ML080370172

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Issuance of License Amendments 281 and 163 Control Room Envelope Habitibility in Accordance with Technical Specification Task Force Traveler 448
ML080370172
Person / Time
Site: Beaver Valley
Issue date: 02/15/2008
From: Nadiyah Morgan
NRC/NRR/ADRO/DORL/LPLI-1
To: Sena P
FirstEnergy Nuclear Operating Co
Morgan N, NRR/DORL, 415-1016
References
TAC MD6628, TAC MD6629
Download: ML080370172 (21)
v • d • e


Text

February 15, 2008 Mr. Peter P. Sena III Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS RE: CONTROL ROOM ENVELOPE HABITIBILITY IN ACCORDANCE WITH TECHNICAL SPECIFICATION TASK FORCE TRAVELER 448 (TAC NOS. MD6628 AND MD6629)

Dear Mr. Sena:

The Commission has issued the enclosed Amendment No. 281 to Facility Operating License No.

DPR-66 for the Beaver Valley Power Station, Unit No. 1 and Amendment No. 163 to Facility Operating License No. NPF-73 for the Beaver Valley Power Station, Unit No. 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 30, 2007.

These amendments modifiy TS requirements related to control room envelope habitability in accordance with the Commission approved Technical Specification Task Force Traveler 448, Revision 3.

A copy of the related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Nadiyah S. Morgan, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

1. Amendment No. 281 to DPR-66
2. Amendment No. 163 to NPF-73
3. Safety Evaluation cc w/encls: See next page

February 15, 2008 Mr. Peter P. Sena III Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS RE: CONTROL ROOM ENVELOPE HABITIBILITY IN ACCORDANCE WITH TECHNICAL SPECIFICATION TASK FORCE TRAVELER 448 (TAC NOS. MD6628 AND MD6629)

Dear Mr. Sena:

The Commission has issued the enclosed Amendment No. 281 to Facility Operating License No.

DPR-66 for the Beaver Valley Power Station Unit No. 1 and Amendment No. 163 to Facility Operating License No. NPF-73 for the Beaver Valley Power Station Unit No. 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 30, 2007.

These amendments modify TS requirements related to control room envelope habitability in accordance with the Commission approved Technical Specification Task Force Traveler 448, Revision 3.

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Nadiyah S. Morgan, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

1. Amendment No. 281 to DPR-66
2. Amendment No. 163 to NPF-73
3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC LPLI-1 R/F RidsNrrDorlLpli-1 NMorgan RidsOgcRp GHill(4) RidsNrrDirsItsb WCartwright BSingal, DorlDpr RidsRegionIMailCenter RidsNrrLASLittle RidsAcrsAcnwMailCenter Package No. : ML080370178 Amendment No.: ML080370172 Tech Spec No.: ML *Input received. No substantive changes made.

OFFICE LPLI-1/PM LPLI-1/LA ITSB/BC (Acting) LPLI-1/BC NAME NMorgan SLittle GWaig* MKowal DATE 2/11/08 2/11/08 2/1/2008 2/15/08 OFFICIAL RECORD COPY

Beaver Valley Power Station, Unit Nos. 1 and 2 cc:

Joseph J. Hagan Ohio EPA-DERR President and Chief Nuclear Officer ATTN: Zack A. Clayton FirstEnergy Nuclear Operating Company P.O. Box 1049 Mail Stop A-GO-19 Columbus, OH 43266-0149 76 South Main Street Akron, OH 44308 Peter P. Sena III Site Vice President James H. Lash FirstEnergy Nuclear Operating Company Senior Vice President of Operations Beaver Valley Power Station and Chief Operating Officer Mail Stop A-BV-SEB1 FirstEnergy Nuclear Operating Company P.O. Box 4, Route 168 Mail Stop A-GO-14 Shippingport, PA 15077 76 South Main Street Akron, OH 44308 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Danny L. Pace Mail Stop A-GO-2 Senior Vice President, Fleet Engineering 76 South Main Street FirstEnergy Nuclear Operating Company Akron, Ohio 44308 Mail Stop A-GO-14 76 South Main Street Manager, Site Regulatory Compliance Akron, OH 44308 FirstEnergy Nuclear Operating Company Beaver Valley Power Station Jeannie M. Rinckel Mail Stop A-BV-A Vice President, Fleet Oversight P.O. Box 4, Route 168 FirstEnergy Nuclear Operating Company Shippingport, PA 15077 Mail Stop A-GO-14 76 South Main Street Commissioner James R. Lewis Akron, OH 44308 West Virginia Division of Labor 749-B, Building No. 6 David W. Jenkins, Attorney Capitol Complex FirstEnergy Corporation Charleston, WV 25305 Mail Stop A-GO-15 76 South Main Street Director, Utilities Department Akron, OH 44308 Public Utilities Commission 180 East Broad Street Manager, Fleet Licensing Columbus, OH 43266-0573 FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 Director, Pennsylvania Emergency 76 South Main Street Management Agency Akron, OH 44308 2605 Interstate Dr.

