ML091730242
| ML091730242 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/18/2009 |
| From: | Ellen Brown Plant Licensing Branch II |
| To: | Swafford P Tennessee Valley Authority |
| Brown E, NRR/DORL, 415-2315 | |
| References | |
| TAC MD8410, TAC MD8411, TAC MD8412 | |
| Download: ML091730242 (54) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 18,2009 Mr. Preston D. Swafford Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 SUB..IECT:
BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 -
ISSUANCE OF AMENDMENTS REGARDING CONTROL ROOM ENVELOPE HABITABILITY (TAC NOS. MD8410, MD8411, AND MD8412)
Dear Mr. Swafford:
The Commission has issued the enclosed Amendment Nos. 275, 302, and 261 to Renewed Facility Operating Licenses Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant, Units 1, 2, and 3, respectively. These amendments are in response to your application dated March 27,2008, as supplemented by letters dated December 19, 2008, February 9, April 24, and May 26, 2009 (TS-444).
The amendments revise the technical specifications (TSs) to adopt the content of Technical Specification Task Force (TSTF) change traveler TSTF-448, Revision 3, Control Room Habitability. The amendments also add a new license condition regarding initial performance of the new surveillance and assessment requirements of the revised TSs.
A copy of the Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely, IRA!
Eva A. Brown, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296
Enclosures:
- 1. Amendment No. 275 to DPR-33
- 2. Amendment No. 302 to DPR-52
- 3. Amendment No. 261 to DPR-68
- 4. Safety Evaluation cc w/enclosures: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 275 Renewed License No. DPR-33
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Tennessee Valley Authority (the licensee) dated March 27, 2008, as supplemented by letters dated December 19, 2008, February 9, April 24, and May 26,2009, 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.
- 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 Renewed Facility Operating License No. DPR-33 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 275, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3.
Accordingly, the license is amended by the addition of paragraph 2.C.(16) as follows:
(16)
Upon Implementation of Amendment No. 275, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), the assessment of the CRE habitability as required by TS 5.5.13.c.(ii), and the measurement of CRE pressure as required by TS 5.5.13.d, shall be considered met. Following Implementation:
(a)
The first performance of SR 3.7.3.4, in accordance with TS 5.5.13.c.(i),
shall be within a specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from November 10, 2003, the date of the most recent successful tracer gas test.
(b)
The first performance of the periodic assessment of the CRE habitability, TS 5.5.13.c.(ii), shall be within 9 months following the initial implementation of the TS change. The next performance of the periodic assessment will be in a period specified by the CRE Habitability Program.
That is 3 years from the last successful performance of the TS 5.5.13.c.(ii) tracer gas test.
(c)
The first performance of the periodic measurement of CRE pressure, TS 5.5.13.d, shall be within 24 months, plus the 180 days allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test.
- 4.
This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Th~~~?PJyC Chi"--ef--'
Plant Licensing B anch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications and Renewed Operating License Date of Issuance:
August 18, 2009
ATTACHMENT TO LICENSE AMENDMENT NO. 275 RENEWED FACILITY OPERATING LICENSE NO. DPR-33 DOCKET NO. 50-259 Replace the following pages of Renewed Operating License DPR-33 with the attached pages.
The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.
REMOVE 3
5 6
INSERT 3
5 6
7 Replace the following pages of Appendix A Technical Specifications with the attached pages.
The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.
REMOVE INSERT 3.7-8 3.7-8 3.7-8a 3.7-10 3.7-10 3.7-11 3.7-11 5.0-21 5.0-21 5.0-21a
-3 (3)
Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)
Pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5)
Pursuant to the Act and 10 CFR Parts 30 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 renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3458 megawatts thermal.
(2)
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 275, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
For Surveillance Requirements (SRs) that are new in Amendment 234 to Facility Operating License DPR-33, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 234. For SRs that existed prior to Amendment 234, 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 234.
BFN-UNIT 1 Renewed License No. DPR-33 Amendment 275
-5 (8)
Deleted.
(9)
Deleted.
(10)
Deleted.
(11)
The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:
"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(12)
Deleted.
(13)
Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for BFN as approved in the safety evaluations dated December 8, 1988; March 31, 1993; April 1, 1993; November 2, 1995; April 25, 2007, and Supplement dated November 3, 1989; subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
(14)
The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(15)
The licensee is required to confirm that the conclusions made in TVA's letter dated September 17, 2004, for the turbine building remain acceptable using seismic demand accelerations based on dynamic seismic analysis prior to the restart of Unit 1.
(16)
Upon implementation of Amendment No. 275, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), the assessment of the CRE habitability as required by TS 5.5.13.c.(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 275
-6 Following Implementation:
(a) The first performance of SR 3.7.4.4, in accordance with TS 5.5.13.c.(i),
shall be within a specific frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from November 10, 2003, the date of the most recent successful tracer gas test.
(b) The first performance of the periodic assessment of the Control Room Envelope (CRE) Habitability, Technical Specification 5.5.13.c.(ii), shall be with 9 months following the initial implementation of the TS Change. The next performance of the periodic assessment will be in a period specified by the CRE Program. That is 3 years from the last successful performance of the Technical Specification 5.5.13.c.(ii) tracer gas test.
(c) The first performance of the periodic measurement of CRE pressure, TS 5.5.13.d, shall be within 24 months, plus 180 days allowed by SR 3.0.2 as measured from the date of the most recent successful pressure measurement test.
D.
The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21 (d), shall be included in the next scheduled update to the UFSAR required by 10 CFR 50.71 (e)(4) following the issuance of this renewed operating license. Until that update is complete, TVA may make changes to the programs and activities described in the supplement without prior Commission approval, provided that TVA evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
E.
