ML091940491
| ML091940491 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/30/2009 |
| From: | Jacqueline Thompson Plant Licensing Branch II |
| To: | Morris J Duke Energy Carolinas |
| Thompson J, NRR/DPR 415-1119 | |
| References | |
| TAC MD9249, TAC MD9250 | |
| Download: ML091940491 (25) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 30, 2009 Mr. J. R. Morris Site Vice President Catawba Nuclear Station Duke Energy Carolinas, LLC 4800 Concord Road York, SC 29745
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE [TSTF]-448, REV. 3, "CONTROL ROOM HABITABILITY PROGRAM" (TAC NOS. MD9249 and MD9250)
Dear Mr. Morris:
The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 250 to Renewed Facility Operating License NPF-35 and Amendment No. 245 to Renewed Facility Operating License NPF-52 for the Catawba Nuclear Station, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated July 14, 2008.
The amendments revise the TSs to establish more effective and appropriate action, surveillance, and administrative requirements related to ensuring the habitability of the control room envelope in accordance with NRC-approved TSTF Standard Technical Specification change traveler TSTF-448, Rev. 3, "Control Room Habitability." Specifically, the proposed amendments would revise TS 3.7.10, "Control Room Area Ventilation," and TS Section 5.5, "Programs and Manuals." The amendments also authorize a change in the Catawba Updated Final Safety Analysis Report.
A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
J. Morris
- 2 If you have any questions, please call me at 301-415-1119.
Docket Nos. 50-413 and 50-414
Enclosures:
- 1. Amendment No. 250 to NPF-35
- 2. Amendment No. 245 to NPF-52
- 3. Safety Evaluation cc w/encls: Distribution via Listserv Sincerely, Jon Thompson, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC NORTH CAROLINA ELECTRIC MEMBERSHIP CORPORATION DOCKET NO. 50-413 CATAWBA NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 250 Renewed License No. NPF-35
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the Catawba Nuclear Station, Unit 1 (the facility) Renewed Facility Operating License No. NPF-35 filed by the Duke Energy Carolinas, LLC, acting for itself, and North Carolina Electric Membership Corporation (licensees), dated July 14, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2
- 2.
Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-35 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 250, which are attached hereto, are hereby incorporated into this license. Duke Energy Carolinas, LLC, shall operate the facility in accordance with the Technical Specifications.
- 3.
Further, Renewed Facility Operating License No. NPF-35 is hereby amended to authorize a change to the Updated Final Safety Analysis Report (UFSAR) to modify sections of the UFSAR as set forth in the license amendment application dated JUly 14, 2008, and evaluated in the safety evaluation dated July 30, 2009.
The licensee shall update the UFSAR by adding a description of the change, as authorized by this amendment, and in accordance with 10 CFR 50.71(e).
- 4.
This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Acting Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to License No. NPF-35 and the Technical Specifications Date of Issuance: July 30, 2009
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC NORTH CAROLINA MUNICIPAL POWER AGENCY NO.1 PIEDMONT MUNICIPAL POWER AGENCY DOCKET NO. 50-414 CATAWBA NUCLEAR STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 245 Renewed License No. NPF-52
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the Catawba Nuclear Station, Unit 2 (the facility) Renewed Facility Operating License No. NPF-52 filed by the Duke Energy Carolinas, LLC, acting for itself, North Carolina Municipal Power Agency No.1 and Piedmont Municipal Power Agency (licensees), dated July 14, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;
- c.
There is reasonable assurance (I) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2
- 2.
Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-52 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 245, which are attached hereto, are hereby incorporated into this license. Duke Energy Carolinas, LLC, shall operate the facility in accordance with the Technical Specifications.
- 3.
Further, Renewed Facility Operating License No. NPF-52 is hereby amended to authorize a change to the Updated Final Safety Analysis Report (UFSAR) to modify sections of the UFSAR as set forth in the license amendment application dated July 14,2008, and evaluated in the safety evaluation dated July 30,2009.
The licensee shall update the UFSAR by adding a description of the change, as authorized by this amendment, and in accordance with 10 CFR 50.71(e).
- 4.
This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION l~~Lt4!