Harrisburg, PA 17110-9364

Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc:

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077

FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

DOCKET NO. 50-334 BEAVER VALLEY POWER STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 281 License No. DPR-66

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by FirstEnergy Nuclear Operating Company, et al.

(the licensee), dated August 30, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-66 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 281, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: February 15, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 281 FACILITY OPERATING LICENSE NO. DPR-66 DOCKET NO. 50-334 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 3 3 Replace the following pages of Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3.7.10-1 3.7.10-1 3.7.10-2 3.7.10-2

3.7.10-3 5.5-20 5.5-20

5.5-21 Replace the following page of Appendix C Additional Conditions with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert

5

FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

OHIO EDISON COMPANY THE TOLEDO EDISON COMPANY DOCKET NO. 50-412 BEAVER VALLEY POWER STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 163 License No. NPF-73

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by FirstEnergy Nuclear Operating Company, et al.

(the licensee), dated August 30, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-73 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 163, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: February 15, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 163 FACILITY OPERATING LICENSE NO. NPF-73 DOCKET NO. 50-412 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 3a 3a Replace the following pages of Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3.7.10-1 3.7.10-1 3.7.10-2 3.7.10-2

3.7.10-3 5.5-21 5.5-20

5.5-21 Replace the following page of Appendix D Additional Conditions with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert

5

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 281 AND 163 TO FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

OHIO EDISON COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412

1.0 INTRODUCTION

By application dated August 30, 2007, Agencywide Document and Management System (ADAMS) No. ML072470380, the FirstEnergy Nuclear Operating Company (FENOC, licensee),

requested changes to the Technical Specifications (TSs) for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2).

On August 8, 2006, the commercial nuclear electrical power generation industry owners group Technical Specifications Task Force (TSTF) submitted a proposed change, TSTF-448, Revision 3, to the improved standard technical specifications (STS) (NUREGs 1430-1434) on behalf of the industry (TSTF-448, Revisions 0, 1, and 2 were prior draft iterations). TSTF-448, Revision 3, is a proposal to establish more effective and appropriate action, surveillance, and administrative STS requirements related to ensuring the habitability of the control room envelope (CRE).

In NRC Generic Letter (GL) 2003-01 (Reference 1), licensees were alerted to findings at facilities that existing TS Surveillance Requirements (SRs) for the Control Room Envelope Emergency Ventilation System (CREEVS) may not be adequate. Specifically, the results of American Society for Testing and Materials (ASTM) E741 (Reference 2) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance is not a reliable method for demonstrating CRE boundary operability. Licensees were requested to address existing TS as follows:

Provide confirmation that your technical specifications verify the integrity [i.e., operability]

of the CRE [boundary], and the assumed [unfiltered] inleakage rates of potentially contaminated air. If you currently have a differential pressure surveillance requirement to

demonstrate CRE [boundary] integrity, provide the basis for your conclusion that it remains adequate to demonstrate CRE integrity in light of the ASTM E741 testing results.

If you conclude that your differential pressure surveillance requirement is no longer adequate, provide a schedule for: 1) revising the surveillance requirement in your technical specification to reference an acceptable surveillance methodology (e.g.,

ASTM E741), and 2) making any necessary modifications to your CRE boundary so that compliance with your new surveillance requirement can be demonstrated.

If your facility does not currently have a technical specification surveillance requirement for your CRE integrity, explain how and at what frequency you confirm your CRE integrity and why this is adequate to demonstrate CRE integrity.

