Browns Ferry Nuclear Plant (BFN) - Response for Additional ...Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) -RESPONSE FOR ADDITIONAL INFORMATION REGARDING

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000

April 24, 2009

TVA-BFN-TS-444

10 CFR 50.90

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskMail Stop: OWFN P1-35Washington, D.C. 20555-0001

In the Matter of ) Docket Nos. 50-259Tennessee Valley Authority ) 50-260

50-296

BROWNS FERRY NUCLEAR PLANT (BFN) - RESPONSE FOR ADDITIONALINFORMATION REGARDING UNITS 1, 2, AND 3 - TECHNICAL SPECIFICATIONS (TS)CHANGE 444 - ADOPTION OF CHANGES TO STANDARD TECHNICAL SPECIFICATIONSUNDER TECHNICAL SPECIFICATION TASK FORCE (TSTF) CHANGE NUMBER - 448,REVISION 3, REGARDING CONTROL ROOM ENVELOPE HABITABILITY

This letter responds to the March 6, 2009, Email from NRC, Brendan Moroney, to TVArequesting that BFN make administrative changes to the TS and TS Bases in TVA's proposedTS-444.

Enclosure 1 provides a revision to the Units 1, 2, and 3 TS pages marked-up to show theproposed change. Enclosure 2 provides a revision to the Units 1, 2, and 3 Bases pagesmarked-up to show the proposed change. TVA incorporated all of the administrative NRCrequested changes into Enclosures 1 and 2. Enclosures 1 and 2 provide complete markup ofthe proposed change.

The revised pages provided in Enclosure 1 does not alter the original determination that thereare no significant hazards considerations associated with the proposed changes, nor do thechanges alter the originally submitted Environmental Assessment and Finding of No SignificantImpact provided by TVA's March 27, 2008 letter (Reference).

U.S. Nuclear Regulatory CommissionPage 2April 24, 2009

In accordance with 10 CFR 50.91 (b)(1), TVA is sending a copy of this letter and theEnclosures to the Alabama State Department of Public Health. TVA currently plans toimplement TS-444 within 60 days of NRC approval.

If you have any questions about this TS change, please contact Russ Godwin at (256) 729-2636.

I declare under penalty of perjury that the foregoing is true and correct. Executed onApril XX, 2009.

incerely,

R. G. WestVice PresidentBrowns Ferry Nuclear Plant

Enclosures:

1. Proposed Technical Specifications Changes (Revised Mark-up)2. Proposed Changes to Technical Specifications Bases Pages (Revised Mark-up)

Reference:

TVA letter to NRC dated March 27, 2008: Browns Ferry Nuclear Plant (BFN) - Units 1, 2,and 3 - Technical Specifications (TS) Change 444 - Adoption of Changes to StandardTechnical Specifications Under Technical Specification Task (TSTF) Change Number - 448,Revision 3, Regarding Control Room Envelope Habitability (ML080910360).

U.S. Nuclear Regulatory CommissionPage 3April 24, 2009

cc: (Enclosures):State Health OfficerAlabama State Department of Public HealthRSA Tower - AdministrationSuite 1552P.O. Box 303017Montgomery, Alabama 36130-3017

Ms. Eva A. Brown, Project ManagerU.S. Nuclear Regulatory Commission(MS 08G9)One White Flint, North11555 Rockville PikeRockville, Maryland 20852-2739

Ms. Heather J. Gepford, Acting Branch ChiefU.S. Nuclear Regulatory CommissionRegion IISam Nunn Atlanta Federal Center61 Forsyth Street, SW, Suite 23T85Atlanta, Georgia 30303-8931

NRC Resident InspectorBrowns Ferry Nuclear Plant10833 Shaw RoadAthens, Alabama 35611-6970

Enclosure I

Browns Ferry Nuclear Plant (BFN)Units 1, 2, and 3

Technical Specifications (TS) Change 444

Adoption of Changes to Standard Technical Specifications Under TechnicalSpecification Task Force (TSTF) Change Number - 448, Revision 3, Regarding

Control Room Envelope Habitability

Proposed Technical Specifications Changes (Revised Mark-up)

TVA has revised the enclosed pages. TVA drew a line through the deleted text and adouble underline for new or revised text. The changes made as a result of the NRC'srequest are highlighted.

CREV System3.7.3

3.7 PLANT SYSTEMS

3.7.3 Control Room Emergency Ventilation (CREV) System

LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

------------------- NOTE ----------------------------------------The main control room envelope (CRE) boundary may be openedintermittently under administrative control.

APPLICABILITY: MODES 1,2, and 3,During operations with a potential for draining the reactor

vessel (OPDRVs).ACTIONS

CONDITION REQUIRED ACTION COMPLETIONTIME

A. One CREV subsystem A.1 Restore CREV subsystem 7 daysinoperable for reasons to OPERABLE status.other than Condition B.

B. 4wG One or More CREVsubsystems inoperabledue to inoperable CREcGntrIGIreG boundary inMODES 1, 2, and 3.

B.1 Initiate action toimplement mitigatingactions.

AND

B.2 Verify mitigating actions

Immediately

ensure CRE occupantexoosures to radioloaical 24 Hourshazards will not exceedlimits, and verify the CREoccupants are protectedfrom smoke and chemicalhazards.

AND

B.4-.3 Restore CRE ,entrelFeem-boundary toOPERABLE status.

24•-Hmm•m

90 days

BFN-UNIT 1 3.7-8 Amendment No.234, 2.46, 251September 27, 2004

CREV System3.7.3

C. Required Action and C.1 Be in MODE 3. 12 hoursassociated CompletionTime of Condition A or B ANDnot met in MODE 1, 2, or3. C.2 Be in MODE 4. 36 hours

(continued)

BFN-UNIT 1 3.7-9 Amendment No.234, 246,251September 27, 2004

CREV System3.7.3

ACTIONS (continued)


D. Required Action and D.1 Place OPERABLE CREV Immediatelyassociated Completion subsystem inTime of Condition A not pressurization mode.met during OPDRVs.

OR

D.2 Initiate action to suspend ImmediatelyOPDRVs.

E. Two CREV subsystems E.1 Enter LCO 3.0.3. Immediatelyinoperable in MODE 1,2,or 3 for reasons otherthan Condition B.

(continued)

BFN-UNIT 1 3.7-10 Amendment No.234, 246, 251September 27, 2004

CREV System3.7.3

ACTIONS (continued)


F. Two CREV subsystems F.1 Initiate action to suspend Immediatelyinoperable during OPDRVs.OPDRVs for reasonsother than Condition B.

OR

Required actions andCompletion times ofCondition B not metduring OPDRVS.

BFN-UNIT 1 3.7-11 Amendment No.234,246, 251September 27, 2004

CREV System3.7.3

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.7.3.1 Operate each CREV subsystem for > 10 31 dayscontinuous hours with the heaters operating.

SR 3.7.3.2 Perform required CREV filter testing in In accordanceaccordance with the Ventilation Filter Testing with the VFTPProgram (VFTP).

SR 3.7.3.3 Verify each CREV subsystem actuates on an 24 monthsactual or simulated initiation signal.

SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordancetesting in accordance with the Control Room with the ControlEnvelope Habitability Program. Room Envelope

HabitabilityVenf;y eac.h CREV subsy•tem. .can maintain a Programpesitiv.e pressure of Ž 0.125 inhe wAterUgauge Felati'je to the outAdoors du ring the 24 months on apressurization Mod of oprtion at a flow STAGGEREDrate of >Ž 27-00 cmand- < 3300 4fM. I E 2-BA1lS

BFN-UNIT 1 3.7-12 Amendment No.234, 246, 251September 27, 2004

CREV System3.7.3

5.5.12 Primary Containment Leakage Rate Testing Program (continued)

Leakage Rate acceptance criteria are:

a. The primary containment leakage rate acceptance criteria is __ 1.0La. During the first unit startup following the testing performed inaccordance with this program, the leakage rate acceptance criteriaare ___ 0.60 La for the Type B and Type C tests, and < 0.75 La for theType A test; and

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate < 0.05 La when tested at __ Pa.

2) Air lock door seals leakage rate is _< 0.02 La when the overallair lock is pressurized to >_ 2.5 psig for at least 15 minutes.

The provisions of SR 3.0.2 do not apply to the test frequenciesspecified in the Primary Containment Leakage Rate TestingProgram. The provisions of SR 3.0.3 are applicable to the PrimaryContainment Leakage Rate Testing Program.