Undine Shoop, Acting Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to License No. NPF-52 and the Technical Specifications Date of Issuance: July 30, 2009
ATIACHMENT TO LICENSE AMENDMENT NO. 250 RENEWED FACILITY OPERATING LICENSE NO. NPF-35 DOCKET NO. 50-413 AND LICENSE AMENDMENT NO. 245 RENEWED FACILITY OPERATING LICENSE NO. NPF-52 DOCKET NO. 50-414 Replace the following pages of the Renewed Facility Operating Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Licenses Licenses NPF-35, page 4 NPF-35, page 4 NPF-52, page 4 NPF-52, page 4 TSs TSs 3.7.10-1 3.7.10-1 3.7.10-2 3.7.10-2 3.7.10-3 3.7.10-3 5.5-15
-4 (2)
Technical SPecifications T~.TBchnical:SP.eCifi~8tions contained in Appendix A. as r~vised through
",mendment.No. 250 which a~attached'hereto, are hereby Incorporated Inlo this renewed opersllriglicense, Duke Energy C"rolifl8S. llC sh~1I ope~te'the facility Irl ~ordance with the Technical Specifications.
(3)
Updated Final safetYAna!Vs~"~eport
,The Updated Final Safety Analysis Report supplement submitted purSuant to 10 CfR 54.21(d), as revised 9n December 16. 2002,* describes Certa;n future activities to be completed beforethe periOd of extended operation. Duke shall
, complete these acti.vities nO later than February 24. 2026. and shall notify the NRC In writing When Implementation of these activities 'Is. complete and can be
-verified by NRC insp~tlon, The Updated Final Safety Analysis' Report supplement as revised-on December 16. 2002, descriQad above, shall be Included In the' neXt scheduled update to the Updated Final safety AnalySis RepQrt required by 10 CFR 50.71(8)(4), followingissuance'ofthis renewed operating IicenSe~ Unlillhat update Is co'mplete, Duke maymak.e changes to the prOgrams described In such supplem~nt withOut prior CommISsion approval, provided that Duke evaluateS each such chin1ge' pursuant to the criteria set forth in 10 CFR 50.59 and otherwise compRes with the requirements in that section.
(4)
Antitrust Conditions Duke ~nergy Carofinas. llC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.
(5)
Fire*Protection prOgram (Section 9.5.1, SER, SSER#2. SSER #3,SSER #4, SSER #5)*
D,uke Energy Carolinas, llC shall implement and main.tain In effect all provisions
-of thEt approved fire protection program as described in the UJ)dated Final Safety Analysis Report, as amended; for the facility and 'as approved in the SER through Supplement 5. subject to the,folloWing provision:'
The licenseij may make changes to the approved fire pr:otection 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.
'The parenthetical notation following the title of this renewed operating license condition denotes the section of the Safety Evaluation Report andlor its supplements Wherein this renewed license condition is discussed.
Renewed license No. NPF-35 Amendment No. 250
-4 (2)
Technical SpecifiCations.
.The Technical'Specificatlons contained if) App~ndb{ A~ as ~vised through
~mendmentNo~ 245 which are,att8Ched'~reto,are hereby incorporated Inlo thi~ renewed operating J~e. Duke Energy CBroli~a5, LLC sh~U operate the
.. fa~i1ity In ~ccordance with the Tectrlical ~pecificatlons.
'I,
'(3):
Updated Flna' Saf~tY,Ana'yS!s' RE;porf',
,.The Updated Final Safety Analysis RepOrt supplement submlttec;t purSuant to 10 CFR '54.21(d), as revised on December 16. 2002,*describes cerbiln future activities 'to be completed before,the period Qf extended oPeration'. Duke shall
, complete these activities no 'ater than February 24, 2026, and shalt notify the NRC In writing wtJen Implementation of these activities is complete and can be
've~fied by NRC insptt,ctlon.
The Updated,Findl Safety Analysis',Report supplement as revised on December 16,2002. descrlQed above, shall be Included In the next scheduled' update to the Updated Final Safety Analysis RepQrt required by 10 CFR 50.71 (e)(4), following,issuance 'of this renewed operating license. Until that update is complete. Duke may make changes to the programs described !n ~uch supplement without prior Comm!ssion approval, provided that Duke,evaluates each such change' pursuant to the criteria set forth In 10 CFR 50.59 and otherwise complies with tbe requirements in that section.
(4)
Antitrust Conditions Duke ~nergy Carolinas, LlC st)all compty with the antitrust conditions deUneated in Appendix C to this renewed operating license.
