ML090290396

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Issuance of Amendments Regarding (Tac Nos. MD8122 and MD8123)
ML090290396
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 01/30/2009
From: Stang J
Plant Licensing Branch II
To: Brandi Hamilton
Duke Energy Carolinas
Thompson Jon, NRR/DORL/LPL 2-1, 415-1119
References
TAC MD8122, TAC MD8123
Download: ML090290396 (19)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 30, 2009 Mr. Bruce H. Hamilton Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078

SUBJECT:

MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING TSTF-448 (TAC NOS. MD8122 AND MD8123)

Dear Mr. Hamilton:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 249 to Renewed Facility Operating License NPF-9 and Amendment No. 229 to Renewed Facility Operating License NPF-17 for the McGuire Nuclear Station, Units 1 and 2. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated January 22, 2008.

The amendments revise the TS requirements related to control room envelope habitability in accordance with TS Task Force (TSTF) traveler TSTF-448, "Control Room Habitability,"

Revision 3. This TS improvement was made available by the Commission on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process (CLlIP).

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,

! (;

.' "ll '('*lLl1

'! ( t John Stang, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-369 and 50-370

Enclosures:

1. Amendment No. 249 to NPF-9
2. Amendment No. 229 to NPF-17
3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC DOCKET NO. 50-369 MCGUIRE NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 249 Renewed License No. NPF-9

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

A. The application for amendment to the McGuire Nuclear Station, Unit 1 (the facility),

Renewed Facility Operating License No. I\IPF-9, filed by the Duke Energy Carolinas, LLC (licensee), dated January 22,2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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.

Enclosure 1

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2. Accordingly, the license is hereby amended by page 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. NPF-9 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 249, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Melanie C. Wong, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-9 and the Technical Specifications Date of Issuance: January 30, 2009

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS. LLC DOCKET NO. 50-370 MCGUIRE NUCLEAR STATION. UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 229 Renewed License No. NPF-17

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

A. The application for amendment to the McGuire Nuclear Station, Unit 2 (the facility),

Renewed Facility Operating License No. NPF-17, filed by the Duke Energy Carolinas, LLC (the licensee), dated January 22,2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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.

Enclosure 2

-2

2. Accordingly, the license is hereby amended by page 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. NPF-17 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 229 , are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Melanie C. Wong, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-17 and the Technical Specifications Date of Issuance: January 30, 2009

ATTACHMENT TO LICENSE AMENDMENT NO. 249 RENEWED FACILITY OPERATING LICENSE NO. NPF-9 DOCKET NO. 50-369 AND LICENSE AMENDMENT NO. 229 RENEWED FACILITY OPERATING LICENSE NO. NPF-17 DOCKET NO. 50-370 Replace the following pages of the Renewed Facility Operating Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert License Pages License Pages NPF-9 page 3 NPF-9 page 3 I\IPF-17 page 3 I\IPF-17 page 3 Appendix B, page B-2 TS Pages TS Pages 3.7.9-1 3.7.9-1 3.7.9-2 3.7.9-2 3.7.9-3 3.7.9-3 5.5-14 5.5-14 5.5-15

-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;

{5} Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproducts and special nuclear materials as may be produced by the operation of McGuire Nuclear Station, Units 1 and 2'" and; (6) Pursuant to the Act and 10 CFR Parts 30 and 40, to receive, possess and process for release or transfer such byproduct material as may be produced by the Duke Training and Technology Center.

C. This renewed operating 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 licensee is authorized to operate the facility at a reactor core full steady state power'level of 3411 megawatts thermal (100%).

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

(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21{d), as revised on December 16,2002, describes certain future activities to be completed before the period of extended operation.

Duke shall complete these activities no later than June 12, 2021, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above. shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71{e)(4), following issuance of this renewed operating license.

Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

Renewed License No. NPF-9 Amendment No. 249

-3 (4) Pursuant to the Act and to 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; (5) Pursuant to the Act and 10 CFR Parts 30,40 and 70, to possesS" but not separate, such byproducts and' special nuclear materials as may be produced by the operation of McGuire Nuclear Station, Units 1 and 2; and, (6) Pursuant to the Act and 10 CFR'Parts 30 and 40, to receive, possess and process for release or transfer such byproduct material as may be produced by the Duke Training and Technology Center.

C. . This renewed operating 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 licensee is authorized to operate the facility at a reactor core full steady state power level of 3411 megawatts thermal (100%).

