ML082320053

R. E. Ginna Nuclear Power Plant-Amendment Control Room Envelope Habitability

ML082320053
Person / Time
Site:	Ginna
Issue date:	08/27/2008
From:	Pickett D Plant Licensing Branch 1
To:	John Carlin Ginna
Pickett D
References
TAC MD6679
Download: ML082320053 (18)

Text

August 27, 2008 Mr. John T. Carlin Vice President R.E. Ginna Nuclear Power Plant R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT - AMENDMENT RE: CONTROL ROOM ENVELOPE HABITABILITY (TAC NO. MD6679)

Dear Mr. Carlin:

The Commission has issued the enclosed Amendment No.105 to Renewed Facility Operating License No. DPR-18 for the R.E. Ginna Nuclear Power Plant. This amendment is in response to your application dated August 16, 2007, as supplemented by letter dated June 16, 2008.

The amendment modifies Technical Specification (TS) requirements related to control room envelope habitability in TS 3.7.9, Control Room Emergency Air Treatment System (CREATS),

and TS section 5.5, Programs and Manuals. The changes are consistent with the Nuclear Regulatory Commission approved Industry/Technical Specification Task Force Traveler No. 448, Revision 3. The availability of this TS improvement was published in the Federal Register on January 17, 2007, as part of the consolidated line item improvement process.

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

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244

Enclosures:

1. Amendment No.105 to Renewed License No. DPR-18

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

August 27, 2008 Mr. John T. Carlin Vice President R. E. Ginna Nuclear Power Plant R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT - AMENDMENT RE: CONTROL ROOM ENVELOPE HABITABILITY (TAC NO. MD6679)

Dear Mr. Carlin:

The Commission has issued the enclosed Amendment No.105 to Renewed Facility Operating License No. DPR-18 for the R.E. Ginna Nuclear Power Plant. This amendment is in response to your application dated August 16, 2007, as supplemented by letter dated June 16, 2008.

The amendment modifies Technical Specification (TS) requirements related to control room envelope habitability in TS 3.7.9, Control Room Emergency Air Treatment System (CREATS),

and TS section 5.5, Programs and Manuals. The changes are consistent with the Nuclear Regulatory Commission approved Industry/Technical Specification Task Force Traveler No. 448, Revision 3. The availability of this TS improvement was published in the Federal Register on January 17, 2007, as part of the consolidated line item improvement process.

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

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244

Enclosures:

1. Amendment No.105 to Renewed License No. DPR-18

2. Safety Evaluation cc w/encls: See next page Package No.: ML082320210 Amendment No.: ML082320053 Tech Spec No.: ML082320161 OFFICE LPLI-1\PM LPLI-1\LA SCVB LPLI-1\BC NAME DPickett SLittle RDennig MKowal DATE 08 /21/ 08 08 /21 / 08 As signed 7/30/2008 08 /27/ 08 Official Record Copy

DATED: August 27, 2008 AMENDMENT NO.105 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-18 R.E. GINNA NUCLEAR POWER PLANT PUBLIC LPLI-1 R/F M. Kowal RidsNrrDorlLpla R. Dennig RidsNrrDssScvb S. Little RidsNrrLASLittle D. Pickett RidsNrrPMDPickett G. Hill (2)

H. Walker OGC RidsOgcMailCenter ACRS RidsAcrsAcnwMailCenter G. Dentel, RI

R.E. Ginna Nuclear Power Plant cc:

Mr. Michael J. Wallace, Vice-Chairman Mr. Charles Donaldson, Esquire Constellation Energy Assistant Attorney General 100 Constellation Way, Suite 1800P New York Department of Law Baltimore, MD 21202 120 Broadway New York, NY 10271 Mr. Henry B. Barron, President, CEO &

Chief Nuclear Officer Mr. George Bastedo, Director Constellation Energy Nuclear Group, Wayne County Emergency Management LLC Office 100 Constellation Way, Suite 200C Wayne County Emergency Operations Baltimore, MD 21202 Center 7336 Route 31 Kenneth Kolaczyk, Sr. Resident Lyons, NY 14489 Inspector R.E. Ginna Nuclear Power Plant Ms. Mary Louise Meisenzahl U.S. Nuclear Regulatory Commission Administrator, Monroe County 1503 Lake Road Office of Emergency Preparedness Ontario, NY 14519 1190 Scottsville Road, Suite 200 Rochester, NY 14624 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. Paul Eddy 475 Allendale Road New York State Department of King of Prussia, PA 19406 Public Service 3 Empire State Plaza, 10th Floor Mr. John P. Spath Albany, NY 12223 New York State Energy, Research, and Development Authority Mr. David F. Wilson 17 Columbia Circle Director, Licensing Albany, NY 12203-6399 R.E. Ginna Nuclear Power Plant 1503 Lake Road Mr. Paul Tonko Ontario, NY 14519 President and CEO New York State Energy, Research, and Mr. Gary L. Detter Development Authority Manager - Nuclear Safety and Security 17 Columbia Circle Constellation Energy Nuclear Group, Albany, NY 12203-6399 LLC 100 Constellation Way, Suite 200C Mr. Carey W. Fleming, Esquire Baltimore, MD 21202 Senior Counsel - Nuclear Generation Constellation Energy Nuclear Group, LLC 100 Constellation Way, Suite 1700P Baltimore, MD 21202