5.5.13 Control Room Envelope Habitability Program

A Control Room Envelope (CRE) Habitability Program shall beestablished and implemented to ensure that CRE habitability ismaintained such that, with an OPERABLE Control RoomEmergency Ventilation (CREV) System, CRE occupants can controlthe reactor safely under normal conditions and maintain it in a safecondition following a radiological event, hazardous chemical release,or a smoke challenge. The program shall ensure that adequateradiation protection is provided to permit access and occupancy ofthe CRE under design basis accident (DBA) conditions withoutpersonnel receiving radiation exposures in excess of 5 rem totaleffective dose equivalent (TEDE) for the duration of the accident.The program shall include the following elements:

a. The definition of CRE and the CRE boundary.

b. Requirements for maintaining the CRE boundary in its designcondition including configuration control and Dreventivemaintenance.

c. Requirements for (i) determining the unfiltered air inleakage pastthe CRE boundary into the CRE in accordance with the testingmethods and at the Frequencies specified in Sections C.1 andC.2 of Regulatory Guide 1.197, "Demonstrating Control Room

(continued)

BFN-UNIT 1 5.0-22 Amendment No. 2,34-•269March 06, 2007

CREV System3.7.3

Envelope Integrity at Nuclear Power Reactors," Revision 0. May2003, and (ii) assessing CRE habitability at the Frequenciesspecified in Sections C.1 and C.2 of Regulatory Guide 1.197.Revision 0.

d. Measurement, at designated locations, of the CRE pressurerelative to all external areas adjacent to the CRE boundaryduring the pressurization mode of operation by one subsystem ofthe CREV System, operating at the flow rate required by theVFTP, at a frequency of 24 months on a STAGGERED TESTBASIS. The results shall be trended and used as part of theperiodic assessment of the CRE boundary.

e. The quantitative limits on unfiltered air leakage into the CRE.These limits shall be stated in a manner to allow directcomparison to the unfiltered air inleakage measured by thetesting described in paragraph c. The unfiltered air inleakagelimit for radiological challenges is the inleakage flow rateassumed in the licensing basis analyses of DBA consequences.Unfiltered air inleakage limits for hazardous chemicals mustensure that exposure of the CRE occupants to these hazards willbe within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies forassessing CRE habitability, determining CRE unfilteredinleakage, and measuring CRE pressure and assessing the CREboundary as required by paragraphs c and d, respectively.

(continued)

BFN-UNIT 1 5.0-23 Amendment No. 2Z4-,269March 06, 2007

CREV System3.7.3

3.7 PLANT SYSTEMS



-NOTE ----------------------------The main control room envelope (CRE) boundary may be openedintermittently under administrative control.

MODES 1, 2, and 3,During operations with a potential for draining the reactor vessel

(OPDRVs).

APPLICABILITY:

ACTIONS



B. Twe One or more CREVsubsystems inoperabledue to inoperable ,entrelFeem-CRE boundary inMODES 1,2, and 3.

B.1 Initiate actions toimplement mitigatingactions.

AND

B.2 Verify mitiaatina actionsensure CRE occupantexposures will not exceedlimits AND

Immediately

24 Hours

24 huf 90 days

B.4-3 Restore CRE GeRttIrr-eem boundary toOPERABLE status.

BFN-UNIT 2 3.7-9 Amendment No. 2-54-, 2-83, 290September 27, 2004

CREV System3.7.3


(continued)

BFN-UNIT 2 3.7-10 Amendment No. 254-, 2-8,, 290September 27, 2004

CREV System3.7.3

ACTIONS (continued)



OR


E. Two CREV subsystems E.1 Enter LCO 3.0.3. Immediatelyinoperable in MODE 1, 2,or 3 for reasons otherthan Condition B.

(continued)

BFN-UNIT 2 3.7-11 Amendment No. 254- 283, 290September 27, 2004

CREV System3.7.3

ACTIONS (continued)


F.' Two CREV subsystems F.1 Initiate action to suspend Immediatelyinoperable during OPDRVs.OPDRVs for reasonsother than Condition B.

OR

Required actions andCompletion times ofCondition B not metduring OPDRVs.

BFN-UNIT 2 3.7-12 Amendment No. 254- 28,3, 290September 27, 2004



SR 3.7.3.1 Operate each CREV subsystem for __ 10 31 dayscontinuous hours with the heaters operating.




HabitabilityVorif; eac, h G REV ,ubsytem. can Maintain a Programpositive pressure ef>- 0125 inches watergauge relative to the o•utdors during the 24m ,R•,h• -•4--apressurization MAde of operation at a flow STAGGEREDrate o-f- 0 7100 and!!r 3300 f.T-EST- BAS

BFN-UNIT 2 3.7-13 Amendment No[ 254September 08, 1998


The peak calculated containment internal pressure for the designbasis loss of coolant accident, Pa, is 50.6 psig. The maximumallowable primary containment leakage rate, La, shall be 2% ofprimary containment air weight per day at Pa.


a. The primary containment leakage rate acceptance criteria is < 1.0La. During the first unit startup following the testing performed inaccordance with this program, the leakage rate acceptance criteriaare < 0.60 La for the Type B and Type C tests, and < 0.75 La for theType A test; and

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate < 0.05 La when tested at > Pa.

2) Air lock door seals leakage rate is < 0.02 La when the overallair lock is pressurized to __ 2.5 psig for at least 15 minutes.

The provisions of SR 3.0.2 do not apply to the test frequenciesspecified in the Primary Containment Leakage Rate TestingProgram. The provisions of SR 3.0.3 are applicable to the PrimaryContainment Leakage Rate Testing Program.


A Control Room Envelope (CRE) Habitability Program shall beestablished and implemented to ensure that CRE habitability ismaintained such that, with an OPERABLE Control RoomEmergency Ventilation (CREV) System, CRE occupants can controlthe reactor safely under normal conditions and maintain it in a safecondition following a radiological event, hazardous chemical release,or a smoke challenge. The program shall ensure that adequateradiation protection is provided to permit access and occupancy ofthe CRE under design basis accident (DBA) conditions withoutpersonnel receiving radiation exposures in excess of 5 rem totaleffective dose equivalent (TEDE) for the duration of the accident.The program shall include the following elements:


b. Requirements for maintaining the CRE boundary in its designcondition including configuration control and preventivemaintenance.

BFN-UNIT 2 5.0-21 Amendment No. 266November 21, 2000

c. Requirements for (i) determining the unfiltered air inleakagepast the CRE boundary into the CRE in accordance with thetesting methods and at the Frequencies specified in SectionsC. 1 and C.2 of Regulatory Guide 1.197, "Demonstrating ControlRoom Envelope Integrity at Nuclear Power Reactors," Revision0, May 2003, and (ii) assessing CRE habitability at theFrequencies specified in Sections C.1 and C.2 of RegulatoryGuide 1.197, Revision 0.

d. Measurement, at designated locations, of the CRE pressurerelative to all external areas adjacent to the CRE boundaryduring the pressurization mode of operation by one subsystemof the CREV System, operating at the flow rate required by theVFTP, at a frequency of 24 months on a STAGGERED TESTBASIS. The results shall be trended and used as part of theperiodic assessment of the CRE boundary.

e. The quantitative limits on unfiltered air leakage into the CRE.These limits shall be stated in a manner to allow directcomparison to the unfiltered air inleakage measured by thetesting described in paragraph c. The unfiltered air inleakagelimit for radiological challenges is the inleakage flow rateassumed in the licensing basis analyses of DBA consequences.Unfiltered air inleakage limits for hazardous chemicals mustensure that exposure of the CRE occupants to these hazardswill be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies forassessing CRE habitability, determining CRE unfilteredinleakage, and measuring CRE pressure and assessing theCRE boundary as required by paragraphs c and d, respectively.

BFN-UNIT 2 5.0-22 Amendment No. 266November 21, 2000

CREV System3.7.3

3.7 PLANT SYSTEMS



--------------------NOTE---------------------The main control room envelope (CRE) boundary may be openedintermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3,During operations with a potential for draining the

(OPDRVs).reactor vessel

ACTIONS



B. T-wG One or more CREVsubsystems inoperabledue to inoperable Getrelreem CRE boundary inMODES 1, 2, and 3.

B. 1 Initiate actions toimplement mitigatingactions.

AND

B.2 Verify mitigating actinsensure CRE occupantexposures to radiologicalhazards will not exceedlimits, and verify the CREoccupants are protectedfrom smoke and chemicalhazards.

Immediately

24 hours

24-, ..... 90 days

AND

B.43 Restore CRE GentrelF-eem boundary toOPERABLE status.

BFN-UNIT 3 3.7-9 Amendment No. 214-241, 249September 27, 2004

CREV System3.7.3


(continued)

BFN-UNIT 3 3.7-10 Amendment No. 214- 241, 249September 27, 2004

CREV System3.7.3

ACTIONS (continued)



OR


E. Two CREV subsystems E.1 Enter LCO 3.0.3. Immediatelyinoperable in MODE 1,2,or 3 for reasons otherthan Condition B.

(continued)

BFN-UNIT 3 3.7-11 Amendment No. 214, 244, 249September 27, 2004

CREV System3.7.3

ACTIONS (continued)


F. Two CREV subsystems F.1 Initiate action to suspend Immediatelyinoperable during OPDRVs.OPDRVs for reasonsother than Condition B.

OR

Required actions andCompletion times ofCondition B not metduring OPDRVs.

BFN-UNIT 3 3.7-12 Amendment No. 2-14-241, 249September 27, 2004

CREV System3.7.3



SR 3.7.3.1 Operate each CREV subsystem for __ 10 31 dayscontinuous hours with the heaters operating.