(2) Technical Specifications

. The Technical Specifications contained in Appendix A, as revised through Amendment No. , are hereby incorporated into this renewed operating license. J'he licensee shall operate the facility in accordance with the Technical Specifications.

(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant

. to 10 CFR 54.21(d), as revised on December 16,2002, describes certain future activities to be completed before the period of extended operation.

Duke shall complete these activities no iater than March 3, 2023, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR50.71(e)(4). following issuance of this renewed operating license.

Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59, and otherwise complies with the requirements in that section.

Renewed License No. NPF-17 Amendment No. 229

APPENDIX 8 ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF-9 Duke Power Power Company LLC shall comply with the following conditions on the schedules noted below:

Amendment Additional Implementation Number Conditions Date Upon implementation of the Amendment adopting TSTF See Condition 448, Revision 3, the determination of control room envelope (CRE) unfiltered inleakage as required by SR 3.7.9.4, in accordance with TS 5.5.16.c.(i), the assessment of CRE habitability as required by TS 5.5.16.c.(ii), and the measurement of CRE pressure as required by TS 5.5.16.d, shall be considered met.

Following implementation:

(a) The first performance of SR 3.7.9.4 in accordance with TS 5.5.16.c.(i), shall be within the specified Frequency of 6 years, plus the 18 month allowance of SR 3.0.2. as measured from October 2003, the date of the most recent successful tracer gas test, as stated in the February 19, 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, TS 5.5.16.c.(ii), shall be within 3 years, plus the 9 month allowance of SR 3.0.2 as measured from October 2003, the date of the most recent successful tracer gas test, as stated in the February 19, 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, TS 5.5.16.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from January 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

Renewed License No. NPF-9 Amendment No. 249 8-2

CRAVS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Control Room Area Ventilation System (CRAVS)

LCO 3.7.9 Two CRAVS trains shall be OPERABLE.

NOTE----------------------------------------------

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies, During CORE ALTERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRAVS train inoperable for reasons other than Condition B.

A.1 Restore CRAVS train to OPERABLE status.

7 days

[

B. One or more CRAVS B.1 Initiate action to implement Immediately trains inoperable due to mitigating actions.

inoperable CRE boundary in MODE AND 1,2,3, or 4.

B.2 Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

AND B.3 Restore CRE boundary to 90 days OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

McGuire Units 1 and 2 3.7.9-1 Amendment Nos. 249 and 229

CRAVS 3.7.9 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Place OPERABLE CRAVS Immediately associated Completion train in emergency mode.

Time of Condition A not met in MODE 5 or 6. or OR during movement of irradiated fuel D.2.1 Suspend CORE Immediately assemblies, or during ALTERATIONS.

CORE ALTERATIONS.

AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.

E. Two CRAVS trains E.1 Suspend CORE Immediately inoperable in MODE 5 ALTERATIONS.

or 6, or during movement of irradiated AND fuel assemblies, or during CORE E.2 Suspend movement of Immediately ALTERATIONS. irradiated fuel assemblies.

OR One or more CRAVS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS.

F. Two CRAVS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4 (for reasons other than Condition B).

(continued)

McGuire Units 1 and 2 3.7.9-2 Amendment Nos. 249 and 229

CRAVS 3.7.9 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME CONDITION REQUIRED ACTION COMPLETION TIME G. One or more CRAVS G.1 Restore CRAVS train(s) 7 days train( s) heater heater to OPERABLE inoperable. status.

OR G.2 Initiate action in 7 days accordance with Specification 5.6.6.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Operate each CRAVS train for ~ 10 continuous hours 31 days with the heaters operating.

SR 3.7.9.2 Perform required CRAVS filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.9.3 Verify each CRAVS train actuates on an actual or 18 months simulated actuation signal.

SR 3.7.9.4 Perform required CRE unfiltered air inleakage testing in In accordance with accordance with the Control Room Envelope Habitability the Control Room Program. Envelope Habitability Program McGuire Units 1 and 2 3.7.9-3 Amendment Nos. 249 and 2 29

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Safety Function Determination Program (SFDP) (continued)

a. Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected;
b. Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists;
c. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and
d. Other appropriate limitations and remedial or compensatory actions.

A loss of safety function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or
b. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or
c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

5.5.16 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 Area Ventilation System (CRAVS), 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.

(continued)

McGuire Units 1 and 2 5.5-14 Amendment Nos. 249 and 229

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 Control Room Envelope Habitability Program (continued)

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 atmospheric pressure during the pressurization mode of operation by one train of the CRAVS, operating at a makeup flow rate of ~ 2200 cfm. at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the periodic assessment of the CRE boundary in accordance with Regulatory Guide 1.197, Figure 1.
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 3.0.2 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.

