A VS train cannot be restored to OPE BLE status within the required Completion Time, the plant must be ought to a MODE in which the LCO does not apply. To achieve this status, he plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to DE 5 within Testing per ASTM 03803-1989 at 30°C and 95%

relative humidity ensures that the filter efficiency is unaffected by moisture.

McGuire Units 1 and 2 B 3.6.10-3 Revision No. 4-eG

AVS B 3.6.10 BASES ACTIONS (continued) 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 plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.10.1 REQUIREMENTS Operating each AVS train from the control room with flow through the HEPA filters and activated carbon adsorbers ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation for~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action.

Inoperable heateFS are addressed by Required Actions 8.1 and 8.2. The inoperability of heaters beP1*,'een required performanoes of this surveillanoe does not affeot OPERABILITY of eaeh /\VS train. Operability of the heaters is demonstrated by the heater po'Ner dissipation test per SR 3.e.10.2.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.6.10.2 This SR verifies that the required AVS filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The AVS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 5) with exceptions as noted in the UFSAR. The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, heater PO'#er dissipation, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.10.3 The automatic startup on a Containment Phase B Isolation signal ensures that each AVS train responds properly. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

McGuire Units 1 and 2 B 3.6.10-4 Revision No. 4-eO

~~~-~-- ~--~-~~--------

CRAVS B 3.7.9 B 3.7 PLANT SYSTEMS B 3.7.9 Control Room Area Ventilation System (CRAVS)

BASES BACKGROUND The CRAVS provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The CRAVS consists of two independent, redundant trains that draw in filtered outside air and mix this air with conditioned air recirculating through the Control Room Envelope (CRE). Each outside air pressure filter train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal absorber 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 prefilters to remove water droplets from the air stream. A second bank of HEPA filters follows the absorber section to collect carbon fines and provides backup in case of failure of the main HEPA filter bank.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. 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 unfltered 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.

The CRAVS is an emergency system. During normal operation the CRE is provided with 100% recirculated air and the outside air pressure filter train is in the standby mode. Upon receipt of the actuating signal(s), the CRE is provided with fresh air through outside air intakes and is circulated through the system filter trains. The prefilters remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal adsorbers. Operation f.or > 15 eontinuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The heater is important to

~ effeetiveRess of the sharooal aElsoF8eFS.

McGuire Units 1 and 2 B 3.7.9-1 Revision No. 4eQ

CRAVS B 3.7.9 BASES ACTIONS (Continued)

D.1, D.2.1, and D.2.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS, if the inoperable CRAVS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CRAVS train in the emergency mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected. An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

E.1 and E.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS, with two CRAVS trains inoperable or with one or more CRAVS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the control room.

This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

Ll If both CRAVS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e., Condition B), the CRAVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

he heaters do not affect OPERABILITY of the CRAVS filter train Insert 2 - Move to because charcoal absorber efficiency testing is performed at 30°C and .QQ Background 1/o relative humidity. The aeoident analysis shows that control room Testing per ASTM D3803-1989 at 30°C and 95% relative humidity ensures that the filter efficiency is unaffected by moisture.

McGuire Units 1 and 2 B 3.7.9-6 Revision No. 4SQ

CRAVS B 3.7.9 BASES ACTIONS (Continued)

~adiation doses are within 10 CFR a0.e7 (Ref. 8) limits during a OBA I

. LOCA under these oonditions.

SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. Operation for ~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action.

lnopOFable heaters are addressed by Required Aotions G.1 and G.2. The inoperability of heaters between required performanoes of this surveillance does not affeot OPERABILITY of eaoh CRAVS train.

Operability of the heaters is demonstrated by the heater power dissipation test per SR 3.7.9.2.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.7.9.2 This SR verifies that the required CRAVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CRAVS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 4).

The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate,I heater po>.ver dissipation, land the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.9.3 This SR verifies that each CRAVS train starts and operates with flow through the HEPA filters and charcoal adsorbers on an actual or simulated actuation signal. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.7.9.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE.

The SURVEILLANCE REQUIREMENTS (continued)

McGuire Units 1 and 2 B 3.7.9-7 Revision No. 4W

3/4. 7 PLANT SYSTEMS BASES 3/4.7.5 ULTIMATE HEAT SINK The limitations on the ultimate heat sink level and temperature ensure that sufficient cooling capacity is available either: ( 1) provide normal cooldown of the facility or (2) mitigate the effects of accident conditions within acceptable limits.

The limitations on minimum water level and maximum temperature are based on providing a 30-day cooling water supply to safety-related equipment without exceeding its design basis temperature and is consistent with the recommendations of Regulatory Guide 1.27, "Ultimate Heat Sink for Nuclear Plants," Rev. 2, January 1976.