To promote standardization and to minimize the resources that would be needed to create and process plant-specific amendment applications in response to the concerns described in the GL, the industry and the NRC proposed revisions to CRE habitability system requirements contained in the STS, using the STS change traveler process. This effort culminated in Revision 3 to traveler TSTF-448, "Control Room Habitability," which the NRC staff approved on January 17, 2007.

Consistent with the traveler as incorporated into NUREG-1431, the licensee proposed revising action and SRs in Specification 3.7.10, "Control Room Emergency Ventilation System (CREVS)," and adding a new administrative controls program, Specification 5.5.14, "Control Room Envelope Habitability Program." The purpose of the changes is to ensure that CRE boundary operability is maintained and verified through effective surveillance and programmatic requirements, and that appropriate remedial actions are taken in the event of an inoperable CRE boundary.

Some editorial and plant-specific changes were incorporated into this safety evaluation (SE) resulting in minor deviations from the model SE text in TSTF-448, Revision 3.

2.0 REGULATORY EVALUATION

2.1 Control Room and Control Room Envelope NRC Regulatory Guide (RG) 1.196, "Control Room Habitability at Light-water Nuclear Power Reactors," Revision 0, May 2003, (Reference 4) uses the term "CRE" in addition to the term "control room" and defines each term as follows:

Control Room: The plant area, defined in the facility licensing basis, in which actions can be taken to operate the plant safely under normal conditions and to maintain the reactor in a safe condition during accident situations. It encompasses the instrumentation and controls necessary for a safe shutdown of the plant and typically includes the critical document reference file, computer room (if used as an integral part of the emergency response plan), shift supervisor's office, operator wash room and kitchen, and other critical areas to which frequent personnel access or continuous occupancy may be necessary in the event of an accident.

Control Room Envelope: The plant area, defined in the facility licensing basis, that in the event of an emergency, can be isolated from the plant areas and the environment external to the CRE. This area is served by an emergency ventilation system, with the

intent of maintaining the habitability of the control room. 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.

NRC RG 1.197, "Demonstrating Control Room Envelope Integrity At Nuclear Power Reactors,"

Revision 0, May 2003 (Reference 5), also contains these definitions, but uses the term CRE to mean both. This is because the protected environment provided for operators varies with the nuclear power facility. At some facilities this environment is limited to the control room, at others, it is the CRE. In this SE, consistent with the proposed changes to the STS, the CRE will be used to designate both. For consistency, facilities should use the term CRE with an appropriate facility-specific definition derived from the above CRE definition.

2.2 CREVS The CREVS (the term used at BVPS for the Control Room Envelope Emergency Ventilation System, CREEVS) provides a protected environment from which operators can control the unit, during airborne challenges from radioactivity, hazardous chemicals, and fire byproducts, such as fire suppression agents and smoke, during both normal and accident conditions.

The CREVS is designed to maintain a habitable environment in the control room envelope for 30 days of continuous occupancy after a design-basis accident (DBA) without exceeding a 5 rem total effective dose equivalent (TEDE).

The CREVS consists of three redundant trains, each capable of maintaining the habitability of the CRE. The CREVS is considered operable when the individual components necessary to limit operator exposure are operable in two trains. A CREVS train is considered operable when the associated:

$ Fan is operable;

$ High efficiency particulate air (HEPA) filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions;

$ Heater, moisture separator, ductwork, valves, and dampers are operable, and air circulation can be maintained; and

$ CRE boundary is operable (the single boundary supports the two credited trains).

The CRE boundary is considered operable when the measured unfiltered air inleakage is less than or equal to the inleakage value assumed by the licensing basis analyses of DBA consequences to CRE occupants.

2.3 Regulations Applicable to Control Room Habitability In Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," General Design Criteria (GDC) 1, 2, 3, 4, 5, and 19 apply to CRE habitability. A summary of these GDCs follows. Facilities not

licensed under the GDC from 10 CFR Part 50 are licensed under similar plant-specific design criteria, as described in the facility's licensing basis documents.

GDC 1, "Quality Standards and Records," requires that structures, systems, and components (SSCs) important to safety be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions performed.

GDC 2, ADesign Basis for Protection Against Natural Phenomena,@ requires that SSCs important to safety be designed to withstand the effects of earthquakes and other natural hazards.

GDC 3, "Fire Protection," requires SSCs important to safety be designed and located to minimize the effects of fires and explosions.

GDC 4, "Environmental and Dynamic Effects Design Bases," requires SSCs important to safety to be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents (LOCAs).