HabitabilityVerify each GRE" sublytemI can maintain a programpositive Ipressure of Ž! 0.125 incher, watergauge rel-ative to- the outdooers during the :24 mnnho4A

.ressurization mode of operation at a flow STAGGEREDrate of Ž! 2700 cftf and !5 3300 cm. TS -II ISig

BFN-UNIT 3 3.7-13 Amendment N4 214September 08, 1998

CREV System3.7.3


The peak calculated containment internal pressure for the design basisloss of coolant accident, Pa, is 50.6 psig. The maximum allowableprimary containment leakage rate, La, shall be 2% of primarycontainment air weight per day at Pa.


a. The primary containment leakage rate acceptance criteria is _< 1.0La. During the first unit startup following the testing performed inaccordance with this program, the leakage rate acceptance criteriaare < 0.60 La for the Type B and Type C tests, and < 0.75 La for theType A test; andb. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate < 0.05 La when tested at _> Pa.

2) Air lock door seals leakage rate is _ 0.02 La when the overall airlock is pressurized to Ž_ 2.5 psig for at least 15 minutes.

The provisions of SR 3.0.2 do not apply to the test frequenciesspecified in the Primary Containment Leakage Rate Testing Program.The provisions of SR 3.0.3 are applicable to the Primary ContainmentLeakage Rate Testing Program.


A Control Room Envelope (CRE) Habitability Program shall beestablished and implemented to ensure that CRE habitability ismaintained such that, with an OPERABLE Control Room EmergencyVentilation (CREV) System, CRE occupants can control the reactorsafely under normal conditions and maintain it in a safe conditionfollowing a radiological event, hazardous chemical release, or a smokechallenge. The program shall ensure that adequate radiationprotection is provided to permit access and occupancy of the CREunder design basis accident (DBA) conditions without personnelreceiving radiation exposures in excess of 5 rem total effective doseequivalent (TEDE) for the duration of the accident. The program shallinclude the following elements:


BFN-UNIT 3 3.7-14 Amendment No. 2[4September 08, 1998

CREV System3.7.3

b. Requirements for maintaining the CRE boundary in its designcondition including configuration control and preventivemaintenance.

c. Requirements for (i) determining the unfiltered air inleakage pastthe CRE boundary into the CRE in accordance with the testingmethods and at the Frequencies specified in Sections C.1 and C.2of Regulatory Guide 1.197, "Demonstrating Control Room EnvelopeIntegrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii)assessing CRE habitability at the Frequencies specified in SectionsC.1 and C.2 of Regulatory Guide 1.197, Revision 0.

d. Measurement, at designated locations, of the CRE pressure relativeto all external areas adjacent to the CRE boundary during thepressurization mode of operation by one subsystem of the CREVSystem, operating at the flow rate required by the VFTP. at afrequency of 24 months on a STAGGERED TEST BASIS. Theresults shall be trended and used as part of the periodicassessment of the CRE boundary.

e. The quantitative limits on unfiltered air leakage into the CRE.These limits shall be stated in a manner to allow direct comparisonto the unfiltered air inleakage measured by the testing described inparagraph c. The unfiltered air inleakage limit for radiologicalchallenges is the inleakage flow rate assumed in the licensing basisanalyses of DBA consequences. Unfiltered air inleakage limits forhazardous chemicals must ensure that exposure of the CREoccupants to these hazards will be within the assumptions in thelicensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies forassessing CRE habitability, determining CRE unfiltered inleakage.and measuring CRE pressure and assessing the CRE boundar asrequired by paragraphs c and d, respectively.

BFN-UNIT 3 3.7-15 Amendment No. 2[4September 08, 1998

Enclosure 2

Browns Ferry Nuclear Plant (BFN)Units 1, 2, and 3

Technical Specifications (TS) Change 444

Adoption of Changes to Standard Technical Specifications Under TechnicalSpecification Task Force (TSTF) Change Number - 448, Revision 3, Regarding

Control Room Envelope Habitability

Proposed Changes to Technical Specifications Bases Pages (Revised Mark-up)

TVA has revised the enclosed pages. TVA drew a line through the deleted text and adouble underline for new or revised text. The changes made at the request of NRC arehighlighted.

CREV SystemB 3.7.3

B 3.7 PLANT SYSTEMS

B 3.7.3 Control Room Emergency Ventilation (CREV) System

BASES

BACKGROUND The CREV System provides a protected environmentfrom which occupants can control the unit following anuncontrolled release of radioactivity. adilgiGalcontrolled environment from ,which the '-u nit cr-n be _afelyoperated following a Design Basis Accident (1DIBA).

The safety related function of the CREV System includestwo independent and redundant high efficiency airfiltration subsystems for emergency treatment of outsidesupply air and a CRE boundary that limits the inleakageof unfiltered air. The CREV Ssystem has a highefficiency particulate air (HEPA) filter bank in the portionof the inlet piping common to both subsystems. EachCREV subsystem consists of a motor-driven fan, anelectric duct air heater, an activated charcoal adsorbersection, an electric charcoal heater, and the associatedductwork valves or and dampers, doors, barriers, andinstrumentation. The HEPA filter bank removesparticulate matter, which may be radioactive. Thecharcoal adsorbers provide a holdup period for gaseousiodine, allowing time for decay; however, no credit istaken in the analyses for the charcoal adsorbers.

The CRE is the area within the confines of the CREboundary that contains the spaces that control roomoccupants inhabit to control the unit during normal andaccident conditions. This area encompasses the controlroom, and may encompass other non-critical areas towhich frequent personnel access or continuousoccupancy is not necessary in the event of an accident.The CRE is protected during normal operation, naturalevent and accident conditions. The CRE boundary is thecombination of walls, floor, roof, ducting. doors,penetrations and equipment that physically form theCRE. The OPERABILITY of the CRE boundar must bemaintained to ensure that the inleakage of unfiltered air

(continued)

BFN-UNIT 1 B 3.7-17 Revision 0, 29January 25, 2005

CREV SystemB 3.7.3

into the CRE will not exceed the inleakage assumed inthe licensing basis analysis of design basis accident(DBA) consequences to CRE occupants. The CRE andits boundary are defined in the Control Room EnvelopeHabitability Program.

Upon receipt of the initiation signal(s) (indicative ofconditions that could result in radiation exposure to CREoccupants con-trol rom perFG,,,,), the CREV Systemautomatically switches to the pressurization mode ofoperation to minimize pievent infiltration of contaminatedair into the CRE -etrte re,-F,. A system of dampersisolates the CRE citr! rFeem. Outside air is taken inthrough the CREV System ventilation intake and ispassed through one of the charcoal adsorber filtersubsystems for removal of airborne radioactive particles.

(continued)


CREV SystemB 3.7.3

BASES

BACKGROUND

(continued)

The CREV System is designed to maintain a habitableenvironment in the CRE centrel room e,,'ironmentfor a 30 day continuous occupancy after a DBA withoutexceeding 5 rem total effective dose equivalent (TEDE). Asingle CREV subsystem operating at a flow rate of 3000 cfm±10 percent will pressurize the CRE centreree,- to about

0.125 inches water gauge to minimize pFevent infiltration of airfrom all surrounding areas adjacent to CRE boundary -bud;,sand the outdoors. CREV System operation in maintaining CREGentre Feem-habitability is discussed in the FSAR,Section 10.12 (Ref. 1).

APPLICABLE The ability of the CREV System to maintain the habitabilitySAFETY ANALYSES of the CRE rentre- ree..; is an explicit assumption for the safety

analyses presented in the FSAR, Chapters 10 and 14 (Refs. 2and 3, respectively). The pressurization mode of the CREVSystem is assumed to operate following a DBA, leos of coolantaccideRt, main steam line bra, and conrol rodak dro cindent

(for the control rod drop accident and- m-ain steam line break, nocredit is taken for any filtration by the G-RE"V System) asdiscussed in the FSAR, Section 14.6 (Ref. 4). The analyses forradiological doses to CRE occupants c-on-pitrol ,roo..m personnel asa result of the various DBAs are summarized in Reference 3.No single active failure will cause the loss of filtered outside airfrom the CRE Gnt+e. room.

There are no offsite or onsite hazardous chemicals that wouldpose a credible threat to CRE habitability (Ref 9).Consequently, engineering controls for the CRE are notrequired to ensure habitability against chemical threat.

The evaluation of a smoke challenge demonstrated that smokewill not result in the inability of the CRE occupants to control thereactor either from the control room or remote shutdown system(Ref 9). The assessment verified that a fire or smoke eventanywhere with the plant should not simultaneously render theremote shutdown system and the CRE uninhabitable, nor wouldit prevent access from the CRE to the remote shutdown systemin the event remote shutdown is required. No automatic CREVactuation is required for hazardous chemical releases or smoke

(continued)


CREV SystemB 3.7.3

and no Surveillance Requirements are required to verifyOPERABILITY in cases of hazardous chemicals or smoke.

The CREV System satisfies Criterion 3 of the NRC PolicyStatement (Ref. 6).

(continued)


CREV SystemB 3.7.3

BASES (continued)

LCO Two redundant subsystems of the CREV System are required tobe OPERABLE to ensure that at least one is available,arsumig if a single active failure disables the other subsystem.Total CREV Asystem failure, such as from a loss of bothventilation subsystems or from an inoperable CRE boundary,could result in exceeding a TEDE of 5 rem to the CREoccupants co-ntrol rom operato.r in the event of a DBA.

