ML082840761

Issuance of Amendments Regarding Control Room Habitability

ML082840761
Person / Time
Site:	Sequoyah
Issue date:	10/28/2008
From:	Moroney B Plant Licensing Branch II
To:	Campbell W Tennessee Valley Authority
Orf, Tracy J.; NRR/DORL 415-2788
References
TAC MD7198, TAC MD7199
Download: ML082840761 (34)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 28, 2008 Mr. William R. Campbell, Jr.

Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 SUB~'ECT: SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS REGARDING CONTROL ROOM HABITABILITY (TAC NOS. MD7198 AND MD7199)

Dear Mr. Campbell,

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 321 to Facility Operating License No. DPR-77 and Amendment No. 313 to Facility Operating License No. DPR-79 for the Sequoyah Nuclear Plant, Units 1 and 2. These amendments are in response to your application dated October 26,2007 (TS-07-02).

The amendments revise the technical specifications (TSs) to adopt the content of Technical Specification Task Force traveler TSTF-448, Revision 3, "Control Room Habitability." The amendments also add a new license condition regarding initial performance of the new surveillance and assessment requirements of the revised TSs.

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

S;;J£~

Brendan T. Moroney, Project Mana Plant Licensing Branch 11-2 Division of Operating Reactor Li sing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosures:

1. Amendment No. 321 to License No. DPR-77

2. Amendment No. 313 to License No. DPR-79

3. Safety Evaluation cc w/enclosures: See next page

Tennessee Valley Authority SEQUOYAH NUCLEAR PLANT cc:

Mr. Timothy P. Cleary, Site Vice President Sequoyah Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Soddy Daisy, TN 37384-2000 Additional Distribution via ListServ

'.. ML082840761 OFFICE LPL2-2/PM LPL2-2/PM LPL2-2/LA ITSB/BC OGC LPL2-2/BC RElliot Not required NAME TOrf BMoroney RSoia By memo -rBoyce DATE 10/15/08 10/28/08 10/15/08 09/17/2008 ML073130139 10/28/08 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-327 SEQUOYAH I\IUCLEAR PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 321 License No. DPR-77

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

A. The application for amendment by Tennessee Valley Authority (the licensee) dated October 26, 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 Title 10 of the Code of Federal Regulations (10 CFR)

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

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-77 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment 1\10. 321, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

-2

3. Accordingly, Facility Operating License DPR-77 is amended by the addition of paragraph 2.C.(29) as follows:

Upon implementation of the amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.7.h, in accordance with TS 6.17.c. (i), the assessment of CRE habitability as required by Specification 6.17.c. (ii), and the measurement of CRE pressure as required by Specification 6.17.d, shall be considered met. Following implementation:

(a) The first performance of SR 4.7.7.h, in accordance with Specification 6.17.c. (i), shall be within the spedfied Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from May 3, 2004; the date of the most recent successful tracer gas test, as stated in the August 4, 2004, letter response to Generic Letter 2003-01; or within the next 18 months if 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 6.17.c. (ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured "from May 3, 2004; the date of the most recent successful tracer gas test, as stated in the August 4, 2004, letter response to Generic Letter 2003-01; or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from May 30, 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

4. This license amendment is effective as of its date of issuance, to be implemented no later than 60 days after issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Thomas H. Boyc ,Chief Plant Licensing B nch 11-2 Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. DPR-77 and the Technical Specifications Date of Issuance: October 28, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 321 FACILITY OPERATING LICENSE NO. DPR-77 DOCKET NO. 50-327 Replace the following pages of Operating License DPR-77 with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3 3 12a 12a 12b Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3/47-17 3/47-17 3/47-18 3/47-18 6-18 6-18 6-19