GDC 5, "Sharing of Structures, Systems, and Components," requires that SSCs important to safety not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, the orderly shutdown and cooldown of the remaining units.

GDC 19, "Control Room," requires that a control room be provided from which actions can be taken to operate the nuclear reactor safely under normal conditions and to maintain the reactor in a safe condition under accident conditions, including a LOCA. Adequate radiation protection is to be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of specified values.

Prior to incorporation of TSTF-448, Revision 3, the STS requirements addressing CRE boundary operability resided only in the following CRE ventilation system specifications:

$ NUREG-1430, TS 3.7.10, "Control Room Emergency Ventilation System (CREVS);"

$ NUREG-1431, TS 3.7.10, "Control Room Emergency Filtration System (CREFS);"

$ NUREG-1432, TS 3.7.11, "Control Room Emergency Air Cleanup System (CREACS);"

$ NUREG-1433, TS 3.7.4, "[Main Control Room Environmental Control (MCREC)]

System;" and

$ NUREG-1434, TS 3.7.3, "[Control Room Fresh Air (CRFA)] System."

In these specifications, the SR associated with demonstrating the operability of the CRE boundary requires verifying that one CREEVS train can maintain a positive pressure relative to the areas adjacent to the CRE during the pressurization mode of operation at a makeup flow rate. Facilities that pressurize the CRE during the emergency mode of operation of the CREEVS have similar SR. Regardless, the results of ASTM E741 (Reference 2) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance is not a reliable method for demonstrating CRE boundary operability. That is, licensees were able to obtain differential pressure and flow measurements satisfying the SR limits even though unfiltered inleakage was determined to exceed the value assumed in the safety analyses.

In addition to an inadequate SR, the action requirements of these specifications were ambiguous regarding CRE boundary operability in the event CRE unfiltered inleakage is found to exceed the analysis assumption. The ambiguity stemmed from the view that the CRE boundary may be considered operable but degraded in this condition, and that it would be deemed inoperable only if calculated radiological exposure limits for CRE occupants exceeded a licensing basis limit; e.g., as stated in GDC 19, even while crediting compensatory measures.

NRC Administrative Letter 98-10 (AL 98-10), "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," states that "the discovery of an improper or inadequate TS value or required action is considered a degraded or nonconforming condition," which is defined in NRC Inspection Manual Chapter 9900; see latest guidance in Regulatory Information Summary (RIS) 2005-20 (Reference 3). AImposing administrative controls in response to an improper or inadequate TS is considered an acceptable short-term corrective action. The NRC staff expects that, following the imposition of administrative controls, an amendment to the inadequate TS, with appropriate justification and schedule, will be submitted in a timely fashion."

Licensees that have found unfiltered inleakage in excess of the limit assumed in the safety analyses and have yet to either reduce the inleakage below the limit or establish a higher bounding limit through re-analysis, have implemented compensatory actions to ensure the safety of CRE occupants, pending final resolution of the condition, consistent with RIS 2005-20.

However, based on GL 2003-01 and AL 98-10, the NRC staff expects each licensee to propose TS changes that include a surveillance to periodically measure CRE unfiltered inleakage in order to satisfy 10 CFR 50.36(d)(3), which requires a facility's TS to include SRs, which it defines as "requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that limiting conditions for operation will be met." (Emphasis added.)

The NRC staff also expects facilities to propose unambiguous remedial actions, consistent with 10 CFR 50.36(d)(2), for the condition of not meeting the limiting condition for operation (LCO) due to an inoperable CRE boundary. The action requirements should specify a reasonable completion time to restore conformance to the LCO before requiring a facility to be shut down.

This completion time should be based on the benefits of implementing mitigating actions to ensure CRE occupant safety and sufficient time to resolve most problems anticipated with the CRE boundary, while minimizing the chance that operators in the CRE will need to use mitigating actions during accident conditions.

2.4 Adoption of TSTF-448 Revision 3 by BVPS-1 and 2 Adoption of TSTF-448, Revision 3, will assure that the facility's TS LCO for the CREVS is met by demonstrating unfiltered leakage into the CRE is within limits; i.e., the operability of the CRE boundary. In support of this surveillance, which specifies a test interval (frequency) described in RG 1.197, TSTF-448 also adds TS administrative controls to assure the habitability of the CRE between performances of the ASTM E741 test. In addition, adoption of TSTF-448 will establish clearly stated and reasonable required actions in the event CRE unfiltered inleakage is found to exceed the analysis assumption.

