ML062540364

Amendment Control Room Habitability and Emergency Air Cleanup and Pressurization

ML062540364
Person / Time
Site:	Beaver Valley
Issue date:	09/25/2006
From:	Colburn T NRC/NRR/ADRO/DORL/LPLI-1
To:	Lash J FirstEnergy Nuclear Operating Co
Colburn T, NRR/DORL, 415-1402
References
TAC MC6050, TAC MC6051
Download: ML062540364 (19)

Text

September 25, 2006 Mr. James H. Lash Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 (BVPS-1 AND 2) -

ISSUANCE OF AMENDMENTS RE: CONTROL ROOM HABITABILITY AND EMERGENCY AIR CLEANUP AND PRESSURIZATION (TAC NOS. MC6050 AND MC6051)

Dear Mr. Lash:

The Commission has issued the enclosed Amendment No. 277 to Facility Operating License No. DPR-66 and Amendment No. 159 to Facility Operating License No. NPF-73 for the BVPS-1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated February 17, 2005, as supplemented May 12 and August 22, 2006.

These amendments revise current TSs 3.7.7.1 (BVPS-1), Control Room Emergency Habitability Systems, and 3.7.7 (BVPS-2), Control Room Emergency Air Cleanup and Pressurization System by dividing these TSs into two specifications, addressing control room emergency ventilation and control room air cooling functions separately. The amendments also improve consistency with the Standard TSs and improve consistency between the units.

J. Lash A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

1. Amendment No. 277 to DPR-66

2. Amendment No. 159 to NPF-73

3. Safety Evaluation cc w/encls: See next page

J. Lash A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

1. Amendment No. 277 to DPR-66

2. Amendment No. 159 to NPF-73

3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC LPLI-1 R/F RidsNrrDorlLpla RidsNrrPMTColburn RidsNrrLASLittle RidsOgc Rp RidsAcrsAcnwMailCenter GHILL(4)

RidsNrrDirsItsb RidsNrrDssCvib RidsRgnIMailCenter BSingal, DORL DPR HWalker Package: ML062540389 ACCESSION NO. ML062540364 *Input received. No substantive changes made.

OFFICE LPLI-1/PM LPLI-1/LA SCVB/BC OGC LPLI-1/BC NAME TColburn SLittle RDennig* SHamrick RLaufer DATE 9/14/06 9/14/06 08/29/2006 9/21/06 9/22/06 OFFICIAL RECORD COPY

Beaver Valley Power Station, Unit Nos. 1 and 2 cc:

Gary R. Leidich James H. Lash President and Chief Nuclear Officer Site Vice President FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 Beaver Valley Power Station 76 South Main Street Mail Stop A-BV-SEB1 Akron, OH 44308 P.O. Box 4, Route 168 Shippingport, PA 15077 Joseph J. Hagan Senior Vice President of Operations Lew W. Myers and Chief Operating Officer Executive Vice President, Special Projects FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Beaver Valley Power Station 76 South Main Street Mail Stop A-BV-SGRP Akron, OH 44308 P.O. Box 4, Route 168 Shippingport, PA 15077 Danny L. Pace Senior Vice President, Fleet Engineering Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Beaver Valley Power Station 76 South Main Street Mail Stop A-BV-A Akron, OH 44308 P.O. Box 4, Route 168 Shippingport, PA 15077 Jeannie M. Rinckel Vice President, Fleet Oversight Commissioner James R. Lewis FirstEnergy Nuclear Operating Company West Virginia Division of Labor Mail Stop A-GO-14 749-B, Building No. 6 76 South Main Street Capitol Complex Akron, OH 44308 Charleston, WV 25305 David W. Jenkins, Attorney Director, Utilities Department FirstEnergy Corporation Public Utilities Commission Mail Stop A-GO-18 180 East Broad Street 76 South Main Street Columbus, OH 43266-0573 Akron, OH 44308 Director, Pennsylvania Emergency Manager, Fleet Licensing Management Agency FirstEnergy Nuclear Operating Company 2605 Interstate Dr.

