ML081420058
| ML081420058 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/10/2008 |
| From: | Lyon C NRC/NRR/ADRO/DORL/LPLIV |
| To: | Minahan S Nebraska Public Power District (NPPD) |
| Lyon, C F, NRR/DLPM, 415-2296 | |
| References | |
| TAC MD7778 | |
| Download: ML081420058 (11) | |
Text
June 10, 2008 Mr. Stewart B. Minahan Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - CORRECTION TO AMENDMENT NO. 230, CONTROL ROOM ENVELOPE HABITABILITY (TAC NO. MD7778)
Dear Mr. Minahan:
The U.S. Nuclear Regulatory Commission (the Commission) issued the enclosed Amendment No. 230 to Facility Operating License No. DPR-46 for the Cooper Nuclear Station. The amendment consisted of changes to the Technical Specifications (TS) in response to your application dated January 14, 2008.
The amendment revises the TS requirements related to control room envelope habitability in accordance with TS Task Force (TSTF) traveler TSTF-448-A, Control Room Habitability, Revision 3. This TS improvement was made available by the Commission on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process (CLIIP).
Due to administrative error, revised license pages including the additional license conditions proposed in your application and discussed in the safety evaluation (SE) enclosed with Amendment No. 230, were inadvertently omitted. In addition, the following editorial errors were found in the SE, as discussed with Mr. D. Van Der Kamp of your staff on May 20, 2008.
- 1. In SE section 2.2, the second paragraph should read, "...after a Design Basis Accident (DBA) without exceeding 5 rem whole body dose or its equivalent to any part of the body following a loss-of-coolant accident (LOCA) or 5 rem total effective dose equivalent (TEDE) following a fuel handling accident."
- 2. In SE section 2.3, the first paragraph, second sentence should read, "...as originally proposed in July 1967."
- 3. In SE section 2.3, the fifth paragraph, second sentence should read, "NPPD states that this is not applicable."
- 4. In SE section 3.3, the third paragraph, last line, should read, "...existing Conditions B and C are re-designated as Conditions C and D, respectively."
- 5. In SE section 3.3, the fifth paragraph, the third line from the end should read, "This new Condition D is needed..."
- 6. In SE section 3.4, the first paragraph, the last line should read, "...without personnel receiving radiation exposures in excess of 5 rem whole body dose or
its equivalent to any part of the body following a loss-of-coolant accident (LOCA) or 5 rem total effective dose equivalent (TEDE) following a fuel handling accident."
Revised license pages and corrected SE pages are enclosed. The changes are identified by a vertical bar on the right. Please replace license pages 4 and 5 with the enclosed pages, and replace the affected pages in the May 12, 2008, SE with the revised pages. The enclosed changes do not affect the NRC staff's conclusion documented in the SE. If you have any questions concerning this matter, please call me at 301-415-2296.
Sincerely,
/RA/
Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosures:
- 1. Revised license pages 4 and 5
- 2. Corrected SE pages 3, 4, 8, and 9 cc w/encls: See next page
(s).: ML081420058 (*)Previously concurred OFFICE LPL4/PM LPL4/LA SCVB/BC OGC LPL4/BC NAME FLyon GLappert(*) RDennig(*) NOT REQD THiltz DATE 06/10/08 5/22/08 6/2/08 ML073130139 06/10/08 Cooper Nuclear Station (09/2007) cc:
Mr. Ronald D. Asche Mr. H. Floyd Gilzow President and Chief Executive Officer Deputy Director for Policy Nebraska Public Power District Missouri Department of Natural Resources 1414 15th Street P.O. Box 176 Columbus, NE 68601 Jefferson City, MO 65102-0176 Mr. Gene Mace Senior Resident Inspector Nuclear Asset Manager U.S. Nuclear Regulatory Commission Nebraska Public Power District P.O. Box 218 P.O. Box 98 Brownville, NE 68321 Brownville, NE 68321 Regional Administrator, Region IV Mr. John C. McClure U.S. Nuclear Regulatory Commission Vice President and General Counsel 611 Ryan Plaza Drive, Suite 400 Nebraska Public Power District Arlington, TX 76011 P.O. Box 499 Columbus, NE 68602-0499 Director, Missouri State Emergency Management Agency Mr. David Van Der Kamp P.O. Box 116 Licensing Manager Jefferson City, MO 65102-0116 Nebraska Public Power District P.O. Box 98 Chief, Radiation and Asbestos Brownville, NE 68321 Control Section Kansas Department of Health Mr. Michael J. Linder, Director and Environment Nebraska Department of Environmental Bureau of Air and Radiation Quality 1000 SW Jackson P.O. Box 98922 Suite 310 Lincoln, NE 68509-8922 Topeka, KS 66612-1366 Chairman Ms. Melanie Rasmussen Nemaha County Board of Commissioners Radiation Control Program Director Nemaha County Courthouse Bureau of Radiological Health 1824 N Street Iowa Department of Public Health Auburn, NE 68305 Lucas State Office Building, 5th Floor 321 East 12th Street Ms. Julia Schmitt, Manager Des Moines, IA 50319 Radiation Control Program Nebraska Health & Human Services R & L Mr. Keith G. Henke, Planner Public Health Assurance Division of Community and Public Health 301 Centennial Mall, South Office of Emergency Coordination P.O. Box 95007 930 Wildwood P.O. Box 570 Lincoln, NE 68509-5007 Jefferson City, MO 65102