(5)
Fire Protection Program (~ection 9;5.1, SER, SSER#2, S$ER #3,SSER #4, SS,ER #5)*
O,uke Energy Carolinas, LlC shall implement and mainJain in effect all provisions of the approved fire protection prograrn8s d~scribed in the U~ted Fin~l.~fBty Analysis ~epOl1, a~ amended; for the facility and 'as approved In the SER through Supplement 5, subject tolhefollowlng provision:
. The "cens~' may make changes to the approved fire pr:otection p.ragram without prior approval ofthe Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the Bvent of a fire.
- The parenthetical notation following the title of this renewed operating license condition denotes the section of the Safety Evaluation Report andfor its supplements wherein'this renewed IIcerise condition is discussed.
Renewed licen58 No. NPF-52 Amendment No, 245
CRAVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Area Ventilation System (CRAVS)
LCO 3.7.10 Two CRAVS trains shall be OPERABLE.
No-rE-------------------------------------------------
The control room envelope (CRE) boundary may be opened intermittently under administrative controls.
APPLICABILITY:
MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One CRAVS train inoperable for reasons other than Condition B.
A.1 Restore CRAVS train to OPERABLE status.
7 days B.
One or more CRAVS trains inoperable due to inoperable CRE boundary in MODES 1, 2, 3, or 4.
B.1 AND B.2 AND B.3 Initiate action to implement mitigating actions.
Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.
Restore CRE boundary to OPERABLE status.
Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 90 days (continued)
Catawba Units 1 and 2 3.7.10-1 Amendment Nos.; 250, 245
REQUIRED ACTIONS (continued CONDITION C.
Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or 4.
D.
Required Action and associated Completion Time of Condition A not met in MODE 5 or 6.
E.
Two CRAVS trains inoperable in MODE 5 or 6, or one or more CRAVS trains inoperable during movement of irradiated fuel assemblies.
OR One or more CRAVS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies.
F.
Two CRAVS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.
REQUIRED ACTION C.1 Be in MODE 3.
AND C.2 Be in MODE 5.
D.1 Place OPERABLE CRAVS train in operation.
E.1 Suspend movement of irradiated fuel assemblies.
F.1 Enter LCO 3.0.3.
CRAVS 3.7.10 COMPLETION TIME 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours Immediately Immediately Immediately (continued)
Catawba Units 1 and 2 3.7.10-2 Amendment Nos. 250, 245
CRAVS 3.7.10 REQUIRED ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME G.
One or more CRAVS train(s) heater inoperable.
G.1 G.2 Restore CRAVS train(s) heater to OPERABLE status.
Initiate action in accordance with Specification 5.6.6.
7 days 7 days SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRAVS train for ~ 10 continuous hours with the heaters operating.
31 days SR 3.7.10.2 Perform required CRAVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with VFTP SR 3.7.10.3 Verify each CRAVS train actuates on an actual or simulated actuation signal.
18 months SR 3.7.10.4 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 Catawba Units 1 and 2 3.7.10-3 Amendment Nos. 250, 245
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.16 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Area Ventilation System (CRAVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:
- a.
The definition of the CRE and the CRE boundary.
- b.
Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
- c.
Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1. and C.2. of RegUlatory Guide 1.197, Revision O.
- d.
Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CRAVS, operating at a makeup flow rate of ~ 4000 cfm, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.
- e.
The quantitative limits on unfiltered air inleakage into the eRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.
The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.
Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
- f.
The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.
Catawba Units 1 and 2 5.5-15 Amendment Nos. 250, 245
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 250 TO RENEWED FACILITY OPERATING LICENSE NPF-35 AND AMENDMENT NO. 245 TO RENEWED FACILITY OPERATING LICENSE NPF-52 DUKE ENERGY CAROLINAS, LLC CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414
1.0 INTRODUCTION
By application dated July 14, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082030155) Duke Energy Carolinas, LLC (Duke, the licensee),
requested changes to the Technical Specifications (TSs) for the Catawba Nuclear Station, Units 1 and 2 (Catawba 1 and 2). The proposed changes would establish more effective and appropriate action, surveillance, and administrative standard technical specifications (STSs) requirements related to ensuring the habitability of the control room envelope (CRE).
On August 8,2006, the commercial nuclear electrical power generation industry owners group Technical Specifications Task Force (TSTF) submitted a proposed change, TSTF-448, Rev. 3, to the improved STSs (NUREGs 1430-1434) on behalf of the industry (TSTF-448, Rev.s 0, 1, and 2 were prior draft iterations) to the U.S. Nuclear Regulatory Commission (NRC) staff.