The Each CREV System subsystem is considered OPERABLEwhen the individual components necessary to limit CREoccupant ,en..,,--pe at,÷ exposure are OPERABLE -bethsubsystems. A subsystem is considered OPERABLE when itsassociated:

a. Fan is OPERABLE;

b. HEPA filter and charcoal adsorbers are not excessivelyrestricting flow and are capable of performing their filtrationfunctions; and

c. The electric duct heater, ductwork, and dampers areOPERABLE.

In addition, the control room bouRdary must be mnaintaine4dDincluding the integrity of the walls, floors, ceilings, ductWork, andaccess-or dooGrs.

In order for the CREV subsystems to be consideredOPERABLE, the CRE boundary must be maintained such thatthe CRE occupant dose from a larae radioactive release doesnot exceed the calculated dose in the licensing basisconsequences analyses for DBAs, and that the CRE occupantsare protected from hazardous chemicals and smoke.

BFN does not have automatic CREV actuations for hazardouschemicals or smoke. Current practices at BFN do not utilizechemicals of sufficient quantity to present a chemical hazard tothe CRE. Smoke is not considered in the current BFN safetyanalysis. Therefore, BFN has no specific limits on chemicalhazards or smoke.

(continued)

BFN-UNIT 1 B 3.7-21 Revision 0, 29Armnendm-ennt nin 246

January 25, 2005

CREV SystemB 3.7.3

The LCO is modified by a Note allowing the CRE mai-GoFIFrooR boundary to be opened intermittently under administrativecontrols. This Note only applies to openings in the CREboundary that can be rapidly restored to the design condition,such as doors, hatches, floor plugs, and access panels. Forentry and exit through doors the administrative control of theopening is performed by the person(s) entering or exiting thearea. For other openings, these controls should beproceduralized and consist of stationing a dedicated individualat the opening who is in continuous communication with theoperators in the CRE main control room. This individual willhave a method to rapidly close the opening and to restore theCRE boundary to a condition equivalent to the design conditionwhen a need for CRE main control room isolation is indicated.

(continued)

BFN-UNIT 1 B 3.7-22 Revision G, 29Amendmert No. 246

January 25, 2005

CREV SystemB 3.7.3

BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, the CREV System must be OPERABLEto ensure that the CRE will remain habitable ,ntI .Gpe.expesuFe during and following a DBA, since the DBA could leadto a fission product release.

In MODES 4 and 5, the probability and consequences of a DBAare reduced because of the pressure and temperaturelimitations in these MODES. Therefore, maintaining the CREVSystem OPERABLE is not required in MODE 4 or 5, except forduring operations with a potential for draining the reactor vessel(OPDRVs).

ACTIONS A.1

With one CREV subsystem inoperable, for reasons other thanan inoperable CRE boundary, the inoperable CREV subsystemmust be restored to OPERABLE status within 7 days. With theunit in this condition, the remaining OPERABLE CREVsubsystem is adequate to perform the CRE occupant GGRtFGtroo radia protection function. However, the overallreliability is reduced because a-sikgle failure in the OPERABLEsubsystem could result in loss of the FedU•ed CREV Systemfunction Gapability. The 7 day Completion Time is based on thelow probability of a DBA occurring during this time period, andthat the remaining subsystem can provide the requiredcapabilities.

(continued)


CREV SystemB 3.7.3

BASES

ACTIONS B.1, B.2 and B.3(continued)

If the unfiltered inleakage of potentially contaminated air pastthe CRE boundary and into the CRE can result in a CREoccupant radiological dose greater than the calculated dose ofthe licensing basis analyses of DBA consequences (allowed tobe up to 5 REM TEDE) the CRE boundary is inoperable.

As discussed in the Applicable Safety Analysis Section, the BFNlicensing bases notes that CRE inleakage limits for hazardouschemicals and smoke are not needed to protect the CREoccupants. Since the limit established for radiological events islimiting, verification of smoke and chemical hazards byadministrative means is acceptable for an inoperable CREboundary. Verification that the periodic check of onsite andoffsite hazardous chemical sources has been performed withinthe time limit defined by the Control Room Habitability Programis an acceptable means to ensure the CRE occupants areprotected from chemical hazards and smoke.

Actions must be taken to restore an OPERABLE CRE boundarywithin 90 days.

During the period that the CRE boundary is consideredinoperable, action must be initiated to implement mitigatingactions to lessen the effect on CRE occupants from the potentialhazards of a radiological or chemical event or a challenge fromsmoke. Actions must be taken within 24 hours to verify that inthe event of a DBA, the mitigating actions will ensure that CREoccupant radiological exposures will not exceed the calculateddose of the licensing basis analyses of DBA conseauences andthat CRE occupants are protected from hazardous chemicalsand smoke. These mitigating actions (i.e., actions that aretaken to offset the consequences of the inoperable CREboundary) should be preplanned for implementation upon entryinto the condition, regardless of whether entry is intentional orunintentional. The 24 hour Completion Time is reasonablebased on the low probability of a DBA occurring during this timeperiod, and the use of mitigating actions. The 90 day

(continued)

BFN-UNIT 1 B 3.7-24 Revision 0, 29Amendment hio. 246

January 25, 2005

CREV SystemB 3.7.3

Completion Time is reasonable based on the determination thatthe mitigating actions will ensure protection of CRE occupantswithin analyzed limits while limiting the probability that CREoccupants will have to implement protective measures that mayadversely affect their ability to control the reactor and maintain itin a safe shutdown condition in the event of a DBA. In addition.the 90 day Completion Time is a reasonable time to diagnose,plan and possibly repair, and test most problems within the CREboundary.if the main control roomn boundary is inoperable in MODES 1, 2,and 3, the CREV trains cannt per•Form their intended functionsActions must be taken to restore an OPERABLE main controeroom bounda'y Within 24 hours. DurinRg the period that the maincontrol room boundary is inoperable, apprpriate compensatomeasures (consistent ,,Aith the intenRt, o-f GQDCn 19) should beutilized to protectO coto roo operators from potential ha-zardsr-such as rad-ioac~tive cont~am.inat~ion, toXic chemnicals, smo~ke-,temperature and relative humidity, and physical security.'

concerns for intentional and unintentioa•l eRntY into thec-ndcfitin. The :21 ho•ur Cmpletion Timle is reasonable basedOn the low probability of a DIA occurring during this time period,andl the use Of omrpeRsatofr m,,easures. The 21 hr, ,

Completion Time ius a typically reasrnhableý time to dliagne,

plan and peosibly repair, and test mest problems with the main

rontrol roonm boundar,'-.

C.1 and C.2

In MODE 1, 2, or 3, if the inoperable CREV subsystem or theCRE G tGI- reeom boundary cannot be restored .to OPERABLEstatus within the required asseGiated Completion Time, the unitmust be placed in a MODE that minimizes accident risk. Toachieve this status, the unit must be placed in at least MODE 3within 12 hours and in MODE 4 within 36 hours. The allowedCompletion Times are reasonable, based on operatingexperience, to reach the required unit conditions from full powerconditions in an orderly manner and without challenging unitsystems.

(continued)

BFN-UNIT 1 B 3.7-25 Revision g, 29Amnurdmet No. 2165

January 25, 2005

CREV SystemB 3.7.3

BASES

ACTIONS(continued)

D.1 and D.2

During OPDRVs, if the inoperable CREV subsystem cannot berestored to OPERABLE status within the required CompletionTime, the OPERABLE CREV subsystem may be placed in thepressurization mode. This action ensures that the remainingsubsystem is OPERABLE, that no failures that would preventautomatic actuation will occur, and that any active failure will bereadily detected.

An alternative to Required Action D.1 is to immediately initiateactions to suspend OPDRVs to minimize the probability of avessel draindown and the subsequent potential for fissionproduct release. Actions must continue until the OPDRVs aresuspended.

(continued)

BFN-UNIT 1 B 3.7-26 Revision 0, 29Amendnment o. 216

January 25, 2005

CREV SystemB 3.7.3

BASES

ACTIONS(continued)

E.1

If both CREV subsystems are inoperable in MODE 1, 2, or 3 forreasons other than an inoperable CRE control room bo.undar(i.e., Condition B), the CREV System may not be capable ofperforming the intended function and the unit is in a conditionoutside of the accident analyses. Therefore, LCO 3.0.3 must beentered immediately.

:F. 1

During OPDRVs, with two CREV subsystems inoperable or withone or more CREV subsystems inoperable due to an inoperableCRE boundary, actions must be initiated immediately tosuspend OPDRVs to minimize the probability of a vesseldraindown and subsequent potential for fission product release.Actions must continue until the OPDRVs are suspended.

