ML071870252

Project, Units 1 and 2, License Amendment Request - Proposed Revision to Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

ML071870252
Person / Time
Site:	South Texas
Issue date:	06/26/2007
From:	Bowman C T South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-07002165, STI: 32161114, TAC MB9859, TSTF-448, Rev 3
Download: ML071870252 (24)

Text

Nuclear Operating Company South Trs Pro/ect Electric Generatin$

Station PO. Box 289 Wadsworth, Texas 77483 -June 26, 2007 NOC-AE-07002165 10CFR50.90 U. S. Nuclear Regulatory Commission Attention:

Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 License Amendment Request Proposed Revision to Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

References:

1) Federal Register Notice, Volume 72, Pages 2022-2033, Technical Specification Improvement To Modify Requirements Regarding Control Room Envelope Habitability Using the Consolidated Line Item Improvement Process, dated January 17, 2007.2) Letter from D. W. Rencurrel, STP Nuclear Operating Company, to the NRC Document Control Desk, dated March 22, 2007 (NOC-AE-07002127)

3) Letter from T. J. Jordan, STP Nuclear Operating Company, to the NRC Document Control Desk, dated December 9, 2003 (NOC-AE-03001635) (TAC NO. MB9859)4) Letter from S. M. Head, STP Nuclear Operating Company, to the NRC Document Control Desk, dated March 21, 2007 (NOC-AE-07002135) (TAC No..MB9859)In accordance with the provisions of 10 CFR 50.90, STP Nuclear Operating Company (STPNOC) is submitting a request for an amendment to the Technical Specifications (TS) South Texas Project Operating Licenses NPF-76 and NPF-80.The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3.STI: 32161114 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway -Comanche Peak -Diablo Canyon -Palo Verde -South Texas Project -Wolf Creek NOC-AE-07002165 Page 2 of 3 Attachment I provides a description of the proposed change, the requested confirmation of applicability, and plant specific verifications.

Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides the existing TS Bases pages marked up to show the proposed change and is for information only.By a separate action, STPNOC submitted a licensing amendment request (Reference

2) to the NRC to adopt the Alternate Source Term (AST). The acceptance criterion for the control room inleakage surveillance proposed by this TSTF 448 licensing amendment request is that established by the AST accident analyses.

Therefore, this TSTF 448 licensing amendment must be implemented after approval and implementation of the AST amendment request. STPNOC requested approval of the AST licensing amendment request by March 30, 2008 with an implementation period of 120 days to follow approval.Once this TSTF 448 licensing amendment request is approved, the amendment shall be implemented within 60 days but no earlier than 60 days following implementation of the AST amendment.

In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this request for license amendment by providing a copy of this letter and its attachments.

In response to NRC Generic Letter 2003-01, submittal of this licensing amendment request fulfills the STPNOC commitment made in Reference 3, and revised by Reference 4, to submit a Technical Specification revision to include periodic verification of control room inleakage.

There are no additional regulatory commitments made in this licensing amendment request.The STPNOC Plant Operations Review Committee has reviewed and concurred with the proposed change to the Technical Specifications.

If there are any questions regarding the proposed amendment, please contact Mr. Scott Head at (361) 972-7136 or me at (361) 972-7454.I declare under penalty of perjury that the foregoing is true and correct.Executed on c0/o2 oa7 date Charles T. Bowman General Manager, Oversight tck/Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)3. Proposed Technical Specification Bases Changes (Mark-Up)

NOC-AE-07002165 Page 3 of 3 cc: (paper copy)(electronic copy)Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mohan C. Thadani Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 7 Dl)11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189 A. H. Gutterman, Esquire Morgan, Lewis & Bockius LLP Mohan C. Thadani U. S. Nuclear Regulatory Commission Thad Hill Eddy Daniels Marty Ryan Harry Holloway Steve Winn NRG South Texas LP Ed Alarcon J. J. Nesrsta R. K. Temple Kevin Pollo City Public Service Jon C. Wood Cox Smith Matthews C. Kirksey City of Austin NOC-AE-07002165 Attachment 1 ATTACHMENT 1 DESCRIPTION AND ASSESSMENT NOC-AE-07002165 Attachment 1 Page 1 of 5 1.0 Description The proposed amendment would modify Technical Specification (TS) requirements related to control room. envelope habitability in TS 3.7.7, Control Room Makeup and Cleanup Filtration System (CRMCFS) and TS Section 6.8, "Administrative Controls-Procedures, Programs, and Manuals".The changes are consistent with Nuclear Regulatory Commission (NRC) noticed Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-448 Revision 3. The availability of this TS improvement was published in the Federal Register on January 17, 2007 as part of the consolidated line item improvement process (CLIIP).2.0 Assessment

2.1 Applicability

of Published Safety Evaluation STP Nuclear Operating Company (STPNOC) has reviewed the safety evaluation, specifically evaluation 6-for facilities that have a Control Room Envelope (CRE)pressurization surveillance requirement, dated January 9, 2007, as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-448.