The changes made by TSTF-448 to the STS requirements for the CREVS and the CRE boundary conform to 10 CFR 50.36(d)(2) and 10 CFR 50.36(d)(3). Their adoption will assure

that the BVPS-1 and 2s CRE will remain habitable during normal operation and DBA conditions.

These changes are, therefore, acceptable from a regulatory standpoint.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the proposed changes against the corresponding changes made to the STS by TSTF-448, Revision 3, which the NRC staff has found to satisfy applicable regulatory requirements, as described above in Section 2.0. The emergency operational mode of the CREVS at the BVPS-1 and 2 pressurizes the CRE to minimize unfiltered air inleakage. The proposed changes are consistent with this design.

3.1 Proposed Changes The proposed amendment would strengthen CRE habitability TS requirements by changing TS 3.7.10, Control Room Emergency Ventilation System and adding a new TS administrative controls program on CRE habitability. Accompanying the proposed TS changes are appropriate conforming technical changes to the TS Bases. The proposed revision to the Bases also includes editorial and administrative changes to reflect applicable changes to the corresponding STS Bases, which were made to improve clarity, conform with the latest information and references, correct factual errors, and achieve more consistency among the STS NUREGs.

Except for plant-specific differences, all of these changes are consistent with STS as revised by TSTF-448, Revision 3.

The NRC staff compared the proposed TS changes to the STS and the STS markups and evaluations in TSTF-448. The staff verified that differences from the STS were adequately justified on the basis of plant-specific design or retention of current licensing basis. The NRC staff also reviewed the proposed changes to the TS Bases for consistency with the STS Bases and the plant-specific design and licensing bases, although approval of the Bases is not a condition for accepting the proposed amendment. However, TS 5.5.10, "Technical Specifications Bases Control Program," provides assurance that the licensee has established and will maintain the adequacy of the Bases. The proposed Bases for TS 3.7.10 refer to specific guidance in NEI 99-03, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001 (Reference 6), which the NRC staff has formally endorsed, with exceptions, through RG 1.196, AControl Room Habitability at Light-Water Nuclear Power Reactors,@ dated May 2003 (Reference 4).

3.2 Editorial Changes The licensee proposed editorial changes to TS 3.7.10, "Control Room Emergency Ventilation System," to establish standard terminology, such as "control room envelope (CRE)" in place of "control room," except for the plant-specific name for the CREEVS (CREVS), and "radiological, chemical, and smoke hazards," in place of various phrases to describe the hazards that CRE occupants are protected from by the CREVS. The licensee also expanded action E of TS 3.7.10 to include movement of fuel assemblies over recently irradiated fuel assemblies.

In TS 5.5.14.d, the licensee proposed a minor editorial change to the pressure test interval description to avoid confusion with the assessment interval of the CRE boundary described in RG 1.197. The TS 5.5.14.d specifies the pressure test interval as 18 months which is consistent with the TSTF-448 model application.

These changes improve the usability and quality of the presentation of the TS, have no adverse impact on safety, and therefore, are acceptable.

3.3 TS 3.7.10, Control Room Emergency Ventilation System The licensee proposed to revise the action requirements of TS 3.7.10, "Control Room Emergency Ventilation System," to acknowledge that an inoperable CRE boundary, depending upon the location of the associated degradation, could cause just one, instead of both CREVS trains to be inoperable. This is accomplished by revising Condition A to exclude Condition B, and revising Condition B to address one or more CREVS trains, as follows:

$ Condition A One required CREVS train inoperable for reasons other than Condition B.

$ Condition B One or more CREVS trains inoperable due to inoperable CRE boundary in MODE 1, 2, 3, or 4.

This change clarifies how to apply the action requirements in the event just one CREVS train is unable to ensure CRE occupant safety within licensing basis limits because of an inoperable CRE boundary. It enhances the usability of Conditions A and B with a presentation that is more consistent with the intent of the existing requirements. This change is an administrative change because it neither reduces nor increases the existing action requirements, and, therefore, is acceptable.