McGuire Units 1 and 2 5.5-15 Amendment Nos. 249 and 229

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 249 TO RENEWED FACILITY OPERATING LICENSE NPF-9 AND AMENDMENT NO. 229 TO RENEWED FACILITY OPERATING LICENSE NPF-17 DUKE ENERGY CAROLINAS, LLC MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370

1.0 INTRODUCTION

By application dated January 22,2008, Duke Energy Carolinas, LLC (Duke, the licensee),

requested changes to the Technical Specifications (TSs) for the McGuire Nuclear Station, Units 1 and 2 (McGuire 1 and 2). This application was resent on May 28, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML081540253) after the official copy sent to the NRC Document Control Desk by letter dated January 22,2008, was received but not properly entered into ADAMS upon original receipt. The letter dated May 28, 2008, only resent the original application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on March 25, 2008 (72 FR 15784).

The proposed changes would revise the TS requirements related to control room envelope habitability in accordance with TS Task Force (TSTF) traveler TSTF-448, "Control Room Habitability," Revision 3. This TS improvement was made available by the Commission on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process (CLlIP).

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).

Enclosure

-2 In NRC Generic Letter 2003-01 (Reference 1), licensees were alerted to findings at facilities that existing TS surveillance requirements for the Control Room Envelope Emergency Ventilation System (CREEVS) may not be adequate. Specifically, the results of 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 [Le., operability]

of the CRE [boundary], and the assumed [untiltered] 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 generic letter, the industry and the NRC proposed revisions to CRE habitability system requirements contained in the STS, using the STS change traveler process. This effort culminated in Revision 3 to traveler TSTF-448, "Control Room Habitability," which the NRC staff approved on January 17, 2007.

Consistent with the traveler as incorporated into NUREG-1433 and NUREG-1434, the licensee proposed revising action and surveillance requirements in Specification 3.7.9, "Control Room Area Ventilation System (CRVAS)" and adding a new administrative controls program, Specification 5.5.16, "Control Room Envelope Habitability Program." The purpose of the changes is to ensure that CRE boundary operability is maintained and verified through effective surveillance and programmatic requirements, and that appropriate remedial actions are taken in the event of an inoperable CRE boundary.

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

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, (Reference 4) uses the term "control room envelope (CRE)" in addition to the term "control room" and defines each term as follows:

-3 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 Regulatory Guide 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 Filtration System The Control Room Emergency Filtration (CREF) system (the term used at McGuire 1 and 2 is the Control Room Area Ventilation System, (CRAVS)) provides a protected environment from which operators can control the unit, during airborne challenges from radioactivity, hazardous chemicals, and fire byproducts, such as fire suppression agents and smoke, during both normal and accident conditions.

The CREF system 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 personnel exceeding radiation exposures of 5 rem whole body dose or its equivalent to any part of the body.

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

  • Outside Air Pressure Filter Train (OAPTF) fan and a Control Room Air Handling unit are operable;
  • High efficiency particulate air (HEPA) filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions;
  • Heater, demister, ductwork, valves, and dampers are operable, and air circulation can be maintained; and

-4

  • Control Room recirculation fan is operable; and
  • CRE boundary is operable (the single boundary supports both subsystems).

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

2.3 Regulations Applicable to Control Room Habitability In Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," General Design Criteria (GDC) 1, 2, 3, 4, 5, and 19 apply to CRE habitability. A summary of these GDCs follows.

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

GDC 2, "Design Basis for Protection Against Natural Phenomena," requires that structures, systems, and components (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:

-5

System;" and

In these specifications, the surveillance requirement associated with demonstrating the operability of the CRE boundary requires verifying that one Control Room Emergency Filtration subsystem can maintain a positive pressure of ~ 1/8 inches of water, with respect to atmospheric pressure during the pressurization mode of operation at a flow rate of:5 2200 cubic feet per minute.

Facilities that pressurize the CRE during the emergency mode of operation of the Control Room Ventilation System have similar surveillance requirements. 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 surveillance requirement, the action requirements of these specifications were ambiguous regarding CRE boundary operability in the event CRE unfiltered inleakage is found to exceed the analysis assumption. The ambiguity stemmed from the view that the CRE boundary may be considered operable but degraded in this condition, and that it would be deemed inoperable only if calculated radiological exposure limits for CRE occupants exceeded a licensing basis limit; e.g., as stated in GDC-19, even while crediting compensatory measures.