The UFSAR supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. TVA shall complete these activities no later than December 20,2013, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
F.
All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of the most recent NRC-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance Program (ISP) appropriate for the configuration of the specimens in the capsule. Any changes to the BWRVIP ISP capsule withdrawal schedule, including spare capsules, must be approved by the NRC prior to implementation. All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements must be approved by the NRC, as required by 10 CFR Part 50, Appendix H.
G.
(1)
During the power uprate power ascension test program and prior to exceeding 30 days of plant operation above a nominal 3293 megawatts thermal power level (1 DO-percent OLTP) or within 30 days of satisfactory completion of steam dryer monitoring and testing that is necessary for achieving 105-percent OLTP (whichever is longer), with plant conditions stabilized at 105-percent OLTP, TVA shall trip a condensate booster pump, a condensate pump, and a main feedwater pump on an individual basis (Le., one at a time). Following each pump trip, TVA shall confirm that plant response to the transient is as expected in accordance BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 275
-7 with previously established acceptance criteria. Evaluation of the test results for each test shall be completed and all discrepancies resolved in accordance with corrective action program requirements and the provisions of the power ascension test program.
(2)
Deleted.
H.
The licensee must complete the thirteen (13) Unit 1 restart commitments that are discussed in Appendix F of the license renewal application, dated December 31,2003, as supplemented by letters dated January 31, 2005, March 2, and April 21, 2006.
Completion of these activities must be met prior to power operation of Unit 1.
I.
This renewed license is effective as of the date of issuance and shall expire midnight on December 20, 2033.
FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By J. E. Over J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:
- 1. Unit 1 - Technical Specifications - Appendices A and B Date of Issuance: May 4, 2006 BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 275
CREV System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.
NOTE-------------------------------------
The main control room envelope (CRE) boundary may be opened intermittently under administrative control.
APPLICABILITY:
MODES 1, 2, and 3, during operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION A One CREV subsystem inoperable for reasons other than Condition B.
B. One or more CREV subsystems inoperable due to inoperable CRE boundary in MODES 1, 2, and 3.
A1 B.1 AND B.2 AND 8.3 REQUIRED ACTION Restore CREV subsystem to OPERABLE status.
Initiate action to implement mitigating actions Verify mitigating actions ensure CRE occupant exposures to radiological hazards wi II not exceed limits, and verify the CRE occupants are protected from smoke and chemical hazards.
Restore CRE boundary to OPERABLE status.
COMPLETION TIME 7 days Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 90 days (continued)
BFN-UNIT 1 3.7-8 Amendment No. 234. 246;-~ 275
CREV System 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or
- 3.
C.1 AND C.2 Be in MODE 3.
Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours (continued)
Amendment No. 234, 2046,-2&~, 275 BFN-UNIT 1 3.7-8a
CREV System 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREV subsystems inoperable during OPDRVs.
OR One or more CREV subsystems inoperable due to an inoperable eRE Boundary during OPDRVs.
F.1 Initiate action to suspend OPDRVs.
Immediately Amendment No. 294, 246, 2&1-, 275 BFN-UNIT 1 3.7-10
CREV System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for ~ 10 continuous hours with the heaters operating.
31 days SR 3.7.3.2 Perform required CREV filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.3.3 Verify each CREV subsystem actuates on an actual or simulated initiation signal.
24 months SR 3.7.3.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Envelope Habitability Program Amendment No. 285;' 2.75 BFN-UNIT 1 3.7-11
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued)
Leakage Rate acceptance criteria are:
- a. The primary containment leakage rate acceptance criteria is ~ 1.0 La.
During the first unit startup following the testing performed in accordance with this program, the leakage rate acceptance criteria are:::;: 0.60 La for the Type B and Type C tests, and ~ 0.75 La for the Type A test; and
- b. Air lock testing acceptance criteria are:
- 1) Overall air lock leakage rate ~ 0.05 La when tested at ;:: Pa.
- 2) Air lock door seals leakage rate is ~ 0.02 La when the overall air lock is pressurized to ;:: 2.5 psig for at least 15 minutes.
The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program 5.5.13 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 (CREV) System, eRE 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:
(continued)
BFN-UNlT 1 5.0-21 Amendment No.-2-34, 275
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Control Room Envelope Habitability Program (continued)
- b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
- c. Requirements for 0) 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 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. Measurements, 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 CREV 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 periodic assessment of the CRE boundary.
- e. The quantitative limits on unfiltered air leakage 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 for flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of the 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.
BFN-UNIT 1 5.0-21a Amendment No. 275
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-260 BROWNS FERRY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 302 Renewed License No. DPR-52
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Tennessee Valley Authority (the licensee) dated March 27,2008, as supplemented by letters dated December 19, 2008, February 9, April 24, and May 26, 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.
- 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 Renewed Facility Operating License No. DPR-52 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 302, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3.
Accordingly, the license is amended by the addition of paragraph 2.C.(16) as follows:
(16)
Upon Implementation of Amendment No. 302 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), the assessment of the CRE habitability as required by TS 5.5.13.c.(ii), and the measurement of CRE pressure as required by TS 5.5.13.d, shall be considered met. Following Implementation:
(a)
The first performance of SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), shall be within a specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from November 10,2003, the date of the most recent successful tracer gas test.
(b)
The first performance of the periodic assessment of the CRE habitability, TS 5.5.13.c.(ii), shall be within 9 months following the initial implementation of the TS change. The next performance of the periodic assessment will be in a period specified by the CRE Habitability Program. That is 3 years from the last successful performance of the TS 5.5.13.c.(ii) tracer gas test.
