Text

ME0693 & ME0694, Issuance of Amendment to Incorporate TSTF-448 Using CLIIP
	ML091270366
Person / Time
Site:	Susquehanna
Issue date:	07/06/2009
From:	Bhalchandra Vaidya; Plant Licensing Branch 1
To:	Spence W; PPL Corp
	vaidya b k
References
	TAC ME0693, TAC ME0694
	Download: ML091270366 (33)
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\.~",R REGV( UNITED STATES

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~ 0.,- NUCLEAR REGULATORY COMMISSION

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0 WASHINGTON, D.C. 20555-0001 I ;:

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,lul y 6, 2009

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~'? ,..0 Mr. William H. Spence Executive Vice President Chief Operating Officer/Chief Nuclear Officer PPL Corporation Two North Ninth Street, GENTW16 Allentown, PA 18101-1179

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 -ISSUANCE OF AMENDMENT RE: REVISION OF TECHNICAL SPECIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448, REVISION 3, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLlIP) (TAC NOS. ME0693 AND ME0694)

Dear Mr. Spence:

The Commission has issued the enclosed Amendment No. 252 to Facility Operating License No. NPF-14 and Amendment NO.232 to Facility Operating License No. NPF-22 for the Susquehanna Steam Electric Station (SSES), Units 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated February 20, 2009.

These amendments modified Technical Specifications (TS) requirements related to control room envelope habitability in TS 3.7.3, "Plant Systems Control Room Emergency Outside Air Supply (CREOAS) System," and TS Section 5.5, "Administrative Controls Programs and Manuals."

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next regular Biweekly Federal Register Notice.

SinCer~!:L_Q.

~(i Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosures:

1. Amendment No. 252 to License No. NPF-14

2. Amendment No232 to License No. NPF-22

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.

DOCKET NO. 50-387 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment N0252 License No. NPF-14

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

A. The application for the amendment filed by PPL Susquehanna, LLC, dated February 20, 2009, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 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.