-3 (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required, any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis, instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the Sequoyah and Watts Bar Unit 1 Nuclear Plants.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The Tennessee Valley Authority is authorized to operate the facility at reactor core power levels not in excess of 3455 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 321 are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Initial Test Program The Tennessee Valley Authority shall conduct the post-fuel-loading initial test program (set forth in Section 14 of Tennessee Valley Authority's Final Safety Analysis Report, as amended), without making any major modifications of this program unless modifications have been identified and have received prior NRC approval. Major modifications are defined as:

a. Elimination of any test identified in Section 14 of TVA's Final Safety Analysis Report as amended as being essential;

b. Modification of test objectives, methods or acceptance criteria for any test identified in Section 14 of TVA's Final Safety Analysis Report as amended as being essential;

c. Performance of any test at power level different from there described; and Facility Operating License No. OPR-77 Amendment No. 321

-12a

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (28) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

(29) Upon implementation of the amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.7 .h, in accordance with TS 6.17.c.(i), the assessment of CRE habitability as required by Specification 6.17.c.(ii), and the measurement of CRE pressure as required by Specification 6.17.d, shall be considered met. Following implementation:

(a) The first performance of SR 4.7 .7.h, in accordance with Specification 6.17 .c.(i),

shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from May 3, 2004; the date of the most recent successful tracer gas test, as stated in the August 4, 2004, letter response to Generic Letter 2003-01 ; or within the next 18 months if 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 6.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from May 3,2004; the date of the most recent successful tracer gas test, as stated in the August 4, 2004, letter response to Generic Letter 2003-01; or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from May 30, 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

D. Exemptions from certain requirements of Appendices G and J to 10 CFR Part 50 are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplements No.1. These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. The exemptions are, therefore, hereby granted. The granting of these exemptions are authorized with the issuance of the License for Fuel Loading and Low Power Testing, dated February 29, 1980. The facility will operate, to the extent authorized herein, Act, and the regulations of the Commission. Additional exemptions are listed in Attachment 1.

Amendment No.1 0;.., 53, 73, 193, 200, 213, 223, 292 3c:1

-12b E. Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Sequoyah Nuclear Plant Security Plan, Training And Qualification Plan, And Safeguards Contingency Plan" submitted by letter dated May 8, 2006.

Amendment NO.1 0, 53, 73, 193, 200, 213, 223, 292 321

PLANT SYSTEMS 3/4.7.7 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.7 Two independent control room emergency ventilation systems (CREVS) shall be OPERABLE.*

APPLICABILITY: ALL MODES and during movement of irradiated fuel assemblies ACTION:

MODES 1,2,3 and 4

a. With one CREVS inoperable for reasons other than Action b, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With one or more CREVS trains inoperable due to inoperable control room envelope (CRE) boundary, immediately initiate action to implement mitigating actions, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> verify mitigating actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed limits, CRE occupants are protected from smoke hazards, and restore CRE boundary to OPERABLE status within 90 days. Otherwise, be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c. With both CREVS inoperable due to actions taken as a result of a tornado warning, restore at I least one train to operable status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in a least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

d. With both CREVS inoperable for reasons other than Action b. or Action c., be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> MODES 5, 6, and during movement of irradiated fuel assemblies

a. With one CREVS inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the operable CREVS in the recirculation mode.

or suspend movement of irradiated fuel assemblies.

b. With both CREVS inoperable or one or more CREVS trains inoperable due to an inoperable CRE bounday, suspend all operations involving movement of irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS 4.7.7 Each CREVS shall be demonstrated OPERABLE:

a. DELETED

b. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes.

• The CRE boundary may be opened intermittently under administrative control.

SEQUOYAH - UNIT 1 3/47-17 Amendment No. 12, 164, 187,256,260, 273,301, 321

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:

1. Verifying that the cleanup system satisfies the in-place testing acceptance criteria and uses the test procedures of Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978 (except for the provisions of ANSI N510 Sections 8 and 9), and the system flow rate is 4000 cfm +/- 10%.

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86° F) and a relative humidity of 70%.

3. Verifying a system flow rate of 4000 cfm +/- 10% during system operation when tested in accordance with ANSI N510-1975.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5% when tested in accordance with ASTM 03803 1989 at a temperature of 30°C (86° F) and a relative humidity of 70%.

e. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 3 inches Water Gauge while operating the system at a flow rate of 4000 cfm +/- 10%.