(c)
The first performance of the periodic measurement of CRE pressure, TS 5.5.13.d, shall be within 24 months, plus the 180 days allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test.
- 4.
This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.
/J/(
Thomas
. oyc, Chief Plant Licensing anch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications and Renewed Operating License Date of Issuance: August 18, 2009
ATTACHMENT TO LICENSE AMENDMENT NO. 302 RENEWED FACILITY OPERATING LICENSE NO. DPR-52 DOCKET NO. 50-260 Replace the following pages of Renewed Operating License DPR-52 with the attached pages.
The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.
REMOVE INSERT 3
5 6
7 3
5 6
Replace the following pages of Appendix A Technical Specifications with the attached pages.
The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.
REMOVE INSERT 3.7-9 3.7-9 3.7-9a 3.7-9a 3.7-11 3.7-11 3.7-12 3.7-12 5.0-21 5.0-21 5.0-21a
-3 sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)
Pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5)
Pursuant to the Act and 10 CFR Parts 30 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 renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:
Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3458 megawatts thermal.
(2)
Technical Specifications The Technical Specifications contained in Appendices A and 8, as revised through Amendment No. 302, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
For Surveillance Requirements (SRs) that are new in Amendment 253 to Facility Operating License DPR-52, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 253. For SRs that existed prior to Amendment 253, 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 253.
(3)
The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix 8 to licensee-controlled documents.
Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's BFN-UNIT 2 Renewed License No. DPR-52 Amendment 302
-5 (8)
Deleted.
(9)
Deleted.
(10) Deleted.
(11) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(12) Deleted.
(13) Deleted.
(14) Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for BFN as approved in the safety evaluations dated December 8, 1988; March 31, 1993; April 1, 1993; November 2, 1995; April 25, 2007, and Supplement dated November 3, 1989; subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
(15) The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(16) Upon implementation of Amendment No. 302, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i),
the assessment of the CRE habitability as required by TS 5.5.13.c.(ii), and the measurement of CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 2 Renewed License No. DPR~52 Amendment 302
-6 Following Implementation:
(a) The first performance of SR 3.7.4.4, in accordance with TS 5.5.13.c.(i),
shall be within a specific frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from November 10, 2003, the date of the most recent successful tracer gas test.
(b) The first performance of the periodic assessment of the Control Room Envelope (CRE) Habitability, Technical Specification 5.5.13.c.(ii), shall be with 9 months following the initial implementation of the TS Change. The next performance of the periodic assessment will be in a period specified by the CRE Program. That is 3 years from the last successful performance of the Technical Specification 5.5.13.c.(ii) tracer gas test.
(c) The first performance of the periodic measurement of CRE pressure, TS 5.5.13.d, shall be within 24 months, plus 180 days allowed by SR 3.0.2 as measured from the date of the most recent successful pressure measurement test.
D.
The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21 (d),
shall be included in the next scheduled update to the UFSAR required by 10 CFR 50.71 (e)(4) following the issuance of this renewed operating license.
Until that update is complete, TVA may make changes to the programs and activities described in the supplement without prior Commission approval, provided that TVA evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
E.
The UFSAR supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. TVA shall complete these activities no later than June 28,2014, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
F. All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of the most recent NRC-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance Program (ISP) appropriate for the configuration of the specimens in the capsule. Any changes to the BWRVIP ISP capsule withdrawal schedule, including spare capsules, must be approved by the NRC prior to implementation. All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements must be approved by the NRC, as required by 10 CFR Part 50, Appendix H.
BFN-UNIT 2 Renewed License No. DPR-52 Amendment 302
-7 G.
This renewed license is effective as of the date of issuance and shall expire midnight on June 28, 2034.
FOR THE NUCLEAR REGULATORY COMIVIISSION Original Signed By J. E. Dyer J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:
- 1. Unit 2 - Technical Specifications - Appendices A and B Date of Issuance: May 4, 2006 BFN-UNIT 2 Renewed License No. DPR-52 Amendment 302
EECW System and UHS 3.7.2 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.
N()TE------------------------------------------------------
The main control room envelope (eRE) boundary may be opened intermittently under administrative control.
APPLICABILITY:
MODES 1, 2, and 3, during operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION A. One CREV subsystem inoperable for reasons other than Condition B.
B. One or more CREV subsystems inoperable due to inoperable CRE boundary in MODES 1, 2, and 3.
Amendment No. ~ ~,2QQ, 302 BFN-UNIT 2 3.7-9 REQUIRED ACTION COMPLETION TIME A.1 Restore CREV subsystem 7 days to OPERABLE status.
B.1 Initiate actions to Immediately implement mitigating actions.
AND B.2 Verify mitigating actions 24 Hours ensure CRE occupant exposures to radiological hazards will not exceed limits, and verify the eRE occupants are protected from smoke and chemical hazards.
AND B.3 Restore CRE boundary to 90 days OPERABLE status.
(continued)
EECW System and UHS 3.7.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or
- 3.
C.1 AND C.2 Be in MODE 3.
Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours (continued)
Amendment No. ~ ~;-200, 302 I BFN-UNIT 2 3.7-9a
EECW System and UHS 3.7.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREV subsystems inoperable during OPDRVs.
OR One or more CREV subsystems inoperable due to an inoperable CRE Boundary during OPDRVs.
F.1 Initiate action to suspend OPDRVs.
Immediately Amendment No. ~ ~-29G, 302 BFN-UNIT2 3.7-11
EECW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for ?-10 continuous hours with the heaters operating.
31 days SR 3.7.3.2 Perform required CREV filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.3.3 Verify each CREV subsystem actuates on an actual or simulated initiation signal.