R.E. GINNA NUCLEAR POWER PLANT, LLC DOCKET NO. 50-244 R.E. GINNA NUCLEAR POWER PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 105 Renewed License No. DPR-18

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

A. The application for amendment filed by the R.E. Ginna Nuclear Power Plant, LLC (the licensee) dated August 16, 2007, as supplemented on June 16, 2008, 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 Renewed Facility Operating License No. DPR-18 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No.105, 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 60 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: August 27, 2008

ATTACHMENT TO LICENSE AMENDMENT NO.105 RENEWED FACILITY OPERATING LICENSE NO. DPR-18 DOCKET NO. 50-244 Replace the following pages of the Facility Operating License 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 3 5 5 6 6

- - -- 7 Replace the following pages of the 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 3.7.9-1 3.7.9-1 3.7.9-2 3.7.9-2

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3.7.9-3 5.5-1 5.5-1 5.5-2 5.5-2 5.5-3 5.5-3 5.5-4 5.5-4 5.5-5 5.5-5 5.5-6 5.5-6 5.5-7 5.5-7 5.5-8 5.5-8 5.5-9 5.5-9 5.5-10 5.5-10 5.5-11 5.5-11 5.5-12 5.5-12

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5.5-13

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 105 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-18 R.E. GINNA NUCLEAR POWER PLANT, LLC R.E. GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244

1.0 INTRODUCTION

By application dated August 16, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072350432), R.E. Ginna Nuclear Power Plant, LLC (the licensee) requested changes to the Technical Specifications (TS) for the R.E. Ginna Nuclear Power Plant. The supplemental letter dated June 16, 2008 (ADAMS Accession No. ML081750264), provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on October 23, 2007 (72 FR 60035).

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 (72 FR 2022).

Consistent with the traveler as incorporated into NUREG-1431, the licensee proposed revising action and SRs in Specification 3.7.9, "Control Room Emergency Air Treatment System (CREATS)," and adding a new administrative controls program, Specification 5.5.16, "CRE 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.

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 "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 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 Air Treatment System (CREATS)

The CREATS (the term use at Ginna 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 CREATS 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 CREATS consists of two redundant trains each capable of maintaining the habitability of the CRE. The CREATS is considered operable when the individual components necessary to limit operator exposure are operable in both trains. A CREATS train is considered operable when the associated:

$ Recirculation fan is operable and capable of providing forced flow:

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

$ Ductwork and dampers associated with the operable CREATS fan are operable, and the CREATS filter flow is a nominal 6000 cfm; and

$ CRE dampers are operable. Dampers AKD03, AKD21, and AKD23 are associated with the A train. Dampers AKD02, AKD22, and AKD24 are associated with the B train.

The CRE automatic isolation dampers are considered operable when the damper can close on an actuation signal to isolate outside air or is closed with motive force removed. As an alternate, the redundant isolation damper may be closed with the motive force removed, such that the flow path is not susceptible to the single active failure.

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. Section 3.1 of Ginnas Updated Final Safety Analysis Report, Conformance With NRC General Design Criteria, states that the discussion of GDC is divided into two parts. Section 3.1.1 discusses the GDC used during the licensing of Ginna Station. Section 3.1.2 discusses the adequacy of the Ginna design relative to the 1972 version of the GDC in 10 CFR Part 50, Appendix A.

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 CREATS train can maintain a positive pressure relative to 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 CREATS have similar SRs. Other facilities that do not pressurize the CRE have only a system flow rate criterion for the emergency mode of operation. 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 (AL) 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," (AL 98-10) 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 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(c)(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(c) (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 R.E. Ginna Nuclear Power Plant, LLC Adoption of TSTF-448, Revision 3, will assure that the facility's TS LCO for the CREATS 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 CREATS and the CRE boundary conform to 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3). Their adoption will better assure that Ginna's 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 CREATS at Ginna isolates but does not pressurize 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 3.7.9, CREATS 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, 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 5.5.13, "TS Bases Control Program," provides assurance that the licensee has established and will maintain the adequacy of the Bases. The proposed Bases for TS 3.7.9 refer to RG 1.196 (Reference 4).