Mail Stop A-GHE-107 Harrisburg, PA 17110-9364 395 Ghent Road Akron, OH 44333 Ohio EPA-DERR ATTN: Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149

Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc:

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077

FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

DOCKET NO. 50-334 BEAVER VALLEY POWER STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 277 License No. DPR-66

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

A. The application for amendment by FirstEnergy Nuclear Operating Company, et al. (the licensee), dated February 17, 2005, as supplemented May 12 and August 22, 2006, 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. 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 Facility Operating License No. DPR-66 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 277, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: September 25, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 277 FACILITY OPERATING LICENSE NO. DPR-66 DOCKET NO. 50-334 Replace the following page of the Facility Operating License with the attached revised page.

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

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

Remove Insert VII VII 3/4 3-35 3/4 3-35 3/4 3-35a 3/4 3-35a 3/4 3-36 3/4 3-36 3/4 7-15 3/4 7-15 3/4 7-16 3/4 7-16 3/4 7-16a 3/4 7-16a 3/4 7-17 3/4 7-17 3/4 7-18 3/4 7-18 3/4 7-18a --

3/4 7-18b --

FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

OHIO EDISON COMPANY THE TOLEDO EDISON COMPANY DOCKET NO. 50-412 BEAVER VALLEY POWER STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.159 License No. NPF-73

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

A. The application for amendment by FirstEnergy Nuclear Operating Company, et al. (the licensee), dated February 17, 2005, as supplemented May 12 and August 22, 2006, 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. 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 Facility Operating License No. NPF-73 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 159, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: September 25, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 159 FACILITY OPERATING LICENSE NO. NPF-73 DOCKET NO. 50-412 Replace the following page of the Facility Operating License with the attached revised page.

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

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

Remove Insert VII VII 3/4 7-14 3/4 7-14 3/4 7-15 3/4 7-15 3/4 7-16 3/4 7-16 3/4 7-17 3/4 7-17 3/4 7-17a --

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 277 AND 159 TO FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

OHIO EDISON COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 (BVPS-1 AND 2)

DOCKET NOS. 50-334 AND 50-412

1.0 INTRODUCTION

By application dated February 17, 2005, as supplemented May 12 and August 22, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML050540581, ML061360076, and ML062360185, respectively, the FirstEnergy Nuclear Operating Company (FENOC, the licensee), requested changes to the Technical Specifications (TSs) for BVPS-1 and 2. The supplements dated May 12 and August 22, 2006, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on April 26, 2005 (70 FR 21458).

The proposed changes would revise current TSs 3.7.7.1 (BVPS-1), Control Room Emergency Habitability Systems, and 3.7.7 (BVPS-2), Control Room Emergency Air Cleanup and Pressurization System. Specifically, the proposed changes would revise the current TSs by dividing these TSs into two specifications, addressing control room emergency ventilation and control room air cooling functions separately. The amendments also improve consistency with the Standard TSs and improve consistency between the units.

1.1 Background BVPS-1 and 2 use pressurized-water reactor (PWR) Nuclear Steam Supply Systems (NSSSs) and turbine generators (TGs) furnished by the Westinghouse Electric Corporation. The balance of the units were designed and constructed by the licensee, with the assistance of their agent, Stone & Webster Engineering Corporation (S&W). As indicated above, in addition to creating separate TSs, the proposed changes will revise the TSs to improve consistency

between BVPS-1 and 2 and make the BVPS-1 and 2 TSs more consistent with the Improved Standard Technical Specifications (ISTS) for Westinghouse Plants, NUREG-1431, Revision 3.

The proposed amendments will revise the control room habitability systems TSs for BVPS-1 and 2. Each BVPS units control room habitability systems include a control room emergency ventilation system (CREVS) and a control room emergency air cooling system (CREACS).

