ML090360713

Issuance of Amendment No. 218, Revise Technical Specifications to Adopt Requirements of TSTF-448, Revision 3, Control Room Habitability Using Consolidated Line Item Improvement Process

ML090360713
Person / Time
Site:	Waterford
Issue date:	02/20/2009
From:	Kalyanam N Plant Licensing Branch IV
To:	Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
TAC MD6547
Download: ML090360713 (31)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 20, 2009 Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - ISSUANCE OF AMENDMENT RE: MODIFICATION OF REQUIREMENTS REGARDING CONTROL ROOM ENVELOPE HABITABILITY (TAC NO. MD6547)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 218 to Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3 (Waterford 3). This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated August 16, 2007, as supplemented by letter dated January 8, 2009.

The amendment adds a new license condition on the control room envelope (CRE) habitability program; revises the TS requirements related to the CRE habitability in TS 3.7.6, "Control Room Emergency Air Filtration System - Operating," TS 3.7.6.2, "Control Room Emergency Air Filtration System - Shutdown," and TS 3.7.6.5, "Control Room Isolation and Pressurization";

and establishes a CRE habitability program in TS Section 6.5, "Administrative Controls Programs." These changes are consistent with the NRC-approved Industry/TS Task Force (TSTF) Traveler TSTF-448, Revision 3, "Control Room Habitability." The availability of this TS improvement was published in the Federal Register on January 17, 2007 (72 FR 2022), as part of the Consolidated Line Item Improvement Process.

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

Sincerely,

~.

N~Oject Ma:;

Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosures:

1. Amendment No. 218 to NPF-38

2. Safety Evaluation cc: w/encl: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY OPERATIONS, INC.

DOCKET NO. 50-382 WATERFORD STEAM ELECTRIC STATION, UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 218 License No. NPF-38

1.

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

A.

The application for amendment by Entergy Operations, Inc. (EOI) dated August 16, 2007, as supplemented by letter dated January 8, 2009, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 3

3.

This license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-38 and Technical Specifications Date of Issuance:

February 20, 2009

ATTACHMENT TO LICENSE AMENDMENT NO. 218 TO FACILITY OPERATING LICENSE NO. NPF-38 DOCKET NO. 50-382 Replace the following pages of the Facility Operating License and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License REMOVE INSERT -4 -8 -9

-10 Technical Specifications REMOVE INSERT 3/47-16 3/47-16 3/47-16a 3/47-16a 3/47-17 3/47-17 3/47-18 3/47-18 3/47-18c 3/47-18c 3/47-18d 3/47-18d 6-8 6-8 6-9 6-9 6-10 6-10

- 4 or indirectly any control over (i) the facility, (ii) power or energy produced by the facility, or (iii) the licensees of the facility. Further, any rights acquired under this authorization may be exercised only in compliance with and subject to the requirements and restrictions of this operating license, the Atomic Energy Act of 1954, as amended, and the NRC's regulations. For purposes of this condition, the limitations of 10 CFR 50.81, as now in effect and as they may be subsequently amended, are fully applicable to the equity investors and any successors in interest to the equity investors, as long as the license for the facility remains in effect.

(b)

Entergy Louisiana, LLC (or its designee) to notify the NRC in writing prior to any change in (i) the terms or conditions of any lease agreements executed as part of the above authorized financial transactions, (ii) any facility operating agreement involving a licensee that is in effect now or will be in effect in the future, or (iii) the existing property insurance coverages for the facility, that would materially alter the representations and conditions, set forth in the staff's Safety Evaluation enclosed to the NRC letter dated September 18, 1989. In addition, Entergy Louisiana, LLC or its designee is required to notify the NRC of any action by equity investors or successors in interest to Entergy Louisiana, LLC that may have an effect on the operation of the facility.

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 EOI is authorized to operate the facility at reactor core power levels not in excess of 3716 megawatts thermal (100% power) in accordance with the conditions specified herein.

2.

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 218,and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. EOI shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 218

- 8

d.

Prior to completion of Phase III of the Waterford 3 startup test program, the licensee shall complete corrective actions related to the 23 NRC issues as identified in the LP&L responses.