2. Verifying that on a safety injection signal or a high radiation signal from the air intake stream, the system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks.

f. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the OOP when they are tested in place in accordance with ANSI N51 0-1975 while operating the system at a flow rate of 4000 cfm +/- 10%.

g. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm +/- 10%.

h. Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

SEQUOYAH - UNIT 1 3/47-18 Amendment No. 12, 68, 88, 263, 321

ADMINISTRATIVE CONTROLS 6.16 DIESEL FUEL OIL TESTING PROGRAM A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

a. Acceptability of new fuel oil prior to addition to storage tanks by determining that the fuel oil has:

1. An API gravity or an absolute specific gravity within limits,

2. A flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and

3. A clear and bright appearance with proper color;

b. Other properties for ASTM 2D fuel oil are within limits within 31 days following sampling and addition to storage tanks; and

c. Total particulate concentration of the fuel oil is :0; 10 mg/I when tested every 31 days in accordance with ASTM D-2276, Method A.

6.17 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge.

The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.

b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

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

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREVS, operating at the flow rate of 4000 cubic feet per minute plus or minus 10 percent, at a Frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.

SEQUOYAH - UNIT 1 6-18 Amendment No. 261,321

ADMINISTRATIVE CONTROLS 6.17 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM (continued)

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 4.0.2 are applicable to the frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

SEQUOYAH - UNIT 1 6-19 Amendment No. 321

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-328 SEQUOYAH NUCLEAR PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment N031 3 License No. DPR-79

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

A. The application for amendment by Tennessee Valley Authority (the licensee) dated October 26,2007, 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 Title 10 of the Code of Federal Regulations (10 CFR)

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

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-79 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 313 ,are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

-2

3. Accordingly, Facility Operating License DPR-79 is amended by the addition of paragraph 2.C.(23) as follows:

Upon implementation of the amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.7.h, in accordance with TS 6.17.c. (i), the assessment of CRE habitability as required by Specification 6.17.c. (ii), and the measurement of CRE pressure as required by Specification 6.17.d, shall be considered met. Following implementation:

(a) The first performance of SR 4.7.7.h, in accordance with Specification 6.17.c. (i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from May 3, 2004; the date of the most recent successful tracer gas test, as stated in the August 4, 2004, letter response to Generic Letter 2003-01 ; or within the next 18 months if 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 6.17.c. (ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from May 3,2004; the date of the most recent successful tracer gas test, as stated in the August 4, 2004, letter response to Generic Letter 2003-01; or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from May 30,2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

4. This license amendment is effective as of its date of issuance, to be implemented no later than 60 days after issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

~

Thomas H. Boy~e, clJief-Plant Licensing Branch 11-2 Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. DPR-79 and the Technical Specifications Date of Issuance: October 28, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 313 FACILITY OPERATING LICENSE NO. DPR-79 DOCKET NO. 50-328 Replace the following pages of Operating License DPR-79 with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3 3 12 12 12a 12a Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3/4 7-17 3/4 7-17 3/47-18 3/47-18 6-19 6/19 6-20

-3 (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the Sequoyah and Watts Bar Unit 1 Nuclear Plants.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The Tennessee Valley Authority is authorized to operate the facility at reactor core power levels not in excess of 3455 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 313 are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Initial Test Program The Tennessee Valley Authority shall conduct the post-fuel-loading initial test program (set forth in Section 14 of Tennessee Valley Authority's Final Safety Analysis Report, as amended), without making any major modifications of this program unless modifications have been identified and have received prior NRC approval. Major modifications are defined as:

a. Elimination of any test identified in Section 14 of TVA's Final Safety Analysis Report as amended as being essential;

b. Modification of test objectives, methods or acceptance criteria for any test identified in Section 14 of TVA's Final Safety Analysis Report as amended as being essential;

c. Performance of any test at power level different from there described; and Facility Operating License No. DPR-79 Amendment No. 313

-12 (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (22) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