These control room habitability systems meet the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR), Appendix A to Part 50, GENERAL DESIGN CREITERIA FOR NUCLEAR POWER PLANTS [GDC] 1, 2, 3, 4, 5, and 19 as described in each units Updated Final Safety Analysis Report (USFAR). The BVPS-1 and 2 control rooms are both a positive pressure design and share a common envelope.

In accordance with the licensees application dated February 17, 2005, the CREVS for BVPS-1 and 2 are configured in accordance with the facilities design and licensing basis. Encompassed within the CREVS design is the control room boundary, whose physical integrity is required in order for CREVS to be able to adequately perform its function. BVPS-1 and 2 CREVS are in physically separate locations within the control room envelope, each with its own components on its side of the combined control room envelope.

1.2 Licensees Approach The proposed changes are separated into four numbered groups wherein change number 1 (group 1), the licensee is proposing a change that will add a new TS for BVPS-1 that will be titled Control Room Emergency Air Cooling System (CREACS), and numbered 3/4.7.6. This change includes reorganizing the control room habitability TSs into two separate TSs consistent with the ISTS. Change number 2 (group 2) addresses the revision of the BVPS-1 Applicability requirements for the control room habitability TSs and associated control room radiation monitors to address fuel movement involving only recently irradiated fuel instead of fuel movement involving any irradiated fuel. In change request number 3 (group 3), the licensee addresses the category of changes necessary to make the existing BVPS-1 and 2 TS requirements for the CREVS as consistent as possible between the units and as consistent as possible with the corresponding ISTS requirements. Change number 4 (group 4) addresses BVPS-1 TS surveillances (4.7.7.1.2) which are replaced in their entirety by a requirement to comply with the applicable BVPS-2 surveillance requirement (SR) (4.7.7.1).

2.0 REGULATORY EVALUATION

The purpose of the Nuclear Regulatory Commission (NRC) staffs review is to evaluate the licensees assessment of the impact of the proposed changes to the BVPS-1 and 2 TSs on design-basis analyses. The NRC staff evaluated the licensees application based on the requirements of GDC 19, Control room, as supplemented by Section 6.4 of NUREG-0800, Standard Review Plan, Technical Specification Task Force 51 (TSTF-51), Revision 2, and NUREG-1431, Revision 3, Standard Technical Specifications - Westinghouse Plants.

3.0 TECHNICAL EVALUATION

The licensee stated that the proposed changes for BVPS-1 and 2 are consistent with the current design basis and licensing basis for BVPS-1 and 2. The proposed changes reorganize

the existing TS requirements to be more consistent with the standard presentation of these requirements.

TSs 3.7.7.1 Control Room Emergency Habitability Systems (BVPS-1) and 3.7.7 Control Room Emergency Air Cleanup and Pressurization System (BVPS-2) previously addressed both CREACS and CREVS components together. The proposed change provides two separate TSs, consistent with the ISTS, that provide more system-specific requirements for each of the control room habitability systems. The licensee stated that the proposed change improves the clarity and understanding of the TS requirements for each control room habitability system.

The proposed changes are separated into four numbered groups wherein change number 1 (group 1) the licensee is proposing a change that will add a new TS for BVPS-1 that will be titled Control Room Emergency Air Cooling System (CREACS) and numbered 3/4.7.6.

Previously, BVPS-1 TS 3/4.7.6 had been deleted by Amendment Nos. 246 and 247. The new TS for the CREACS will be inserted into the unused TS (3/4.7.6) space. This change includes reorganizing the control room habitability TSs into two separate TSs consistent with the ISTS.

The new TSs will add Limiting Condition for Operation (LCO), Applicability, Action and SR criteria for CREACS. The new CREACS TS replaces the control room air temperature requirements that are part of the existing Control Room Habitability TS (3/4.7.7). This includes BVPS-1 LCO 3.7.7.1.c, Action c, Action c.1", SR 4.7.7.1.1.a, and BVPS-2 SR 4.7.7.1.a which are replaced by the adoption of a new TS 3/4.7.6 for the CREACS. The TS title of 3/4.7.7.1 (BVPS-1) and 3/4.7.7 (BVPS-2) will be revised to Control Room Emergency Ventilation Systems (CREVS). This change will make the BVPS-1 CREVS TS number 3/4.7.7.1, which will be similar to BVPS-2 CREVS TS number 3/4.7.7.