3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM BACKGROUND The CREFS provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

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

The CRE is the area within the confines f the CRE boundary that contains the spaces that control room occupants inhabit to control the un* during normal and accident conditions. This area encompasses the control room, and may ncompass other non-critical areas to which frequent personnel access or continuous occupanc is not necessary in the event of an accident. The CRE is protected during normal operation, n tural events, and accident conditions. The CRE boundary is the combination of walls, floor, ro f, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY o the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE ill not exceed the inleakage assumed in the licensing basis analysis of design basis accident BA) consequences to CRE occupants. The CRE and its boundary are defined in the Control R om Envelope Habitability Program.

The CREFS is an emergency system, parts of which ay also operate during normal unit operation in the standby mode of operation. Upon re eipt of the actuating signal(s), normal air supply to the CRE is isolated, and the stream of ventila

• n air is recirculated through the system filter trains. The prefilters or demisters remove any large articles in the air, and any entrained water droplets present, to prevent excessive loading of th HEPA filters and charcoal adsorbers.

8etR the demister and heater are important to the effective ss of the charcoal adsorbers.

The ~

demister Actuation of the CREFS places the system in the emergency ode (i.e., isolation with is recirculation mode) of operation. Actuation of the system clos s the unfiltered outside air intake

.___ _ ___. and unfiltered exhaust dampers, and aligns the system for recir lation of the air within the CRE through the redundant trains of HEPA and charcoal filters. Thee ergency mode also allows for pressurization and filtered ventilation of the air supply to the CRE.

The heaters are not required for OPERABILITY since the carbon laboratory tests are performed at 95% relative humidity, but are maintained in the system to provide additional efficiency margin.

SHEARON HARRIS - UNIT 1 B 3/4 7-3e Amendment No. 156

3/4. 7 PLANT SYSTEMS BASES 3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM (Continued)

APPLICABLE SAFETY ANALYSIS The CREFS 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 CREFS 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 FSAR, Chapter 15 (Ref. 2).

The CREFS provides protection from smoke and hazardous chemicals to the CRE occupants.

The analysis of toxic chemical hazards found no impact on control room habitability from toxic chemical sources (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 CREFS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

The CREFS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LIMITING CONDITION FOR OPERATION (LCO)

Two independent and redundant CREFS trains 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 ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem TEDE or its equivalent to any part of the body to the CRE occupants in the event of a large radioactive release.

Each CREFS train is considered OPERABLE when the individual components necessary to limit CRE occupant exposure are OPERABLE. A CREFS train is OPERABLE when the associated:

a. Fan is OPERABLE,

b. HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions, and C. Ffeate~.~ mister, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In order for the CREFS trains 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.

SHEARON HARRIS - UNIT 1 B 3/4 7-39 Amendment No. +ea

3/4.7 PLANT SYSTEMS BASES 3.7.6 b.3 and c.3 In MODE 5 or 6, or during movement of irradiated fuel assemblies, or during movement of loads over spent fuel pools, with one or more CREFS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

SURVEILLANCE REQUIREMENTS SR 4.7.6.a Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. Operation with the heaters on for

~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The surveillance frequency is controlled under the Surveillance Frequency Control Program.

SR 4.7.6.b, C, e, and f ANSI N510-1980 will be used as a procedural guide for surveillance testing. Criteria for laboratory testing of charcoal and for in-place testing of HEPA filters and charcoal adsorbers is based upon a removal efficiency of 99% for elemental, particulate and organic forms of radioiodine.

SR 4.7.6.d.1 This SR verifies that the HEPA filters and charcoal adsorbers are not excessively blocked. The filter pressure drop was chosen to be half-way between the estimated clean and dirty pressure drops for those components. This assures the full functionality of the filters for a prolonged period, even at the Technical Specification limit. The surveillance frequency is controlled under the Surveillance Frequency Control Program.

SR 4.7.6.d.2 This SR verifies that each CREFS train starts and operated on an actual or simulated actuation signal. The surveillance frequency is controlled under the Surveillance Frequency Control Program.

SHEARON HARRIS - UNIT 1 B 3/4 7-3k Amendment No. 4.§e

3/4. 7 PLANT SYSTEMS BASES 3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM (Continued)

SR 4.7.6.d.4 This SR *1erifies that eaoh CREFS train heater operates within assumed parameters. The surveillanoe frequenoy is oontrolled under the Surveillanoe Frequenoy Control Program.

SR 4.7.6.g 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 OBA consequences is no more than 5 rem TEDE 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 OBA consequences.

In MODES 1, 2, 3, or 4, when unfiltered air inleakage is greater than the assumed flow rate, ACTION a.2 must be entered. ACTION a.2 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. 5) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 6). These compensatory measures may also be used as mitigating actions as required by ACTION a.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref.

7). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis OBA consequence analysis, repairing the CRE boundary, or a combination of these actions.

Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

REFERENCES

1. FSAR, Section 9.4

2. FSAR, Chapter 15

3. FSAR, Section 6.4

4. FSAR, Section 9.5 and Corrective Action Program Assignment 100903-05

5. Regulatory Guide 1.196

6. NEI 99-03,"Control Room Habitability Assessment," June 2001

7. 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)

SHEARON HARRIS - UNIT 1 B 3/4 7-31 Amendment No. §4

The heaters are not required for OPERABILITY since the carbon laboratory tests are performed at 95% relative humidity, 3/4. 7 PLANT SYSTEMS but are maintained in the system to provide additional efficiency margin.

BASES 3/4.7.7 REACTOR AUXILIARY BUILDING EMERGENCY EXHAUST SYSTEM The OPERABILITY of the Reactor Auxiliary Building Emergency Exhaust System ensures that radioactive materials leaking from the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the environment. Operation with the heaters on for ~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that Reatef failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action~11 The operation of this system and the resultant effect on offsite dosage calculations was assumed in the safety analyses. ANSI N510-1980 will be used as a procedural guide for surveillance testing. Criteria for laboratory testing of charcoal and for in- place testing of HEPA filters and charcoal adsorbers is based upon removal efficiencies of 95% for organic and elemental forms of radioiodine and 99% for particulate forms. The filter pressure drop was chosen to be half-way between the estimated clean and dirty pressure drops for these components. This assures the full functionality of the filters for a prolonged period, even at the Technical Specification limit.

The LCO is modified by a note allowing the Reactor Auxiliary Building Emergency Exhaust System (RABEES) ventilation boundary to be opened intermittently under administrative controls.

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

This individual will have a method to rapidly close the opening when a need for RABEES isolation is indicated.

If the RABEES boundary is inoperable in MODES 1, 2, 3, and 4, the RABEES trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE RABEES boundary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the period that the RABEES boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19, 60, 64, and 10 CFR Part 100) should be utilized to protect plant personnel from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security.

Preplanned measures should be available to address these concerns. HNP will have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into this condition. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed out of service time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the RABEES boundary. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed out of service time is reasonable based on the low probability of a OBA occurring during this time period, and the availability of compensatory measures.

SHEARON HARRIS - UNIT 1 B 3/4 7-3m Amendment No. 456

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The heaters are not required for OPERABILITY since the carbon laboratory tests are performed at 95% relative humidity, REFUELING OPERATIONS but are maintained in the system to provide additional efficiency margin.

BASES DING EMERGENCY EXHAUST SYSTEM

. The limitations on the Fuel H ndling Building Emergency Exhaust System ensure that all radioactive material releas from an irradiated fuel assembly will be filtered through the HEPA filters and charcoal adsor r prior to discharge to the atmosphere. Operation with the heaters on for ~ 15 continuous mi tes demonstrates OPERABILITY of the system. Periodic operation ensures that * , blockage, fan or motor failure, or excessive vibration can be detected for corrective action. he surveillance frequency is controlled under the Surveillance Frequency Control Program. The OPERABILITY of this system and the resulting iodine removal capacity are consistent with the assumptions of the safety analyses. ANSI N510-1980 will be used as a procedural guide for surveillance testing. Criteria for laboratory testing of charcoal and for in-place testing of HEPA filters and charcoal adsorbers is based upon removal efficiencies of 95%

for organic and elemental forms of radioiodine and 99% for particulate forms. The filter pressure drop was chosen to be half-way between the estimated clean and dirty pressure drops for these components. This assures the full functionality of the filters for a prolonged period, even at the Technical Specification limit.

The LCO is modified by a note allowing the Fuel Handling Building Emergency Exhaust System (FHBEES) ventilation boundary to be opened intermittently under administrative controls. For entry and exit through doors, the administrative control of opening is performed by the person(s) entering or exiting the area. For other openings, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for FHBEES isolation is indicated.

SHEARON HARRIS - UNIT 1 B 3/4 9-4 Amendment No. 4.§e

FBACS 83.7.11 B 3.7 PLANT SYSTEMS B 3. 7.11 Fuel Building Air Cleanup System (FBACS)

BASES BACKGROUND The FBACS filters airborne radioactive particulates from the area of the spent fuel pool following a fuel handling accident in the Fuel Building.

_ _ _ _ _ _ _ _ _ _ _ _ _ _The FBACS, in conjunction with other normally operating systems, also The heaters are not required for rovides environmental control of temperature and humidity in the spent OPERABILITY since the carbon uel pool area.

laboratory tests are performed at 95% relative humidity, but are he FBACS is a single train system which consists of a heater, a prefilter, maintained in the system to hI efficiency particulate air (HEPA) filter, an activated charcoal dsorb section for removal of gaseous activity (principally iodines), and provide additional efficiency fan. Du ork, valves or dampers, and instrumentation also form part

.....m_a_r_g_in_._ _ _ _ _ _ _ _ _......,f the syste .