STPNOC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to the South Texas Project (STP) Units 1 & 2, and justifies this amendment for the incorporation of the changes to the STP TS's.2.2 Optional Changes and Variations STPNOC is not proposing any variations or deviations from the TS changes described in the TSTF-448, Revision 3, or the NRC staff's model safety evaluation dated January 9, 2007, except as noted below.STPNOC proposes to reference NEI 99-03, Revision 0, dated June 2001, in the TS bases for TS 3.7.7, instead of Revision 1, dated March 2003, because the NRC has not formally endorsed Revision 1.In the Background of TS Bases 3.7.7, the discussion of actuation of the CRMCFS is clarified by inserting the following, "There is no automatic actuation of the CRMCFS system for hazardous chemical or smoke. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release. 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." This clarification represents the current plant specific design. In the future, if the STP design or environment change, new Action d. of TS 3.7.7 NOC-AE-07002165 Attachment 1 Page 2 of 5 addresses hazardous chemicals and smoke to assure that appropriate mitigating actions and / or design feature(s) are considered.

In the Applicable Safety Analyses of TS Bases 3.7.7, the discussion of hazardous chemical releases and smoke challenges is clarified by inserting the following, "The CRMCFS provides protection from smoke and hazardous chemicals to the CRE occupants.

The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release. 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. Based on this, the STPNOC has determined no CRMCFS actuation is required for hazardous chemical releases or smoke and no Surveillance Requirements are required to verify operability for hazardous chemical or smoke." This clarification represents the current plant specific design. In the future, if the STP design or environment change, new Action d. of TS 3.7.7 addresses hazardous chemicals and smoke to assure that appropriate mitigating actions and / or design feature(s) are considered.

In Surveillance Requirement SR 4.7.7.e.3 of TS Bases 3.7.7, the discussion of hazardous chemical releases and smoke challenges is clarified by inserting the following, "There is no CRMCFS actuation for hazardous chemical releases or smoke and there are no surveillance requirements that verify operability for hazardous chemical or smoke.The hazardous chemical analyses for the STP do not assume any control room isolation and assumes air enters at normal makeup ventilation flow rates. No in-leakage test is required to determine unfiltered in-leakage from hazardous chemical since this would be a value much less than that currently assumed in the hazardous chemical analyses.

There is no regulatory limit on the amount of smoke allowed in the control room. The plant's ability to manage smoke infiltration was assessed qualitatively.

The conclusion is that the operator maintains the ability to safely shutdown the plant during a smoke event originating inside or outside the control room. Therefore, no in-leakage test is required to be conducted to measure the amount of smoke that could infiltrate into the control room." This clarification represents the current plant specific design. In the future, if the STP design or environment change, new Action d. of TS 3.7.7 addresses hazardous chemicals and smoke to assure that appropriate mitigating actions and / or design feature(s) are considered.

STP is adopting the 18 month scheduling allowance of SR 3.0.2 for performing the CRE unfiltered inleakage determination surveillance as stated in the corrected model licensing amendment request published by the NRC in a Memorandum on February 2, 2007.In addition due to the STP being a Custom Technical Specification plant, there were differences in TS numbering and in the TS Bases references.

NOC-AE-07002165 Attachment 1 Page 3 of 5 These differences are administrative in nature and do not have any safety significance.

TS 6.8.3.p.3 identifies the following exceptions to Sections C. 1 and C.2 of Regulatory Guide 1.197, Revision 0: 1. C. -Section 4.3.2, "Periodic CRH Assessment" from NEI 99-03 Revision 1 will be used as input to a site specific Self Assessment procedure.

Justification:

Appendix H of NEI 99-03 Revision 0 is specifically written to support the initial assessment.

Section 4.3.2 "Periodic CRH Assessment" of NEI 99-03 Revision 1 is specifically written to support the periodic assessments required by Figure 1 of Regulatory Guide 1.197.2. C. 1.2 -No peer reviews are required to be performed.

Justification:

Vulnerabilities were identified in STP's self-assessment conducted April 10-13, 2000. Three offsite peers were involved in the assessment.