The licensee stated that the air cooling portion of the BVPS-1 and 2 control room habitability systems will be addressed by its own separate TSs, and that this is consistent with ISTS 3.7.11.

Current BVPS-1 TS LCO 3.7.7.1.c and current BVPS-2 SR 4.7.7.1.a specify a requirement to verify that the control room temperature is #88 EF. The licensee also stated that the specified temperature of 88 EF does not represent a design limit and was chosen for inclusion in the original TS arbitrarily to provide a positive indication that the control room air conditioning system was functioning. The design basis of the emergency cooling coils in the CREACS is to maintain the control room air temperature #120 EF. Additionally, the licensee stated, and the NRC staff acknowledges, that the emergency cooling coils are not normally in service, and that verification of the control room air temperature does not provide an adequate verification of the heat removal capacity of the emergency cooling coils. To address this issue, the licensees proposed change includes removing BVPS-1 LCO 3.7.7.1.c and BVPS-2 SR 4.7.7.1.a and adding BVPS-1 and 2 SR 4.7.6.1 to verify the heat removal capacity of the CREACS every 18 months using the emergency cooling coils. The NRC staff has determined that an 18-month surveillance interval is reasonable and adequate to verify operability of this system, therefore, the staff finds this acceptable.

In addition, the licensee stated that the proposed LCO requires two trains of CREACS to be operable. The BVPS-1 and 2 main control rooms share a common area and a common enclosed environment when the control rooms are isolated from the outside atmosphere. The CREACS TS only addresses heat removal. Each train of the BVPS-1 and 2 CREACS must be capable of removing sufficient heat to maintain the temperature on its side of the control room.

Although the BVPS-1 and 2 CREACS arrangements are slightly different, each units CREACS

will circulate air across redundant heat exchangers cooled by river water at BVPS-1 and service water at BVPS-2. Since each units CREACS only circulates air on its respective side of the control room, neither units CREACS required train can be used to ensure sufficient temperature control of the other units side of the control room.

Based upon the NRC staffs review and assessment of the information provided by the licensee in its letter dated February 17, 2005, the staff finds this proposed change (group 1) acceptable because no physical plant modifications are involved, and as stated by the licensee, the proposed changes provide two separate TSs consistent with the ISTS, provide more system-specific requirements for each control room habitability system, improve clarity (and thereby enhance safety), and are consistent with the current licensing and design basis.

In change number 2 (group 2), the requested change addresses the revision of the BVPS-1 Applicability requirements for the control room habitability TS (proposed new CREVS TS) and associated control room radiation monitors to address fuel movement involving only recently irradiated fuel instead of fuel movement involving any irradiated fuel. This change does not affect BVPS-2 because the current corresponding BVPS-2 Applicability (for CREVS and the associated control room radiation monitors) already addresses fuel movement involving recently irradiated fuel. The change includes the following:

BVPS-1 TS 3.3.3.1, Radiation Monitoring, Table 3.3.6 Notation (4), Action 41, in Table 3.3-6 and Table 4.3-3 footnote ## have been revised to address only recently irradiated fuel assemblies.

BVPS-1 TS 3.7.7.1, Control Room Emergency Habitability Systems, (proposed BVPS-1 3.7.7, CREVS) Applicability has been revised to address only recently irradiated fuel assemblies.

BVPS-1 TS 3.7.7 Action b has been clarified to apply to recently irradiated fuel assemblies.