(23) Upon implementation of the amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.7 .h, in accordance with TS 6.17.c.(i), the assessment of CRE habitability as required by Specification 6.17 .c.(ii), and the measurement of CRE pressure as required by Specification 6.17.d, shall be considered met. Following implementation:

(a) The first performance of SR 4.7.7.h, in accordance with Specification 6.17.c.(i),

shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from May 3, 2004; the date of the most recent successful tracer gas test, as stated in the AL1gust 4, 2004, letter response to Generic Letter 2003-01; or within the next 18 months if 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 6.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from May 3, 2004; the date of the most recent successful tracer gas test, as stated in the August 4, 2004, letter response to Generic Letter 2003-01; or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from May 30,2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

D. Exemptions from certain requirements of Appendices G and J to 10 CFR Part 50 are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplements No.1 and No.5. These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Therefore, these exemptions are hereby granted. The facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the regulations of the Commission.

Amendment No. 65, 162, 170, 204, 214, 273, 282, 313

-12a A temporary exemption from General Design Criterion 57 found in Appendix A to 10 CFR part 50 is described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No.5, Section 6.2.4. This exemption is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest. The exemption, therefore, is hereby granted and shall remain in effect through the first refueling outage as discussed in Section 6.2.4 of Supplement 5 to the Safety Evaluation Report. The granting of the exemption is authorized with the issuance of the Facility Operating License. The facility will operate, to the extent authorized herein, in conformity with the application as amended, the provisions of the Act, and the regulations of the Commission. Additional Exemptions are listed in Attachment 2.

E. Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Sequoyah Nuclear Plant Security Plan, Training And Qualification Plan, And Safeguards Contingency Plan" submitted by letter dated May 8, 2006.

F. Reactor Safety Methodology Applications Programs (Section 24.0)

TVA will provide a report prepared by the Kaman Sciences Corporation (KSC) on a full scale nuclear safety and availability analysis within six months from the date of the KSC report.

G. This amended license is subject to the following additional condition for the protection of the environment:

Before engaging in additional construction or operational activities which may result in an environmental impact that was not evaluated by the Commission, Tennessee Valley Authority will prepare and record an environmental evaluation of such activity. When the evaluation indicates that such activity may result in a significant adverse environmental impact that was not evaluated, or that is significantly greater than that evaluated in the Final Environmental Statement prepared by the Tennessee Valley Authority and the Environmental Impact Appraisal prepared by the Commission in May 1979, the Tennessee Valley Authority shall provide a written evaluation of such activities and obtain prior approval from the Director, Office of Nuclear Reactor Regulation.

H. Deleted I. TVA shall immediately notify the Commission of any accident at this facility which could result in an unplanned release of quantities of fission products in excess of allowable limits for normal operation established by the Commission.

J. TVA shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

Amendment 2,65,162,170,204,214, 267, 273, 282, 313

PLANT SYSTEMS 3/4.7.7 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.7 Two independent control room emergency ventilation systems (CREVS) shall be OPERABLE.*

APPLICABILITY: ALL MODES and during movement of irradiated fuel assemblies ACTION:

MODES 1, 2, 3 and 4

a. With one CREVS inoperable for reasons other than Action b, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With one or more CREVS trains inoperable due to inoperable control room envelope (CRE) boundary, immediately initiate action to implement mitigating actions, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> verify mitigating actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed limits, CRE occupants are protected from smoke hazards, and restore CRE boundary to OPERABLE status within 90 days. Otherwise, be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c. With both CREVS system inoperable due to actions taken as a result of a tornado warning, restore at least one train to operable status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

d. With both CREVS inoperable for reasons other than Action b. or Action c., be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODES 5, 6, and during movement of irradiated fuel assemblies

a. With one CREVS inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the operable CREVS in the recirculation mode or suspend movement of irradiated fuel assemblies.

b. With both CREVS inoperable or one or more CREVS trains inoperable due to an inoperable CRE bounday, suspend all operations involving movement of irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS 4.7.7 Each CREVS shall be demonstrated OPERABLE:

a. DELETED

b. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes.

