ML091320562

Application for Technical Specification Change to Correct Minor Error in Amendment 70

ML091320562
Person / Time
Site:	Watts Bar
Issue date:	04/30/2009
From:	Skaggs M Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WBN-TS-09-05
Download: ML091320562 (10)

Text

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 April 30, 2009 10 CFR 50.'90 WBN-TS-09-05 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 In the Matter of ) Docket No. .50-390 Tennessee Valley Authority )

WATTS BAR NUCLEAR PLANT (WBN) - UNIT 1 - APPLICATION FOR TECHNICAL SPECIFICATION (TS) CHANGE TO CORRECT, MINOR ERROR IN AMENDMENT 70

References:

1. TVA Letter to NRC dated October 26, 2007, 'Watts Bar Nuclear Plant (WBN) -

Unit 1 - Technical Specifications Change 07 "Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with Technical Specification Task Force (TSTF)-448, Revision 3, Using the Consolidated Line Item Improvement Process" (ML073380948)

2. NRC Letter to TVA dated October 8, 2008, "Watts Bar Nuclear Plant, Unit 1 -

Issuance of Amendment Regarding Control Room Envelope Habitability (TAC.

No. MD7474)" (ML082730261)

Pursuant to 10 CFR 50.90, TVA is submitting a request for a TS change (WBN-TS-09-05) to License NPF-90 for WBN Unit 1. During the development of TS Change TVA-WBN-TS-07-14, submitted to the NRC on October 26, 2007 (Reference 1), the number for a new TS section being added to Section 5.7, "Procedures, Programs, and Manuals," was transposed. The new section should have been numbered 5.7.2.20 but was listed as 5.2.7.20 in the submittal released to the NRC.

The minor error was carried forward in the Safety Evaluation for Amendment 70, which was approved on October 8, 2008 (Reference 2).

This administrative error affected pages 5.0-25 and 5.0-25a. Provided in Attachment 1 of the enclosure are the existing TS pages marked up to show the proposed change. of the Enclosure provides revised (clean) TS pages.

U.S. Nuclear Regulatory Commission Page 3 April 30, 2009 TVA has determined that this minor error correction does not impact the Regulatory Analysis, nor does it change the conclusion of the No Significant Hazards Consideration evaluation submitted in Reference 1. However, for this minor error correction, a brief No Significant Hazards Consideration evaluation is provided in the enclosure which has determined that there are no significant hazards considerations associated with the proposed change and that this change qualifies for a categorical exclusion from the environmental review pursuant to the provisions of 10 CFR 5.22(C)(9). Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and attachments to the Tennessee State Department of Public Health.

TVA requests routine processing of this TS change by the NRC and that the implementation of the revised TS be within 30 days of NRC approval.

There are no regulatory commitments associated with this submittal. If you have any questions regarding this change, please contact Mike Brandon, Manager, Site Licensing and Industry Affairs, at (423) 365-1824.

I declare under the penalty of perjury that the foregoing is true and correct. Executed on the 30th day of April 2009.

Since ely, Mike Skaggs Site Vice President Watts Bar Nuclear Plant Enclosures cc (w/enclosures):

NRC Resident Inspector U. S. Nuclear Regulatory Commission Watts Bar Nuclear Plant Mr. John G. Lamb, Senior Project Manager 1260 Nuclear Plant Road Division of Operating Reactor Licensing Spring City, Tennessee 37381 Office of Nuclear Reactor Regulation MS 0-8 H1A Washington, D.C. 20555-0001 U. S. Nuclear Regulatory Commission Mr. Lawrence E. Nanny, Director Region II Division of Radiological Health Sam Nunn Atlanta Federal Center 3rd Floor 61 Forsyth Street, SW, Suite 23T85 L & C Annex Atlanta, Georgia 30303 401 Church Street Nashville, Tennessee 37243

.I I.

Enclosure Tennessee Valley Authority Watts Bar Nuclear Plant Unit 1 Docket Number 50-390, NPF-90 Technical Specification Change WBN-TS-09-05 Change to Correct Minor Error in Amendment 70 Significant Hazards Consideration TVA is requesting to amend Operating License NPF-90 for the WBN. The proposed change would correct a typographical error contained in Watts Bar Technical Specification 5.0, "Administrative Controls." During the development of TS Change TVA-WBN-TS-07-14, submitted to the NRC on October 26, 2007 (Reference 1), the number for a new TS section being added to Section 5.7, "Procedures, Programs, and Manuals," was transposed. The new section should have been numbered 5.7.2.20 but was listed as 5.2.7.20 in the submittal released to the NRC. The minor error was carried forward in the Safety Evaluation for Amendment 70, which was approved on October 8, 2008 (Reference 2). This administrative error affected pages 5.0-25 and 5.0-25a.