3.2 Editorial Changes The licensee proposed editorial changes to TS 3.7.9, "CREATS," to establish standard terminology, such as "control room envelope (CRE)" in place of "control room," except for the plant-specific name for the CREEVS, (CREATS) These changes improve the usability and quality of the presentation of the TS, have no impact on safety, and therefore, are acceptable.

3.3 TS 3.7.9, CREATS The licensee proposed to establish new action requirements in TS 3.7.9, "CREATS," for an inoperable CRE boundary. Currently, if one CREATS train is determined to be inoperable due to an inoperable CRE boundary, existing Action A would apply and require restoring the train (and the CRE boundary) to operable status in 7 days. If two trains are determined to be inoperable due to an inoperable CRE boundary, existing Action D specifies no time to restore the trains (and the CRE boundary) to operable status, but requires immediate entry into the shutdown actions of LCO 3.0.3. 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 add a new Condition B, "One or more CREATS trains inoperable due to inoperable CRE boundary in MODE 1, 2, 3 or 4." New Action B would allow 90 days to restore the CRE boundary (and consequently, the affected CREATS trains) to operable status, provided that mitigating actions are immediately implemented and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are verified to ensure, that in the event of a DBA, CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke.

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. 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 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 one CREATS train inoperable, Condition A is revised to state, "One CREATS train inoperable for reasons other than Condition B." To distinguish new Condition B from the existing condition for two CREATS trains inoperable, Condition D (renumbered as Condition F) is revised to state, "Two CREATS trains inoperable during MODE 1, 2, 3 or 4 for reasons other than Condition B." The changes to existing Conditions A and D are less restrictive because these Conditions will no longer apply in the event one or two CREATS trains are inoperable due to an inoperable CRE boundary during unit operation in Mode 1, 2, 3 or 4. 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, C, E, and D are re-designated C, D, E, and F, respectively.

The licensee also proposed to modify the CREATS 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 E of TS 3.7.9 that states, "One or more CREATS trains inoperable due to an inoperable CRE boundary during movement of irradiated fuel assemblies." The specified Required Action proposed for this condition is the same as for the existing condition of Action E which states ATwo CREATS trains inoperable during movement of irradiated fuel assemblies.@ Accordingly, the new condition is stated with the other condition in Action E using the logical connector "OR" in accordance with the STS writer's guide (TSTF-GG-05-01, AWriter=s Guide for Plant-Specific Improved Technical Specifications,@

June 2005). The practical result of this presentation in format is the same as specifying two separately numbered Actions, one for each condition. It makes the TS Actions table easier to use by avoiding 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 movement of irradiated fuel assemblies. Therefore, this change is administrative and acceptable.

The CREATS is an emergency system. In the emergency mode of operation, actuation of the CREATS starts both recirculation fans and closes dampers. This action isolates the CRE and begins cleanup recirculation of the control room environment. The CREATS consists of two independent, redundant trains that recirculate and filter the air in the CRE. The CRE boundary limits the inleakage of unfiltered air. Each CREATS train consists of a pre-filter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodine), and a fan. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system. A second bank of filters follows the adsorber section to collect carbon fines. The licensee proposed a new surveillance, SR 3.7.9.4, to Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program. The CRE Habitability Program is described in TS Section 5.5, in accordance with the approved version of TSTF-448. Based on the adoption of TSTF-448, Revision 3, the licensees proposal to add new SR 3.7.9.4 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 5.5.16, 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 5.5.16, 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 3.7.9.4, this program is intended to ensure the operability of the CRE boundary, which as part of an operable CREATS 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 total effective dose equivalent (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. 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.

Licensee controlled programs will be used to verify the integrity of the CRE boundary.

Conditions that generate relevant information from those programs will be entered into the corrective action process, trended and used as part of a 36-month assessment program for the CRE boundary. The NRC staff recognizes that non-pressurized CREs may not be able to conduct a differential pressure (dp) test, nevertheless, the staff believes that all plants requesting the adoption of TSTF-448 should include in their request, a method to collect data that will serve as input to a periodic assessment of the CRE boundary. The use of programs to verify the integrity of the CRE boundary, the use of a corrective action program, trending of relevant information as part of the assessment program will provide 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 LCO 3.7.9, 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). 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 5.5.16 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 5.5.16, 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 New York 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 installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. 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 (72 FR 60035). 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. NRC Generic Letter 2003-01, "Control Room Habitability," dated June 12, 2003, (GL 2003-01).

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. 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.

Principal Contributor: H. Walker Date: August 27, 2008