The CRE boundary may be opened intermittently under administrative control.

SEQUOYAH - UNIT 2 3/47-17 Amendment No. 154,179,247,251,262,290, 313

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal ad sorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:

1. Verifying that the cleanup system satisfies the in-place testing acceptance criteria and uses the test procedures of Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978 (except for the provisions of ANSI N51 0 Sections 8 and 9), and the system flow rate is 4000 cfm +/- 10%.

2. Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86° F) and a relative humidity of 70%.

3. Verifying a system flow rate of 4000 cfm + 10% during system operation when tested in accordance with ANSI N510-1975.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal ad sorber operation by verifying within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5% when tested in accordance with ATSM 03803-1989 at a temperature of 30°C (86°F) and a relative humidity of 70%.

e. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 3 inches Water Gauge while operating the system at a flow rate of 4000 cfm +/- 10%.

2. Verifying that on a safety injection signal or high radiation signal from the air intake stream, the system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks.

f. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the OOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm +/- 10%.

g. After each complete or partial replacement of a charcoal ad sorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm +/- 10%.

h. Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

SEQUOYAH - UNIT 2 3/47-18 Amendment No. 60, 77, 254, 313

ADMINISTRATIVE CONTROLS 6.16 DIESEL FUEL OIL TESTING PROGRAM A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

a. Acceptability of new fuel oil prior to addition to storage tanks by determining that the fuel oil has:

1. An API gravity or an absolute specific gravity within limits,

2. A flash point and kinematic viscosity within limits for ASTM 20 fuel oil, and

3. A clear and bright appearance with proper color;

b. Other properties for ASTM 20 fuel oil are within limits within 31 days following sampling and addition to storage tanks; and

c. Total particulate concentration of the fuel oil is ~ 10 mgtl when tested every 31 days in accordance with ASTM 0-2276, Method A.

6.17 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge.

The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.

b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

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

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREVS, operating at the flow rate of 4000 cubic feet per minute plus or minus 10 percent, at a Frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.

SEQUOYAH - UNIT 2 6-19 Amendment No. 252, 313

ADMINISTRATIVE CONTROLS 6.17 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM (continued)

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air in leakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 4.0.2 are applicable to the frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

SEQUOYAH - UNIT 2 6-20 Amendment No. 31 3

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 321 TO FACILITY OPERATING LICENSE NO. DRP-77 AND AMENDMENT NO. 313 TO FACILITY OPERATING LICENSE NO DPR-79 TENNESSEE VALLEY AUTHORITY SEOUOYAH NUCLEAR PLANT. UNIT 1 AND 2 DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

By application dated October 26, 2007 (Agencywide Document and Management System Accession No. ML073030033), Tennessee Valley Authority (TVA, the licensee) submitted a license amendment request regarding the Sequoyah Nuclear Plant (SON), Units 1 and 2 Operating Licenses. The proposed amendment would revise the SON Technical Specifications (TSs) to adopt the content of Technical Specifications Task Force (TSTF) traveler TSTF-448, Revision 3, "Control Room Habitability." TSTF-448, Revision 3, is a proposal to establish more effective and appropriate action, surveillance, and administrative standard TS (STS) requirements related to ensuring the habitability of the control room envelope (CRE).

In Generic Letter 2003-01, "Control Room Habitability," June 12. 2003 (GL 2003-01), the Nuclear Regulatory Commission (NRC, Commission) alerted licensees to findings at facilities that existing TS surveillance requirements (SRs) for the control room emergency ventilation system (CREVS) may not be adequate. Specifically, the results of American Society for Testing and Materials E741-00, "Standard Test Method for Determining Air change in a Single Zone by Means of Tracer Gas Dilution," 2000 (ASTM E741) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance is not a reliable method for demonstrating eRE boundary operability. licensees were requested to address existing TS as follows:

Provide confirmation that your technical specifications verify the integrity [Le.,

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

-2 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 GL 2003-01, 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, which the NRC staff approved on January 17, 2007, and provided a model safety evaluation.