(continued)

BFN-UNIT 1 B 3.7-27 Revision 0, 29Amendment No. 2006

January 25, 2005

CREV SystemB 3.7.3

BASES (continued)

SURVEILLANCE SR 3.7.3.1REQUIREMENTS

This SR verifies that a subsystem in a standby mode starts ondemand and continues to operate. Standby systems should bechecked periodically to ensure that they start and functionproperly. As the environmental and normal operating conditionsof this system are not severe, testing each subsystem onceevery month provides an adequate check on this system.Monthly heater operation dries out any moisture that hasaccumulated in the charcoal as a result of humidity in theambient air. The CREV System must be operated for _> 10continuous hours with the heaters energized to dry out anymoisture and to demonstrate the function of the system.Furthermore, the 31 day Frequency is based on the knownreliability of the equipment and the two subsystem redundancyavailable.

SR 3.7.3.2

This SR verifies that the required CREV testing is performed inaccordance with the Ventilation Filter Testing Program (VFTP).The VFTP includes testing HEPA filter performance, charcoaladsorber efficiency, minimum system flow rate, and the physicalproperties of the activated charcoal (general use and followingspecific operations). Specific test Ffrequencies and additionalinformation are discussed in detail in the VFTP.

(continued)

BFN-UNIT 1 B 3.7-28 Revision 0

CREV SystemB 3.7.3

BASES


(continued) This SR verifies that on an actual or simulated initiation signal,each CREV subsystem starts and operates. This SR includesverification that dampers necessary for proper CREV operationfunction as required. The LOGIC SYSTEM FUNCTIONALTEST in SR 3.3.7.1.4 and SR 3.3.7.1.6 overlaps this SR toprovide complete testing of the safety function. The Frequencyof 24 months is based on BFN's normal operating cycle.

SR 3.7.3.4

This SR verifies the OPERABILITY of the CRE boundary bytesting for unfiltered air inleakage past the CRE boundary andinto the CRE. The details of the testing are specified in theControl Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose toCRE occupants calculated in the licensing basis analyses ofDBA consequences is no more that 5 rem TEDE and the CREoccupants are protected from hazardous chemicals and smoke.There is no automatic CREV actuation for hazardous chemicalreleases or smoke and there are no Surveillance Requirementsto verify the OPERABILITY in cases of hazardous chemicals orsmoke. This SR verifies that the unfiltered air inleakage into theCRE is no greater than the flow rate assumed in the licensingbasis analysis of DBA consequences. When unfiltered airinleakage is greater than the assumed flow rate, Condition Bmust be entered. Required Action B.3 allows time to restore theCRE boundary to OPERABLE status provided mitigating actionscan ensure that the CRE remains within the licensing basishabitability limits for occupants following an accident.Compensatory measures are discussed in Regulatory Guide1.196, Section C.2.7.3, (Ref. 6) which endorses, withexceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 7).These compensatory measures may also be used as mitigatingactions as required by Required Action B.2. Temporaryanalytical methods may also be used as compensatorymeasures to restore OPERABILITY (Ref. 8). Options forrestoring the CRE boundary to OPERABLE status include

(continued)


CREV SystemB 3.7.3

changing the licensing basis DBA consequences analysis.repairing the CRE boundary, or a combination of these actions.

(continued)


CREV SystemB 3.7.3

SURVEILLANCEREQUIREMENTS

(continued)

SR 3.7.3.4

Depending upon the nature of the problem and thecorrective action, a full scope inleakage test may not benecessary to establish that the CRE boundary has beenrestored to OPERABLE status.

This RR verifies the integrity Of the control roomencnloure and the assumed inleakage rates of potentiallycontaminated- air. The cone-trol room-n positive pressure,with respect4 to outdooers is periodically tested to verifyproper fun"tion o,,f thte CREV Syste÷m. During- heemnergency moede of operation, the CREV System; i6designed to slightly pre66urize the control room Ž! 0.125inc~hes, water gauge positive presrsure with Frespect to theoutdoors to prevent unfiltered inleakage. The CREVSystemn is designed to mnaintain this positive pressure at-aflow rate of Ž! 2700 cfmn and !• 3300 cfM to the controlroomn in the peressurization mode. The Frequency o924 moenths on a STAG-G-E"R'ED -T-EST- BASIS is consistentwi.At-h ind-ustrFY practice anRd other filtration systems SRs.

(continued)


CREV SystemB 3.7.3

REFERENCES 1. FSAR, Section 10.12.

2. FSAR, Chapter 10.


4. FSAR, Section 14.6.

5. NRC No. 93-102, "Final Policy Statement onTechnical Specification Improvements," July 23, 1993.

6. NRC Regulatory Guide 1.196, "Control RoomHabitability At Light-Water Power Reactors". January2007.

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

8. Letter from Eric J. Leeds (NRC) to James W. Davis(NEI) dated January 30, 2004, "NEI Draft WhitePaper, Use of Generic Letter 91-18 Process andAlternative Source Terms in the Context of ControlRoom Habitability." (ADAMS Accession No.MIL040300694)

9. FSAR, Chapter 10.12.5.3, Toxic Gas Protection

(continued)


CREV SystemB 3.7.3

B 3.7 PLANT SYSTEMS


BASES

BACKGROUND The CREV System provides a protected environment fromwhich occupants can control the unit following an uncontrolledrelease of radioactivity., adioo•gically o•t•rGoled envi9ronmntfrom which the unit can be safely operated following a DesigBasis Accident (OBA).

The safety related function of the CREV System includes twoindependent and redundant high efficiency air filtrationsubsystems for emergency treatment of outside supply air and aCRE boundary that limits the inleakage of unfiltered air. TheCREV Ssystem has a high efficiency particulate air (HEPA) filterbank in the portion of the inlet piping common to bothsubsystems. Each CREV subsystem consists of a motor-drivenfan, an electric duct air heater, an activated charcoal adsorbersection, an electric charcoal heater, and the associatedductwork, valves or aP4 dampers, doors, barriers andinstrumentation. The HEPA filter bank removes particulatematter, which may be radioactive. The charcoal adsorbersprovide a holdup period for gaseous iodine, allowing time fordecay; however, no credit is taken in the analyses for thecharcoal adsorbers.

The CRE is the areas within the confines of the CRE boundarythat contains the spaces that control room occupants inhabit tocontrol the unit during normal and accident conditions. Thisarea encompasses the control room, and may encompass othernon-critical areas to which freaquent personnel access orcontinuous occupancy is not necessary in the event or anaccident. The CRE is protected during normal operation,natural event and accident conditions. The CRE boundary isthe combination of wall, floor, roof, ducting. doors, penetrationsand equipment that physically form the CRE. TheOPERABILITY of the CRE boundary must be maintained toensure that the inleakage of unfiltered air in the CRE will notexceed the inleakage assumed in the licensing basis analysis of

(continued)


CREV SystemB 3.7.3

design basis accident (CBA) consequences to CRE occupants.The CRE and its boundary are defined in the Control RoomEnvelope Habitability Program.

Upon receipt of the initiation signal(s) (indicative of conditionsthat could result in radiation exposure to CRE occupants GGtr-l

.... psnn), the CREV System automatically switches tothe pressurization mode of operation to minimize-pfeveýinfiltration of contaminated air into the CRE ntFroe rFeoo. Asystem of dampers isolates the CRE GotF .lreeom. Outside airis taken in through the CREV System ventilation intake and ispassed through one of the charcoal adsorber filter subsystemsfor removal of airborne radioactive particles.

(continued)


CREV SystemB 3.7.3

BASES

BACKGROUND

(continued)

The CREV System is designed to maintain a habitableenvironment in the CRE the control roomeR.Fnmei-for a 30 day continuous occupancy after a DBAwithout exceeding 5 rem total effective dose equivalent (TEDE).A single CREV subsystem operating at a flow rate of 3000 CFM± 10 percent will pressurize the CRE Gentrav ree,4 to about0.125 inches water gauge to minimize preveRt infiltration of airfrom all surrounding areas adiacent to CRE boundary [,Abid-n

and the outdoors. CREV System operation in maintaining CREG*G.-,re r.m, habitability is discussed in the FSAR,Section 10.12 (Ref. 1).

APPLICABLESAFETY ANALYSES

The ability of the CREV System to maintain the habitabilityof the CRE ontrI rFeeom is an explicit assumption for the safetyanalyses presented in the FSAR, Chapters 10 and 14 (Refs. 2and 3, respectively). The pressurization mode of the CREVSystem is assumed to operate following a DBA loss of coolanta•ccident, mnain steam mine break, -and-control rGod d ient

(for the controm Fl rddp accident anld Main steam line break, 9n

creditis taken fr any filtratioen by the GRE, system), asdiscussed in the FSAR, Section 14.6 (Ref. 4). The analyses forradiological doses to CRE occupants control room per.on•el asa result of the various DBAs are summarized in Reference 3.No single active failure will cause the loss of filtered outside airfrom the CRE GO-MM'f ee.


The evaluation of a smoke challenge demonstrated that smokewill not result in the inability of the CRE occupants to control thereactor either from the control room or remote shutdown system(Ref 9). The assessment verified that a fire or smoke eventanywhere with the plant should not simultaneously render theremote shutdown system and the CRE uninhabitable, nor wouldit prevent access from the CRE to the remote shutdown systemin the event remote shutdown is required. No automatic CREV

(continued)

BFN-UNIT 2 B 3.7-19 Revision Q, 29January 25, 2005

CREV SystemB 3.7.3

actuation is required for hazardous chemical releases or smokeand no Surveillance Requirements are required to verifyOPERABILITY in cases of hazardous chemicals or smoke.