17.

Basemat The licensee shall comply with its commitments to perform a basemat cracking surveillance program and additional confirmatory analyses of basemat structural strength as described in its letter of February 25, 1985. Any significant change to this program shall be reviewed and approved by the NRC staff prior to its implementation.

18.

Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a)

Fire fighting response strategy with the following elements:

1.

Pre-defined coordinated fire response strategy and Guidance

2.

Assessment of mutual aid fire fighting assets

3.

Designated staging areas for equipment and materials

4.

Command and control

5.

Training of response personnel (b)

Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets

2.

Communications

3.

Minimizing fire spread

4.

Procedures for implementing integrated fire response strategy

5.

Identification of readily-available pre-staged equipment

6.

Training on integrated fire response strategy

7.

Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1.

Water spray scrubbing

2.

Dose to onsite responders

19.

Control Room Envelope Habitability Program Upon implementation of Amendment No. 218 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 6.5.17, in accordance with TS 6.5.17.c.(i),

the assessment of CRE habitability as required by Specification 6.5.17.c.(ii), and the measurement of CRE pressure as required by Specification 6.5.17.d, shall be considered met. Following implementation:

AMENDMENT NO. 134,203, 218 Revi~ed by letter dated October 28, 2004 Revi~ed by letter dated July 26, 2007

- 9 (a)

The first performance of SR 6.5.17, in accordance with Specification 6.5.17.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 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 6.5.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 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 6.5.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from August 13, 2008, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

D.

The facility requires an exemption from certain requirements of Appendices E and J to 10 CFR Part 50. These exemptions are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement NO.1 0 (Section 6.1.2) and Supplement No.8 (Section 6.2.6), respectively. 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. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E.

EOI 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 plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Physical Security, Safeguards Contingency and Training & Qualification Plan,"

and was submitted on October 4, 2004.

AMENDMENT NO. 4T4, 218 Re\\fi8ed by letter dBted July 26, 2007

- 10 F.

Except as otherwise provided in the Technical Specifications or the Environmental Protection Plan, EOI shall report any violations of the requirements contained in Section 2.C of this license in the following manner.

Initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73(b), (c) and (e).

G.

Entergy Louisiana, LLC 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.

H.

This license is effective as the date of issuance and shall expire at midnight on December 18, 2024.

FOR THE NUCLEAR REGULATORY COMMISSION original signed by H.R. Denton Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosures:

1. (DELETED)

2. Attachment 2

3. Appendix A (Technical Specifications) (NUREG-1117)

4. Appendix B (Environmental Protection Plan)

5. Appendix C (Antitrust Conditions)

Date of Issuance: March 16, 1985 AMENDMENT NO. 218

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM AIR CONDITIONING SYSTEM CONTROL ROOM EMERGENCY AIR FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two control room emergency air filtration trains (S-8) shall be OPERABLE. (Note 1)

APPLICABILITY:

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

ACTION:

a.

With one control room emergency air filtration train inoperable for reasons other than ACTION b, restore the inoperable train to OPERABLE status within 7 days.

b.

With one or more control room emergency air filtration trains inoperable due to inoperable control room envelope boundary in MODES 1, 2, 3, or 4, then perform the folloWing:

1.

Immediately initiate action to implement mitigating actions; and

2.

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 control room envelope occupant exposures to radiological, chemical, and smoke hazards will not exceed limits; and

3.

Within 90 days, restore the control room envelope boundary to OPERABLE status.

c.

If the require ACTION and associated allowable outage times of ACTION a or b are not met in MODES 1, 2, 3, or 4, then 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.

If the required ACTION and the associated allowable outage time of ACTION a is not met in MODES 5 or 6, or during movement of irradiated fuel assemblies, then perform the following:

1.

Immediately place OPERABLE control room emergency air filtration train in emergency radiation protection mode (or toxic gas protection mode if automatic transfer to toxic gas protection mode is inoperable); or

2.

Immediately suspend movement of irradiated fuel assemblies and operations involving CORE ALTERATIONS.

WATERFORD - UNIT 3 3/47-16 AMENDMENT NO. 115, 149, 170, 188, 218

PLANT SYSTEMS ACTION (Continued):

e.