NRC Administrative Letter 98-10, "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). AL 98-10 further states that "Imposing administrative controls in response to an improper or inadequate TS is considered an acceptable short-term corrective action. The staff expects that, following the imposition of administrative controls, an amendment to the TS, with appropriate justification and schedule, will be submitted in a timely fashion."

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

However, based on GL 2003-01 and AL 98-10, the staff expects each licensee to propose TS changes that include a surveillance to periodically measure CRE unfiltered inleakage in order to satisfy 10 CFR 50.36(c)(3), which requires a facility's TS to include surveillance requirements, 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.)

- 6 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.

The 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 McGuire 1 and 2 Adoption of TSTF-448, Revision 3, will assure that the facility's TS LCO for the CREF system 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 the test interval (frequency) described in Regulatory Guide 1.197, TSTF-448 also adds TS administrative controls to assure the habitability of the CRE between performances of the CRE unfiltered inleakage 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 CREF system 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 the McGuire 1 and 2 CRE will remain habitable during normal operation and design basis accident 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 pressurization mode of the CRAVS at McGuire 1 and 2 pressurizes the CRE to minimize unfiltered air inleakage. The proposed changes are consistent with this design.

3.1 Proposed Changes The proposed amendment would strengthen CRE habitability TS requirements by changing TS 3.7.9, CRAVS, and adding a new TS administrative to TS 5.5 controls program on CRE habitability. Accompanying the proposed TS changes are appropriate conforming technical changes to the TS Bases. The proposed revision to the Bases also includes editorial and administrative changes to reflect applicable changes to the corresponding STS Bases, which were made to improve clarity, conform with the latest information and references, correct factual errors, and achieve more consistency among the STS NUREGs. Except for plant specific differences, all of these changes are consistent with STS as revised by TSTF-448, Revision 3.

The NRC staff compared the proposed TS changes to the STS and the STS markups and evaluations in TSTF-448. The NRC 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

- 7 plant-specific design and licensing bases, although approval of the Bases is not a condition for accepting the proposed amendment. However, TS 5.5.10, "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 specific guidance in NEI 99-03, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001 (Reference 6), which the NRC staff has formally endorsed, with exceptions, through Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," dated May 2003 (Reference 4).

3.2 Editorial Changes The licensee proposed editorial changes to TS 3.7.9, "Control Room Emergency Filtration," to establish standard terminology, such as "control room envelope (CRE)" in place of "control room,"

except for the plant-specific name for the CREF. The licensee also proposed "radiological, chemical, and smoke hazards (or challenges)" in place of various phrases to describe the hazards that CRE occupants are protected from by the CREF. The 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, "Control Room Area Ventilation System" The licensee proposed to revise the action requirements of TS 3.7.9, CRAVS, to acknowledge that an inoperable CRE boundary, depending upon the location of the associated degradation, could cause just one, instead of both CRAVS subsystems to be inoperable. This is accomplished by revisill9 Condition A to exclude Condition B, and revisill9 Condition B to address one or more CREF subsystems, as follows:

  • Condition A One CRAVS subsystem inoperable for reasons other than Condition B.

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

The licensee proposed to replace and reorder existing Required Action B.1, "Restore control room boundary to OPERABLE status," which has a 24-hour Completion Time, with Required Action B.1, to immediately initiate action to implement mitigating actions; Required Action B.2, to verify, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that 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; and Required Action B.3, to restore CRE boundary to operable status within 90 days.

The 24-hour Completion Time of new Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions as directed

-8 by Required Action B.1. The 90-day Completion Time of new Required Action B.3 is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 90-day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary. Therefore, proposed Action B is acceptable.

The licensee proposes to add a new condition to Action E of TS 3.7.9 that states, "One or more CRAVS trains inoperable due to an inoperable CRE boundary in Mode 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS." The specified Required Action proposed for this condition is the same as for existing condition of Action E which states "Two CRAVS trains inoperable in Mode 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS."

