ML081790194

License Amendment No. 257, Added New License Condition and Revised Technical Specifications, Related to Control Room Habitability in Accordance with TSTF-448 Using CLIIP

ML081790194
Person / Time
Site:	Fort Calhoun
Issue date:	06/30/2008
From:	Markley M NRC/NRR/ADRO/DORL/LPLIV
To:	Bannister D Omaha Public Power District
Markley M, NRR/DORL/LPL4, 301-415-5723
References
TAC MD5577
Download: ML081790194 (20)

Text

June 30, 2008 Mr. David J. Bannister Vice President and CNO Omaha Public Power District Fort Calhoun Station FC-2-4 Post Office Box 550 Fort Calhoun, NE 68023-0550

SUBJECT:

FORT CALHOUN STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT RE:

CONTROL ROOM ENVELOPE HABITABILITY (TAC NO. MD5577)

Dear Mr. Bannister:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 257 to Renewed Facility Operating License No. DPR-40 for the Fort Calhoun Station, Unit No. 1.

The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated May 16, 2007.

The amendment revises the TS requirements related to the control room envelope habitability in accordance with TS Task Force (TSTF) Traveler TSTF-448-A, Revision 3, Control Room Habitability. The amendment also adds a license condition regarding initial performance of new surveillance and assessment requirements. The TS improvement was published in the Federal Register on January 17, 2007 (72 FR 2022), as part of the consolidated line item improvement process.

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

Sincerely,

/RA by Jack Donohew for/

Michael T. Markley, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-285

Enclosures:

1. Amendment No. 257 to DPR-40

2. Safety Evaluation cc w/encls: See next page

Pkg ML081790191, Amdt. ML081790194, License/App B/TS Pgs ML081790257

(*) Concurrence SE Input

(**)Concurrence via e-mail OFFICE NRR/LPL4/PM NRR/LPL4/PM NRR/LPL4/LA NRR/DIRS/ITSB/BC OGC (waiver)

NRR/LPL4/BC NRR/LPL4/PM NAME MMarkley (**)

JDonohew JBurkhardt RElliott (*)

(ML072980233)

THiltz MMarkley, JND for DATE 6/29/08 6/30/08 6/27/08 5/15/08 & 6/12/08 6/30/08 6/30/08

Ft. Calhoun Station, Unit 1 (6/10/2008) cc:

Winston & Strawn ATTN: David A. Repke, Esq.

1700 K Street, N.W.

Washington, DC 20006-3817 Chairman Washington County Board of Supervisors P.O. Box 466 Blair, NE 68008 Mr. John Hanna, Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 310 Fort Calhoun, NE 68023 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R & L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Mr. Thomas C. Matthews Manager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 550 Fort Calhoun, NE 68023-0550 Ms. Melanie Rasmussen Radiation Control Program Officer Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319

OMAHA PUBLIC POWER DISTRICT DOCKET NO. 50-285 FORT CALHOUN STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 257 Renewed License No. DPR-40

1.

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

A.

The application for amendment by the Omaha Public Power District (the licensee), dated May 16, 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 license 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.

ENCLOSURE 1

2.

Accordingly, Renewed Facility Operating License No. DPR-40 is amended by changes as indicated in the attachment to this license amendment. Paragraph 3.B. of Renewed Facility Operating License No. DPR-40 is hereby amended to read as follows:

B.

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 257, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

In addition, paragraph 3.F. of Renewed Facility Operating License No. DPR-40 is hereby amended to read as follows:

F.

Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 257, are hereby incorporated into this license. Omaha Public Power District shall operate the facility in accordance with the Additional Conditions.

3.

Appendix B, Additional Conditions, to Renewed Facility Operating License DPR-40 is amended to add a new license condition (4), designated as Amendment No. 257, to read as follows:

(4)

Upon implementation of Amendment No. 257 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by TS 3.1, Table 3-3, Item 10.b. in accordance with TS 5.24c.(i), the assessment of CRE habitability as required by Specification 5.24c.(ii), and the measurement of CRE pressure as required by Specification 5.24d, shall be considered met. Following implementation:

(a)

The first performance of TS 3.1, Table 3-3, Item 10.b., in accordance with Specification 5.24c.(i), shall be within the next 18 months as the time period since the most recent successful tracer gas test is greater than 6 years.

(b)

The first performance of the periodic assessment of CRE habitability, Specification 5.24c(ii), shall be within the next 9 months as the time period since the most recent successful tracer gas test is greater than 3 years.