With one or more control room emergency air filtration trains inoperable due to an inoperable control room envelope boundary in MODES 5 or 6, or during movement of irradiated fuel assemblies, immediately suspend movement of irradiated fuel assemblies and operations involving CORE ALTERATIONS.

f.

With two control room emergency air filtration trains inoperable in MODES 1, 2, 3, or 4 for reasons other than ACTION b, immediately enter LCO 3.0.3.

g.

With two control room emergency air filtration trans inoperable in MODES 5 and 6 or during movement of irradiated fuel assemblies, immediately suspend movement of irradiated fuel assemblies and operations involving CORE ALTERATIONS.

SURVEILLANCE REQUIREMENTS 4.7.6.1 Each control room air filtration train (S-8) shall be demonstrated OPERABLE:

a.

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 10 continuous hours with the heaters on.

b.

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 filtration train 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, and the system flow rate is 4225 cfm

+/-10%.

Note 1:

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

WATERFORD - Ur"\\IIT 3 3/47-16a AMENDMENT NO. 218

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

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 0.5% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C and a relative humidity of 70%.

3.

Verifying a system flow rate of 4225 cfm +/-10% during train operation when tested in accordance with ANSI N510-1975.

c.

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 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 0.5% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C and a relative humidity of 70%.

d.

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 7.8 inches water gauge while operating the train at a flow rate of 4225 cfm +/-10%.

2.

Verifying that on a safety injection actuation test signal or a high radiation test signal, the train automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks and the normal outside airflow paths isolate.

3.

Verifying that heaters dissipate 10 +1.0, -1.0 kW when tested in accordance with ANSI N510-1975.

4.

Verifying that on a toxic gas detection signal, the system automatically switches to the isolation mode of operation.

e.

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 DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 4225 cfm +/-1 0%.

f.

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 N51 0-1975 while operating the train at a flow rate of 4225 cfm +/-10%.

g.

Perform required control room envelope unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

WATERFORD - UNIT 3 3/47-17 AMENDMENT NO. 115,170, 194 218

THIS PAGE HAS BEEN DELETED.

WATERFORD - UNIT 3 3/47-18 Amendment No. 115, 149, 188 218

THIS PAGE HAS BEEN DELETED.

WATERFORD - UNIT 3 3/47-18c Amendment No. ~~5. ~49. ~88 218

THIS PAGE HAS BEEN DELETED.

WATERFORD - UNIT 3 3/47-18d Amendment No. 115, 149, 218

ADMINISTRATIVE CONTROLS 6.5.10 not used 6.5.11 not used 6.5.12 not used 6.5.13 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 for use 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 or a water and sediment content within limits,

b. Within 31 days following addition of new fuel oil to storage tanks, verify that the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 2D fuel oil, and

c. Total particulate concentration of the fuel oil is s 10 mgtl when tested every 31 days.

The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Diesel Fuel Oil Testing Program surveillance frequencies.

6.5.14 not used 6.5.15 not used 6.5.16 not used 6.5.17 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 Air Filtration System, 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 total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

WATERFORD - UNIT 3 6-8 AMENDMENT NO. ~8, 63, 79,

~OO, ~09,~88,2~6 218

ADMINISTRATIVE CONTROLS 6.5.17 Control Room Envelope Habitability Program (Continued)

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 control room emergency air filtration, operating at the flow rate required by SR 4.7.6.1.b, at a FREQUENCY of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the assessment of the CRE boundary.

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.

WATERFORD - UNIT 3 6-9 AMENDMENT NO. 218

Pages 6-11 through page 6-13 not used WATERFORD - UNIT 3 6-10 AMENDMENT NO, 218 Next Page is 6-14

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 218 TO FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382

1.0 INTRODUCTION

By application dated August 16, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072320066), as supplemented by letter dated January 8, 2009 (ADAMS Accession No. ML090120460), Entergy Operations, Inc. (the licensee),

requested changes to the Technical Specifications (TSs) for Waterford Steam Electric Station, Unit 3 (Waterford 3). The proposed amendment allows Waterford 3 to adopt the U.S. Nuclear Regulatory Commission (NRC)-approved Industry TS Task Force (TSTF) Traveler TSTF-448, Revision 3, "Control Room Habitability." The availability of this TS improvement was published in the Federal Register on January 17, 2007 (72 FR 2022), as part of the Consolidated Line Item Improvement Process.