-2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-14 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No252 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION

~~~

Nancy L. Salgado, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: Jul y 6, 2009

ATTACHMENT TO LICENSE AMENDMENT NO. 252 FACILITY OPERATING LICENSE NO. NPF-14 DOCKET NO. 50-387 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

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

REMOVE INSERT TS/3.7-6 TS/3.7-6 TS/3.7-7 TS/3.7-7 TS/3.7-8 TS/3.7-8 TS/3.7-9 TS/3.7-9 TS/5.0-188 TS/5.0-18C

-3 (4) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the 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 PPL Susquehanna, LLC is authorized to operate the facility at reactor core power levels not in excess of 3952 megawatts thermal in accordance with the conditions specified herein. The preoperational tests, startup tests and other items identified in License Conditions 2.C.(36), 2.C.(37), 2.C.(38), and 2.C.(39) to this license shall be completed as specified.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 252 and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

For Surveillance Requirements (SRs) that are new in Amendment 178 to Facility Operating License No. NPF-14, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 178. For SRs that existed prior to Amendment 178, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 178.

(3) Conduct of Work Activities During Fuel Load and Initial Startup The operating licensee shall review by committee all facility construction, Preoperational Testing, and System Demonstration activities performed concurrently with facility initial fuel loading or with the facility Startup Test Amendment No. a, 44J,4+8,~, 488,~, 2Ja, 2de,~,~, 2J9, 240, 244, 242, 24J, ~

~,~,~,~,~,~, ~,252

PPL Rev.

CREOAS System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Outside Air Supply (CREOAS) System LCO 3.7.3 Two CREOAS subsystems shall be OPERABLE.

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

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

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREOAS subsystem A.1 Restore CREOAS subsystem 7 days inoperable for reasons other to OPERABLE status.

than Condition B.

B. One or more CREOAS B.1 Initiate action to implement Immediately subsystems inoperable due mitigating actions to inoperable CRE boundary in MODES 1, 2, and 3. AND B.2 Verify mitigating actions ensure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

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

(continued)

SUSQUEHANNA - UNIT 1 TS / 3.7-6 Amendment ~,252

PPL Rev.

CREOAS System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met AND in MODE 1, 2, or 3.

C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and --------------------NOTE--------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A not met during -------------------------------------------------

movement of irradiated fuel assemblies in the secondary D.1 Place OPERABLE CREOAS Immediately containment, during CORE subsystem in pressurization/

ALTERATIONS, or during filtration mode.

OPDRVs.

OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs.

E. Two CREOAS subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

(continued)

SUSQUEHANNA - UNIT 1 rs / 3.7-7 Amendment 2ro,252

PPL Rev.

CREOAS System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREOAS subsystems ---------------------NOTE-------------------

inoperable during movement LCO 3.0.3 is not applicable.

of irradiated fuel assemblies -------------------------------------------------

in the secondary containment, during CORE F.1 Suspend movement of Immediately ALTERATIONS, or during irradiated fuel assemblies in OPDRVs. the secondary containment.

OR AND One or more CREOAS F.2 Suspend CORE Immediately subsystems inoperable due ALTERATIONS.

to an inoperable CRE boundary during movement AND of irradiated fuel assemblies in the secondary F.3 Initiate action to suspend Immediately containment, during CORE OPDRVs.

ALTERATIONS, or during OPDRVs SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREOAS filter train for > 10 31 days continuous hours with the heaters operable.

SR 3.7.3.2 Perform required CREOAS filter testing in In accordance with the VFTP accordance with the Ventilation Filter Testing Program (VFTP).

SR 3.7.3.3 Verify each CREOAS subsystem actuates on an 24 months actual or simulated initiation signal.

(continued)

SUSQUEHANNA - UNIT 1 TS / 3.7-8 Amendment~, 252

PPL Rev.

CREOAS System 3.7.3 SURVEILLANCE FREQUENCY SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordance with the testing in accordance with the Control Room Control Room Envelope Envelope Habitability Program. Habitability Program SUSQUEHANNA - UNIT 1 TS / 3.7-9 Amendment 4-78-;

252

PPL Rev.

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.14 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 Outside Air Supply (CREOAS) 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 whole body or its equivalent to any part of the body for the duration of the accident.

The program shall include the following elements:

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

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

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Section C.1 and Co2 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 subsystem of the CREOAS System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CRE boundary.

SUSQUEHANNA - UNIT 1 TS / 5.0-18B Amendment 252

PPL Rev.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued)

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

f. The provisions of SR 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.

SUSQUEHANNA - UNIT 1 TS / 5.0-18C Amendment252

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.

DOCKET NO. 50-388 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment NO.232 License No. NPF-22