Since the SaN TSs are not in the format of NUREG [NRC technical report designation] -1431, Revision 3, "Standard Technical Specifications for Westinghouse Plants," the licensee is proposing to incorporate the content, not the format, of STS changes made by TSTF-448, Revision 3 to address control room habitability TS issues. The proposed amendment would modify the SaN TS requirements related to CRE habitability in TS 3.7.7, "Control Room Emergency Ventilation System (CREVS)" and TS Section 6, "Administrative Controls." The licensee submitted changes to the TS Bases that reflect the proposed TS changes. The proposed amendments contain certain plant-specific variations or deviations from the TS changes described in the TSTF-448, Revision 3, or the applicable parts of the NRC staff's model safety evaluation dated January 17, 2007. Finally, the licensee proposed license conditions to support implementation of the proposed TS changes. The purpose of the proposed 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 1.196, "Control Room Habitability at Light-water Nuclear Power Reactors," Revision 0, May 2003 (RG 1.196) uses the term "control room envelope" 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

-3 non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident.

NRC Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity At Nuclear Power Reactors, Revision 0, May 2003 (RG 1.197), 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 Emergency Ventilation System (CREVS)

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

The CREVS is designed to maintain a habitable environment in the CRE for the duration of a design basis accident (DBA), without exceeding a 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE).

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

• Fan is operable;

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

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

• CRE boundary is operable (the single boundary supports both systems).

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 Title 10 to the Code of Federal Regulations (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.

-4 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, "Design 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 CRE ventilation system specification, NUREG-1431, TS 3.7.10, "Control Room Emergency Filtration System (CREFS)." In this specification, the SR associated with demonstrating the operability of the CRE boundary requires verifying that one CREVS subsystem can maintain a positive pressure relative to the areas adjacent to the CRE during the pressurization mode of operation at a makeup How rate. Facilities that pressurize the CRE during the emergency mode of operation of the CREVS 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 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.

-5 NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," December 29, 1998 (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, "Technical Guidance." The NRC's guidance for handling such conditions is contained in 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," September 26, 2005 (RIS 2005-20). "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 !\IRC 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 I\IRC 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.

3.0 TECHNICAL EVALUATION

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

3.1 Proposed Changes The proposed amendment would strengthen CRE habitability TS requirements by changing TS 3/4.7.7, CONTROL ROOM EMERGENCY VENTILATION SYSTEM and adding a new TS administrative controls program on CRE habitability. Accompanying the proposed TS changes are appropriate conforming technical changes to the TS Bases. The proposed revision to the Bases also includes editorial and administrative changes to reflect applicable changes to the corresponding TS, which were made to improve clarity, conform to the latest information and

-6 references, and correct factual errors. Except for plant-specific differences, all of these changes are consistent with the content of 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, Revision 3. The staff verified that differences from the STS were adequately justified on the basis of plant-specific design or retention of current licensing bases.

The NRC staff also reviewed the proposed changes to the TS Bases for consistency with the plant-specific design and licensing bases, although approval of the Bases is not a condition for accepting the proposed amendment. However, TS 6.8.4 "TS BASES CONTROL PROGRAM,"

provides assurance that the licensee has established and will maintain the adequacy of the Bases. The proposed Bases for TS 3/4.7.7 refer to specific guidance in Nuclear Energy Institute 99-03, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001 (NEI 99-03), which the NRC staff has formally endorsed, with exceptions, through RG 1.196.

3.2 Editorial Changes The licensee proposed editorial changes to TS 3/4.7.7 to establish standard terminology, such as "control room envelope (CRE)" except for the plant-specific name for the CREVS, and "radiological, chemical, and smoke hazards" in place of various phrases to describe the hazards that CRE occupants are protected from by the CREVS. 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 3/4.7.7, Control Room Emergency Ventilation System The licensee proposed changes to action requirements and SRs for TS 3/4.7.7. The proposed changes adopt the content of changes made to STS by TSTF-448, Revision 3.