24 months SR 3.7.3.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Envelope Habitability Program Amendment No.-266, 302 BFN-UNIT 2 3.7-12
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued)
The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 50.6 psig. The maximum allowable primary containment leakage rate, La, shall be 2% of primary containment air weight per day at Pa.
Leakage Rate acceptance criteria are:
- a. The primary containment leakage rate acceptance criteria is::; 1.0 La.
During the first unit startup following the testing performed in accordance with this program, the leakage rate acceptance criteria are::; 0.60 La for the Type 8 and Type C tests, and::; 0.75 La for the Type A test; and
- b. Air lock testing acceptance criteria are:
- 1) Overall air lock leakage rate:":: 0.05 La when tested at ~ Pa.
- 2) Air lock door seals leakage rate is :":: 0.02 La when the overall air lock is pressurized to 2: 2.5 psig for at least 15 minutes.
The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.
5.5.13 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CREhabitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation (CREV) 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:
(continued)
BFN-UNIT 2 5.0-21 Amendment No. ~-29-3; 302
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Control Room Envelope Habitability Program (continued)
- b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
- c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision O.
- d. Measurements, 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 CREV 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 periodic assessment of the CRE boundary.
- e. The quantitative limits on unfiltered air leakage 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 for flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of the 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.
BFN-UNIT 2 5.0-21a Amendment No. 25a, 293, 302
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-296 BROWNS FERRY NUCLEAR PLANT, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 261 Renewed License No. DPR-68
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Tennessee Valley Authority (the licensee) dated March 27, 2008, as supplemented by letters dated December 19, 2008, February 9, April 24, May 26, 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.
- 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 Renewed Facility Operating License No. DPR-68 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 261, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3.
Accordingly, the license is amended by the addition of paragraph 2.C.(12) as follows:
(12)
Upon Implementation of Amendment No. 261, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), the assessment of the CRE habitability as required by TS 5.5.13.c.(ii), and the measurement of CRE pressure as required by TS 5.5.13.d, shall be considered met. Following Implementation:
(a)
The first performance of SR 3.7.3.4, in accordance with TS 5.5.13.c.(i),
shall be within a specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from November 10, 2003, the date of the most recent successful tracer gas test.
(b)
The first performance of the periodic assessment of the CRE habitability, TS 5.5.13.c.(ii), shall be within 9 months following the initial implementation of the TS change. The next performance of the periodic assessment will be in a period specified by the CRE Habitability Program.
That is 3 years from the last successful performance of the TS 5.5.13.c.(ii) tracer gas test.
(c)
The first performance of the periodic measurement of CRE pressure, TS 5.5.13.d, shall be within 24 months, plus the 180 days allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test.
- 4.
This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/1 Thomas H. Boyce, hief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications and Renewed Operating License Date of Issuance: August 18, 2009
ATTACHMENT TO LICENSE AMENDMENT NO. 261 RENEWED FACILITY OPERATING LICENSE NO. DPR-68 DOCKET NO. 50-296 Replace the following pages of Renewed Operating License DPR-68 with the attached pages.
The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.
REMOVE INSERT 3
5 6
3 5
6 7
Replace the following pages of Appendix A Technical Specifications with the attached pages.
The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.
REMOVE INSERT 3.7-9 3.7-9 3.7-9a 3.7-11 3.7-11 3.7-12 3.7-12 5.0-21 5.0-21 5.0-21a
-3 (3)
Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)
Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5)
Pursuant to the Act and 10 CFR Parts 30 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 renewed operating license shall be deemed to contain and is SUbject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3458 megawatts thermal.
(2)
Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 261, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
For Surveillance Requirements (SRs) that are new in Amendment 212 to Facility Operating License DPR-68, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 212. For SRs that existed prior to Amendment 212, 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 perfonned prior to implementation of Amendment 212.
BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 261
-5 (9) The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(10) 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 (11) The licensee shall implement and maintain all Actions required by to NRC Order EA-06-137, issued June 20,2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.
(12) Upon completion of Amendment No. 261, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5. 13.c(ii), and the measurement of the CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 3 Renewed License No. DPR-68 Amendment 261
-6 Following Implementation:
(a)
The first performance of SR 3.7.4.4, in accordance with TS 5.5.13.c.(i), shall be within a specific frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from November 10, 2003, the date of the most recent successful tracer gas test.
(b)
The first performance of the periodic assessment of the Control Room Envelope (CRE) Habitability, Technical Specification 5.5.13.c.(ii), shall be with 9 months following the initial implementation of the TS Change. The next performance of the periodic assessment will be in a period specified by the CRE Program. That is 3 years from the last successful performance of the Technical Specification 5.5.13.c.(ii) tracer gas test.
(c)
The first performance of the periodic measurement of CRE pressure, TS 5.5.13.d, shall be wit~lin 24 months, plus 180 days allowed by SR 3.0.2 as measured from the date of the most recent successful pressure measurement test.
D.
The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d),
shall be included in the next scheduled update to the UFSAR required by 10 CFR 50.71 (e)(4) following the issuance of this renewed operating license.
Until that update is complete, TVA may make changes to the programs and activities described in the supplement without prior Commission approval, provided that TVA evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
E.
The LlFSAR supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. TVA shall complete these activities no later than July 2,2016, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
F. All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of the most recent NRC-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance Program (ISP) appropriate for the configuration of the specimens in the capsule. Any changes to the BWRVIP ISP capsule withdrawal schedule, including spare capsules, must be approved by the NRC pl;or to implementation. All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements must be approved by the NRC, as required by 10 CFR Part 50, Appendix H.
BFN-UNIT 3 Renewed License No. DPR-68 Amendment 261
-7 G.