TSTF-448, Rev. 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 NRC Generic Letter (GL) 2003-01, licensees were alerted to findings at facilities that existing TS surveillance requirements (SRs) for the Control Room Envelope Emergency Ventilation System (CREEVS) may not be adequate. Specifically, the results of American Society of Testing and Materials (ASTM) Standard E741 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 TSs as follows:
- 2 Provide confirmation that your technical specifications verify the integrity [Le., operability]
of the CRE [boundary], and the assumed [unfiltered] inleakage rates of potentially contaminated air. If you currently have a differential pressure surveillance requirement to demonstrate CRE [boundary] integrity, provide the basis for your conclusion that it remains adequate to demonstrate CRE integrity in light of the ASTM E741 testing results. If you conclude that your differential pressure surveillance requirement is no longer adequate, provide a schedule for: 1) revising the surveillance requirement in your technical specification to reference an acceptable surveillance methodology (e.g.,
ASTM E741), and 2) making any necessary modifications to your CRE boundary so that compliance with your new surveillance requirement can be demonstrated.
If your facility does not currently have a technical specification surveillance requirement for your CRE integrity, explain how and at what frequency you confirm your CRE integrity and why this is adequate to demonstrate CRE integrity.
To promote standardization and to minimize the resources that would be needed to create and process plant-specific amendment applications in response to the concerns described in the GL, the industry and the NRC staff proposed revisions to CRE habitability system requirements contained in the STSs, using the STSs change traveler process. This effort culminated in Rev.
3 to traveler TSTF-448, "Control Room Habitability," which the NRC staff approved on January 17, 2007 (72 FR 2022).
Consistent with the traveler as incorporated into NUREG-1431, the licensee proposed revising the action statement and SRs in Specification 3.7.10, "Control Room Emergency Filtration System (CREFS)," and adding a new administrative controls program, Specification 5.5.16, "Control Room Envelope Habitability Program." The purpose of these changes is to ensure that CRE boundary operability is maintained and verified through effective SRs and programmatic requirements, and that appropriate remedial actions are taken in the event of an inoperable CRE boundary.
Some editorial and plant-specific changes were incorporated into this Safety Evaluation (SE) resulting in minor deviations from the model SE text in TSTF-448, Rev. 3.
2.0 REGULATORY EVALUATION
2.1 Control Room and Control Room Envelope NRC Regulatory Guide (RG) 1.196, "Control Room Habitability at Light-water Nuclear Power Reactors," Rev. 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.
- 3 Control Room Envelope: The plant area, defined in the facility licensing basis that in the event of an emergency, can be isolated from the plant areas and the environment external to the CRE. This area is served by an emergency ventilation system, with the intent of maintaining the habitability of the control room. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident.
NRC RG 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors,"
Rev. 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 SE, consistent with the proposed changes to the STSs, the CRE will be used to designate both environments as defined above. For consistency, facilities should use the term CRE with an appropriate facility-specific definition derived from the above CRE definition.
2.2 Control Room Area Ventilation System The Control Room Area Ventilation System (CRAV System or CRAVS, the term used by the licensee at Catawba for the CREEVS) provides a protected environment from which operators can control the unit, during airborne challenges from radioactiVity, hazardous chemicals, and fire byproducts such as fire suppression agents and smoke, during both normal and accident conditions.
The CRAVS 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 a 5 rem total effective dose equivalent (TEDE).
The CRAV System is shared between the two units at Catawba.
The CRAV System consists of two independent, redundant trains, each capable of maintaining the habitability of the CRE. A CRAVS train is considered operable when the individual components necessary to limit CRE occupant exposure are operable in both trains. Therefore, A CRAVS train is operable when the associated:
Pressurizing filter train fan is operable High efficiency particulate air filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions
- Ductwork, dampers/valves, controls, doors and barriers are operable, and air circulation can be maintained
- The 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.
- 4 2.3 Regulations Applicable to Control Room Habitability In Appendix A, "General Design Criteria for Nuclear Power Plants," to Title 10 of the Code of Federal Regulations (10 CFR), Part 50, "Domestic Licensing of Production and Utilization Facilities," General Design Criteria (GDC) 1,2, 3, 4, 5, and 19 apply to CRE habitability.