The supplemental letter dated January 8, 2009, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on September 25, 2007 (72 FR 54473).

On August 8, 2006, the commercial nuclear electrical power generation industry owners group Technical Specifications Task Force (TSTF) submitted a proposed change, TSTF-448, Revision 3, to the improved standard technical specifications (STS) (NUREGs 1430-1434) on behalf of the industry (TSTF-448, Revisions 0, 1, and 2 were prior draft iterations). TSTF-448, Revision 3, is a proposal to establish more effective and appropriate action, surveillance, and administrative STS requirements related to ensuring the habitability of the control room envelope (CRE).

In NRC Generic Letter (GL) 2003-01, "Control Room Habitability" (Reference 1), licensees were alerted to findings at facilities that existing TS surveillance requirements for the Control Room Emergency Air Cleanup System (CREACS) may not be adequate. Specifically, the results of American Society for Testing and Materials (ASTM) E741 (Reference 2) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure

- 2 surveillance is not a reliable method for demonstrating CRE boundary operability. Licensees were requested to address the existing TS as follows:

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

operability] of the CRE [boundary], and the assumed [unfiltered] inleakage rates of potentially contaminated air. If you currently have a differential pressure surveillance requirement to demonstrate CRE integrity, provide the basis for your conclusion that it remains adequate to demonstrate CRE integrity in light of the ASTM E741 testing results. If you conclude that your differential pressure surveillance requirement is no longer adequate, provide a schedule for:

1) revising the surveillance requirement in your technical specification to reference an acceptable surveillance methodology (e.g., ASTM E741), and 2) making any necessary modifications to your CRE [boundary] so that compliance with your new surveillance requirement can be demonstrated.

If your facility does not currently have a technical specification surveillance requirement for your CRE integrity, explain how and at what frequency you confirm your CRE integrity and why this is adequate to demonstrate CRE integrity.

To promote standardization and to minimize the resources that would be needed to create and process plant-specific amendment applications in response to the concerns described in the GL, the industry and the NRC proposed revisions to CRE habitability system requirements contained in the STS, using the STS change traveler process. This effort culminated in Revision 3 to traveler TSTF-448, "Control Room Habitability," which the NRC staff approved on January 17, 2007.

Consistent with the traveler as incorporated into NUREG-1432, Vol. 1, Revision 3, "Standard Technical Specifications Combustion Engineering Plants Specifications," the licensee proposed revising action and surveillance requirements in TS 3.7.6.1, "Control Room Emergency Air Filtration System - Operating," deleting TS 3.7.6.2, "Control Room Emergency Air Filtration System - Shutdown," deleting TS 3.7.6.5, "Control Room Isolation and Pressurization," and adding a new administrative controls program, TS 6.5.17, "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. In TSTF-448, Revision 3, the control room emergency ventilation system for Combustion Engineering plants is designated as the Control Room Emergency Air Cleanup System (CREACS). At Waterford 3, the control room emergency ventilation system is designated as the Control Room Emergency Air Filtration System (CREAFS).

Waterford 3 currently has three TSs that cover the entire CREAFS. TSs 3.7.6.1 and 3.7.6.2 currently contain requirements for the air filtration train (S-8) portion of the CREAFS. TS 3.7.6.1 contains requirements when operating in Modes 1, 2, 3, and 4, while TS 3.7.6.2 contains requirements when shut down in Modes 5 and 6. TS 3.7.6.5 currently contains requirements for

- 3 all other portions of the CREAFS in all Modes. The license amendment request combines the requirements of all three specifications into one, and modifies the actions and surveillance requirements to be consistent with TSTF-448, Revision 3. The new TS 3.7.6.1, "Control Room Emergency Air Filtration System," contains requirements for all portions of the CREAFS in all Modes, Proposed actions and surveillance requirements in the modified TS 3.7,6,1 are consistent with 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" 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, which 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, 2.2 Control Room Emergency Air Filtration System (CREAFS)

The CREAFS (the term used at Waterford 3 for the Control Room Envelope Air Filtration 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,

- 4 The CREAFS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a design-basis accident (DBA) without exceeding a 5 roentgen equivalent man (rem) whole body dose or its equivalent to any part of the body, 5 rem total effective dose equivalent (TEDE).