The CREV System satisfies Criterion 3 of the NRC PolicyStatement (Ref. 6).

(continued)


CREV SystemB 3.7.3

BASES (continued)

LCO Two redundant subsystems of the CREV System are required tobe OPERABLE to ensure that at least one is available,ass. •-" if a single active failure, such as from a loss of bothventilation subsystems or from an inoperable CRE boundary,disables the other subsystem. Total system failure could resultin exceeding a TEDE of 5 rem to the CRE occupants GGRtre4reom eperteir• in the event of a DBA.

The Each CREV subsystem y6t is considered OPERABLEwhen the individual components necessary to limit CREoccupant ""te-"peatmr exposure are OPERABLE in bothsubsystems. A subsystem is considered OPERABLE when itsassociated:

a. Fan is OPERABLE;



I• addition, the control roo..m bounda"y must be maintained,inc~luding the integrity of the walls, floors, ceilings, ductwerk, andaGGess de~frs-

In order for the CREV subsystems to be consideredOPERABLE, the CRE boundary must be maintained such thatthe CRE occupant dose from a large radioactive release doesnot exceed the calculated dose in the licensing basisconsequences analyses for DBAs. and that the CRE occupantsare protected from hazardous chemicals and smoke.


(continued)

BFN-UNIT 2 B 3.7-21 Revision G, 29,Amendment No. 283

January 25, 2005

CREV SystemB 3.7.3

The LCO is modified by a Note allowing the CRE maih•GGRt-9From boundary to be opened intermittently under administrativecontrols. This Note only applies to openings in the CREboundary that can be rapidly restored to the design condition.such as doors, hatches, floor pluas and access panels. Forentry and exit through doors the administrative control of theopening is performed by the person(s) entering or exiting thearea. For other openings, these controls should beproceduralized and consist of stationing a dedicated individualat the opening who is in continuous communication with theoperators and CRE main control room. This individual will havea method to rapidly close the opening and to restore the CREboundary to a condition equivalent to the design condition whena need for CRE main control room isolation is indicated.

(continued)

BFN-UNIT 2 B 3.7-22 Revision 0, 29Ame•ndment No. 283

January 25, 2005

CREV SystemB 3.7.3

BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, the CREV System must be OPERABLEto ensure that the CRE will remain habitable enr#eI -peratrexpesu~eduring and following a DBA, since the DBA could leadto a fission product release.

In MODES 4 and 5, the probability and consequences of a DBAare reduced because of the pressure and temperaturelimitations in these MODES. Therefore, maintaining the CREVSystem OPERABLE is not required in MODE 4 or 5, except forduring operations with potential for draining the reactor vessel(OPDRVs).

ACTIONS A.1

With one CREV subsystem inoperable, for reasons other than ininoperable CRE boundary, the inoperable CREV subsystemmust be restored to OPERABLE status within 7 days. With theunit in this condition, the remaining OPERABLE CREVsubsystem is adequate to perform the CRE occupant GGntF9troom radia protection function. However, the overallreliability is reduced because a Sihgle failure in the OPERABLEsubsystem could result in loss of the FedU•ed CREV Systemfunction a . The 7 day Completion Time is based on thelow probability of a DBA occurring during this time period, andthat the remaining subsystem can provide the requiredcapabilities.

(continued)


CREV SystemB 3.7.3

BASES

ACTIONS B.1, B.2, and B.3




During the period that the CRE boundary is consideredinoperable, action must be initiated to implement mitigatingactions to lessen the effect on CRE occupants from the potentialhazards of a radiological or chemical event or a challenge fromsmoke. Actions must be taken within 24 hours to verify that inthe event of a DBA, the mitigating actions will ensure that CREoccupant radiological exposures will not exceed the calculateddose of the licensing basis analyses of DBA consequences andthat CRE occupants are protected from hazardous chemicalsand smoke. These mitigating actions (i.e., actions that aretaken to offset the consequences of the inoperable CREboundary) should be preplanned for implementation upon entryinto the condition. regardless of whether entry is intentional orunintentional. The 24 hour Completion Time is reasonablebased on the low probability of a DBA occurring during this timeperiod, and the use of mitigating actions. The 90 day

(continued)


January 25, 2005

CREV SystemB 3.7.3

Completion Time is reasonable based on the determination thatthe mitigating actions will ensure protection of CRE occupantswithin analyzed limits while limiting the probability that CREoccupants will have to implement protective measures that mayadversely affect their ability to control the reactor and maintain itin a safe shutdown condition in the event of a DBA. In addition,the 90 day Completion Time is a reasonable time to diagnose.plan and possibly repair, and test most problems within the CREboundary.

If the main r0ntrol room boundar is inoprble in MODES 1, 2,aR , I ' i i ; t iIIIIUL aUI IUGIaI LIIUII IF ILt U II QLIU Ii;.

A~ctions mu-t be taken to restore an OPER-A.LE main contrOlroom boundary ,within "2 hours. During the period that the maincontrol rOOm bo.unday is inoperable, appropriate compensatorym:easures (Ronsis'tePntl With the intent of GDC 19) should beutilized to .prtect controlI room operator from potential haza••sSUch as.radioactie contamination, tGXic chemicals, smoke,•temperature and relative humidity, and physical security.Prepla.ed. measures should be available to.adre theseconcern. -for intentional and unintentional entry into theconditior. The 24 hur COmPletion Time is reasonable basedOn the loW probability f a DBA occu-'rr'ng du.rig this time perida•nd the use Of compensatory m .easures. The 21 hourG er pletieR T im e nG a tynpi,-• lh, reas-• abl-el wern al-e ..... ,

plan and possibly repair, and test most problem- s with the mminconrol1 room boundar.9p

C.1 and C.2

In MODE 1, 2, or 3, if the inoperable CREV subsystem or theCRE ronntroI r-,,m boundary cannot be restored to OPERABLEstatus within the reguired assGGoated Completion Time, the unitmust be placed in a MODE that minimizes accident risk. Toachieve this status, the unit must be placed in at least MODE 3within 12 hours and in MODE 4 within 36 hours. The allowedCompletion Times are reasonable, based on operatingexperience, to reach the required unit conditions from full powerconditions in an orderly manner and without challenging unitsystems.

(continued)

BFN-UNIT 2 B 3.7-25 Revision 0, 29Amend•mpnt ho. 283

January 25, 2005

CREV SystemB 3.7.3

BASES

ACTIONS(continued)

D.1 and D.2



(continued)


January 25, 2005

CREV SystemB 3.7.3

BASES

ACTIONS(continued)

E.1

If both CREV subsystems are inoperable in MODE 1, 2, or 3 forreasons other than an inoperable CRE control room boundar.(i.e., Condition B), the CREV System may not be capable ofperforming the intended function and the unit is in a conditionoutside the accident analyses. Therefore, LCO 3.0.3 must beentered immediately.

F. 1

During OPDRVs, with two CREV subsystems inoperable or withone or more CREV subsystems inoperable due to an inoperableCRE boundary, actions must be initiated immediately tosuspend OPDVRs to minimize the probability of a vesseldraindown and subsequent potential for fission product release.Actions must continue until the OPDRVs are suspended.

(contfinued)

BFN-UNIT 2 B 3.7-27 Revision 0, 29Am~endrment No. 283

January 25, 2005

CREV SystemB 3.7.3

BASES (continued)



SR 3.7.3.2

This SR verifies that the required CREV testing is performed inaccordance with the Ventilation Filter Testing Program (VFTP).The VFTP includes testing HEPA filter performance, charcoaladsorber efficiency, minimum system flow rate, and the physicalproperties of the activated charcoal (general use and followingspecific operations). Specific test frequencies and additionalinformation are discussed in detail in the VFTP.

(continued)


CREV SystemB 3.7.3

BASES


(continued) This SR verifies that on an actual or simulated initiation signal,each CREV subsystem starts and operates. This SR includesverification that dampers necessary for proper CREV operationfunction as required. The LOGIC SYSTEM FUNCTIONALTEST in SR 3.3.7.1.4 and SR 3.3.7.1.6 overlaps this SR toprovide complete testing of the safety function. The frequencyof 24 months is based on BFN's normal operating time.