In Attachment 2 of a letter from the licensee to the NRC staff dated December 9,2003, regarding Catawba's response to GL 2003-01 (ADAMS Accession No. ML033510109), it is confirmed that Catawba 1 and 2 were designed to the GDC as outlined in 10 CFR Part 50, Appendix A. A summary of these GDCs follows.
GDC 1, "Quality Standards and Records," requires that structures, systems, and components (SSCs) important to safety be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions performed.
GDC 2, "Design Basis for Protection Against Natural Phenomena," requires that SSCs important to safety be designed to withstand the effects of earthquakes and other natural hazards.
GDC 3, "Fire Protection," requires SSCs important to safety be designed and located to minimize the effects of fires and explosions.
GDC 4, "Environmental and Dynamic Effects Design Bases," requires SSCs important to safety to be designed to accommodate the effects of, and to be compatible with, the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents (LOCAs).
GDC 5, "Sharing of Structures, Systems, and Components," requires that SSCs important to safety not be shared among nuclear power units unless it can be shown that such snaring will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, the orderly shutdown and cooldown of the remaining units.
GDC 19, "Control Room," requires that a control room be provided from which actions can be taken to operate the nuclear reactor safely under normal conditions and to maintain the reactor in a safe condition under accident conditions, including a LOCA. Adequate radiation protection is to be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of specified values. Prior to incorporation of TSTF-448, Rev. 3, the STSs requirements addressing CRE boundary operability resided only in the CRE ventilation system specification TS 3.7.10, "Control Room Emergency Filtration System (CREFS)" found in NUREG-1431.
In this specification, the SR associated with demonstrating the operability of the CRE boundary requires verifying that one CREEVS train can maintain a positive pressure relative to the areas adjacent to the CRE during the pressurization mode of operation at a makeup flow rate.
Facilities that pressurize the CRE during the emergency mode of operation of the CREEVS have similar SRs. Regardless, the results of ASTM E741 tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance is not a reliable method for demonstrating CRE boundary operability. That is, licensees were able to
- 5 obtain differential pressure and flow measurements satisfying the SR limit even though unfiltered inleakage was determined to exceed the value assumed in the safety analyses.
In addition to an inadequate SR, the action requirements of these specifications were ambiguous regarding CRE boundary operability in the event CRE unfiltered inleakage is found to exceed the analysis assumption. The ambiguity stemmed from the view that the CRE boundary may be considered operable but degraded in this condition, and that it would be deemed inoperable only if calculated radiological exposure limits for CRE occupants exceeded a licensing basis limit; e.g., as stated in GDC-19, even while crediting compensatory measures.
NRC Administrative Letter (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." A "degraded or nonconforming condition" is defined in NRC Inspection Manual Chapter 9900 (see also latest guidance in Regulatory Issue Summary (RIS) 2005-20). AL 98-10 also states that "Imposing administrative controls in response to improper or inadequate TS is considered an acceptable short-term corrective action. The [NRC] staff expects that, following the imposition of administrative controls, an amendment to the inadequate TS, with appropriate justification and schedule, will be submitted in a timely fashion."
Licensees that have found unfiltered inleakage in excess of the limit assumed in the safety analyses, and have yet to either reduce the inleakage below the limit or establish a higher bounding limit through re-analysis, have implemented compensatory actions to ensure the safety of CRE occupants, pending final resolution of the condition, consistent with RIS 2005-20.
However, based on GL 2003-01 and AL 98-10, the NRC staff expects each licensee to propose TS changes that include a surveillance to periodically measure CRE unfiltered inleakage in order to satisfy 10 CFR 50.36(c)(3), which requires a facility's TS to include SRs, which it defines as "requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that limiting conditions for operation will be met." (Emphasis added.)
The NRC staff also expects facilities to propose unambiguous remedial actions, consistent with 10 CFR 50.36(c)(2), for the condition of not meeting the limiting condition for operation (LCD) due to an inoperable CRE boundary. The action requirements should specify a reasonable completion time to restore conformance to the LCD 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 Adoption of TSTF-448, Rev. 3, will assure that a facility's TS LCD for the CRAVS is met by demonstrating that 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, Rev. 3, 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, Rev. 3, will establish clearly stated and reasonable required actions in the event CRE unfiltered inleakage is found to exceed the analysis assumption.