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

Fan is operable; High-efficiency particulate air (HEPA) filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; and Heater, demister, ductwork, valves, and dampers are operable, and air circulation can be maintained.

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

2.3 Regulations Applicable to Control Room Habitability In Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR), "Technical specifications," the NRC established its regulatory requirements related to the content of TS.

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

In 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 SSCs important to safety be designed to withstand the effects of natural phenomena such as earthquakes,

- 5 tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions.

GOC 3, "Fire protection," requires that SSCs important to safety be designed and located to minimize the probability and effect of fires and explosions.

GOC 4, "Environmental and dynamic effects design bases," requires that 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).

GOC 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.

GOC 19, "Control room," requires that a control room be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including LOCAs. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident 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.

Prior to incorporation of TSTF-448, Revision 3, the Combustion Engineering STS requirements addressing CRE boundary operability resided only in the following CRE ventilation system specification:

NUREG-1432, TS 3.7.11, "Control Room Emergency Air Cleanup System (CREACS)"

In this TS, the SR associated with demonstrating the operability of the CRE boundary requires verifying that one CREACS train can maintain a positive pressure relative to the areas adjacent to the CRE during the pressurization mode of operation at a makeup flow rate. Facilities that pressurize the CRE during the emergency mode of operation of the CREACS have similar SRs.

Other facilities that do not pressurize the CRE have only a system flow rate criterion for the emergency mode of operation. Regardless, the results of ASTM E741 (Reference 2) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance (or the alternative surveillance at non-pressurization facilities) is not a reliable method for demonstrating CRE boundary operability. That is, licensees were able to obtain differential pressure and flow measurements satisfying the SR limits even though unfiltered inleakage was determined to exceed the value assumed in the safety analyses.

In addition to an inadequate SR, the action requirements of this TS 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 GOC 19, even while crediting compensatory measures).

- 6 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 Regulatory Issue Summary (RIS) 2005-20 (Reference 3). NRC AL 98-10 also states that "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 fas~lion."

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

However, based on GL 2003-01 and AL 98-10, the NRC staff expects each licensee to propose TS changes that include a surveillance to periodically measure CRE unfiltered inleakage in order to satisfy 10 CFR 50.36(c)(3), which requires a facility's TS to include SRs, which it defines as "requirements relating to test, calibration, or inspection to assure that the necessary quality of [structures,] systems and components is maintained, that facility operation will be within safety limits, and that limiting conditions for operation will be met."

The NRC staff also expects facilities to propose unambiguous remedial actions, consistent with 10 CFR 50.36(c)(2), for the condition of not meeting the limiting condition for operation (LCO) due to an inoperable CRE boundary. The action requirements should specify a reasonable completion time to restore conformance to the LCO before requiring a facility to be shut down.

This completion time should be based on the benefits of implementing mitigating actions to ensure CRE occupant safety and sufficient time to resolve most problems anticipated with the CRE boundary, while minimizing the chance that operators in the CRE will need to use mitigating actions during accident conditions.

2.4 Adoption of TSTF-448, Revision 3, by Waterford 3 Adoption of TSTF-448, Revision 3, will assure that the facility's TS LCO for the CREAFS is met by demonstrating unfiltered leakage into the CRE is within limits (i.e., the operability of the CRE boundary). In support of this surveillance, which specifies a test interval (frequency) described in Regulatory Guide 1.197, TSTF-448 also adds TS administrative controls to assure the habitability of the CRE between performances of the ASTM E741 test. In addition, adoption of TSTF-448 will establish clearly stated and reasonable required actions in the event CRE unfiltered inleakage is found to exceed the analysis assumption.