Corrective actions (plant modifications) were completed prior to the successful ASTM E741 Tracer Tests conducted in March 2004 for Unit 1 and February 2007 for Unit 2. Maintenance level of effort is appropriate for the Control Room Envelope Habitability Program.2.2 Licensing Condition Regarding Initial Performance of New Surveillance and Assessment Requirements STPNOC proposes the following as a license condition to support implementation of the proposed TS changes: Upon implementation of this License Amendment Request adopting TSTF-448, Revision 3, the determination of CRE unfiltered air inleakage as required by SR 4.7.7.e.3, in accordance with TS 6.8.3.p.3.(i), the assessment of CRE habitability as required by Specification 6.8.3.p.3.(ii), and the measurement of CRE pressure as required by Specification 6.8.3.p.4, shall be considered met. Following implementation: (a) For Unit 1, the first performance of SR 4.7.7.e.3, in accordance with Specification 6.8.3.p.3.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 9, 2004, the date of the most recent successful tracer gas test, as stated in the letter from T.J. Jordan, STP Nuclear Operating Company, to the NRC Document Control Desk, dated August 5, 2004 (NOC-AE-04001758), response to Generic Letter 2003-01, or within the next 18 months if the time NOC-AE-07002165 Attachment 1 Page 4 of 5 period since the most recent successful tracer gas test is greater than 6 years.For Unit 2, the first performance of SR 4.7.7.e.3, in accordance with Specification 6.8.3.p.3.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from February 12, 2007, the date of the most recent successful tracer gas test, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.(b) For Unit 1, the first performance of the periodic assessment of CRE habitability, Specification 6.8.3.p.3.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 9, 2004, the date of the most recent successful tracer gas test, as stated in the letter from T.J. Jordan, STP Nuclear Operating Company, to the NRC Document Control Desk, dated August 5, 2004 (NOC-AE-04001758), response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.For Unit 2, the first performance of the periodic assessment of CRE habitability, Specification 6.8.3.p.3.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from February 12, 2007, the date of the most recent successful tracer gas test, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.(c) For Unit 1, the first performance of the periodic measurement of CRE pressure, Specification 6.8.3.p.4 , shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from April 30, 2007, the date. of the most recent successful pressure measurement test.For Unit 2, the first performance of the periodic measurement of CRE pressure, Specification 6.8.3.p.4, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from February 16, 2007, the date of the most recent successful pressure measurement test.3.0 Regulatory Analysis 3.1 No Significant Hazards Determination STPNOC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

NOC-AE-07002165 Attachment 1 Page 5 of 5 STPNOC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to STP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).3.2 Commitments STPNOC is making no formal commitments that would derive from NRC approval of the proposed amendment.

4.0 Environmental

Evaluation STPNOC has reviewed the environmental evaluation included in the model safety evaluation dated January 9, 2007, as part of the CLIIP. STPNOC has concluded that the staff's findings presented in that evaluation are applicable to STP Units 1 & 2, and the evaluation is hereby incorporated by reference for this application.

NOC-AE-07002165 Attachment 2 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (Mark-up)

NOC-AE-07002165 Attachment 2 Page 1 of 5 PLANT SYSTEMS 3/4.7.7 CONTROL ROOM MAKEUP AND CLEANUP FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.7 Three independent Control Room Makeup and Cleanup Filtration Systems shall be OPERABLE.APPLICABILITY:

All MODES.ACTION: MODES 1, 2, 3, and 4: a. With one Control Room Makeup and Cleanup Filtration System inoperable for reasons other than condition d, 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 Control Room Makeup and Cleanup Filtration Systems inoperable for reasons other than condition d, restore at least two systems to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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. With three Control Room Makeup and Cleanup Filtration Systems inoperable tfor reasons other than condition d,, suspend all operations involving movement of spent fuel, and crane operation with loads over the spent fuel pool, and restore at least one system to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 />.d. One or more Control Room Makeup and Cleanup Filtration Systems inoperable dtue to inoperable Control Room Envelope (CRE) boundary perform the following:

1)1 immediate-ly initiate action to- implement mitigating actions, and 2) 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~exposures to radiological, chemical and smoke hazards will not exceed limits, and 3) within 90 days restore CRE boundary to OPERABLE status.MODES 5 and 6: a. With one Control Room Makeup and Cleanup Filtration System inoperable for reasorns other than condition c, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE Control Room Makeup and Cleanup Filtration Systems in the recirculation and makeup air filtration mode, or suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, movement of spent fuel, and crane operation with loads over the spent fuel pool.b. With more than one Control Room Makeup and Cleanup Filtration System inoperable for reasons other than condition c, or with the OPERABLE Control Room Makeup and Cleanup Filtration Systems required to be in the recirculation and makeup air filtration mode by ACTION a. not capable of being powered by an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, movement of spent fuel, and crane operations with loads over the spent fuel pool.SOUTH TEXAS -UNITS 1 & 2 3/4 7-16 Unit 1 -Amendment No. 1-2-7 Unit 2 -Amendment No. 4 NOC-AE-07002165 Attachment 2 Page 2 of 5 PLANT SYSTEMS MODES 5 and 6: '(Continued)

c. One or more controi Rooi6m Make'up and ClealnuppFiltrati0n Inoperable due to inoperable CRE boundary, or during movement of irradiated fuel assemblies, suspend all operations involving CORE ALTERATIONS, "movement of spent fuel, and crane operations with loads over thie spent fuel pool.SURVEILLANCE REQUIREMENTS 4.7.7 Each Control Room Makeup and Cleanup Filtration System shall be demonstrated OPERABLE: a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is less than or equal to 78)F;b. At least once per 92 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers of the makeup and cleanup air filter units and verifying that the system operates for at least 10 continuous hours with the makeup filter unit heaters operating;

c. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by: 1) Verifying that the makeup and cleanup systems satisfy the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% for HEPA filter banks and 0.10% for charcoal adsorber banks 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 system flow rate is 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/- 10%for the makeup units;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, meets~the laboratory testing criteria of ASTM D3803-1989, "Standard Test Method for Nuclear-Grade Activated Carbon," for a methyl iodide penetration of less than 1.0% when tested at a temperature of 30'C and a relative humidity of 70%; and 3) Verifying a system flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm +10% for the makeup units during system operation when tested in accordance with ANSI N510-1980.

d. 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, meets the laboratory testing criteria of ASTM D3803-1989 for a methyl iodide penetration of less than 1.0% when tested at a temperature of 30'C and a relative humidity of 70%.SOUTH TEXAS -UNITS 1 & 2 3/4 7-17 Unit 1 -Amendment No. 4-2-7 Unit 2 -Amendment No. 446 NOC-AE-07002165 Attachment 2 Page 3 of 5 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

e. At least once per 18 months by: 1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks isless than 6.1 inches Water Gauge for the makeup units and 6.0 inches Water Gauge for the cleanup units while operating the system at a flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/- 10% for the makeup units.2) Verifying that on a control room emergency ventilation test signal (High Radiation and/or Safety Injection test signal), the system automatically switches into a recirculation and makeup air filtration mode of operation with flow through the HEPA filters and charcoal adsorber banks of the cleanup and makeup units;3) Verifying that the systemn maintains the conetroll roo~m envelope at a positive pre~ssu1re of greater than or equal to 1 j8 incr-h WNater Gauge at loss than or equal toý A pressuri za;tion flow of :200 cfmA rolative to adjacont areas duyring sytem epeicatiOnR Perform required CRE unfiltered, air inleakagetest in ac orancewith the Control Room Envelope Habitability Program; and 4) Verifying that the makeup filter unit heaters dissipate 4.5 + 0.45 kW when tested in accordance with ANSI N510-1980.

f. After each complete or partial replacement of a HEPA filter bank, by verifying that the HEPA filter bank 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 6000 cfm +/- 10% for the cleanup units and 1000 cfm +10% for the makeup units; and g. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the charcoal adsorber bank satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than0.10%

in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/-10% for the makeup units.1}4 Measured feints at a nesitive nressuro but less Than 1/8 nob Water ~aueo are accentable it an evalulation, considering approqpriate compensatory action, demons1trates that thE cnedition meet the requirements-of GDC 19. The proviscione6 of this- noeW expire at 0800 On September 19, 2005 SOUTH TEXAS -UNITS 1 & 2 3/4 7-18 Unit 1 -Amendment No. 1-2-7 Unit 2 -Amendment No. 4-146 NOC-AE-07002165 Attachment 2 Page 4 of 5 6.0 ADMINISTRATIVE CONTROLS 6.8 Procedures, Programs, and Manuals 6.8.3.o. (continued)

3. If crack indications are found in any SG tube, then the next inspection for each SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever is less). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.e. Provisions for monitoring operational primary-to-secondary leakage.6 8..3.p. Control Room Enveiope HabitabilityProgram A controli R om Envelope (CRE) Habi tability P~rogram shall'be est'ablisheedand implemented toensdrUe' that CRE habitability is maintained such that, with ,an....OPERABLE Control Room Makeup and Cleanup Filtration'System, CRE occupants cancontrol the reactor safely Under normal conditions and maintain it in a'safe .condition following a radiologicaleve'nt, hazardous chemical release6,oor a smoke challenge.