SR 3.7.3.4


The CRE is considered habitable when the radiological dose toCRE occupants calculated in the licensing basis analyses ofDBA consequences is no more that 5 rem TEDE and the CREoccupants are protected from hazardous chemicals and smoke.There is no automatic CREV actuation for hazardous chemicalreleases or smoke and there are no Surveillance Requirementsto verify the OPERABILITY in cases of hazardous chemicals orsmoke. This SR verifies that the unfiltered air inleakage into theCRE is no areater than the flow rate assumed in the licensingbasis analysis of DBA consequences. When unfiltered airinleakage is greater than the assumed flow rate. Condition Bmust be entered. Required Action B.3 allows time to restore theCRE boundary to OPERABLE status provided mitigating actionscan ensure that the CRE remains within the licensing basishabitability limits for occupants following an accident.Compensatory measures are discussed in Regulatory Guide,1.196, Section C.2.7.3, (Ref. 6) which endorses, withexceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 7).These compensatory measures may also be used as mitigatingactions as required by Required Action B.2. Temporaryanalytical methods may also be used as compensatorvmeasures to restore OPERABILITY (Ref. 8). Options forrestoring the CRE boundary to OPERABLE status include

(continued)

BFN-UNIT 2 B 3.7-29 Amendment 255November 30, 1998

CREV SystemB 3.7.3


(continueL)-

BFN-UNIT 2 B 3.7-30 Amendment 255November 30, 1998

CREV SystemB 3.7.3

T-his SR verifies the integrity of the control room enclosure andthe asumed iloakage rates of potentially ntaminated aiThe control room positie pra.r, with respecot to- out-doors isperiod ically tested tovrfIpoe function) of the CREV~ System.During the emergec- md of operation, the CRE=V System is6designed to slightly pressurize the cntrmIl room Ž 0.125 incheswater gauge porsitive pressure with respect to the outdoors toprevent unfiltereFPd inleakage. The CREV. System is designed to

maritain this positive pessue at a flow Fate of Ž 27-00 ,f+ ;and•"3300 cfm to the control room in the pressurization mode. The

....... 9 n) -r A -f 7Mr7AIF=FeqUeRGY Q-1 - MG H6UILIt ORI a S ~xL IL

con~sistent WitnM iar'practice ana otner nitation systemsSR6-.





5. NRC No. 93-102, "Final Policy Statement on TechnicalSpecification Improvements," July 23, 1993.

6. NRC Regulatory Guide 1.196, "Control Room Habitability AtLight-Water Power Reactors". January 2007.

7. NEI 99-03, "Control Room Habitability Assessment," June2001.

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEl)dated January 30. 2004. "NEI Draft White Paper, Use ofGeneric Letter 91-18 Process and Alternative Source Termsin the Context of Control Room Habitability." (ADAMSAccession No. ML040300694)

9. FSAR, Chapter 10.12.5.3, Toxic Gas Protection

(continued)


CREV SystemB 3.7.3

B 3.7 PLANT SYSTEMS


BASES

BACKGROUND The CREV System provides a protected environment fromwhich occupants cab control the unit following an uncontrolledrelease of radioactivity ralogicaRlly controlled en..iro.....fromn w.hicrh. the uit can be safely operated following a DesignBasis Accident (DBA).

The safety related function of the CREV System includes twoindependent and redundant high efficiency air filtrationsubsystems for emergency treatment of outside supply air and aCRE boundary that limits the inleakage of unfiltered air. TheCREV Ssystem has a high efficiency particulate air (HEPA) filterbank in the portion of the inlet piping common to bothsubsystems. Each CREV subsystem consists of a motor-drivenfan, an electric duct air heater, an activated charcoal adsorbersection, an electric charcoal heater, and the associatedductwork, valves or end dampers, doors, barriers, andinstrumentation. The HEPA filter bank removes particulatematter, which may be radioactive. The charcoal adsorbersprovide a holdup period for gaseous iodine, allowing time fordecay; however, no credit is taken in the analyses for thecharcoal adsorbers.

The CRE is the area within the confines of the CRE boundarythat contains the spaces that control room occupants inhabit tocontrol the unit during normal and accident conditions. Thisarea encompasses the control room, and may encompass othernon-critical areas to which frequent personnel access orcontinuous occupancy is not necessary in the event of anaccident. The CRE is protected during normal operation,natural event and accident conditions. The CRE boundary isthe combination of walls, floor, roof, ducting, doors, penetrationsand equipment that physically form the CRE. TheOPERABILITY of the CRE boundary must be maintained toensure that the inleakage of unfiltered air into the CRE will notexceed the inleakage assumed in the licensing basis analysis ofdesign basis accident (DBA) consequences to CRE occupants.

(continued)


CREV SystemB 3.7.3

The CRE and its boundary are defined in the Control RoomEnvelope Habitability Program.

Upon receipt of the initiation signal(s) (indicative of conditionsthat could result in radiation exposure to CRE occupants centret,G.M-Pe.SO.eI), the CREV System automatically switches tothe pressurization mode of operation to minimize pie~entinfiltration of contaminated air into the CRE nnmtrc I-n-rm,-. Asystem of dampers isolates the CRE -entre- reo-.m Outside air istaken in through the CREV System ventilation intake and ispassed through one of the charcoal adsorber filter subsystemsfor removal of airborne radioactive particles.

(continued)


CREV SystemB 3.7.3

BASES

BACKGROUND(continued)

The CREV System is designed to maintain the corntrol roomeFenmffent a habitable environment in the CRE for a 30 daycontinuous occupancy after a DBA without exceeding 5 remtotal effective dose equivalent (TEDE). A single CREVsubsystem operating at a flow rate of 3000 cfm ± 10 percent willpressurize the CRE centrel roee to about 0.125 inches watergauge to minimize pFeveRt infiltration of air from all surroundingareas adjacent to CRE boundary,,,,,,,•r, and the outdoors.CREV System operation in maintaining CRE coiGr# oFomhabitability is discussed in the FSAR, Section 10.12 (Ref. 1).

APPLICABLE The ability of the CREV System to maintain the habitabilitySAFETY ANALYSES of the CRE GcntGI- reoom is an explicit assumption for the safety

analyses presented in the FSAR, Chapters 10 and 14 (Refs. 2and 3, respectively). The pressurization mode of the CREVSystem is assumed to operate following DBA, loss of coolant

acident, mnain steam line break, and controlrodopacen(for the conrol1 rod drop accident and- main steam line br~eak, nocnredit i3 taken for any filtration by the GRE" system),asdiscussed in the FSAR, Section 14.6 (Ref. 4). The analyses forradiological doses to CRE occupants as a result of the variousDBAs are summarized in Reference 3. No single active failurewill cause the loss of filtered outside air from the CRE GGR#9e

F-GGM.


The evaluation of a smoke challenge demonstrated that smokewill not result in the inability of the CRE occupants to control thereactor either from the control room or remote shutdown system(Ref 9). The assessment verified that a fire or smoke eventanywhere with the plant should not simultaneously render theremote shutdown system and the CRE uninhabitable, nor wouldit prevent access from the CRE to the remote shutdown systemin the event remote shutdown is required. No automatic CREVactuation is required for hazardous chemical releases or smoke

(continued)


CREV SystemB 3.7.3

and no Surveillance Requirements are required to verifyOPERABILITY in cases of hazardous chemicals or smoke.The CREV System satisfies Criterion 3 of the NRC PolicyStatement (Ref. 6).

(continued)

BFN-UNIT 3 B 3.7-20 Revision Q, 29January 25, 2005

CREV SystemB 3.7.3

BASES (continued)

LCO Two redundant subsystems of the CREV System are required tobe OPERABLE to ensure that at least one is available,assumn if a single active failure, such as from a loss of bothventilation subsystems or form an inoperable CRE boundary.disables the other subsystem. Total system failure could resultin exceeding a TEDE of 5 rem to the CRE occupants GGR*Gt.. .. +'-'-r in the event of a DBA.

The Each CREV-System subsystem is Considered OPERABLEwhen the individual components necessary to limit CREoccuDant ,Gn+,. vpefate -exposure are OPERABLE i-bet-hSubSyste•e. A subsystem is considered OPERABLE when itsassociated:

a. Fan is OPERABLE;



In addition, the control room bou-nday must be maintainedincluding the integrity 'of the walls,, flomor, Gcelings, ducerk, andaccess doors6.

In order for the CREV subsystems to be consideredOPERABLE, the CRE boundary must be maintained such thatthe CRE occurpant dose from a larae radioactive release doesnot exceed the calculated dose in the licensing basisconsequences analyses for DBAs, and that the CRE occupantsare protected from hazardous chemicals and smoke.


(continued)

BFN-UNIT 3 B 3.7-21 Revision 0, 29Amed•ment No. 21

January 25, 2005

CREV SystemB 3.7.3

The LCO is modified by a Note allowing the CRE main e~riFrom boundary to be opened intermittently under administrativecontrols. This note only applies to openings in the CREboundary that can be rapidly restored to the design conditionsuch as doors, hatches, floor plugs, and access panels. Forentry and exit through doors the administrative control of theopening is performed by the person(s) entering or exiting thearea. For other openings, these controls should beproceduralized and consist of stationing a dedicated individualat the opening and to restore the CRE boundary who is incontinuous communication with the operators in the CRE. Thisindividual will have a method to rapidly close the opening and torestore the CRE boundary to a condition equivalent to thedesign condition when a need for CRE m-ain control roomisolation is indicated.

(continued)

BFN-UNIT 3 B 3.7-22 Revision Q, 29Amendment No. 2I11

January 25, 2005

CREV SystemB 3.7.3

BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, the CREV System must be OPERABLEto ensure that the CRE will remain habitable ,G,,GI-,p ...expesuie during and following a DBA, since the DBA could leadto a fission product release.