- 6 The changes made by TSTF-448, Rev. 3, to the STSs requirements for the CREFS and the CRE boundary conform to 10 CFR 50.36(c) (2) and 10 CFR 50.36(c) (3). Their adoption will better assure that a plant's CRE will remain habitable during normal operation and design basis accident conditions. The staff has therefore concluded that these changes are acceptable for adoption by licensees.
3.0 TECHNICAL EVALUATION
The NRC staff reviewed the proposed changes against the corresponding changes made to the STSs by TSTF-448, Rev. 3, which the NRC staff has found to satisfy applicable regulatory requirements, as described above in Section 2.0. The operational mode of the CRAV System at Catawba 1 and 2 pressurizes the CRE to minimize unfiltered air inleakage. The proposed changes are consistent with this design.
3.1 Proposed Changes The proposed amendment would strengthen CRE habitability TS requirements by changing TS 3.7.10, "Control Room Area Ventilation (CRAV) 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 STSs Bases, which were made to improve clarity, conform to the latest information and references, correct factual errors, and achieve more consistency among the STSs NUREGs.
Except for plant-specific differences, all of these changes are consistent with STSs as revised by TSTF-448, Rev. 3.
The NRC staff compared the proposed TS changes to the STSs and the STSs markups and evaluations in TSTF-448, Rev. 3. The NRC staff verified that differences from the STSs were adequately justified on the basis of plant-specific design or the retention of the current licensing basis. The NRC staff also reviewed the proposed changes to the TS Bases for consistency with the STSs Bases and the plant-specific design and licensing bases. The proposed Bases for TS 3.7.10 refer to specific guidance in NEI 99-03, "Control Room Habitability Assessment Guidance," Rev. 0, dated June 2001, which the NRC staff has formally endorsed, with exceptions, through RG 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," dated May 2003.
3.2 Editorial Changes The licensee proposed editorial changes to TS 3.7.10, "Control Room Area Ventilation System (CRAVS)," to establish standard terminology, such as "control room envelope (CRE)" in place of "control room," except for the plant-specific name for the CRAV System, and "radiological, chemical, and smoke hazards" in place of various phrases to describe the hazards that CRE occupants are protected from by the CRAV System.
The licensee also proposes an administrative change to remove a footnote to the Completion Time for LCO Required Action A.1. This footnote provided for an extension to the time that one CRAV train may be inoperable from the original 7 days up to 14 days to allow for maintenance and upgrades to the nuclear service water system headers associated with each unit. This
- 7 footnote was provided with an expiration date of midnight December 31,2006, if not used, and was no longer applicable upon completion of these activities.
These changes improve the usability and quality of the presentation of the TSs, have no adverse impact on safety, and therefore, are acceptable.
3.3 TS 3.7.10, "Control Room Area Ventilation System (CRAVS),"
The licensee proposed to revise the action requirements ofTS 3.7.10, "Control Room Area Ventilation System (CRAVS)," to acknowledge that an inoperable CRE boundary, depending upon the location of the associated degradation, could cause just one, instead of both, CRAV trains to be inoperable. This is accomplished by revising Condition A to exclude Condition B, and revising Condition B to address one or more CRAV trains, as follows:
Condition A - One CRAV train inoperable for reasons other than Condition 8.
Condition B - One or more CRAV trains inoperable due to inoperable CRE boundary in MODE 1, 2, 3, or 4.
This change clarifies how to apply the action requirements in the event just one CRAV train is unable to ensure CRE occupant safety within licensing basis limits because of an inoperable CRE boundary. It enhances the usability of Conditions A and B with a presentation that is more consistent with the intent of the existing requirements. This change is an administrative change because it neither reduces nor increases the existing action requirements, and, therefore, is acceptable.
New Required Action B.1 requires the licensee to immediately initiate action to implement mitigating actions. New Required Action 8.2 requires that in addition to B.1, the licensee will 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 exposure and exposure to hazardous chemicals and smoke will not exceed the calculated dose of the licensing basis analyses of the DBA consequences. New Required Action B.3 requires the licensee to restore the CRE boundary to operable status within gO days.
The 24-hour Completion Time of new Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions as directed by Required Action B.1. The gO-day Completion Time of new Required Action B.3 is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The gO-day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary. Therefore, proposed Actions B.1, B.2, and 8.3 are acceptable.