The licensee stated that the changes proposed in this request include the separation of the CREVS and CREACS into two different TSs. Since the CREACS may be used to satisfy the BVPS-1 fuel-handling accident (FHA) radiological safety analysis assumption of a control room atmosphere purge following an FHA involving non-recently irradiated fuel, the proposed Applicability of the new BVPS-1 CREACS TS addresses fuel movement involving recently irradiated and non-recently irradiated fuel. However, the isolation and pressurization functions of the CREVS (and associated radiation monitors) are not required to satisfy the BVPS-1 FHA safety analysis assumptions to limit the radiological dose from an FHA involving non-recently irradiated fuel. Therefore, the Applicability of the new separate CREVS TS (and associated control room radiation monitors) is revised to no longer require CREVS during fuel movement involving non-recently irradiated fuel. The Applicability of the proposed new BVPS-1 CREVS TS and associated control room radiation monitors will continue to require system and component operability during Modes 1-4 and for fuel movement involving recently irradiated fuel.

The licensee also stated, and the NRC staff agrees, that the proposed change to the BVPS-1 applicability for CREVS and the control room radiation monitors makes these BVPS-1 TS

requirements consistent with the current corresponding BVPS-2 TS requirements. The corresponding BVPS-2 TS 3/4.7.7 Applicability (and the Applicability for the BVPS-2 control room radiation monitors) were previously revised to only address fuel movement involving recently irradiated fuel in BVPS-2 Amendment No. 121, dated August 30, 2001 (ADAMS Accession No. ML012330496). The licensee stated that the basis for the acceptability of the BVPS-2 change that incorporated recently irradiated fuel in the Applicability of TS 3/4.7.7 (and the Applicability for BVPS-2 control room radiation monitors) as discussed in the NRC safety evaluation (SE) associated with Amendment No. 121, is now applicable to the corresponding BVPS-1 requirements.

Section 2.2.1 [adding the term recently irradiated fuel to various TS Sections] of the NRC staffs SE for Amendment No. 121 states, in part, the following; The term recently is added to Applicability and requirements preceding the word irradiated in the proposed changes for several TSs. The term recently when used in this context represents the decay period for the reduction of radionuclide inventory available for release in the event of an FHA. The licensee has determined that the calculated dose consequences resulting from a design-basis FHA will not exceed 10 CFR 50.67 dose limitations after a (specified) decay period of 100 hours4.167 days <br />0.595 weeks <br />0.137 months <br />. This change is consistent with NRC-approved Technical Specification Task Force Traveler form 51 (TSTF-51), Revision 2, to NUREG-1431, Standard Technical Specifications - Westinghouse Plants, which was approved on October 15, 1999." Because of this statement and other applicable parts of the staffs SE for Amendment No. 121 that provided the basis for the acceptability of the BVPS-2 change that incorporated recently in the applicability of TS 3/4.7.7, the staff finds requested change number 2 (group 2) acceptable.

With respect to change number 3 (group 3), the licensee addressed the category of changes necessary to make the existing BVPS-1 and 2 TS requirements for CREVS as consistent as possible between the units and as consistent as possible with the corresponding ISTS requirement, ISTS 3.7.10, Control Room Emergency Filtration System, however, because of format considerations, the ISTS requirements are revised as necessary to integrate uniformly with the existing BVPS TS format and presentation. BVPS does not have a Ventilation Filter Test Program like the ISTS to simplify the presentation of SRs. Therefore, the current BVPS-1 and 2 SRs for filter testing are retained in the proposed CREVS TS. The list of changes that fall into this category are:

1. The LCO is changed to require two CREVS trains operable.

2. BVPS-1 and 2 LCOs 3.7.7.1.a/b are being deleted and the details on individual component operability are being relocated to the TS Bases. This relocation includes the footnote ** contents pertaining to automatic actuation on CIB.

3. A Note is added to the LCO to allow the control room boundary to be open intermittently under administrative control.

4. BVPS-1 LCO 3.7.7.1,

• footnote to the LCO : the phrase train of dampers is replaced with CREVS train.