This renewed license is effective as of the date of issuance and shall expire midnight on July 2, 2036.
FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By J. E. Dyer J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:
- 1. Unit 3 - Technical Specifications - Appendices A and B Date of Issuance: May 4, 2006 BFN-UNIT 3 Renewed License No. OPR-68 Amendment 261
CREV System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCD 3.7.3 Two CREV subsystems shall be OPERABLE.
NOTE-----------------------------------
The main control room envelope (CRE) boundary may be opened intermittently under administrative control.
APPLICABILITY:
MODES 1, 2, and 3, during operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION A. One CREV subsystem inoperable for reasons other than Condition B.
B. One or more CREV subsystems inoperable due to inoperable CRE boundary in MODES 1, 2, and 3.
BFN-UNIT 3 REQUIRED ACTION A.1 Restore CREV subsystem to OPERABLE status.
8.1 Initiate actions to implement mitigating actions.
AND B.2 Verify mitigating actions ensure CRE occupant exposures to radiological hazards will not exceed limits, and verify the eRE occupants are protected from smoke and chemical hazards.
AND B.3 Restore CRE boundary to OPERABLE status.
COMPLETION TIME 7 days Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 90 days (contInued) 3.7-9 Amendment No. 214, 241-;~, 261
CREV System 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or
- 3.
C.1 AND C.2 Be in MODE 3.
Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours (continued)
Amendment No. 214. 241, -249-, 261 BFN-UNIT 3 3.7-9a I
CREV System 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREV subsystems inoperable during OPDRVs.
F.1 Initiate action to suspend OPDRVs.
Immediately OR One or more CREV subsystems inoperable due to an inoperable CRE Boundary during OPDRVs.
Amendment No. 214,241,449, 261 BFN-UNIT 3 3.7-11
CREV System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for ~ 10 continuous hours with the heaters operating.
31 days SR 3.7.3.2 Perform required CREV filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.3.3 Verify each CREV subsystem actuates on an actual or simulated initiation signal.
24 months SR 3.7.3.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Envelope Habitability Program Amendment No.-2.:f.S, 261 BFN-UNIT 3 3.7-12
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued)
The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 50.6 psig. The maximum allowable primary containment leakage rate, La, shall be 2% of primary containment air weight per day at Pa.
Leakage Rate acceptance criteria are:
- a. The primary containment leakage rate acceptance criteria is :s; 1.0 La.
During the first unit startup following the testing performed in accordance with this program, the leakage rate acceptance criteria are :s; 0.60 La for the Type B and Type C tests, and :s; 0.75 La for the Type A test; and
- b. Air lock testing acceptance criteria are:
- 1) Overall air lock leakage rate 50 0.05 La when tested at :?: Pa.
- 2) Air lock door seals leakage rate is ~. 0.02 La when the overall air lock is pressurized to 2: 2.5 psig for at least 15 minutes.
The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.
5.5.13 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 (CREV) 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:
BFN-UNIT 3 5.0-21 Amendment No..~T~ 261
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Control Room Envelope Habitability Program (continued)
- b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
- c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision O.
- d. Measurements, 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 CREV 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 periodic assessment of the CRE boundary.
- e. The quantitative limits on unfiltered air leakage 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 for flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of the CRE occupants to these hazards will be within the assumptions in the licensing basis.
- 1. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing eRE habitability, determining eRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.
BFN-UNIT 3 5.0-21a Amendment No. ~~ 261
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 275 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-33 AMENDMENT NO. 302 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-52 AMENDMENT NO. 261 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-68 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296
1.0 INTRODUCTION
By application dated March 27, 2008, as supplemented by letters dated December 19, 2008, February 19, April 24, and May 26,2009, the Tennessee Valley Authority (TVA, the licensee) requested changes to the technical specifications (TSs) for the Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3. The proposed changes would revise technical specifications to adopt Technical Specification Task Force (TSTF) change traveler TSTF-448 regarding the habitability of the control room envelope (CRE). The licensee also proposed license conditions regarding the initial performance of the new surveillance and assessment requirements.
Notice of the licensee's original application and the staff's proposed no significant hazards consideration were published in the Federal Register on August 26, 2008 (73 FR 50362). The December 19, 2008, supplement contained additional information related to smoke and chemical effects. A revised notice and proposed no significant hazards consideration were published in the Federal Register on January 27,2009 (74 FR 4775).
The supplements dated February 9, April 24, and May 26, 2009, provided additional information that clarified the application, did not expand the scope of the application as previously noticed, and did not change the Nuclear Regulatory Commission (NRC) staff's proposed no significant hazards consideration determination as published in the Federal Register on January 27,2009 (74 FR 4775).
- 2
2.0 REGULATORY EVALUATION
On August 8, 2006, the TSTF submitted a proposed change, TSTF-448, Revision 3, to the improved standard technical specifications (STSs) (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 CRE.
In Generic Letter (GL) 2003-01, dated December 8,2003 (Agencywide Document and Management System (ADAMS) No. ML033430322) (Reference 1), the NRC alerted licensees to findings at facilities that existing TS surveillance requirements (SRs) for the Control Room Emergency Ventilation (CREV) System might not be adequate. Specifically, the results of the 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 surveillance is not a reliable method for demonstrating CRE boundary operability. Licensees were requested to address existing TS as follows.
Provide confirmation that your technical specifications verify the integrity
[i.e., operability] of the CRE [boundary], and the assumed [unfiltered]
in-leakage rates of potentially contaminated air. If you currently have a differential pressure surveillance requirement to demonstrate CRE [boundary]
integrity, provide the basis for your conclusion that it remains adequate to demonstrate CRE integrity in light of the ASTM E741 testing results. If you conclude that your differential pressure surveillance requirement is no longer adequate, provide a schedule for: 1) revising the surveillance requirement in your technical specification to reference an acceptable surveillance methodology (e.g., ASTM E741), and 2) making any necessary modifications to your CRE [boundary] so that compliance with your new surveillance requirement can be demonstrated.