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

A. The application for the amendment filed by the PPL Susquehanna, LLC, dated February 20, 2009, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 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.

-2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-22 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 232 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION

~/~

Nancy L. Salgado, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: Jul y 6, 2009

-3 (4) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the 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 PPL Susquehanna, LLC is authorized to operate the facility at reactor core power levels not in excess of 3952 megawatts thermal in accordance with the conditions specified herein. The preoperational test, startup tests and other items identified in License Conditions 2.C.(20), 2.C.(21), 2.C.(22), and 2.C.(23) to this license shall be completed as specified.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 232 ,and the Environmental Protection Plan contained in Appendix S, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

For Surveillance Requirements (SRs) that are new in Amendment 151 to Facility Operating License No. NPF-22, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 151. For SRs that existed prior to Amendment 151, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 151.

2.C.(3) PPL Susquehanna, LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Review Report for the facility and as approved in Fire Protection Program, Section 9.5, SER, SSER#1, SSER#2, SSER#3, SSER#4, SSER#6, Safety Evaluation of Fire Protection dated August 9, 1989, Safety Evaluation Amendment No.4, 2, 400, -+W, ~, ~, 492, -+W, 242, 24J, 24J, 24a, 24e, 24+, ~, ~

22Q, 224, 222, ~, 224, aas. aas. 22+, 228, 23Q, ~,232

ATTACHMENT TO LICENSE AMENDMENT NO.232 FACILITY OPERATING LICENSE NO. NPF-22 DOCKET NO. 50-388 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

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

REMOVE INSERT TS/3.7-6 TS/3.7-6 TS/3.7-7 TS/3.7-7 TS/3.7-8 TS/3.7-8 TS/3.7-9 TS/3.7-9 TS/5.0-18B TS/5.0-18C

PPL Rev.

CREOAS System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Outside Air Supply (CREOAS) System LCO 3.7.3 Two CREOAS subsystems shall be OPERABLE.

NOTES----------------------------------------------

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

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A, One CREOAS subsystem A,1 Restore CREOAS subsystem to 7 days inoperable for reasons other OPERABLE status.

than Condition B.

B. One or more CREOAS B.1 Initiate action to implement Immediately subsystems inoperable due mitigating actions to inoperable CRE boundary in MODES 1, 2, and 3. AND B.2 Verify mitigating actions to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

(continued)

SUSQUEHANA - UNIT 2 TS'3.7-6 Amendment 4-7-7,232

PPL Rev.

CREOAS System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met AND in MODE 1,2, or3.

C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and --------------------NOTE--------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A not met during --------------------------------------------------

movement of irradiated fuel assemblies in the secondary containment, during CORE D.1 Place OPERABLE CREOAS Immediately ALTERATIONS, or during subsystem in pressurization!

OPDRVs. filtration mode.

OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs.

E. Two CREOAS subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

(continued)

SUSQUEHANA - UNIT 2 TS !3.7-7 Amendment +++,232

PPL Rev.

CREOAS System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREOAS subsystems --------------------NOTE--------------------

inoperable during movement LCO 3.0.3 is not applicable.

of irradiated fuel assemblies -------------------------------------------------

in the secondary containment, during CORE F.1 Suspend movement of Immediately ALTERATIONS, or during irradiated fuel assemblies in OPDRVs. the secondary containment.

OR AND One or more CREOAS F.2 Suspend CORE Immediately subsystems inoperable due ALTERATIONS.

to an inoperable CRE boundary during movement AND of irradiated fuel assemblies in the secondary F.3 Initiate action to suspend Immediately containment, during CORE OPDRVs.

ALTERATIONS, or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREOAS filter train for ~ 10 31 days continuous hours with the heaters operable.

SR 3.7.3.2 Perform required CREOAS filter testing in In accordance with the VFTP accordance with the Ventilation Filter Testing Program (VFTP).

SR 3.7.3.3 Verify each CREOAS subsystem actuates on an 24 months actual or simulated initiation signal.

(continued)

SUSQUEHANA - UNIT 2 TS / 3.7-8 Amendment -t7-7~32

PPL Rev.

CREOAS System 3.7.3 SURVEILLANCE FREQUENCY SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordance with the testing in accordance with the Control Room Control Room Envelope Envelope Habitability Program. Habitability Program SUSQUEHANA - UNIT 2 TS/3.7-9 Amendment +a-+,

232

PPL Rev.

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.14 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 Outside Air Supply (CREOAS) 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 whole body or its equivalent to any part of the body for the duration of the accident.

The program shall include the following elements:

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

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

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Section 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 subsystem of the CREOAS System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CRE boundary.

SUSQUEHANNA - UNIT 2 TS / 5.0-18B Amendment 232

PPL Rev.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued)

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