(c)

The first performance of the periodic measurement of CRE pressure, Specification 5.24d., shall be within the next 138 days.

4.

The license amendment is effective as of its date of issuance and shall be implemented within 270 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Thomas G. Hiltz, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-40 and Technical Specifications Date of Issuance: June 30, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 257 RENEWED FACILITY OPERATING LICENSE NO. DPR-40 DOCKET NO. 50-285 Replace the following pages of the Renewed Facility Operating License No. DPR-40, the Appendix A Technical Specifications, and Appendix B, Additional Conditions, with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

License Pages REMOVE INSERT Page 3 Page 3 Page 4 Page 4 Technical Specifications REMOVE INSERT REMOVE INSERT TOC - Page 1 TOC - Page 1 3.1 - Page 17 3.1 - Page 18 TOC - Page 3 TOC - Page 3 3.1 - Page 18 3.1 - Page 19 2.8 - Page 7 2.8 - Page 7 3.1 - Page 19 3.1 - Page 20 2.8 - Page 8 2.8 - Page 8 3.1 - Page 20 3.1 - Page 21 2.8 - Page 13 2.8 - Page 13 3.1 - Page 21 3.1 - Page 22 2.12 - Page 1 2.12 - Page 1 3.1 - Page 22 3.1 - Page 23 2.12 - Page 2 2.12 - Page 2 3.2 - Page 1 3.2 - Page 1 3.1 - Page 3 3.2 - Page 2 3.2 - Page 3 3.1 - Page 3 3.1 - Page 4 3.2 - Page 3a 3.2 - Page 4 3.1 - Page 4 3.1 - Page 5 3.2 - Page 3b 3.2 - Page 5 3.1 - Page 5 3.1 - Page 6 3.2 - Page 4 3.2 - Page 6 3.1 - Page 6 3.1 - Page 7 3.2 - Page 5 3.2 - Page 7 3.1 - Page 7 3.1 - Page 8 3.2 - Page 6 3.2 - Page 8 3.1 - Page 8 3.1 - Page 9 3.2 - Page 7 3.2 - Page 9 3.1 - Page 9 3.1 - Page 10 3.2 - Page 8 3.2 - Page 10 3.1 - Page 10 3.1 - Page 11 3.2 - Page 9 3.2 - Page 11 3.1 - Page 11 3.1 - Page 12 3.2 - Page 10 3.2 - Page 12 3.1 - Page 12 3.1 - Page 13 3.2 - Page 11 3.2 - Page 13 3.1 - Page 13 3.1 - Page 14 3.2 - Page 12 3.2 - Page 14 3.1 - Page 14 3.1 - Page 15 3.2 - Page 13 3.2 - Page 15 3.1 - Page 15 3.1 - Page 16 5.0 - Page 21 3.1 - Page 16 3.1 - Page 17 Appendix B REMOVE INSERT Appendix B - Page 2

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 257 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285

1.0 INTRODUCTION

By application dated May 16, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML071380058), Omaha Public Power District (OPPD, the licensee) requested changes to the Technical Specifications (TS, Appendix A) and Additional Conditions (Appendix B) to Renewed Facility Operating License No. DPR-40) for the Fort Calhoun Station (FCS), Unit No. 1. The proposed changes are to adopt the U.S. Nuclear Regulatory Commission (NRC)-approved Industry/TS Task Force (TSTF) Traveler TSTF-448, Revision 3.

The availability of this TS improvement was published in the Federal Register on January 17, 2007 (72 FR 2022), as part of the Consolidated Line Item Improvement Process.

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 a letter dated December 5, 2003 (ADAMS Accession No. ML033430569), the licensee provided additional information related to Nuclear Regulatory Commission (NRC) Generic Letter (GL) 2003-01, Control Room Habitability (Reference 1). In NRC GL 2003-01, licensees were alerted to findings at facilities that existing TS surveillance requirements 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 control room envelope 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 ENCLOSURE 2

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 generic letter, 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-1432, the licensee proposed revising action and surveillance requirements in the following TS Limiting Conditions for Operation (LCOs):

2.8.2(4), Refueling Operations - Containment, Control Room Ventilation System (CRVS) 2.8.3(5), Refueling Operations - Spent Fuel Pool, Control Room Ventilation System (CRVS) 2.12.1, Control Room Ventilation Systems, Control Room Air Filtration System - Operating The revision would also modify Surveillance Requirements (SR) in TS SR 3.1, Instrumentation and Control, and 3.2, Equipment and Sampling Tests. A new administrative program, TS 5.24, Control Room Envelope Habitability Program, is also proposed. 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. The staff review and approval includes the associated TS Bases and supporting Updated Safety Analysis Report (USAR) Appendix G sections related to the CRVS.