In MODES 4 and 5, the probability and consequences of a DBAare reduced because of the pressure and temperaturelimitations in these MODES. Therefore, maintaining the CREVSystem OPERABLE is not required in MODE 4 or 5, except forduring operations with potential for draining the reactor vessel(OPDRVs).

ACTIONS A.1

With one CREV subsystem inoperable, for reasons other thanan inoperable CRE boundary, the inoperable CREV subsystemmust be restored to OPERABLE status within 7 days. With theunit in this condition, the remaining OPERABLE CREVsubsystem is adequate to perform the CRE occupant 144rGoGm iatin protection function. However, the overallreliability is reduced because a sigle failure in the OPERABLEsubsystem could result in a loss of the redUGed CREV Systemfunction-Gapablity. The 7 day Completion Time is based on thelow probability of a DBA occurring during this time period, andthat the remaining subsystem can provide the requiredcapabilities.

(continued)


CREV SystemB 3.7.3

BASES

ACTIONS B.1, B.2 and B.3(continued)




During the period that the CRE boundary is consideredinoperable, action must be initiated to implement mitigatingactions to lessen the effect on CRE occupants from the potentialhazards of a radiological or chemical event or a challenge fromsmoke. Actions must be taken within 24 hours to verify that inthe event of a DBA. the mitigating actions will ensure that CREoccupant radiological exposures will not exceed the calculateddose of the licensing basis analyses of DBA consequences andthat CRE occupants are protected from hazardous chemicalsand smoke. These mitigating actions (i.e., actions that aretaken to offset the consequences of the inoperable CREboundary) should be preplanned for implementation upon entryinto the condition, regardless of whether entry is intentional orunintentional. The 24 hour Completion Time is reasonablebased on the low probability of a DBA occurring during this timeperiod, and the use of mitigating actions. The 90 dayCompletion Time is reasonable based on the determination that

(continued)

BFN-UNIT 3 B 3.7-24 Revision Q, 29AmenRdment No. 211-

January 25, 2005

CREV SystemB 3.7.3

the mitigating actions will ensure protection of CRE occupantswithin analyzed limits while limiting the probability that CREoccupants will have to implement protective measures that mayadversely affect their ability to control the reactor and maintain itin a safe shutdown condition in the event of a DBA. In addition,the 90 day Completion Time is a reasonable time to diagnose.plan and possibly repair, and test most problems within the CREboundary.if the maiR control room boundary MODES 1, 2,and 3, the GREV trains, cannot perfor~m theirF intended functions.Actio u.s.... + urgt be taken t•o erestore an . + . ER-A-BLE main controlroom boundary WAithin 21 hours. DuFrig the period that the mnaincontrol roo boundary is 1in rble, appropriate mOMpensatomeasures (consistent With the intent of GIDC 19) should beutilized to protect control room operator•s fromr potential hazardssuch as radioactiVe contamination, toxic chemicals, smoke,temperature and relative humidity, and physical security.Preplanned measures shoul-id be available to address thsoRnce•rn for intentiroal aRd unintentional entny in•o theonndtion. Th• :24 hnou Completion Time is reasonable based

on the low probability of a DBA occurring duFrig this time period,anmd thme u Of compensato' measures. The m21 houvvmupmemvl R Timev is a tuypvvmirsal •llly ,esva l time vm~m te-dign •

plan and possibly repair, and test mot pmrblems with the maincontrol room boundar9,.

C.1 and C.2

In MODE 1, 2, or 3, if the inoperable CREV subsystem or theCRE control room boundar.y cannot be restored to OPERABLEstatus within the reguired asseGiated Completion Time, the unitmust be placed in a MODE that minimizes accident risk. Toachieve this status, the unit must be placed in at least MODE 3within 12 hours and in MODE 4 within 36 hours. The allowedCompletion Times are reasonable, based on operatingexperience, to reach the required unit conditions from full powerconditions in an orderly manner and without challenging unitsystems.

(continued)

BFN-UNIT 3 B 3.7-25 Revision Q, 29Amendment No. 2115

January 25, 2005

CREV SystemB 3.7.3

BASES

ACTIONS(continued)

D.1 and D.2



(continued)

BFN-UNIT 3 B 3.7-26 Revision QO, 29Amendmert hi. 241

January 25, 2005

CREV SystemB 3.7.3

BASES

ACTIONS(continued)

E.1

If both CREV subsystems are inoperable in MODE 1, 2, or 3 forreasons other than an inoperable CRE control room bounda. y(i.e., Condition B), the CREV System may not be capable ofperforming the intended function and the unit is in a conditionoutside the accident analyses. Therefore, LCO 3.0.3 must beentered immediately.

F.1

During OPDRVs, with two CREV subsystems inoperable or withione or more CREV subsystems inoperable due to an inoperableCRE boundary, actions must be initiated immediately tosuspend OPDVRs to minimize the probability of a vesseldraindown and subsequent potential for fission product release.Actions must continue until the OPDRVs are suspended.

(continued)

BFN-UNIT 3 B 3.7-27 Revision 0, 29AmendmeRnt No. 241

January 25, 2005

CREV SystemB 3.7.3

BASES (continued)



SR 3.7.3.2

This SR verifies that the required CREV testing is performed inaccordance with the Ventilation Filter Testing Program (VFTP).The VFTP includes testing HEPA filter performance, charcoaladsorber efficiency, minimum system flow rate, and the physicalproperties of the activated charcoal (general use and followingspecific operations). Specific test frequencies and additionalinformation are discussed in detail in the VFTP.

(continued)


CREV SystemB 3.7.3

BASES

SURVEILLANCE SIR 3.7.3.3REQUIREMENTS

(continued) This SR verifies that on an actual or simulated initiation signal,each CREV subsystem starts and operates. This SR includesverification that dampers necessary for proper CREV operationfunction as required. The LOGIC SYSTEM FUNCTIONALTEST in SR 3.3.7.1.4 and SR 3.3.7.1.6 overlaps this SR toprovide complete testing of the safety function. The frequencyof 24 months is based on BFN's normal operating cycle.

SR 3.7.3.4


The CRE is considered habitable when the radiological dose toCRE occupants calculated in the licensing basis analyses ofDBA consequences is no more that 5 rem TEDE and the CREoccupants are protected from hazardous chemicals and smoke.There is no automatic CREV actuation for hazardous chemicalreleases or smoke and there are no Surveillance Reguirementsto verify the OPERABILITY in cases of hazardous chemicals orsmoke. This SR verifies that the unfiltered air inleakage into theCRE is no greater than the flow rate assumed in the licensingbasis analysis of DBA consequences. When unfiltered airinleakage is greater than the assumed flow rate, Condition Bmust be entered. Required Action B.3 allows time to restore theCRE boundary to OPERABLE status provided mitigating actionscan ensure that the CRE remains within the licensing basishabitability limits for occupants following an accident.Compensatory measures are discussed in Reaulatory Guide1.196, Section C.2.7.3, (Ref. 6) which endorses, withexceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 7).These compensatory measures may also be used as mitigatingactions as required by Required Action B.2. Temporaryanalytical methods may also be used as compensatorymeasures to restore OPERABILITY (Ref. 8). Options forrestoring the CRE boundary to OPERABLE status include

(continued)


CREV SystemB 3.7.3


(continued)


CREV System3.7.3

BASES

SURVEILLANCE

SURVEILLANCEREQUIREMENTS

(continued)

SR 3.7.3.4

Depending upon the nature of the problem and thecorrective action, a full scope inleakage test may not benecessary to establish that the CRE boundary has beenrestored to OPERABLE status.

This SDR .erifies the integrity of the con. ÷trol room enclosurean the• ass me iie kg Fatesnv Ofn nnpvuu.•emuntI QU am| v

cntaminRated air. The control room positive pressure,ithrespec.t to outdoor is periodically tested to werify properfuncfTiorn oaf t ihe- GRE'.' System. Duing the em ergencY mod•of operation, the GREV System is designed to slightlypmressuize the c-ontroGlm room Ž 0.125 inches water gaugepositive pessuire wIth respect to the outdoors to preventunfiltered , The GRE" System is designed tomaintaain this porsitive pressure at a flow rate of -> 22700- cfmand !• 33900 c-fm to the control room in the pressuri-zation-1moede. The FrFequency of 24 monOths, on a'STAGGEREDTFEST BRASIS iscnitn vihids practiceA and- otherfiltration systems SRs.f





5. NRC No. 93-102, "Final Policy Statement on TechnicalSpecification Improvements," July 23, 1993.

(continued)

BFN-UNIT 3 3.7-31 Revision G, 29January 25, 2005

CREV System3.7.3

6. NRC Regulatory Guide 1.196, "Control RoomHabitability At Light-Water Power Reactors". January2007.

(continued)

BFN-UNIT 3 3.7-32 Revision G, 29January 25, 2005

CREV System3.7.3

BASES

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

8. 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 AlternativeSource Terms in the Context of Control RoomHabitability." (ADAMS Accession No. ML040300694)

9. FSAR, Chapter 10.12.5.3. Toxic Gas Protection

(continued)

BFN-UNIT 3 3.7-33 Revision 0, 29January 25, 2005

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