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

In the pressurization mode of operation, the CRAVS isolates unfiltered ventilation air supply intakes, filters the emergency ventilation air supply to the CRE, and pressurizes the CRE to minimize unfiltered air inleakage past the CRE boundary. The licensee proposed to delete the CRE pressurization surveillance requirement (SR). The SR requires verifying that one CREF subsystem, operating in the emergency radiation state, can maintain a pressure of ~1/8 inches water gauge, relative to the adjacent rad waste and turbine buildings during the pressurization mode of operation at a makeup flow rate of :5 2200 cfm. The deletion of this SR is proposed because measurements of unfiltered air leakage into the CRE at numerous reactor facilities demonstrated that a basic assumption of this SR, an essentially leak-tight CRE boundary, was incorrect for most facilities. Hence, meeting this SR by achieving the required CRE pressure is not necessarily a conclusive indication of CRE boundary leak tightness, i.e., CRE boundary operability. In a response to GL 2003-01 the licensee reported that it had determined that the CRE pressurization surveillance, SR 3.7.9.4, was inadequate to demonstrate the operability of the CRE boundary, and proposed to replace it with an inleakage measurement SR and aCRE Habitability Program in TS Section 5.5, in accordance with the approved version of TSTF-448.

Based on the adoption of TSTF-448, Revision 3, the licensee's proposal to delete the current SR 3.7.9.4 is acceptable.

The proposed CRE inleakage measurement SR (new SR 3.7.9.4) 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

- 9 C.2 of Regulatory Guide 1.197, Revision 0 (Reference 5). The 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, "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 the new proposed SR 3.7.9.4, this program is intended to ensure the operability of the CRE boundary, which as part of an operable Control Room Emergency Filter System 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 whole body dose or its equivalent to any part of the body 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 Regulatory Guide 1.196 (Reference 4), which endorsed, with exceptions, NEI 99-03 (Reference 6). Maintaining the CRE boundary in its design condition provides assurance that its leak-tightness will not significantly degrade between CRE inleakage determinations.

Assessment of CRE habitability at the frequencies stated in Sections C.1 and C.2 of Regulatory Guide 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 Regulatory Guide 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.

- 10 Measurement of CRE pressure with respect to atmospheric pressure for use in assessing the CRE boundary at a frequency of 18 months on a staggered test basis (with respect to the CRAVS subsystems). This element is intended to ensure that CRE differential pressure is regularly measured to identify changes in pressure warranting evaluation of the condition of the CRE boundary. Obtaining and trending pressure data provides additional assurance that significant degradation of the CRE boundary will not go undetected between CRE inleakage determinations.

Quantitative limits on unfiltered inleakage. This element is intended to establish the CRE inleakage limit as the CRE unfiltered infiltration rate assumed in the CRE occupant radiological consequence analyses of design basis accidents. Having an unambiguous criterion for the CRE boundary to be considered operable in order to meet LCO 3.7.3, will ensure that associated action requirements will be consistently applied in the event of CRE degradation resulting in inleakage exceeding the limit.

Consistent with TSTF-448, Revision 3, the program states that the provisions of SR 3.0.2 are applicable to the program frequencies for performing the activities required by program paragraph number c, parts (I) and (ii) (assessment of CRE habitability and measurement of CRE inleakage),

and paragraph number d (measurement of CRE differential pressure). This statement is needed to avoid confusion. SR 3.0.2 is applicable to the surveillance that references the testing in the CRE Habitability Program. However, SR 3.0.2 is not applicable to Administrative Controls unless specifically invoked. Providing this statement in the program eliminates any confusion regarding whether SR 3.0.2 is applicable, and is acceptable.

Consistent with TSTF-448, Revision 3, proposed TS 5.5.16 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 5.5.14, which is consistent with the model program TS approved by the NRC staff in TSTF-448, Revision 3, is acceptable.

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

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no

- 11 significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (73 FR 15784). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

7.0 REFERENCES

1. NRC Generic Letter (GL) 2003-01, "Control Room Habitability," dated June 12,2003.
2. American Society for Testing and Materials (ASTM) E 741 - 00, "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution," 2000, (ASTM E741).
3. NRC Regulatory Issue Summary 2005-20, Rev.1: Revision to NRC Inspection Manual Part 9900 Technical Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded and Nonconforming Conditions Adverse to Quality or Safety,"

dated April 16, 2008.

4. Regulatory Guide (RG) 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, dated May 2003.
5. RG 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors,"

Revision 0, May 2003.

Principal Contributor: John Stang Date: January 30, 2009

ML090290396 NRR-058 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA DIRS/ITSB/BC OGC NRRlLPL2-1/BC NRR/LPL2-1/PM NAME JThompson MO'Brien RElliott NOT REQUIRED MWong JStang DATE 1/27/09 1/29/09 1/29/09 ML073130139 1/30/09 1/30/09

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