If your facility does not currently have a technical specification surveillance requirement for your CRE integrity, explain how and at what frequency you confirm your CRE integrity and why this is adequate to demonstrate CRE integrity.
To promote standardization and to minimize the resources that would be needed to create and process plant-specific amendment applications in response to the concerns described in the generic letter, the industry and the NRC proposed revisions to CRE habitability system requirements contained in the STSs, 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, Standard Technical Specifications, General Electric Plants, BWR [Boiling Water Reactor]/4, the licensee proposed revising action and SRs in TS 3.7.3, Control Room Emergency Ventilation (CREV) System, and adding a new administrative controls program, TS 5.5.13, Control Room Envelope Habitability Program. The purpose of the changes is to ensure that CRE boundary operability is maintained
- 3 and verified through effective surveillance and programmatic requirements, and that appropriate remedial actions are taken in the event of an inoperable CRE boundary.
The BFN is an STS plant. The differences in TS numbering and TS bases references, combined with some editorial and plant specific changes that were incorporated into this safety evaluation, resulted in minor deviations from the model safety evaluation text in TSTF-448, Revision 3.
2.1 Control Room and Control Room Envelope Regulatory Guide (RG) 1.196, Control Room Habitability at Light-water Nuclear Power Reactors, Revision 0, May 2003, uses the term "control room envelope" in addition to the term "control room" and defines each term as follows:
Control Room: The plant area, defined in the facility licensing basis, in which actions can be taken to operate the plant safely under normal conditions and to maintain the reactor in a safe condition during accident situations. It encompasses the instrumentation and controls necessary for a safe shutdown of the plant and typically includes the critical document reference file, computer room (if used as an integral part of the emergency response plan), shift supervisor's office, operator wash room and kitchen, and other critical areas to which frequent personnel access or continuous occupancy may be necessary in the event of an accident.
Control Room Envelope: The plant area, defined in the facility licensing basis that in the event of an emergency, can be isolated from the plant areas and the environment external to the CRE. This area is served by an emergency ventilation system, with the intent of maintaining the habitability of the control room. This area encompasses the control room, and may encompass other 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, also contains these definitions, but uses the term CRE to mean both.
This is because the protected environment provided for operators varies with the nuclear power facility. At some facilities this environment is limited to the control room; at others, it is the CRE. In this safety evaluation, consistent with the proposed changes to the STS, the CRE will be used to designate both. For consistency, facilities should use the term CRE with an appropriate facility-specific definition derived from the above CRE definition.
2.2 Control Room Emergency Ventilation (CREV) System The CREV System (the term used at BFN for the Control Room Envelope Emergency Ventilation System, CREEV 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 CREV System is designed to maintain a habitable environment in the control room envelope for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding 5 rem total effective dose equivalent (TEDE).
At BFN, there are two control rooms, one of which is common to Units 1 and 2 and the other dedicated to Unit 3. The CREV System is common to both control rooms. The CREV System consists of two redundant subsystems, each capable of maintaining the habitability of the CRE associated with both the control rooms. A CREV subsystem is considered operable when the associated:
- Fan is OPERABLE
- High efficiency particulate air filters and charcoal adsorbers are not excessively restricting flow and are capable of performing their filtration functions; and
- Electric duct heater, ductwork, and dampers are OPERABLE.
- CRE boundary is operable 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 The construction permits for BFN Units 1, 2, and 3 predate the formal issuance of the current Appendix A, General Design Criteria (GDC), to Title 10 to the Code of Federal Regulations Part 50. During the construction permit licensing process, Units 1 and 2 were evaluated against the Comment Draft of 27 Criteria, which was issued on November 22, 1965, while Unit 3 was evaluated against the Comment Draft of 70 Criteria, which was issued on July 10, 1967. The design bases of each BFN unit were reevaluated at the time of initial Final Safety Analysis Report (FSAR) preparation against the draft of the 70 criteria current at the time of operating license application. As stated in Appendix A of BFN Updated FSAR, based on the understanding of the intent of the proposed criteria current at the time of operating license application, BFN conforms with the intent of the Atomic Energy Commission GDC for nuclear Power Plant Construction Permits. As the GDC were finalized, the requirements were placed in Appendix A, General Design Criteria for Nuclear Power Plants, to Title 10, Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities.
GDC 1, 2, 3, 4, 5, and 19 apply to CRE habitability. A summary of these GDC 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.
- 5 GOC 3, Fire Protection, requires SSCs important to safety be designed and located to minimize the effects of fires and explosions.
GOC 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).
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 reactor safely under normal conditions and to maintain the reactor in a safe condition under accident conditions, including a LOCA. Adequate radiation protection is to be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of specified values.
Prior to incorporation of TSTF-448, Revision 3, the STS requirements addressing CRE boundary operability resided only in the following CRE ventilation system specifications:
NUREG-1430, TS 3.7.10, "Control Room Emergency Ventilation system (CREVS),"
NUREG-1431, TS 3.7.10, "Control Room Emergency Filtration System (CREFS),"
NUREG-1432, TS 3.7.11, "Control Room Emergency Air Cleanup System (CREACS),"
NUREG-1433, TS 3.7.4, "Main Control Room Environmental Control (MCREC) System," and NUREG-1434, TS 3.7.3, "Control Room Fresh Air (CRFA)
System."