The licensee proposed establishing new action requirements for an inoperable CRE boundary.

The existing TS 3.7.7 actions are more restrictive than would be appropriate for situations in which CRE occupant imp!ementation of compensatory measures or mitigating actions would temporarily afford adequate CRE occupant protection from postulated airborne hazards. To account for such situations in MODES 1,2,3, and 4, the licensee proposes to modify TS 3.7.7 by adding a new ACTION step b, to apply when one or more Control Room Emergency Air Filtration Systems are inoperable due to an inoperable CRE boundary. In such cases, per the licensee's revised Action b, the licensee is required to immediately initiate action to implement mitigating actions (revised ACTION b), and verify, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, mitigating actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed limits, and mitigating actions are taken for exposure to smoke hazards and restore CRE boundary to OPERABLE status within 90 days. Otherwise, the licensee must have the plant in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. To distinguish the revised TS 3.7.7 ACTION b, from the existing ACTIONS for an inoperable CREVS, the licensee proposed revising TS 3.7.7 ACTION a, in Operational MODES 1,2,3, and 4, to state, 'With one CREVS Train inoperable for reasons other than ACTION b."

The 24-hour completion time of new ACTION b 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 of ACTION b 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

-7 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, and is a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary. Therefore, proposed changes to TS 3.7.7 ACTION b are acceptable.

The licensee proposed to modify TS 3.7.7 ACTION b for MODES 5,6, and during movement of irradiated fuel assemblies, to also apply when one or more CREVS Trains are inoperable due to an inoperable CRE boundary. This modification to TS 3.7.7 ACTION b. is needed because the proposed modification to TS 3.7.7 ACTION b requirements will only apply in MODES 1,2,3, and 4. The modification of TS 3.7.7 ACTION b (MODES 5,6, and during movement of irradiated fuel assemblies) will ensure that an ACTION is specified for an inoperable CRE boundary during all MODES of applicability. Therefore, this change is administrative and acceptable.

The licensee proposed deleting SR 4.7.7.e.3, which requires verification that the system can maintain a positive pressure of at least 1/8 inches water gauge relative to the adjacent areas during the filtered pressurization mode of operation at a pressurization flow rate of 4000 cubic feet per minute +/- 10 percent. The deletion of this SR is proposed because measurements of unfiltered air inleakage into the CRE at numerous reactor facilities have 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). The licensee proposed replacing the existing TS control room pressurization surveillance, TS SR 4.7.7.e.3, with an inleakage measurement SR and CRE Habitability Program in the TS (described in section 3.4), in accordance with the approved version of TSTF-448, Revision 3. In place of the pressurization SR, the licensee proposed adding a new SR 4.7.7.h that will require performance of CRE unfiltered air inleakage testing in accordance with the CRE Habitability Program described in proposed TS 6.17. The performance of unfiltered air inleakage testing past the CRE boundary into the CRE will be in accordance with the testing methods and at the frequencies specified in the CRE Habitability Program. Based on the adoption of the content of TSTF-448, Revision 3, the licensee's proposal to delete SR 4.4.7.e.3 and add SR 4.7.7.h is acceptable.

3.4 TS 6.17, Control Room Envelope Habitability Program The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Revision 3. In combination with SR 4.7.7.h, this program is intended to ensure the operability of the CRE boundary, which as part of an operable CREVS will ensure that CRE habitability is maintained such that CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under DBA conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident.

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

-8 Definitions of CRE and the 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 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, which endorsed, with exceptions, NEI 99-03. 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, 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 Regulatory Guide 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.

Measurement of CRE pressure with respect to all areas adjacent to the CRE boundary at designated locations for use in assessing the CRE boundary at a frequency of 18 months on a staggered test basis (with respect to the CREVS trains).