f. The provisions of SR 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.

SUSQUEHANNA - UNIT 2 TS /5.0-18C Amendment 232

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 252 TO FACILITY OPERATING LICENSE NO. NPF-14 AND AMENDMENT NO. 232 TO FACILITY OPERATING LICENSE NO. NPF-22 PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-387 AND 388

1.0 INTRODUCTION

By application dated February 20, 2009 (Agencywide Documents Access and Management system (ADAMS) Accession No. ML090641019), PPL Susquehanna, LLC (the licensee),

requested changes to the Technical Specifications (TSs) for Susquehanna Steam Electric Station, Units 1 and 2 (SSES-1 and 2).

The proposed amendment would modify TS requirements related to control room envelope habitability in TS 3.7.3, "Plant Systems Control Room Emergency Outside Air Supply (CREOAS)

System," and TS Section 5.5, "Administrative Controls Programs and Manuals."

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

In NRC Generic Letter (GL) 2003-01 (Reference 1), licensees were alerted to findings at facilities that existing TS Surveillance Requirements (SRs) for the Control Room Envelope Emergency Ventilation System (CREEVS) may not be adequate. Specifically, the results of 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:

-2 Provide confirmation that your technical specifications verify the integrity [i.e., operability]

of the CRE [boundary], and the assumed [unfiltered] inleakage rates of potentially contaminated air. If you currently have a differential pressure surveillance requirement to demonstrate CRE [boundary] integrity, provide the basis for your conclusion that it remains adequate to demonstrate CRE integrity in light of the ASTM E741 testing results.

If you conclude that your differential pressure surveillance requirement is no longer adequate, provide a schedule for: 1) revising the surveillance requirement in your technical specification to reference an acceptable surveillance methodology (e.g.,

ASTM E741), and 2) making any necessary modifications to your CRE boundary so that compliance with your new surveillance requirement can be demonstrated.

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

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

Consistent with the traveler as incorporated into NUREG-1433, the licensee proposed revising action and SRs in Specification 3.7.3, "Control Room Emergency Outside Air Supply (CREOAS)

System," and adding a new administrative controls program, Specification 5.5.14, "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 (SE) resulting in minor deviations from the model SE text in TSTF-448, Revision 3.

2.0 REGULATORY EVALUATION

2.1 Control Room and Control Room Envelope NRC Regulatory Guide (RG) 1.196, "Control Room Habitability at Light-water Nuclear Power Reactors," Revision 0, May 2003, (Reference 4) uses the term "control room envelope" 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 fer a safe shutdown of the plant and typically includes the critical document reference iile, 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 eve,' t of an accident.

-3 Control Room Envelope: The plant area, defined in the facility licensing basis that in the event of an emergency, can be isolated from the plant areas and the environment external to the CRE. This area is served by an emergency ventilation system, with the intent of maintaining the habitability of the control room. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident.

NRC RG 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors,"

Revision 0, May 2003 (Reference 5), also contains these definitions, but uses the term CRE to mean both. This is because the protected environment provided for operators varies with the nuclear power facility. At some facilities this environment is limited to the control room; at others, it is the CRE. In this SE, 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 Outside Air System (CREOAS)

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

The CREOAS 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 rem whole body dose or its equivalent to any part of the body.

The CREOAS is shared between the two units at the Susquehanna Steam Electric Station.

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

Fans 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

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 DBA consequences to CRE occupants.

- 4 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.

In Attachment 1 of a letter from PPL Susquehanna, LLC (now PPL Corporation) dated August 11, 2003 titled: "SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO GENERIC LETTER 2003-01 CONTROL ROOM HABITABILITY (Agencywide Document and Management System (ADAMS) No. ML032310442), it is confirmed that Susquehanna Steam Electric Station "was licensed to the applicable General Design Criteria." 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 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 in the CRE ventilation system specification NUREG-1433, TS 3.7.4, "Main Control Room Environmental Control (MCREC) System." In this specification, the SR associated with demonstrating the operaollity of the CRE boundary required verifying that one CREEVS train could 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 CREEVS have similar SRs. Regardless,

-5 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. That is, licensees were able to obtain differential pressure and flow measurements satisfying the SR limit even though unfiltered inleakage was determined to exceed the value assumed in the safety analyses.

In addition to an inadequate SR, the action requirements of these specifications were ambiguous regarding CRE boundary operability in the event CRE unfiltered inleakage is found to exceed the analysis assumption. The ambiguity stemmed from the view that the CRE boundary may be considered operable but degraded in this condition, and that it would be deemed inoperable only if calculated radiological exposure limits for CRE occupants exceeded a licensing basis limit; e.g., as stated in GDC-19, even while crediting compensatory measures.