In these specifications, the surveillance requirement associated with demonstrating the operability of the CRE boundary requires verifying that one CREEV System train subsystem 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 CREEV System have similar surveillance requirements. Other facilities that do not pressurize the CRE have only a system flow rate criterion for the emergency mode of operation. Regardless, the results of ASTM E741 (Reference 2) tracer Gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance (or the alternative surveillance at non-pressurization facilities) is not a reliable method for demonstrating CRE boundary operability. That is, licensees were able to obtain differential pressure and flow measurements satisfying the SR limits even though unfiltered inleakage was determined to exceed the value assumed in the safety analyses.
- 6 In addition to an inadequate surveillance requirement, the action requirements of these specifications were ambiguous regarding CRE boundary operability in the event CRE unfiltered inleakage is found to exceed the analysis assumption. The ambiguity stemmed from the view that the CRE boundary may be considered operable but degraded in this condition, and that it would be deemed inoperable only if calculated radiological exposure limits for CRE occupants exceeded a licensing basis limit (e.g., as stated in GDC 19, even while crediting compensatory measures).
NRC Administrative Letter (AL) 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," 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) 2055-20 (Reference 3). 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, and 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.
These compensatory measures are in place 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 TSs to include surveillance requirements, which it defines as "requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that limiting conditions for operation will be met." (Emphasis added.)
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, Units 1, 2, and 3 Adoption of TSTF-448, Revision 3, will assure that the facility's TS LCO for the CREV System is met by demonstrating unfiltered leakage into the CRE is within limits (Le., the operability of the CRE boundary). In support of this surveillance, which specifies a test interval (frequency) described in RG 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.
- 7 The changes made by TSTF-448 to the TS requirements for the CREV System and the CRE boundary conform to 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3). Their adoption will better assure that the CRE at BFN 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 to the BFN TSs 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 CREV System at BFN pressurizes the CRE to minimize unfiltered air inleakage. The proposed changes are consistent with this design.
3.1 Proposed Changes The proposed amendments would strengthen CRE habitability TS requirements by changing TS 3.7.3, Control Room Emergency Ventilation (CREV) 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 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 STSs as revised by TSTF-448, Revision 3.
The NRC staff compared the proposed TS changes to the STSs and the STS markups and evaluations in TSTF-448. The staff verified that differences from the STSs were adequately justified based on of plant-specific design or retention of current licensing basis. The NRC staff also reviewed the proposed changes to the TS Bases for consistency with the STS Bases and the 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, Technical Specifications (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 Guideline NEI 99-03, Control Room Habitability Assessment Guidance, Revision 0, dated June 2001, which the NRC staff has formally endorsed, with exceptions, through RG 1.196.
3.2 Editorial Changes The licensee proposed editorial changes to TS 3.7.3, Control Room Emergency Ventilation (CREV) System, to establish standard terminology, such as "control room envelope (CRE)" in place of "control room," the plant-specific name for the Control Room Emergency ventilation (CREV) system in place of bracketed terms [CREEV System] and [CRFA], 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 CREV System. These changes improve the usability and quality of the presentation of the TS, have no impact on safety, and therefore, are acceptable.
- 8 The changes proposed by the licensee in the letter dated March 27, 2008, did not include references to chemical and smoke hazards in TS Section 3.7.3, TS Section 5.5.13, nor TS Bases 3.7.3. The licensee stated that CRE hazard evaluations were performed in accordance with RG 1.78 for chemicals stored onsite, offsite within a 5-mile radius, or transported near the site by barge, rail, or surface road. The evaluations determined that only chlorine traveling by barge presents a hazard to the CRE occupants; however, due to the low probability of a chlorine event, it was excluded from the control room habitability analysis. The licensee stated that the CREV System is not designed to protect the CRE occupants from these hazards. On October 15, 2008, the staff informed the licensee that entire removal of chemical and smoke hazards from control room habitability in TSs is not acceptable. The staff noted that even if quantitative requirements do not exist for smoke and chemical hazards, a qualitative discussion should be included in the control room habitability sections of the TSs with supporting basis provided in the TS Bases section. By letter dated December 29,2008, the licensee agreed to include the use of the CRE in TSs as a means to protect the CRE occupants from smoke and chemical hazards and provided the staff with revised TS Sections. The proposed wording of TS 3.7.3, Required Action B.2, with respect to smoke and chemicals, states "... verify the CRE occupants are protected from smoke and chemical hazards." The proposed wording is slightly different from the NRC model safety evaluation, because there are no quantitative CRE inleakage limits for hazardous chemicals and smoke at BFN. The proposed Bases for Required Action B.2 also is slightly different from the model Bases for the same reason. The NRC staff finds the proposed wording for Required Action B.2 in TS Section 3.7.3 is acceptable, because the licensee will perform periodic assessment of CRE habitability as required by proposed TS 5.5.13, "CRE Room Habitability Program," and as part of this periodic assessment, the licensee is required to ensure exposure of CRE occupants to the chemical hazards will be within the assumptions in the licensing basis as stated in proposed TS 5.5.13.e.
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, Control Room Emergency Ventilation (GREY) SYstem The licensee proposed to revise the action requirements of TS 3.7.3 to acknowledge that an inoperable CRE boundary, depending upon the location of the associated degradation, could cause just one, instead of both CREV subsystems to be inoperable. This is accomplished by revising Condition A to exclude Condition B, and revising Condition B to address one or more CREV System trains as follows:
- Condition A One CREV subsystem inoperable for reasons other than Condition B.
- Condition B One or more CREV subsystems inoperable due to inoperable CRE boundary in MODES 1, 2, and 3.