The FBACS is a manually initiated system, which may also be operated during normal plant operations.

The FBACS is discussed in the UFSAR, Sections 6.5.1, 9.4.5, and 15. 7.4 (Refs. 1, 2, and 3, respectively) because it may be used for normal, as well as post accident, atmospheric cleanup functions.

APPLICABLE The FBACS design basis is established by the consequences of SAFETY ANALYSES the limiting Design Basis Accident (OBA), which is a fuel handling accident in the Fuel Building. The analysis of the fuel handling accident, given in Reference 3, assumes that all fuel rods in an assembly are damaged and the fission product inventory in the gap is released. The FBACS is assumed to be operating during the release and a once through filter efficiency of 90% for elemental iodine and 70% for organic iodine is assumed. All of the release passes through the FBACS due to the negative air pressure maintained by the FBACS in the Fuel Building, (i.e., no bypass leakage is assumed). The integrated dose is calculated using assumptions in Reference 3, which are consistent with the methodology utilized (continued)

HBRSEP Unit No. 2 B 3.7-63 Revision No. 22

FBACS B 3.7.11 BASES APPLICABLE in Regulatory Guide 1.183 (Ref. 8).

SAFETY ANALYSES (continued) The FBACS satisfies Criterion 3 of the NRC Policy Statement.

LCO The FBACS is required to be OPERABLE and operating. Total system failure could result in the atmospheric release from the fuel handling building exceeding the 10 CFR 50.67 (Ref. 4) limits in the event of a fuel handling accident.

The FBACS is considered OPERABLE when the individual components necessary to control exposure in the fuel handling building are OPERABLE. The FBACS is considered OPERABLE when its:

a. Fan is OPERABLE;

b. HEPA filter and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration function; and C. Plea~ uctwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

APPLICABILITY During movement of irradiated fuel in the fuel handling area, the FBACS is required to be OPERABLE and operating to alleviate the consequences of a fuel handling accident.

ACTIONS A.J.

When the FBACS is inoperable during movement of irradiated fuel assemblies in the fuel building, action must be taken to place the unit in a condition in which the LCO does not apply. Action must be taken immediately to suspend movement of irradiated fuel assemblies in the fuel building. This does not preclude the movement of fuel to a safe position.

(continued)

HBRSEP Unit No. 2 B 3.7-64 Revision No. 22

FBACS B 3.7.11 BASES (continued)

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS The FBACS should be checked periodically to ensure that it functions properly. As the environmental and normal operating conditions on this system are not severe, testing once every month provides an adequate check on this system.

Operation '.*.tith the heaters on for ~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The 31 day Frequency is based on the known reliability of the equipment.

SR 3.7.11.2 This SR verifies that the required FBACS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.11.3 This SR verifies the integrity of the fuel building enclosure. The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FBACS. The FBACS is designed to maintain a slight negative pressure in the fuel building, to prevent unfiltered LEAKAGE.

The Frequency of 18 months is consistent with the guidance provided in NUREG-0800, Section 6.5.1 (Ref. 5).

ISTS SR 3.7.13.4 is modified by a Note. This Note provides clarification that the Surveillance is not applicable when the only movement of irradiated fuel is movement of a spent fuel shipping cask containing irradiated fuel. This Note is necessary to permit the shipping cask to be removed from the fuel handling building. When the side walls are opened to (continued)

HBRSEP Unit No. 2 B 3.7-65 Revision No. 12

No changes to this page. FBACS Included for information B 3.7.11 BASES SURVEILLANCE SR 3.7.11.3 (continued)

REQUIREMENTS (continued) permit cask egress, ISTS SR 3.7.13.4 cannot be met. OPERABILITY of the FBACS is not necessary when irradiated fuel assemblies are in a spent fuel shipping cask because irradiated fuel assemblies are protected from damage and associated release of fission products by the cask and other controls associated with shipments of spent fuel assemblies. The terms "shipping cask" and "shipment" used within this specification and bases also applies to the transfer cask/dry fuel storage container used to transfer fuel to the onsite Independent Spent Fuel Storage Installation (ISFSI).

REFERENCES 1. UFSAR, Section 6.5.1.

2. UFSAR, Section 9.4.5.

3. UFSAR, Section 15.7.4.

4. 10 CFR 50.67.

5. NUREG-0800, Section 6.5.1, Rev. 2, July 1981.

6. Licensee Event Report (LER) 50-26/97-05, dated May 22, 1997.

7. Deleted.

8. Regulatory Guide 1.183.

HBRSEP Unit No. 2 B 3.7-66 Revision No. 39