The changes made by TSTF-448 to the STS requirements for the CREAFS 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 Waterford 3 CRE will remain habitable during normal operation and DBA conditions. These changes are, therefore, acceptable from a regulatory standpoint.

- 7

3.0 TECHNICAL EVALUATION

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

Proposed TS Changes The proposed amendment would strengthen CRE habitability TS requirements by changing TS 3.7.6.1, "Control Room Emergency Air Filtration 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 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.

The NRC staff compared the proposed TS changes to the STS and the STS markups and evaluations in TSTF-448. The NRC staff also reviewed the proposed changes to the TS Bases for consistency with the STS Bases and the plant-specific design and licensing bases, although approval of the Bases is not a condition for accepting the proposed amendment. However, TS 6.16, "Technical Specification Bases Control Program," provides assurance that the licensee has established and will maintain the adequacy of the Bases. The proposed Bases for TS 3.7.6.1 refer to specific guidance in Nuclear Energy Institute (NEI) 99-03, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001 (Reference 6), which the NRC staff has formally endorsed, with exceptions, through Regulatory Guide 1.196 (Reference 4).

The proposed changes by Waterford 3 are discussed below.

3.1 Editorial Changes The licensee proposed editorial changes to TS 3.7.6.1 "Control Room Emergency Air Filtration System," to establish standard terminology, such as control room envelope (eRE) in place of "control room," and "radiological, chemical, and smoke hazards (or challenges)" in place of various phrases to describe the hazards that CRE occupants are protected from by the CREAFS. These changes improve the usability and quality of the presentation of the TS, have no impact on safety and, therefore, are acceptable.

3.2 TS 3.7.6.1, CREAFS The licensee proposed to establish new action requirements in TS 3.7.6.1, "CREAFS," for an inoperable CRE boundary in Modes 1, 2, 3, and 4. Currently, in these Modes, if an inoperable CRE boundary exists, existing Actions in TS 3.7.6.5 would apply. These existing Actions are more restrictive than would be appropriate in situations for which CRE occupant implementation of compensatory measures or mitigating actions would temporarily afford adequate CRE occupant protection from postulated airborne hazards. To account for such situations, the licensee proposed to revise the action requirements consistent with TSTF-448, Revision 3, for

- 8 an inoperable CRE boundary. As discussed in Section 1.0, "Introduction," TS 3.7.6.5 is deleted and the modified Actions are now contained in TS 3.7.6.1. The new Actions will allow gO days to restore the CRE boundary (and consequently, the affected CREAFS trains) to operable status, provided that mitigating actions are immediately implemented and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are verified to ensure, that in the event of a DBA, CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke.

The 24-hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The gO-day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The gO-day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary. Therefore, the proposed Actions for an inoperable CRE in Modes 1, 2, 3, and 4, are acceptable.

The licensee proposed to add new Actions to TS 3.7.6.1 for when one or more CREAFS trains are inoperable, as well as Actions due to an inoperable CRE boundary, in Modes 5 or 6, or during movement of irradiated fuel assemblies. Currently, in these Modes, when one or rr.ore CREAFS trains are inoperable or if an inoperable CRE boundary exists, existing Actions in TS 3.7.6.2 or TS 3.7.6.5 would apply. As discussed in Section 1.0 of this safety evaluation, TS 3.7.6.2 and TS 3.7.6.5 are deleted and the modified Actions are now contained in TS 3.7.6.1. The Actions proposed for these conditions in TS 3.7.6.1 are consistent with TSTF-448, Revision 3, and require suspending movement of irradiated fuel assemblies if the CRE is inoperable or if both CREAFS trains are inoperable. When only one CREAFS train is inoperable, and cannot be restored within 7 days, Actions consist of either suspending movement of irradiated fuel assemblies or placing the operable train in service. These changes, in Modes 5 or 6, or during movement of irradiated fuel assemblies, are acceptable since activities that can result in a potential accident are suspended if a complete loss of the safety function exists. When one train is inoperable, placing the operable train in service ensures that the safety function can be carried out if an accident occurs. Therefore, these proposed changes are acceptable.

In its August 16, 2007, letter, the licensee also proposed to modify the CREAFS LCO by adding a note allowing the CRE boundary to be opened intermittently under administrative controls. As stated in the proposed LCO Bases:

This note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.