This change clarifies how to apply the action requirements in the event just one CREV subsystem is unable to ensure CRE occupant safety within licensing basis limits because of an inoperable CRE boundary. It enhances the usability of Conditions A and B with a presentation that is more consistent with the intent of the existing requirements. This change is an administrative change because it neither reduces nor increases the existing action requirements, and, therefore, is acceptable. The licensee proposed to replace existing Required Action B.1, "Restore boundary to OPERABLE status," which has a 24-hour
- 9 Completion Time, with Required Action B.1, to immediately initiate action to implement mitigating actions; Required Action B.2, to verify, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and further verify that the CRE occupants are protected from hazardous chemicals and smoke; and Required Action B.3, to restore CRE boundary to operable status within 90 days.
The 24-hour Completion Time of new Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions as directed by Required Action B.1. The 90-day Completion Time of new Required Action B.3 is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 90-day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary. Therefore, proposed 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 CREV subsystems inoperable due to an inoperable CRE boundary during OPDRVs [operations with a potential for draining the reactor vessel]." The specified Required Actions proposed for this condition are the same as for the other existing condition for Action F, which states, "Two CREV subsystems inoperable 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 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 OPDRVs. Therefore, this change is administrative and acceptable.
In the emergency radiation state of operation, the CREV System 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 3.7.3.4. This SR requires verifying that one CREV System subsystem operating in the emergency radiation state can maintain a pressure of greater than or equal to 0.125 inches water gauge, relative to outdoors during the pressurization mode of operation at a makeup flow rate of greater than or equal to 2700 cubic feet per minute (cfm) and less than or equal to 3300 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 leaktight 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). However, in its response to GL 2003-01, the licensee reported that CRE pressurization surveillance, SR 3.7.3.4, as performed at BFN also quantified CRE unfiltered inleakage. The licensee further stated that the results of unfiltered inleakage values determined by the tracer gas testing using ASTM E741 methods confirmed that the inleakage quantification testing periodically performed at BFN since 1991 has been and remains adequate to detect degradation of the CRE. However, the licensee's decision to adopt TSTF-448, Revision 3 has
- 10 now resulted in their proposal to replace the CRE pressurization surveillance, SR 3.7.3.4, with an inleakage measurement SR and a CRE habitability Program in TS Section 5.5.13, in accordance with the approved version of TSTF-448. Based on the adoption of TSTF-448, Revision 3, the licensee's proposal to delete existing SR 3.7.3.4 is acceptable.
In its place, the licensee proposed a new SR 3.7.3.4, which states, "[p]erform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program." The CRE Habitability Program TS, proposed in TS 5.5.13, requires that the program include "[r]equirements 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." 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 5.5.13, 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 3.7.4.4, this program is intended to ensure the operability of the CRE boundary, which as part of an operable CREV System will ensure that CRE habitability is maintained such that CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under DBA conditions without personnel receiving radiation exposures in excess of 5 rem 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 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 in-leakage determinations.
Assessment of CRE habitability at the freq uencies stated in Sections C.1 and Co2 of RG 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 RG 1.197. This element is intended to ensure that the plant assesses CRE habitability
- 11 consistent with Sections C.1 and C.2 of RG 1.197. Assessing CRE habitability at the NRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not go undetected between CRE inleakage determinations. Determination of CRE inleakage using test methods acceptable to the NRC staff assures that test results are reliable for ascertaining CRE boundary operability. Determination of CRE inleakage at the NRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not occur between CRE inleakage determinations.
Measurement of CRE pressure with respect to all areas adjacent to the CRE boundary at designated locations will be performed as part of assessing the CRE boundary at a frequency of 24 months on a staggered test basis (with respect to CREV System 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 design basis accidents. Having an unambiguous criterion for the CRE boundary to be considered operable in order to meet LCO 3.7.3, will ensure that associated action requirements will be consistently applied in the event of CRE degradation resulting in inleakage exceeding the limit.
The program must state 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) (measurement of CRE inleakage and assessment of CRE habitability), and paragraph number d (measurement of CRE differential pressure). This statement is needed to avoid confusion. SR 3.0.2 is applicable to the surveillance that references the testing in the CRE Habitability Program. However, SR 3.0.2 is not applicable to Administrative Controls unless specifically invoked. Providing this statement in the program eliminates any confusion regarding whether SR 3.0.2 is applicable, and is acceptable.
Consistent with TSTF-448, Revision 3, the proposed TS 5.5.13 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, TS 5.5.13 is consistent with the model program TS approved by the NRC staff in TSTF-448, Revision 3, and is acceptable.
3.5 Implementation of New Surveillance and Assessment Requirements by the Licensee The licensee has proposed license conditions regarding the initial performance of the new surveillance and assessment requirements. The new license conditions adopt the conditions in section 2.3 of the model application published in the Federal Register on January 17, 2007 (72 FR 2022). Plant specific changes were made to these proposed license conditions. The proposed plant specific license conditions are consistent with the model application, and are acceptable.
- 12
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Alabama 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 installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding (74 FR 4775). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
7.0 REFERENCES
- 1. NRC Generic Letter 2003-01, "Control Room Habitability," dated June 12, 2003.
- 2. ASTM E741-00, "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution," 2000.
- 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.
- 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, dated May 2003.
- 13
- 6. NEI 9903, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001.
Principal Contributors: Nageswara Karipineni Matthew Hamm Date:
August 18, 2009
" ML091730242 NRR-58 OFFICE LPL2-2/PM LPL-WB/LA SCVBIBC ITSB/BC OGC LPL2-2/BC NAME EBrown BClayton RDennig ALewin for RElliott Not Required TBoyce by memo dated w/ comments DATE 08/12/09 07/16/09 6/10/09 08/17/09 ML073130139 08/18/09