TVA has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

This change is limited only to correcting a typographical error in a section number (5.7.2.20 versus 5.2.7.20) contained in Technical Specification Section 5.0, which will not change the intent of the added section previously approved in License Amendment 70. Therefore, no increase in the probability or consequences of an accident previously evaluated has been created.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

This change is limited only to correcting a typographical error in a section number (5.7.2.20 versus 5.2.7.20) contained in Technical Specification Section 5.0, which will not change the intent of the added section previously approved in License Amendment 70. Therefore, the possibility of a new or different kind of accident from those previously analyzed has not been created.

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3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

This change is limited only to correcting a typographical error in a section number (5.7.2.20 versus 5.2.7.20) contained in Technical Specification Section 5.0, which will not change the intent of the added section previously approved in License Amendment 70. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Conclusions Based on the above, TVA concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified. In addition, based on the considerations discussed above, (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.

ENVIRONMENTAL EVALUATION A review has determined that the proposed amendment would not change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would not change an inspection or surveillance requirement. In addition, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

REFERENCES

1. TVA Letter to NRC dated October 26, 2007, "Watts Bar Nuclear Plant (WBN) -

Unit 1 - Technical Specifications Change 07 "Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with Technical Specification Task Force (TSTF)-448, Revision 3, Using the Consolidated Line Item Improvement Process" (ML073380948)

2. NRC Letter to TVA dated October 8, 2008, "Watts Bar Nuclear Plant, Unit 1 -

Issuance of Amendment Regarding Control Room Envelope Habitability (TAC No. MD7474)" (ML082730261)

E-2

Attachment I Tennessee Valley Authority Watts Bar Nuclear Plant Unit I Docket Number 50-390, NPF-90 Technical Specification Change WBN-TS-09-05 Change to Correct Minor Error in Amendment 70 Proposed Technical Specification Change (Markup)

Technical Specification Pages 5.0-25 5.0-25a

,. 1. h Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.7.2.19 Containment Leakage Rate Testing Program (continued)

Leakage rate acceptance criteria are:

a. Containment overall leakage rate acceptance criterion Is !51.0 aL During the first unit startup following testing In accordance with this program, the leakage rate acceptance criteria are < 0.60 L, for the combined Type B and Type C tests, and

< 0.75 L. for Type A tests.

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate is

• 0.05 L, when tested at > P,.

2) For each door, leakage rate is

• 0.01 L. when pressurized to Ž: 6 psig.

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing 5 .0 Program.

Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body for the duration of the accident. The program shall include the following elements:

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

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

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

Revision 0, May 2003, and (il) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

(continued)

Watts Bar-Unit 1 5.0-25 Amendment

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.W20 Control Room Envelope Habitability Program (continued)

(4.~d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREVS, operating at the flow rate defined In the Ventilation Filter Testing Program (VFTP), at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month 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 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.

Watts Bar-Unit 1 5.0-25a

Attachment 2 Tennessee Valley Authority Watts Bar Nuclear Plant Unit I Docket Number 50-390, NPF-90 Technical Specification Change WBN-TS-09-05 Change to Correct Minor Error in Amendment 70 Proposed Technical Specification Revisions (Final Typed)

Technical Specification Pages 5.0-25 5.0-25a

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.7.2.19 Containment Leakage Rate Testing Program (continued)

Leakage rate acceptance criteria are:

a. Containment overall leakage rate acceptance criterion is _<1.0 L,. During the first unit startup following testing in accordance with this program, the leakage rate acceptance Criteria are < 0.60 La for the combined Type B and Type C tests, and

< 0.75 La for Type A tests.

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate is < 0.05 L, when tested at > Pa.

2) For each door, leakage rate is < 0.01 L, when pressurized to > 6 psig.

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

5.7.2.20 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body for the duration of the accident. The program shall include the following elements:

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

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

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

Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

(continued)

Watts Bar-Unit 1 5.0-25 Amendment.5, 70

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.7.2.20 Control Room Envelope Habitability Program (continued)

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREVS, operating at the flow rate defined in the Ventilation Filter Testing Program (VFTP), at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month 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 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.

Watts Bar-Unit 1 5.0-25a Amendment5, 70