In a memorandum dated February 2, 2007 (ADAMS Accession No. ML070330657), the staff issued a revised model license condition regarding the initial performance of new surveillance and assessment requirements. The OPPD application dated May 16, 2007, proposes a license condition according to the revised NRC model.

The licensee also identified changes to the TS Bases in Attachment 2 to its application.

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 3), uses the term "control room envelope (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 4), 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.

2.2 Control Room Ventilation System (CRVS)

The CRVS 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 CRVS 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 roentgen equivalent man (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 CRVS consists of two redundant trains, each capable of maintaining the habitability of the CRE. The CRVS is considered operable when the individual components necessary to limit operator exposure are operable in both trains. A CRVS 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, demister, ductwork, valves, and dampers are operable, and air circulation can be maintained; and CRE boundary is operable (the single boundary supports both 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 Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR), Technical Specifications, the NRC established its regulatory requirements related to the content of TS.

Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. The rule does not specify the particular requirements to be included in a plants TS. As stated in 10 CFR 50.36(d)(2)(i), the [l]imiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulations in 10 CFR 50.36(d)(3) state that [s]urveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components will be maintained within safety limits, and that the limiting conditions for operation will be met.

In a memorandum dated September 18, 1992, the Commission approved the staff proposal in SECY-92-223, Resolution of Deviations Identified During the Systematic Evaluation Program (ADAMS Accession No. ML003763736) (Reference 5), not to apply 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, to plants with construction permits prior to May 21, 1971. FCS was licensed for construction prior to May 21, 1971, and at that time committed to the draft General Design Criteria (GDC). The draft GDC, which are similar to Appendix A, General Design Criteria for Nuclear Power Plants in 10 CFR Part 50, are contained in Appendix G of the FCS USAR.

FCS Design Criteria 1, 2, 3, 4, 5, 11, 23, and 40 apply to CRE habitability. A summary of the applicable criteria follows.

FCS Criterion 1, Quality Standards, requires those systems and components of reactor facilities which are essential to the prevention of accidents which could effect public health and safety or to mitigation of their consequences shall be identified and then designed, fabricated, and erected to quality standards that reflect the importance of the safety function to be performed.

FCS Criterion 2, Performance Standards, requires that those systems and components of reactor facilities which are essential to the prevention of accidents which could affect public health and safety or to mitigation of their consequences shall be designed, fabricated, and erected to performance standards that will enable the facility to withstand, without loss of capability to protect the public, the additional forces that might be imposed by natural phenomena such as earthquakes, tornadoes, flooding conditions, winds, ice and other local site effects.

FCS Criterion 3, Fire Protection, requires that the reactor facility be designed (1) to minimize the probability of events such as fires and explosions and (2) to minimize the potential effects of such events to safety. Noncombustible and fire resistant materials shall be used whenever practical throughout the facility, particularly in areas containing critical portions of the facility such as containment, control room, and components of engineered safety features.

FCS Criterion 4, Sharing of Systems, requires that reactor facilities not share systems or components unless it is shown safety is not impaired by the sharing.

FCS Criterion 5, Records Requirement, requires records of the design, fabrication, and construction of essential components of the plant shall be maintained by the reactor operator or under its control throughout the life of the reactor.

FCS Criterion 11, Control Room, requires that the facility be provided with a control room from which actions to maintain safe operational status of the plant can be controlled. Adequate radiation protection shall be provided to permit access, even under accident conditions, to equipment in the control room or other areas as necessary to shutdown and maintain safe control of the facility without radiation exposures of personnel in excess of 10 CFR 20 limits. It shall be possible to shut the reactor down and maintain it in a safe shutdown condition if access to the control room is lost due to fire or other accident causes.1 FCS Criterion 23, Protection Against Multiple Disability for Protection Systems, requires the effects of adverse conditions to which redundant channels or protection systems might be exposed in common, either under normal conditions or those of an accident, shall not result in loss of protection function.

FCS Criterion 40, Missile Protection, requires that protection for engineered safety features shall be provided against the dynamic effects and missiles that might result from plant equipment failures.