The program shall-ensure that adequate radiation protectiohnis provided to permit access and occupancy of the CRE under design basis accident (DBA) conditionswithout personnel receiving radiation exposures in excess ofT5 rem totalidose equivalent (TEDE) :for the, duration' of the accident. -The programr shall include 4he following elements:;.

41. Th'e'definitlion of the' C RE an6d thfe, CR buinidary.

2. equiremen

'ts, fo-r maiintaining the CREbou~n'dar'y in- its'd-esign condition including configuration controluand pev ve maintenance.

3. Requirements for (i) determining ithe un~filtered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified ,in Sections C.1 and C.2 of RegulatoryGuideA1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii).assessing CRE habitability at the Frequencies specified in Sections and C.:2 of Regulatory Guide 1.197, Revision 0.Thefolowig

're xcptins o SctinsCA1 and C..2 of Reg~ulator y Guide 1.197, Revision .0:.1), _C._ -Section 4.3.2 "'Pelriodi~c CR sesment roNI 99-03 Revision I will'be used as input to a site specific Self Assessment

., 2) C.1:2 -N opeer reViews are required to be performed.

SOUTH TEXAS -UNITS 1 & 2 6-12c Unit 1 -Amendment No. 1-68 Unit 2 -Amendment No. 4-57 NOC-AE-07002165 Attachment 2 Page 5 of 5 6.0 ADMINISTRATIVE CONTROLS 6.8 Procedures, Programs, and Manuals 6.8.3.p (continued)

4. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by two trains of the Control Room Makeup and Cleanup Filtration System, operating at the flow rate required by the Surveillance Requirement 4.7.7.c.3, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall' be trended and used as part of the .18 month assessment of the CRE boundary.5. The quantitative limits on unfiltered air inleakage into the CRE, These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph

3. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.6.; The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary, as required by paragraphs 3 and 4, respectively.

SOUTH TEXAS -UNITS 1 & 2 6-12d Unit 1 -Amendment No. 4.68 Unit 2 -Amendment No. 457 NOC-AE-07002165 Attachment 3 ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (Mark-up)

NOC-AE-07002165 Attachment 3 Page 1 of 8 PLANT SYSTEMS BASES 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," March 1974.3/4.7.6 NOT USED 3/4.7.7 CONTROL ROOM MAKEUP AND CLEANUP FILTRATION SYSTEM (CRMCFS)BACKGROUND The C RMCFS provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity,_

hazardous chemicals, or smoke.The CRiCFS consists-of three independent, redundant 50%'trainis that recirculate and filter the air in-the control room envelope (CRE) and a CRE boundary that limits the in-leakage of unfiltered air. Each'CRMCFS 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,s barriers, and instrumentation also form part of the system. 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.

This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access Or continuous occupancy is not necessary in'the event of an accident.

The CRE is protected during normal operation, natural events, and accident conditions.

The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the in-leakage of unfiltered air into the CRE will not exceed the in-leakage assumed inthe licensing basis analysis of design basis accident (DBA) consequences to CRE occupants.

The CRE and its boundary are defined in the Control Room Envelope Habitability Program.The CRMCFS is an emergency system, parts of which may also operate during normal unit operations in the standby mode of operation.

Upon receipt of the actuating signal(s), normal air supply to the CRE is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal absorbers.

Continuous operation of one train for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month on a staggered bases, with'the heaters on, reduces moisture buildup on the HEPA filters and absorbers.

The heaters are ýimportant toWtheeffectiveness,of the charcoal absorbers.

Actuation of the CRMCFS to the emergency mode of operation for radiological

.conditions, closes the unfiltered outside airintake and unfiltered exhaust dampers, and aligns the system for recirculation of the airwithin the CRE through the redundant SOUTH TEXAS -Units 1 & 2 B 3/4 7-5 Unit 1 -Amendment No. xxxxxxx Unit 2 -Amendment No. xxxxxxx NOC-AE-07002165 Attachment 3 Page 2 of 8 PLANT SYSTEMS BASES trains of HEPA and the charcoal filters. Thelemergency radiation state alsoIinitiates pressurization and filtered ventilation of the air supply to the CRE. There is no automatic actuation of the CRMCFSsystem for hazardous chemical or smoke. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release. 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.Outside air is filtered and added to the air being recirculated from the CRE.Pressurization of the CRE minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas adjacent to the CRE boundary.The air entering the CRE is continuously monitored by radiation detectors.