The licensee proposed to add a new condition to Action E of TS 3.7.10 that states, "One or more CRAVS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies." The specified Required Action proposed for this condition is the same as for the existing condition of Action E, which states, "Two CRAV trains inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies." Accordingly, the new condition is stated with the other condition in Action E using the logical connector "OR".
- 8 The practical result of this presentation in format is the same as specifying two separately numbered Actions, one for each condition. Its advantage is to make the TS Actions table easier to use by avoiding having an additional numbered row in the Actions table. The new condition in Action E is needed because proposed Action B will only apply in Modes 1, 2, 3, and 4. As such, this change will ensure that the Actions table continues to specify a condition for an inoperable CRE boundary during movement of irradiated fuel assemblies. Therefore, this change is administrative and acceptable.
The licensee proposed to delete the existing CRE pressurization SR 3.7.10.4. This SR requires verifying that one CRAV train can maintain a pressure of ~.125 inches water gauge, relative to the adjacent area, during the pressurization mode of operation at a makeup flow rate of ~4000 cfm. The deletion of this SR is proposed because measurements of unfiltered air leakage into the CRE at numerous reactor facilities demonstrated that a basic assumption of this SR, an essentially leak-tight CRE boundary, was incorrect for most facilities. Hence, meeting this SR by achieving the required CRE pressure is not necessarily a conclusive indication of aCRE boundary leak. The licensee has proposed to replace it with an inleakage measurement SR and a CRE Habitability Program in TS Section 5.5, in accordance with the approved version of TSTF-448, Rev. 3. Based on the adoption of TSTF-448, Rev. 3, the licensee's proposal to delete SR 3.7.10.4 is acceptable.
The proposed CRE inleakage measurement in the revised SR 3.7.10.4 states, "Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Habitability Program." The CRE Habitability Program TS, proposed TS 5.5.16, requires that the program include "Requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of RG 1.197, Rev. O. This guidance references ASTM E741 as an acceptable method for ascertaining the unfiltered leakage into the CRE. The licensee has proposed to follow this method. Therefore, the proposed CRE inleakage measurement SR is acceptable.
3.4 TS 5.5.16, "Control Room Envelope Habitability Program" The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Rev. 3. In combination with SR 3.7.10.4, 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:
- 1) 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
- 9 the general definitions discussed in Section 2.1 of this SE. Establishing what is meant by the CRE and the CRE boundary will preclude ambiguity in the implementation of the program.
- 2) Configuration control and preventive maintenance of the CRE boundary This element is intended to ensure that the CRE boundary is maintained in its design condition.
Guidance for implementing this element is contained in RG 1.196, which endorsed with exceptions NEI 99-03, Rev. O. Maintaining the CRE boundary in its design condition provides assurance that its leak-tightness will not significantly degrade between CRE inleakage determinations.
- 3) 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 RG 1.197, Rev. 0 "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," issued May 2003, and (ii) assessing CRE habitability at the frequencies specified in Sections C.1. and C.2. of RG 1.197, Rev. O.
This element is intended to ensure that the plant assesses CRE habitability consistent with Sections C.1 and C.2 of RG 1.197 and NRC-approved exceptions. 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.
- 4) Measurement of CRE pressure with respect to all areas adjacent to the CRE boundary at designated locations at a frequency of 18 months on a staggered test basis. The results shall be trended and used as part of the 18-month assessment of the CRE boundary.
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.
- 5) Quantitative limits on unfiltered inleakage into the CRE 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 3.7.10 will ensure that associated action requirements will be consistently applied in the event of CRE degradation resulting in inleakage exceeding the limit.
- 6) Consistent with TSTF-448, Rev. 3, the program states that the provisions of SR 3.0.2 are applicable to the program frequencies for performing the activities required by program paragraph number c, parts (i) and (ii) (assessment of CRE habitability and measurement of CRE inleakage), and paragraph number d (measurement of CRE differential pressure).
- 10 This statement is needed to avoid confusion. SR 3.0.2 is applicable to the surveillance that references the testing in the CRE Habitability Program. However, SR 3.0.2 is not applicable to Administrative Controls unless specifically invoked. Providing this statement in the program eliminates any confusion regarding whether SR 3.0.2 is applicable, and is acceptable.