The licensee proposed to replace existing Required Action B.1, "Restore control room boundary to OPERABLE status," which has a 24-hour Completion Time, with Required Action B.1, to immediately initiate action to implement mitigating actions; Required Action B.2, to verify, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that mitigating actions ensure CRE occupant radiological exposures will not exceed limits, and that CRE occupants are protected from chemical and smoke hazards; and Required Action B.3, to restore CRE boundary to operable status within 90 days.

The 24-hour Completion Time of new Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions as directed by Required Action B.1. The 90-day Completion Time of new Required Action B.3 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. The 90-day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary. Therefore, proposed Actions B.1, B.2, and B.3 are acceptable.

The licensee proposed to add a new condition to Action E of TS 3.7.10 that states, "One or more CREVS trains inoperable due to an inoperable CRE boundary during movement of recently irradiated fuel assemblies." The specified Required Action proposed for this condition is the same as for the existing condition of Action E (revised as discussed previously), which states ATwo required CREVS trains inoperable during movement of recently irradiated fuel assemblies or during movement of fuel over recently irradiated fuel assemblies.@ Accordingly, the new condition is stated with the other condition in Action E using the logical connector "OR. The practical result of this presentation in format is the same as specifying two separately numbered

Actions, one for each condition. Its advantage is to make the TS Actions table easier to use by avoiding having an additional numbered row in the Actions table. The new condition in Action E is needed because proposed Action B will only apply in Modes 1, 2, 3, and 4. As such, this change will ensure that the Actions table continues to specify a condition for an inoperable CRE boundary during Modes 5 and 6 and during refueling. Therefore, this change is administrative and acceptable.

In the emergency mode of operation, the CREVS isolates unfiltered ventilation air supply intakes, filters the emergency ventilation air supply to the CRE, and pressurizes the CRE to minimize unfiltered air inleakage past the CRE boundary. The licensee proposed to delete the CRE pressurization SR. This SR requires verifying that one CREVS train, operating in the emergency mode, can maintain a pressure of 0.125 inch water gauge, relative to the adjacent the outside atmosphere during the pressurization mode of operation at a makeup flow rate between 800 cfm and 1000 cfm. The deletion of this SR is proposed because measurements of unfiltered air leakage into the CRE at numerous reactor facilities demonstrated that a basic assumption of this SR, an essentially leak-tight CRE boundary, was incorrect for most facilities.

Hence, meeting this SR by achieving the required CRE pressure is not necessarily a conclusive indication of CRE boundary leak tightness, i.e., CRE boundary operability. In its response to GL 2003-01, dated December 5, 2003, the licensee reported that it had determined that the Beaver Valley Power Station CRE pressurization surveillance, SR 3.7.10.4, was inadequate to demonstrate the operability of the CRE boundary, and proposed to replace it with an inleakage measurement SR and a CRE Habitability Program in TS Section 5.5, in accordance with the approved version of TSTF-448. Based on the adoption of TSTF-448, Revision 3, the licensee's proposal to delete SR 3.7.10.4 is acceptable.

The proposed CRE inleakage measurement SR states, "Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program." The CRE Habitability Program TS, proposed TS 5.5.14, requires that the program include "Requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of RG 1.197, Revision 0 (Reference 5). This guidance references ASTM E741 (Reference 2) as an acceptable method for ascertaining the unfiltered leakage into the CRE. The licensee has proposed to follow this method. Therefore, the proposed CRE inleakage measurement SR is acceptable.

3.4 TS 5.5.14, Control Room Envelope Habitability Program The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Revision 3. In combination with SR 3.7.10.4, this program is intended to ensure the operability of the CRE boundary, which as part of an operable CREVS will ensure that CRE habitability is maintained such that CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under DBA conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident.

A CRE Habitability Program TS acceptable to the NRC staff requires the program to contain the following elements:

  • Definitions of CRE and CRE boundary. This element is intended to ensure that these definitions accurately describe the plant areas that are within the CRE, and also the interfaces that form the CRE boundary, and are consistent with the general definitions discussed in Section 2.1 of this SE. Establishing what is meant by the CRE and the CRE boundary will preclude ambiguity in the implementation of the program.
  • Configuration control and preventive maintenance of the CRE boundary. This element is intended to ensure the CRE boundary is maintained in its design condition. Guidance for implementing this element is contained in RG 1.196 (Reference 4), which endorsed, with exceptions, Nuclear Energy Institute 99-03 (Reference 6). Maintaining the CRE boundary in its design condition provides assurance that its leak-tightness will not significantly degrade between CRE inleakage determinations.
  • Assessment of CRE habitability at the frequencies stated in Sections C.1 and C.2 of RG 1.197, Revision 0 (Reference 5), and measurement of unfiltered air leakage into the CRE in accordance with the testing methods and at the frequencies stated in Sections C.1 and C.2 of RG 1.197. [The licensee proposed the following exception[s] to Sections C.1 and C.2 of RG 1.197, to be listed in the TS with this program element.] [Insert plant-specific evaluation of licensee=s proposed exceptions.] This element is intended to ensure that the plant assesses CRE habitability consistent with Sections C.1 and C.2 of RG 1.197 [and NRC approved exceptions]. Assessing CRE habitability at the NRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not go undetected between CRE inleakage determinations. Determination of CRE inleakage using test methods acceptable to the NRC staff assures that test results are reliable for ascertaining CRE boundary operability. Determination of CRE inleakage at the NRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not occur between CRE inleakage determinations.
  • Measurement of CRE pressure with respect to all areas adjacent to the CRE boundary at designated locations for use in assessing the CRE boundary at a frequency of 18 months on a staggered test basis (with respect to the CREVS trains). This element is intended to ensure that CRE differential pressure is regularly measured to identify changes in pressure warranting evaluation of the condition of the CRE boundary. Obtaining and trending pressure data provides additional assurance that significant degradation of the CRE boundary will not go undetected between CRE inleakage determinations.
  • Quantitative limits on unfiltered inleakage. This element is intended to establish the CRE inleakage limit as the CRE unfiltered infiltration rate assumed in the CRE occupant radiological consequence analyses of design basis accidents. Having an unambiguous criterion for the CRE boundary to be considered operable in order to meet LCO 3.7.10 will ensure that associated action requirements will be consistently applied in the event of CRE degradation resulting in inleakage exceeding the limit.

Consistent with TSTF-448, Revision 3, the program states that the provisions of SR 3.0.2 are applicable to the program frequencies for performing the activities required by program paragraph number c, parts (i) and (ii) (assessment of CRE habitability and measurement of CRE inleakage), and paragraph number d (measurement of CRE differential pressure). This statement is needed to avoid confusion. SR 3.0.2 is applicable to the surveillance that references the testing in the CRE Habitability Program. However, SR 3.0.2 is not applicable to

Administrative Controls unless specifically invoked. Providing this statement in the program eliminates any confusion regarding whether SR 3.0.2 is applicable, and is acceptable.

Consistent with TSTF-448, Revision 3, proposed TS 5.5.14 states that (1) a CRE Habitability Program shall be established and implemented, (2) the program shall include all of the NRC-staff required elements, as described above, and (3) the provisions of SR 3.0.2 shall apply to program frequencies. Therefore, TS 5.5.14, which is consistent with the model program TS approved by the NRC staff in TSTF-448, Revision 3, is acceptable.

3.5 Implementation of New Surveillance and Assessment Requirements by the Licensee The licensee has proposed license conditions regarding the initial performance of the new surveillance and assessment requirements. The new license conditions adopted the conditions in Section 2.3 of the model application published in the Federal Register on January 17, 2007 (72 FR 2022). Plant-specific changes were made to these proposed license conditions. The proposed plant-specific license conditions are consistent with the model application, and are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change SRs.

The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding November 20, 2007 (72 FR 65365). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

7.0 REFERENCES

1. NRC Generic Letter 2003-01, "Control Room Habitability," dated June 12, 2003, (GL 2003-01).
2. ASTM E 741 - 00, "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution," 2000, (ASTM E741).
3. NRC Regulatory Issue Summary 2005-20: Revision to Guidance Formerly Contained in NRC Generic Letter 91-18," Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," dated September 26, 2005 (RIS 2005-20).
4. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, dated May 2003.
5. Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003.
6. NEI 99-03,"Control Room Habitability Assessment Guidance," Revision 0, dated June 2001.
7. FENOC, Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, August 30, 2007, ADAMS No. ML072470380
8. FENOC, 180 Day Response Letter to Generic Letter 2003-01, Control Room Habitability, December 5, 2003, ADAMS No. ML033430285 Principal Contributors: William Cartwright Alan Lising Date: February 15, 2008
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