This element is intended to ensure that CRE differential pressure is regularly measured to identify changes in pressure warranting evaluation of the condition of the CRE boundary. Obtaining and trending pressure data provides additional assurance that significant degradation of the CRE boundary will not go undetected between CRE inleakage determinations. Per the Licensee's letter, the CRE differential pressure is measured, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREVS, operating at the flow rate of 4000 cubic feet per minute plus or minus 10 percent, at a Frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18-month assessment of the CRE boundary. SaN's definition of STAGGERED TEST BASIS is: "A STAGGERED TEST BASIS" shall consist of a test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals. The testing of one system, subsystem, train or other designated

-9 component at the beginning of each subinterval. The STS definition is: "A STAGGERED TEST BASIS" shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function. Therefore, in order to prescribe testing one of the subsystems every 18 months as stated in TSTF-448, Revision 3, the frequency must be stated as "36 months on a STAGGERED TEST BASIS," for SQN. The staff found that, for SQN, a frequency of "36 months on a STAGGERED TEST BASIS" is equivalent to the STS requirement, and is, therefore, acceptable.

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 3.7.7 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 4.0.2 are applicable to the program frequencies for performing the activities required by program paragraph number c, parts (i) and (ii) (assessment of CRE habitability and measurement of CRE inleakage), and paragraph number d (measurement of CRE differential pressure).

This statement is needed to avoid confusion. SR 4.0.2 is applicable to the surveillance that references the testing in the CRE Habitability Program.

However, SR 4.0.2 is not applicable to Administrative Controls unless specifically invoked. Providing this statement in the program eliminates any confusion regarding whether SR 4.0.2 is applicable, and is acceptable. Consistent with TSTF-448, Revision 3, proposed SQN TS 6.17 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 4.0.2 shall apply to program frequencies. Therefore, proposed TS 6.17 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 the following as a license condition to support implementation of the proposed TS changes:

Upon implementation of the amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.7.h, in accordance with TS 6.17.c. (i), the assessment of CRE habitability as required by

- 10 Specification 6.17.c. (ii), and the measurement of CRE pressure as required by Specification 6.17.d, shall be considered met. Following implementation:

(a) The first performance of SR 4.7.7.h, in accordance with Specification 6.17.c. (i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from May 3, 2004; the date of the most recent successful tracer gas test, as stated in the August 4, 2004, letter response to Generic Letter 2003-01; or within the next 18 months if 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 6.17.c. (ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from May 3, 2004; the date of the most recent successful tracer gas test, as stated in the August 4, 2004, letter response to Generic Letter 2003-01; or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from May 30,2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

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.

3.7 Summary of Adoption of TSTF-448, Revision 3, by SON, Units 1 and 2 The licensee is not proposing to adopt the STS format used by TSTF-448, Revision 3, because SON TSs use a format that predates STS and licensees are not required to adopt the format of STS. Instead, the licensee proposes adoption of TSTF-448, Revision 3 content. The changes to SON TSs will assure the facility's TS LCO for the CREVS is met by demonstrating CRE operability at a test interval (frequency) described in RG 1.197. The changes also add TS administrative controls to assure the habitability of the CRE between tests. In addition, changes to SON TS based on TSTF-448, Revision 3 content will establish clearly stated and reasonable required actions in the event CRE unfiltered inleakage exceeds the analysis assumption.

Revision 3 of TSTF-448 made changes to the STS for the CREVS and the CRE boundary that meet the requirements of 10 CFR 50.36(c)(2), 10 CFR 50.36(c)(3), and the other regulatory requirements described in Section 2.0. The licensee proposed adopting TSTF-448, Revision 3 content to address plant-specific design issues while retaining the current SON licensing bases.

The NRC staff concluded that the changes meet the regulatory requirements outlined above, address SON plant-specific design issues, and allow for retention of the current licensing bases.

The proposed plant-specific adoption of TSTF-448, Revision 3 content will assure that SON's

- 11 CRE will remain habitable during normal operation and DBA conditions. These changes are, therefore, acceptable.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change 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 and change SRs.

The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no-significant-hazards considerations, and there has been no public comment on the finding (72 FR 68219). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

Principal contributor: Ravinder P. Grover Date: October 28, 2008