NRC Administrative Letter 98-10, "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 deflned in NRC Inspection Manual Chapter 9900; see latest guidance in RIS 2005-20 (Reference 3). "Imposing administrative controls in response to improper or inadequate TS is considered an acceptable short-term corrective action. The NRC staff expects that, following the imposition of administrative controls, an amendment to the inadequate TS, with appropriate justification and schedule, will be submitted in a timely fashion."

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

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

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

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

2.4 Adoption of TSTF-448 Revision 3, by Susquehanna Steam Electric Station Adoption of TSTF-448, Revision 3, will assur>> that the facility's TS LCO for the CREOAS is met by demonstrating unfiltered leakage into the \*.~RE is within limits (i.e., the operability of the CRE boundary). In support of this surveillance, wt, ch specifies a test interval (frequency) described in RG 1.197, TSTF-448 also adds TS administr..tive controls to assure the habitability of the CRE between performances of the ASTM E741 test. In addition, adoption of TSTF-448 will establish

-6 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 CREOAS 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 a plant's CRE will remain habitable during normal operation and DBA conditions.

These changes are, therefore, acceptable from a regulatory standpoint.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the proposed changes against the corresponding changes made to the STS by TSTF-448, Revision 3, which the NRC staff has found to satisfy applicable regulatory requirements, as described above in Section 2.0. The emergency operational mode of the CREOAS at Susquehanna 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 3.7.3, CREOAS and adding a new TS administrative controls program on CRE habitability.

Accompanying the proposed TS changes are appropriate conforming technical changes to the TS Bases. The proposed revision to the Bases also includes editorial and administrative changes to reflect applicable changes to the corresponding STS Bases, which were made to improve clarity, conform to the latest information and references, correct factual errors, and achieve more consistency among the STS NUREGs. Except for plant-specific differences, all of these changes are consistent with STS as revised by TSTF-448, Revision 3.

The NRC staff compared the proposed TS changes to the STS and the STS markups and evaluations in TSTF-448. The staff verified that differences from the STS were adequately justified on the basis of plant-specific design or retention of current licensing basis. In particular, the frequency of measuring the pressurization cited in new TS 5.5.14 d. is 24 months. This is greater than the 18 months cited in the TSTF-448 model, but conforms with the equivalent frequency in Susquehanna's existing TS in SR 3.7.3.4. The NRC staff also reviewed the proposed changes to the TS Bases for consistency with the STS Bases and the plant-specific design and licensing bases, although approval of the Bases is not a condition for accepting the proposed amendment. However, TS 5.5.10, "TS Bases Control Program," provides assurance that the licensee has established and will maintain the adequacy of the Bases. The proposed Bases for TS 3.7.3 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 RG 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," dated lVIay 2003 (Reference 4).

3.2 Editorial Changes The licensee proposed editorial changes to TS 3.7.3, "CREOAS," to establish standard terminology, such as "control room envelope (CRE)" in place of "control room," except for the plant-specific name for the MCREC, and "radiological, chemical, and smoke hazards" in place of various phrases to describe the hazards that CRE occupants are protected from by the

-7 CREOAS. These changes improve the usability and quality of the presentation of the TS, have no impact on safety, and therefore, are acceptable.

3.3 TS 3.7.3, CREOAS The licensee proposed to revise the action requirements of TS 3.7.3 CREOAS to acknowledge that an inoperable CRE boundary, depending upon the location of the associated degradation, could cause just one, instead of both CREOAS trains to be inoperable. This is accomplished by revising Condition A to exclude Condition B, and revising Condition B to address one or more CREOAS trains, as follows:

Condition A One CREOAS train inoperable for reasons other than Condition B.

Condition B One or more CREOAS trains inoperable due to inoperable CRE boundary in MODE 1, 2, and 3 This change clarifies how to apply the action requirements in the event just CREOAS train 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 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , that CRE occupant radiological exposures will not exceed limits, and that CRE occupants are protected from chemicals and smoke; and Required Action B.3, to restore CRE boundary to operable status within gO 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 by Required Action B.1. The gO-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 eRE 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, proposed Actions B.1, B.2, and B.3 are acceptable The licensee proposed to add a new condition to Action F of TS 3.7.3 that states, "One or more CREOAS subsystems inoperable due to an inoperable CRE boundary during movement of irradiated fuel assemblies in secondary containment, during CORE ALTERATIONS, or during OPDRVs." The specified Required Actions proposed for this condition are the same as for the other existing condition for Action F, which states, "Two CREOAS subsystems inoperable during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs." Accordingly, the new condition is stated with the other condition in Action F using the logical connector "OR". The practical result of this presentation in