One detector output above the set point will cause actuation of the emergency radiation state.Two CRMCFS trains operating at a flow rate of <2000 cfm will pressurize the CRE to about 0.125 inches water gauge relative to external areas adjacent to the CRE -boundary.

The CRMCFS operation in maintaining the CRE habitable is discussedin the UFSAR, Section 9.4.Redundant supply and recirculation trains provide the reqluitredfiltration should an excessive pressure drop develop across a filter train combination.

Normally open isolation dampers are arranged in series pairs so that-the failure of one damper to shut will not result in a breach of isolation.

The CRMCFS is designed in accordance with Seismic Category I requirements.

The CRMCFS is designed to maintain a habitable environ'ment-in'the CRE for 30 daysof continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem total effective dose equivalent.(TEDE).

This limitation is consistent with the requirements of General Design Criterion 19-of Appendix A, 10 CFR 50. ANSINS 010-1980 will be used as a proceduralguide forsureillance testing.APPLICABLE SAFETY ANALYSIS The CRMCFS 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 CRMCFS 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 UFSAR, Chapter 15.The CRMCFS provides protection from smoke and hazardous chemicals to the CRE occupants.

The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release. 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. Based on this, the South Texas Project has determined no SOUTH TEXAS -Units 1 & 2 B 3/4 7-5 Unit 1 -Amendment No. xxxxxxx Unit 2 -Amendment No. xxxxxxx NOC-AE-07002165 Attachment 3 Page 3 of 8 PLANT SYSTEMS BASES CRMCFS actuation is required for hazardous chemical releases or smoke and no..Surveillance Requirements are required to verify operability for hazardous chemical or smoke.The worst case single active failure of a component of the CRMCFS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.The CRMCFS satisfies Criterion 3 of 10 CFR 50.36(c) (2)(i1).1 LCO Three independent and redundant CRMCFS trains are required to be OPE-RABLE to ensure that at least two are available if a single active failure disables one train. Total system failure, such as from a loss of all ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem total effective dose equivalent (TEDE) to the CRE occupants in the event of a large radioactive release.Each CRMCFS train is considered OPERABLE when the individual components necessary to limit CRE occupant exposure areOPERABLE.

A CRMCFS train is OPERABLE when the associated:

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

In order for the CRMCFS trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive r eiease 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.APPLICABILITY In MODES 1, 2, 3, 4, 15, and 6, and duIring movement of irradiated'fuel assemblies, the CRMCFS must be OPERABLE to ensure that the.CRE will remain habitable during and following a DBA.During movement of irradiated fuel assemblies, the CRMC FFS must be OPERABLE to cope with the release from afuel handling accident.ACTIONS MODES 1, 2, 3, and 4: SOUTH TEXAS -Units 1 & 2 B 3/4 7-5 Unit 1 -Amendment No. xxxxxxx Unit 2 -Amendment No. xxxxxxx NOC-AE-07002165 Attachment 3 Page 4 of 8 PLANT SYSTEMS BASES ACTIONS a, b, and c: The time limits associated with these ACTIONS to restore an inoperable train to OPERABLE status are consistent with the redundancy and___,__capability of the system and the low probability of a design basis accident While the affected train(s) is out of service. A limited allowed outage time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for all three trains to be out of service simultaneously in recognition of the fact that there are common plenums and some maintenance or testing activities required opening or entry into these common plenums. This time is reasonable to diagnose, plan, and possibly repair problems with the boundary or the ventilation system.'This is acceptable based on the low probability of a design basis event in that brief allowed outage time and because administrative controls impose compensatory actions that reduce the already small risk associated with being in the ACTION. The compensatory actions are consistent with the intent of GDC 19 to protect plant personnel from potential hazards such as radioactive contamination, smoke,: and temperature, etc. Pre-planned measures should be available to address these concerns for intentional and unintentional entry into the condition.

The compensatory actions include: Procedures will preclude intentionally removing multiple trains of Control Room Envelope HVAC from service if Containment Spray is not functional or intentionally making a train of Containment Spray unavailablewhen multiple trains of Control Room Envelope:HVAC are out of service. For purposes of this compensatorY action, Containment Spray is considered functional if at least one train can be manually or automatically initiated.