Consistent with TSTF-448, Rev. 3, proposed TS 5.5.16 states that (1) a CRE Habitability Program shall be established and implemented, (2) the program shall include all of the NRC staff required elements, as described above, and (3) the provisions of SR 3.0.2 shall apply to program frequencies. Therefore, TS 5.5.16, which is consistent with the model program TS approved by the NRC staff in TSTF-448, Rev. 3, is acceptable.
3.5 Implementation of New Surveillance and Assessment Requirements by the Licensee The licensee has proposed license conditions regarding the initial performance of the new surveillance and assessment requirements. The new license conditions adopted the conditions in Section 2.3 of the model application published in the Federal Register on January 17, 2007 (72 FR 2022). Plant-specific changes were made to these proposed license conditions. The proposed plant-specific license conditions are consistent with the model application, and are acceptable.
4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
The Commission's regulations in 10 CFR 50.92(c), "Issuance of amendment," state that the Commission may make a final determination that a license amendment involves no significant hazards consideration if operation of the facility in accordance with the amendment would not:
(1)
Involve a significant increase in the probability or consequences or an accident previously evaluated; or (2)
Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)
Involve a significant reduction in a margin of safety.
The following analysis from the environmental consideration published in the Federal Register on January 17, 2007 as part of the Consolidated Line Item Improvement Process for TSTF-448, Rev. 3, was reviewed by the licensee and the licensee concluded that the NRC staff's findings presented therein are applicable to Catawba 1 and 2 and incorporated this environmental consideration by reference into its letter dated July 14, 2008:
Criterion 1-The Proposed Change Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.
The proposed change does not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, or configuration of the facility. The proposed change does not alter or prevent the ability of structures, systems, and components (SSCs) to perform their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed change revises the TS for the CRE emergency ventilation system, which is a mitigation system designed to
- 11 minimize unfiltered air leakage into the CRE and to filter the CRE atmosphere to protect the CRE occupants in the event of accidents previously analyzed. An important part of the CRE emergency ventilation system is the CRE boundary. The CRE emergency ventilation system is not an initiator or precursor to any accident previously evaluated.
Therefore, the probability of any accident previously evaluated is not increased.
Performing tests to verify the operability of the CRE boundary and implementing a program to assess and maintain CRE habitability ensure that the CRE emergency ventilation system is capable of adequately mitigating radiological consequences to CRE occupants during accident conditions, and that the CRE emergency ventilation system will perform as assumed in the consequence analyses of design basis accidents. Thus, the consequences of any accident previously evaluated are not increased. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Criterion 2 - The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated.
The proposed change does not impact the accident analysis. The proposed change does not alter the required mitigation capability of the CRE emergency ventilation system, or its functioning during accident conditions as assumed in the licensing basis analyses of design basis accident radiological consequences to CRE occupants. No new or different accidents result from performing the new surveillance or following the new program. The proposed change does not involve a physical alteration of the plant (Le., no new or different type of equipment will be installed) or a significant change in the methods governing normal plant operation. The proposed change does not alter any safety analysis assumptions and is consistent with current plant operating practice.
Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Criterion 3 -The Proposed Change Does Not Involve a Significant Reduction in the Margin of Safety.
The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The proposed change does not affect safety analysis acceptance criteria. The proposed change will not result in plant operation in a configuration outside the design basis for an unacceptable period of time without compensatory measures. The proposed change does not adversely affect systems that respond to safely shut down the plant and to maintain the plant in a safe shutdown condition. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
The NRC staff has reviewed the licensee's analysis and, based on this review, has concluded that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff has made a final determination that the proposed amendment involves no significant hazards determination.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the South Carolina State official was notified of the proposed issuance of the amendments. The State official had no comments.
- 12
6.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change SRs.
The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has made a final finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (74 FR 26431).
The amendments also relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusions set forth in 10 CFR 51.22(c)(9) and (10). Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The NRC staff has concluded, based on the considerations discussed above, that: (1) the amendment does not (a) involve a significant increase in the probability or consequences of an accident previously evaluated or, (b) create the possibility of a new or different kind of accident from any previously evaluated or, (c) involve a significant reduction in a margin of safety and therefore, the amendment does not involve a significant hazards consideration; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (3) such activities will be conducted in compliance with the Commission's regulations, and (4) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
V. Cusumano M. Hamm Date: July 30, 2009
- no significant change to SE input sent via memo dated 116/09
EWilliamson UShoop JThompson DATE 07/27/09 07/27/09 01/06/09 11/06/07**
07/30/09 07/30/09