-8 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. This new condition in Action F is needed because proposed Action B will only apply in Modes 1, 2, and 3. As such, this change will ensure that the Actions table continues to specify a condition for an inoperable CRE boundary during refueling and OPDRVs. Therefore, this change is administrative and acceptable.

In operation, the CREOAS isolates unfiltered ventilation air supply intakes, filters the emergency ventilation air supply to the CRE, and pressurizes the CRE to minimize unfiltered air inleakage past the CRE boundary. The licensee proposed to delete the CRE pressurization SR. This SR requires verifying that each CREOAS subsystem can maintain a pressure z 0.125 inches water gauge, relative to the outside atmosphere during the pressurizationlfiltration mode of operation at a makeup flow rate of S 5810 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, Le., CRE boundary operability. Based on the adoption of TSTF-448, Revision 3, the licensee's proposal to delete SR 3.7.3.4 is acceptable.

The proposed CRE inleakage measurement SR states, "Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program." The CRE Habitability Program TS, proposed TS 5.5.14, requires that the program include Requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of RG 1.197, Revision 0 (Reference 5). This guidance references ASTM E741 (Reference 2) as an acceptable method for ascertaining the unfiltered leakage into the CRE. The licensee has proposed to follow this method. Therefore, the proposed CRE inleakage measurement SR is acceptable.

3.4 TS 5.5.14, CRE Habitability Program The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Revision 3. In combination with SR 3.7.3.4, this program is intended to ensure the operability of the CRE boundary, which as part of an operable CREOAS will ensure that CRE habitability is maintained such that CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under DBA conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TED E) 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 eRE boundary.

-9 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 SE. Establishing what is meant by the CRE and the CRE boundary will preclude ambiguity in the implementation of the program.

Configuration control and preventive maintenance of the CRE boundary.

This element is intended to ensure the CRE boundary is maintained in its design condition.

Guidance for implementing this element is contained in RG 1.196 (Reference 4), which endorsed, with exceptions, t\lEI 99-03, Rev. 0 (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 RG 1.197. Assessing CRE habitability at the t\lRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not go undetected between CRE inleakage determinations. Determination of CRE inleakage using test methods acceptable to the NRC staff assures that test results are reliable for ascertaining CRE boundary operability. Determination of CRE inleakage at the NRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not occur between CRE inleakage determinations.

Measurement of CRE pressure with respect to all areas adjacent to the CRE boundary at designated locations for use in assessing the CRE boundary at a frequency of 24 months on a staggered test basis (with respect to the CREOAS 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 3.7.3 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).

- 10 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, the licensee's proposed TS 5.5.14 states that (1) aCRE 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, the proposed TS 5.5.14, is consistent with the model program TS approved by the !\IRC staff in TSTF-448, Revision 3, and is acceptable.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change SRs.

The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendments involve no significant-hazards considerations, and there has been no public comment on the finding (74 FR 18256 - April 21, 2009). The amendments also relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22( c)(9) and (c)( 10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

- 11

7.0 REFERENCES

1. NRC Generic Letter 2003-01, "Control Room Habitability," dated June 12,2003, (GL 2003-01).

2. 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: Revision to Guidance Formerly Contained in NRC Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," dated September 26, 2005 (RIS 2005-20).

4. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, dated May 2003.

5. Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003.

6. NEI 99-03, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001

7. License Amendment Request from PPL Corporation dated February 20,2009 (Agencywide Documents Access and Management System (ADAMS) No.

ML090641019)

8. Susquehanna Steam Electric Station Response To Generic Letter 2003-01 "Control Room Habitability" (Agencywide Documents Access and Management System (ADAMS)

No. ML032310442)

Principal Contributors: V. Cusumano, NRR/DIRS M. Hamm, NRR/DIRS Date: Jul y 6. 2009

ML091270366

) Not Required per ML072980233 (**) No substantial chance to SE Input Memo OFFICE LPL1-1/PM LPL 1-1/LA NRR/ITSB/BC OGC LPL 1-1/BC NAME BVaidya SLittie REliiot(**) Not Required (*) NSalgado DATE 7/1/09 7/1/09 04120109 716/09

v t e Letter Sequence Approval
TAC:ME0693, Control Room Habitability (Approved, Closed) TAC:ME0694, Control Room Habitability (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2009-03-23 [Table View]

ML091270366

Text

SUBJECT:

Dear Mr. Spence:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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