Prior to incorporation of TSTF-448, Revision 3, the STS requirements addressing CRE boundary operability resided primarily in the CRE ventilation system specifications of NUREG-1432, TS 3.7.11, Control Room Emergency Air Cleanup System (CREACS). In this specification, the 1

Amendment 201 to FCS Renewed Facility Operating License, issued December 5, 2001 (Reference 7), allowed the current alternative source term (AST) used in design-basis radiological accidents for control room habitability to be replaced with an AST in accordance with 10 CFR 50.67, and following the guidance of RG 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. Holders of operating licenses using AST shall meet the requirements of 10 CFR 50, Appendix A, GDC 19, except that with regard to the control room access and occupancy, adequate protection shall be provided to ensure that radiation exposures shall not exceed 0.05 Sievert (5 rem) TEDE as defined in 10 CFR 50.2 for the duration of the event.

SR associated with demonstrating the operability of the CRE boundary requires verifying that one CRVS 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 CRVS have similar SRs. Regardless, the results of ASTM E741 (Reference 2) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance (or the alternative surveillance at non-pressurization facilities) 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 Issue Summary (RIS) 2005-20 (Reference 5)]. Imposing 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 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 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 FCS Unit 1 Adoption of TSTF-448, Revision 3, will assure that the facility's TS LCO for the CRVS 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) of 6 years, 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 CRVS and the CRE boundary conform to 10 CFR 50.36(d)(2) and 10 CFR 50.36(d)(3). Although FCS Unit 1 does not have the STS format, its adoption of these changes is consistent with NRC-approved Industry/TSTF STS change TSTF-448, Revision 3. The adoption of these changes will better assure that the FCS Unit 1 CRE will remain habitable during normal operation and DBA conditions. These changes are, therefore, considered appropriate for use at FCS.

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 CRVS at FCS Unit 1, 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 LCOs 2.8.2(4), 2.8.3(5), and 2.12.1, 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 to the latest information and references, correct factual errors, and achieve more consistency among the STS NUREGs. Except for plant-specific differences, 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. Approval of the identified TB Bases is through Specification 5.20, Technical Specification (TS) Bases Control Program. This provides assurance that the licensee has established correct Bases for the TSs, is not changing the licensing basis of the plant without NRC review and approval, and will maintain the adequacy of the TS Bases. The proposed Bases for the TS LCOs 2.8.2(4), 2.8.3(5), and 2.12.1 refer to specific guidance in Nuclear Entergy Institute (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, Control Room Habitability at Light-Water Nuclear Power Reactors, dated May 2003 (Reference 3). Based on its review of the changes to the TS Bases, the NRC staff has not identified any problems with the identified changes.

3.2 Editorial Changes The licensee proposed editorial changes to TS LCOs 2.8.2(4), 2.8.3(5), and 2.12.1 to establish standard terminology, such as control room envelope (CRE) in place of control room, except for the plant-specific name for the CRVS, and radiological, chemical, and smoke hazards (or challenges) in place of various phrases to describe the hazards that CRE occupants are protected from by the CRVS. The licensee has also proposed changes to the TS Tables of contents to (1) change the title of Specification 2.12, "Control Room Systems," to Control Room Ventilation Systems and (2) to add the new Specification 5.24, "Control Room Habitability Program." These changes improve the usability and quality of the presentation of the TS, have no negative impact on safety, do not add any requirements to the TSs, and, therefore, are acceptable.

3.3 Revisions to TS LCOs: 2.8.2(4), Refueling Operations - Containment, Control Room Ventilation System (CRVS); 2.8.3(5), Refueling Operations - Spent Fuel Pool, Control Room Ventilation System (CRVS); and 2.12.1, Control Room Ventilation Systems, Control Room Air Filtration System - Operating The licensee proposed to establish new action requirements in CRVS TS LCOs for an inoperable CRE boundary. Currently, if one CRVS train is determined to be inoperable, the required action is to restore the train to operable status in 7 days. If two trains are determined to be inoperable due to an inoperable CRE boundary, FCS Custom TS (CTS) does not specify a time to restore the trains (and the CRE boundary) to operable status, but requires immediate entry into the shutdown actions of LCO 2.0.1. These existing Actions are more restrictive than would be appropriate in situations for which CRE occupant implementation of compensatory measures or mitigating actions would temporarily afford adequate CRE occupant protection from postulated airborne hazards. To account for such situations, the licensee proposed to revise the action requirements to insert the following new Required Action (2) to TS CTS 2.12.1, Control Room Air Filtration System - Operating: "With one or more control room air filtration trains inoperable due to inoperable CRE boundary." The new Required Action would allow 90 days to restore the CRE boundary (and consequently, the affected CRVS trains) to operable status, provided that mitigating actions are initiated immediately and mitigating actions to ensure CRE occupant exposures to radiological, chemical, and smoke hazards are verified not to exceed limits within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24-hour Completion Time of the new Required Action 2.12.1(2) is reasonable based on the low probability of a DBA occurring during this time period, and the use of 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. The 90-day Completion Time of the new Required Action 2.12.1(2) is a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary. Therefore, proposed Required Action 2.12.1(2) is acceptable.