Mr. Paul V. Fleming, Director of Nuclear Mr. John F. McCann, Director Safety Assurance Licensing, Entergy Nuclear Northeast Nebraska Public Power District Entergy Nuclear Operations, Inc.
P.O. Box 98 440 Hamilton Avenue Brownville, NE 68321 White Plains, NY 10601-1813
(5) Additional Conditions The Additional Conditions contained in Appendix C, as revised through Amendment No. 178, are hereby incorporated into this license. Nebraska Public Power District shall operate the facility in accordance with the Additional Conditions.
(6) Deleted (7) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:
(a) Fire fighting response strategy with the following elements:
- 1. Pre-defined coordinated fire response strategy and guidance
- 2. Assessment of mutual aid fire fighting assets
- 3. Designated staging areas for equipment and materials
- 4. Command and control
- 5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:
- 1. Protection and use of personnel assets
- 2. Communications
- 3. Minimizing fire spread
- 4. Procedures for implementing integrated fire response strategy
- 5. Identification of readily-available pre-staged equipment
- 6. Training on integrated fire response strategy
- 7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:
- 1. Water spray scrubbing
- 2. Dose to onsite responders (8) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.
Revised by letter dated August 9, 2007 Amendment No. 230 4 of 5
(9) Upon implementation of Amendment No. 230 adopting TSTF-448-A, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.4.4, in accordance with Specification 5.5.13.c.(i), the assessment of CRE habitability as required by Specification 5.5.13.c.(ii), and the measurement of CRE pressure as required by Specification 5.5.13.d, shall be considered met. Following implementation:
(a) The first performance of SR 3.7.4.4, in accordance with Specification 5.5.13.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from July 12, 2004, the date of the most recent successful tracer gas test. (The tracer gas test was stated to have been performed in July, 2004, in the September 30, 2004 letter response to Generic Letter 2003-01).
(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.13.c.(ii), shall be within the next 9 months.
(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.13.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from May 4, 2007, the date of the most recent successful pressure measurement test.
D. (Not Used)
E. This license is effective as of the date of issuance and shall expire at midnight, January 18, 2014.
FOR THE ATOMIC ENERGY COMMISSION ORIGINAL SIGNED BY A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:
Appendices A & B - Technical Specifications Appendix C - Additional Conditions Date of Issuance: January 18, 1974 Amendment No. 183, 230 5 of 5
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 safety evaluation, 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 Control Room Emergency Filter System (CREF)
The CREF (the term used at Cooper Nuclear Station 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 CREF 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 5 rem whole body dose or its equivalent to any part of the body following a loss-of-coolant accident (LOCA) or 5 rem total effective dose equivalent (TEDE) following a fuel handling accident.
The CREF consists of a single-train capable of maintaining the habitability of the CRE. CNS was licensed with a single-train CREF system. The CREF is considered operable when the individual components necessary to limit operator exposure are operable. The CREF is considered operable when the associated:
$ Fans are OPERABLE (one supply fan, the emergency booster fan and the exhaust booster fan);
$ High efficiency particulate air (HEPA) filter and charcoal adsorber are not excessively restricting flow and are capable of performing their filtration functions; and,
$ Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.