- 9 The allowance of this note is acceptable because the administrative controls will ensure that the opening will be quickly sealed to maintain the validity of the licensing basis analyses of DBA conseq uences.

In the pressurization mode of operation, the CREAFS 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 modify the CRE pressurization SR. SR 4.7.6.5 currently requires verifying that the CRE can maintain a pressure of 1/8 inches water gauge, relative to the outside atmosphere during the pressurization mode of operation at a makeup flow rate of 200 cubic feet per minute. The modification of this SR is proposed because measurements of unfiltered air leakage into the CRE at numerous reactor facilities demonstrated that a basic assumption of this SR, an essentially leak-tight CRE boundary, was incorrect for most facilities. Hence, meeting this SR by achieving the required CRE pressure is not necessarily a conclusive indication of CRE boundary leak tightness, i.e.,

CRE boundary operability. Based on the adoption of TSTF-448, Revision 3, the licensee's proposal to modify SR 4.7.6.5 is acceptable. SR 4.7.6.5 is a part of TS 3.7.6.5. The new SR for verifying Operability of the CRE is proposed SR 4.7.6.1.g. As discussed in Section 1.0 of this safety evaluation, TS 3.7.6.5 is deleted and the modified SRs are now contained in TS 3.7.6.1.

The proposed CRE inleakage measurement SR states, "Perform required control room envelope unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program." The CRE Habitability Program TS, proposed TS 6.5.17, requires that the program include requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0 (Reference 5). This guidance references ASTM E741 (Reference 2) as an acceptable method for ascertaining the unfiltered leakage into the CRE. The licensee has proposed to follow this method. Therefore, the proposed CRE inleakage measurement SR is acceptable.

3.3 TS 6.5.17, CRE Habitability Program The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Revision 3. In combination with SR 4.7.6.1.g, this program is intended to ensure the operability of the CRE boundary, which as part of an operable CREAFS 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 or its equivalent to any part of the body, 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

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

Definitions of CRE and CRE boundary. This element is intended to ensure that these definitions accurately describe the plant areas that are within the CRE, and also the interfaces that form the CRE boundary, and are consistent with the general definitions discussed in Section 2.1 of this

- 10 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 freguencies 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 freguencies 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 inleakqge 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 CREAFS 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.

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 3.7.6.1, 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

- 11 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 TS 6.5.17 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, TS 6.5.17, which is consistent with the model program TS approved by the NRC staff in TSTF-448, Revision 3, is acceptable.

3.4 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 the proposed license conditions. The proposed plant specific license conditions are consistent with the model application, and are acceptable.

3.5 License Conditions In its letter dated August 16, 2007, as supplemented by letter dated January 8,2009, the licensee agreed to add license conditions related to the initial performance of the new surveillance and assessment requirements. Paragraph 2.C.19 of Facility Operating License No.

NPF-38 is hereby amended to add a new license condition, designed as Amendment No. 218, to read as follows:

Upon implementation of Amendment No. 218 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 6.5.17, in accordance with TS 6.5.17.c.(i), the assessment of CRE habitability as required by Specification 6.5.17.c.(ii), and the measurement of eRE pressure as required by Specification 6.5.17.d, shall be considered met.

Following implementation:

(a)

The first performance of SR 6.5.17, in accordance with Specification 6.5.17.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 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 6.5.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004

- 12 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 6.5.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from August 13, 2008, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

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

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant-hazards considerations, and there has been no public comment on the finding published in the Federal Register on September 25, 2007 (72 FR 54473). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(1 0). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1.

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

- 13

2.

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

3.

U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2005-20, Revision 1, "Revision to NRC Inspection Manual Part 9900 Technical Guidance,

'Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality and Safety, dated April 16, 2008 (ADAMS Accession No. ML073440103).

4.

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

5.

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

6.

Nuclear Energy Institute (NEI) 99-03, "Control Room Habitability Assessment Guidance,"

Revision 0, dated June 2001 (ADAMS Accession No. ML031620248).

Principal Contributor: A. Lewin Date: February 20 I 2009

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