Existing TS LCO 2.12.1 Required Actions (2) and (3) are renumbered to be (3) and (4),

respectively, with conforming changes to indicate applicability of new Required Action (2). To

distinguish the new Required Action 2.12.1(2) from the existing condition for one CRVS train inoperable, Required Action 2.12.1(1) is revised to state, With one control room air filtration train inoperable for reasons other than (2) Also the renumbered Required Actions (3) and (4) have the phrase "or (2)" [for Required Action (3)] or the phrase "for reasons other than (2)" [for Required Action (4)] added to their text.

An additional Required Action for one or more CRVS trains inoperable is added to FCS CTS 2.8.2(4) that states, If one or more CRVS trains are inoperable due to an inoperable control room envelope (CRE) boundary, immediately suspend CORE ALTERATIONS and REFUELING OPERATIONS. Similarly an additional Required Action and Condition for one or more CRVS trains inoperable is added to FCS CTS 2.8.3(5) that states, If one or more CRVS trains are inoperable due to an inoperable control room envelope (CRE) boundary, immediately suspend REFUELING OPERATIONS. These changes are less restrictive because these Required Actions only apply in the event one or more CRVS trains are inoperable due to an inoperable CRE boundary. This is acceptable because the new Required Actions of FCS CTS 2.8.2(4) and 2.8.3(5) establish adequate remedial measures in the described conditions.

The licensee also proposed to modify the TS by adding a Note to the Specifications of LCOs 2.8.2(4), 2.8.3(5), and 2.12.1 allowing the CRE boundary to be opened intermittently under administrative controls. A second Note is added to the Specifications for TS LCOs 2.8.2(4) and 2.8.3(5) that calls for the CRVS to be placed in toxic gas protection mode if automatic transfer of toxic gas protection mode is not functional. 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 second Note requires provides for the management of fans and air dampers for CRVS recirculation mode. This is acceptable to the staff.

The licensee proposed to add a new Required Action (2) to TS LCO 2.8.2(4) and new Required Action (3) to TS LCO 2.8.3(5) that states, If one or more CRVS trains are inoperable due to an inoperable control room envelope (CRE) boundary, immediately suspend CORE ALTERATIONS and REFUELING OPERATIONS. During core alterations and refueling operations, TS LCO 2.8.2(4) and TS LCO 2.8.3(5) requires that the CRVS to be in operation in Filtered Air mode.

Therefore, to achieve the effects of the TSTF-448, Revision 3, Combustion-Engineering Owners Group (CEOG) STS, Condition E, OR statement, a new required action was added to TS 2.8.2(4) and 2.8.3(5). The new action requires the suspension of CORE ALTERATIONS and REFUELING OPERATIONS if one or more CRVS trains are inoperable due to an inoperable CRE boundary. The new Required Action is needed to ensure that the Required Action continues to specify a condition for an inoperable CRE boundary during CORE ALTERATIONS and REFUELING OPERATIONS, and during REFUELING OPERATIONS in the spent fuel pool areas. Therefore, this change is administrative and acceptable to the staff.

In the emergency radiation state of operation, the CRVS, including the Control Room Air Filtration System (CRAFS), 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 CRVS train operating in the emergency radiation state, can maintain a pressure of 0.125 inches water gauge, relative to the adjacent external areas during the pressurization mode of operation at a makeup flow rate of at least 3000 cfm (cubic feet per minute). The modification 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. Based on the adoption of TSTF-448, Revision 3, the licensees proposal to modify the SR found in FCS CTS 3.1, Table 3-3, Item 10.b, is acceptable to the staff.

The proposed CRE inleakage measurement SR states, Perform required control room envelope (CRE) unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program. The CRE Habitability Program TS, proposed TS 5.24, 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 4). This guidance references ASTM E741 (Reference 2) as an acceptable method for ascertaining the unfiltered leakage into the CRE. Therefore, the proposed CRE inleakage measurement SR is acceptable.