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 design basis accident 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. CNS was designed and constructed to meet the intent of the proposed 70 GDC for Nuclear Power Plants issued by the Atomic Energy Commission (AEC), as originally proposed in July 1967. A summary of these GDCs follows.
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. NPPD states they meet Criterion 1: Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences shall be designed, fabricated, and erected to quality standards that reflect the importance of the safety function to be 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. NPPD states they were designed to Criterion 2: Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences shall be designed, fabricated, and erected to performance standards that will allow the plant to withstand additional forces imposed by natural phenomena.
In accordance with 10 CFR 50.48(a), CNS is required to have a fire protection plan that is in compliance with 1971 GDC 3. Conformance with Draft GDC 3 is therefore superseded in its entirety by 1971 GDC 3. 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). NPPD states that this is not applicable. (An equivalent proposed-GDC (pre-1971) was not proposed). The CNS Environmental Qualification Program complies with 10 CFR 50.49. Systems and equipment which are required to function after accidents or transients are designed to withstand the most severe forces and environmental effects, including missiles from equipment failures. A High Energy Line Break (HELB) study demonstrated that the safe shutdown ability of CNS would not be degraded by a HELB. This study included the effects of pipe whip.
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. NPPD states that this is not applicable since CNS is a single unit nuclear power plant.
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
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 of new Required Action B.3 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.
To distinguish new Condition B from the existing condition for CREF inoperable, Condition A is revised to state, "CREF System inoperable for reasons other than Condition B. The change to existing Condition A is less restrictive because this Condition will no longer apply in the event the CREF System is inoperable due to an inoperable CRE boundary during unit operation in Mode 1, 2, 3. This is acceptable because the new Action B establishes adequate remedial measures in this condition. With the addition of a new Condition B, existing Conditions B and C are re-designated C and D, respectively.
The licensee also proposed to modify the CREF LCO by adding a NOTE allowing the CRE boundary to be opened intermittently under administrative controls. As stated in the LCO Bases, this NOTE "only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated." The allowance of this NOTE is acceptable because the administrative controls will ensure that the opening will be quickly sealed to maintain the validity of the licensing basis analyses of DBA consequences.
The licensee proposed to add a new condition to Action D of TS 3.7.4 that states, "CREF System inoperable due to an inoperable CRE boundary during movement of lately irradiated fuel assemblies in the secondary containment or during OPDRVs (operations with a potential for draining the reactor vessel)." The specified Required Actions proposed for this condition are the same as for the other existing condition for Action D, which states, ARequired Action and associated CT of Condition A not met during movement of lately irradiated fuel assemblies in the secondary containment or during OPDRVs.@ Accordingly, the new condition is stated with the other condition in Action D 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. This new Condition D is needed because proposed Action B will only apply in Modes 1, 2, and 3. As such, this change will ensure that the Actions table continues to specify a condition for an inoperable CRE boundary during refueling and OPDRVs. Therefore, this change is administrative and acceptable.
In the emergency radiation mode of operation, the CREF isolates normal unfiltered outside air intake path, 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 surveillance requirement (SR). This SR requires verifying that the CREF System operating in the emergency radiation mode can maintain a pressure of 0.1 inches water gauge relative to all adjacent areas during the pressurization mode of operation at a makeup flow rate of 990 cubic feet per minute (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 January 14, 2008, the licensee proposed to replace the CRE pressurization surveillance, SR 3.7.4.4, 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 3.7.4.4 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 5.5.13, 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 Regulatory Guide 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 5.5.13, CRE Habitability Program The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Revision 3. In combination with SR 3.7.4.4, this program is intended to ensure the operability of the CRE boundary, which as part of an operable CREF 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 design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body dose or its equivalent to any part of the body following a loss-of-coolant accident (LOCA) or 5 rem total effective dose equivalent (TEDE) following a fuel handling 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 safety evaluation. 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 Regulatory Guide 1.196 (Reference 4), which endorsed, with exceptions, NEI 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.