• The plant will not make planned simultaneous entries into TS'3.7,7'ACTION c for .MODES 1, 2;, 3 and 4 and TS,37.8 AcToN b"or. dc.The compensato'ry action may in-clu-diei pliacing 1fa-ns -in puli-to-l6c"ik as necessary to preclude there being a motive force to transport contaminated air to a clean environment, in the event of an accident.These compensatory actions also include administrative controls on opening plenums or other openings such that appropriate communication is established with the control room to assure timely-closing of the system if necessary.

Since the Control Room Envelope boundary, integrity also affects operability of the' overall system, entry and exit is administratively controlled..

Administrative control of entry and exit through doors is performed by the persons entering or exiting the area.Extended opening of the boundary is coordinated with the control room with appropriate plans for closure and communication.

ACTION d: SOUTH TEXAS -Units 1 & 2 B 3/4 7-5 Unit 1 -Amendment No. xxxxxxx Unit 2 -Amendment No. xxxxxxx NOC-AE-07002165 Attachment 3 Page 5 of 8 PLANT SYSTEMS BASES If the unfiltered in-leakage0of potentialIly contaminated air past the CRE .boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem total effective dose equivalent (TEDE)), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable.

Actions must be taken to restore an OPERABLE CRE boundary within 90 days., During the period that the CRE boundalry is consideried inoperable, action must be initiated-to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. The "Control Room Envelope Habitability Program" Procedure will contain.a list of mitigating actions.Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected, from hazardous chemicals and smoke. These mitigating actions (i.e.;, actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CompletionTime for implementation of the mitigating actions is reasonable based on the low probability of!a DBA occurring during this time period, and the use of the mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement

....protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan.and possibly.

repair, and test most problems with the CRE boundary.MODES 5 and 6: ACTION a.In MODE 5 or 6, or during movement of irradiated fuel assemblies,*if the inoperable, for reasons other than Action c., CRMCFS train cannot be restored to OPERABLE status within 7 days, action must, be taken to immediately place the remaining OPERABLE CRMCFS trains in the emergency mode. This action ensures that the remaining trains are OPERABLE, that no failures preventing automatic actuation will occur, and that any active failures wouldbe readily detected.An alternative to Action a. is to immediately suspend operations involving positive reactivity additions that could result in loss of required .SHUTDOWN MARGIN or refueling boron concentration are necessary to assure continued safe operation.

Introduction of coolant inventory must SOUTH TEXAS -Units 1 & 2 B 3/4 7-5 Unit 1 -Amendment No. xxxxxxx Unit 2 -Amendment No. xxxxxxx NOC-AE-07002165 Attachment 3 Page 6 of 8 PLANT SYSTEMS BASES be from sources that have a boron concentration greater than what would be required in the RCS for minimum SHUTDOWN MARGIN or refueling boron concentration.

This may result'in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

Introduction of temperature changes, including temperature increases when operating with a positive moderator temperature coefficient, must also be evaluated to not result in operation below the required SHUTDOWN MARGIN or refueling boron concentration limits.This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.ACTIONS MODES 5 and6 (Continued):

ACTION b.In MODE 5 or 6, or during movement of irradiated fuel assemblies with less than the minimum required Control Room Makeup and Cleanup Filtration Systems (two or more) OPERABLE, or with the OPERABLE CRMCFS trains required to be in the recirculation and makeup air filtration mode by ACTION a. not capable of being powered byan OPERABLE emergency power source, then suspending operations involving positive reactivity additions that could result in 1oss of required SHUTDOWN MARGIN or refueling boron concentration are necessary to assure continued

'safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required in the RCS for minimum SHUTDOWN MARGIN or refueling boron concentration.

This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

Introduction of temperature changes, including temperature increases when operating with a positive moderator temperature coefficient, must also beevaluated to not result in operation below the required SHUTDOWN MARGIN or refueling boron concentration limits.Control rod withdrawal is not allowed except that it is permissible to unlock the control rods for rapid refueling.

To unlock the~control rods, they must be withdrawn at least one step. However, since the control rods are above the active fuel when. the unlocking process" occurs, there is no reactivity addition.ACTION c: With one or more CRMCFS 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.SOUTH TEXAS -Units 1 & 2 B 3/4 7-5 Unit 1 -Amendment No. xxxxxxx Unit 2 -Amendment No. xxxxxxx NOC-AE-07002165 Attachment 3 Page 7 of 8 PLANT SYSTEMS BASES SURVEILLANCE REQUiREMENTS SR 4.7.1.a This SR verifies the system iS capable'of providing the necessary cooling for the CRE instrument and personnel.