3.4 TS 5.24 on the CRE Habitability Program The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Revision 3. In combination with SRs found in FCS CTS 3.1, Table 3-3, Item 10.b, this program is intended to ensure the operability of the CRE boundary, which as part of an operable CRVS 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 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 RG 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.

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: This element is intended to ensure that the plant assesses CRE habitability consistent with Sections C.1 and C.2 of RG 1.197. Assessing CRE habitability at the frequencies specified in RG 1.197 provides assurance that significant degradation of the CRE boundary will not go undetected between CRE inleakage determinations. Determination of CRE inleakage using test methods specified in RG 1.197 assures that test results are reliable for ascertaining CRE boundary operability. Determination of CRE inleakage at the frequencies specified in RG 1.197 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: 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 DBAs. Having an unambiguous criterion for the CRE boundary to be considered operable in order to meet FCS CTS, 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 3.0.1 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 3.0.1 is applicable to the surveillance that references the testing in the CRE Habitability Program. However, SR 3.0.1 is not applicable to Administrative Controls unless specifically invoked. Providing this statement in the program eliminates any confusion regarding whether SR 3.0.1 is applicable, and is acceptable.

Consistent with TSTF-448, Revision 3, proposed TS 5.24 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 3.0.1 shall apply to program frequencies. Therefore, TS 5.24, which is consistent with the model program TS approved by the NRC staff in TSTF-448, Revision 3, is acceptable.

3.5 License Conditions In the OPPD letter dated May 16, 2007, the licensee agreed to add license conditions related to the initial performance of new surveillance and assessment requirements. Appendix B,

Additional Conditions, to Renewed Facility Operating License DPR-40 is amended to add a new license condition (4), designated as Amendment No. 257, to read as follows:

(4)

Upon implementation of Amendment No. 257 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by TS 3.1, Table 3-3, Item 10.b. in accordance with TS 5.24c.(i), the assessment of CRE habitability as required by Specification 5.24c.(ii), and the measurement of CRE pressure as required by Specification 5.24d, shall be considered met.

Following implementation:

(a)

The first performance of TS 3.1, Table 3-3, Item 10.b., in accordance with Specification 5.24c.(i), shall be within the next 18 months as the time period since the most recent successful tracer gas test is greater than 6 years.

(b)

The first performance of the periodic assessment of CRE habitability, Specification 5.24c(ii), shall be within the next 9 months as the time period since the most recent successful tracer gas test is greater than 3 years.

(c)

The first performance of the periodic measurement of CRE pressure, Specification 5.24d., shall be within the next 138 days.

The license conditions are based on the model license condition issued by the NRC on February 2, 2007 (ADAMS Accession No. ML070330657). Therefore, the proposed license condition is acceptable to the staff.

3.6 Conclusions In Sections 3.2 through 3.4 of this safety evaluation, the NRC staff addressed the licensee's proposed changes to the TSs. Based on the staff's conclusions that these changes are acceptable, the NRC staff also concludes that the proposed changes to the TSs meet 10 CFR 50.36. Based on this and the conclusion in Section 3.5 of this safety evaluation that the proposed license conditions are acceptable, the NRC staff further concludes that the proposed amendment is acceptable.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration and there has been no public comment on such finding

published in the Federal Register on June 19, 2007 (72 FR 33784). Accordingly, the amendment meets 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 amendment.

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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1.

U.S. Nuclear Regulatory Commission, Generic Letter 2003-01, Control Room Habitability, dated June 12, 2003 (ADAMS Accession No. ML031620248).

2.

ASTM E741 - 00, Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution, 2000 (ASTM E741).

3.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.196, Revision 0, Control Room Habitability at Light-Water Nuclear Power Reactors, dated May 2003 (ADAMS Accession No. ML031490611).

4.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.197, Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors, Revision 0, May 2003 (ADAMS Accession No. ML031490664).

5.

U.S. Nuclear Regulatory Commission, 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 (ADAMS Accession No. ML052020424).

6.

Nuclear Energy Institute (NEI) 99-03, Control Room Habitability Assessment Guidance, Revision 0, June 2001 (ADAMS Accession No. ML020600236).

7.

Letter dated December 5, 2001, from A. B. Wang, NRC,

Subject:

Fort Calhoun Station, Unit No. 1, Issuance of Amendment [201] (TAC No. MB1221) (ADAMS Accession No. ML013030027).

Principal Contributor: A. Lising R. Grover Date: June 30, 2008