• A Check;every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is.sufficient to detect and correct any issues with"the system in a timeily manner.SR 4.7.7,b Standby SystemS soshudibe checked periodically to ensure th'at they function properly.

AS the environment and normal operating conditions on this system are nottoo severe, testing each train once every 92 days on a staggered test bases provides an adequate check of this system.-Operation for >10 continuous hours with the heaters energized provides confidence the charcoal filters are functional.

The Frequency is basedon the reliability of the equipment and the three train design.SR 4.7.7*.This SR verifies the HEPA filters and charcoal absorber bankswilk perform their'design function by measuring penetration'and bypass leakage. 'the flow, rates specified are those used in the design calculationsforýrthe system.,,The Frequency of 18 months is based on industry operatingexperience and is consisten twith the typical refueling cycle.SR 4.7.71d This SR verifies the efficiency of the activated carbon absorber sectiohnby laboratory test!ing of representative samPle'sI of the activated carbon exposed simultaneously tothe same service conditions as the absorber section. This sample is taken in accordance with Regulatory Guide C.6.b of 1.52, Revision2, March 1978-. Thelaboratoy testing acceptance criteria is in accordance With ASTM D3803-1989 for methyl iodine penetration.

SR 4.7.71e.1, 2 and 4 These SRs Verifies that each CRMCFS trains starts and operates on an actual or simulated actuation signal and the filtration system performs as designed.

The. Frequencyof 18 months is based on industry operating experience and is consistent with thetypical refueling cYCle.SR k4.7.7.'e.3 This SR verifies the OPEiRABiLIT of the CRErboundary by testing for unfiltered air in-leakage pastthe CRE boundary and into the CRE. The SOUTH TEXAS -Units 1 & 2 B 3/4 7-5 Unit 1 -Amendment No. xxxxxxx Unit 2 -Amendment No. xxxxxxx NOC-AE-07002165 Attachment 3 Page 8 of 8 PLANT SYSTEMS BASES details, of th~e-1te'sting9 ares~pec'ified( in the', Contrd.ol Room -Envelope Habitability Program. The CRE is considered habitable When the.radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem total effective dose equivalent TEDE) andte RE occupantsareprotectedfrom .hazardous chemicals and 'smoke.This SR verifies that the unfiltered air iný-ieakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences.

When unfiltered air in-leakage is greater than the assumed flow rate in MODES 1, 2, 3,and 4, Action d must be entered.: Action d allows time to restore the CRE boundary to OPERABLE Status provided mitigating actions can ensure that the CRE remains within the licensing basis habitabilityý limits for the occupants folloWing an accident.Compensator -measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, which endorses,.

with exceptions, NEI 99-03, Section 8.4 and Appendix F. These compensatory measures may also be used as.mitigating actions as required by Actiond,.

Temporary analytical; methods may also be used as compensatory measures to restore4OPERABILIT Options for restoring the CREb5oundary to OPERABLE status include changing thelicensin6g basis DBA consequence analysis, repairing thle CRE boundary,,or a combination of these actions. iDepending upon the nature of the problem and the corrective action,; a full in-leakage test may-not be necessary to establish that the CRE bboundary has beenh restored'to 0PERABLE status,'There is- :no- CRMCFS actuation

for hazardous chemicai reeiases or smo6ke and there are no surveillance requirements that verify operability for haza rdous c6h emical ors smoke. "The hazardous che m'ical anallyses for. the South Texas Project do not assume any control room isolation and assumes airenters atnormal makeup ventilation flow rates. No in-leakage test-is required to determine unfiltered in-leakage from hazardous chemical since this would be a value much Iess. than that currently assumed inrthe hazardous chemical analyses.

There is no regulatory limit on the amount of smoke allowed in the control room. Thie plant's ability to manage smoke infiltration was assessed qualitativeiy.

The Conclus ion i s that the ope rator maintains the abi lity to safely shutdow h the plant during a smoke eventoio6ginating inside or outside the control room. Therefore, no in-ieakage testfis required to be conducted to measure the amrount of smoke that could infiltra'teinto the contrl room.SR,4.7.7.f and-g Thes e sRsl ve rify that after eachcompleteorpartial replacemeht of the either the HEPA filter bank1or theacharcoal absorber bank that each satisfies the in-pliace penetration and bypass Ieakage test in accordance with ANSI N51 o-1 980forDOP teSt aerosol.SOUTH TEXAS -Units 1 & 2 B 3/4 7-5 Unit 1 -Amendment No. xxxxxxx Unit 2 -Amendment No. xxxxxxx