5. BVPS-2 LCO 3.7.7,

• footnote to the LCO: the phrase train of dampers and fans of the pressurization filtration unit is replaced with CREVS train. This footnote is also moved to modify the word OPERABLE in the proposed LCO wording.

6. A new Action a.2 is added to address an inoperable control room boundary. A new action statement a.3 is added to provide guidance when two required CREVS trains are inoperable for reasons other than those specified in proposed Action a.2.

7. BVPS-1 LCO 3.7.7.1, action a is revised and becomes proposed action a.1" and is placed under a new action header titled MODES 1, 2, 3 and 4: The current action a is additionally modified by replacing the words less than two emergency ventilation subsystems, fans, and associated filters OPERABLE, restore at least two subsystems with the words one required CREVS train inoperable, restore the CREVS train...

8. BVPS-2 LCO 3.7.7, action under the header MODES 1, 2, 3 and 4" is revised and becomes proposed action a.1". The words required CREVS are added to modify the word train. The words of the pressurization filtration Unit or one of two isolation dampers in series are deleted. The word system is replaced with CREVS train. The words at least are deleted.

9. BVPS-1 LCO 3.7.7.1, current action b. and b.1 are replaced by simplified actions a.1, b.1, and b.2. The current action a.1 is deleted.

10. BVPS-2 LCO 3.7.7, current actions a and b, under movement of recently irradiated fuel, are simplified to address one required CREVS train being inoperable or two required CREVS trains being inoperable when performing fuel movement involving recently irradiated fuel assemblies. The details on individual component inoperability are deleted. These two actions are modified to require immediate suspension of fuel assembly movement. Proposed action b.1 is also modified to allow plant operation beyond 7 days if the remaining CREVS train is placed in the emergency pressurization mode of operation.

11. BVPS-1 SR 4.7.7.1.1: the phrase emergency ventilation subsystem is replaced with CREVS.

12. BVPS-2 SR 4.7.7.1: the words Control Room Emergency Air Cleanup and Pressurization System are replaced with CREVS.

13. BVPS-1 SR 4.7.7.1.1.b: the phrase initiating flow through the HEPA filter and charcoal adsorber train and is replaced with verifying that the CREVS train operates. The words with the heaters in operation are added following the words 15 minutes. The symbol for greater than are equal to is added prior to 15 minutes.

14. BVPS-2 SR 4.7.7.1.b: the phrase initiating flow through the HEPA filter and charcoal adsorber train and is replaced with verifying that each CREVS train operates.

15. BVPS-2 SR 4.7.7.1.c.1: the phrase the pressurization filtration system is replaced with each CREVS train. The charcoal adsorber efficiency testing requirements are clarified

to require a penetration and bypass leakage acceptance criteria of less than 0.05 percent rather than removal capability of greater than or equal to 99.5 percent.

16. BVPS-2 SR 4.7.7.1.c.2: the phrase the pressurization filtration system is replaced with each CREVS train. The HEPA filter efficiency testing requirements are clarified to require a penetration and bypass leakage acceptance criteria of less than 0.05 percent rather than removal capability of greater than or equal to 99.5 percent.

17. BVPS-1 SR 4.7.7.1.1.c.1: the phrase the ventilation system is replaced with the CREVS train.

18. BVPS-1 SR 4.7.7.1.1.c.3: the word system is replaced with of the CREVS train.

19. BVPS-2 SR 4.7.7.1.c.3: the word system is replaced with of each CREVS train.

20. BVPS-1 SR 4.7.7.1.1.d.1: the phrase the ventilation system is replaced with the CREVS train.

21. BVPS-2 SR 4.7.7.1.e.1: the phrase the pressurization filtration system is replaced with each CREVS train.

22. BVPS-1 SR 4.7.7.1.1.d.2 (BVPS-2 SR 4.7.7.1.e.2) that requires verification of automatic train actuation is revised to state only that each CREVS train actuates on a simulated or actual actuation signal without reference to the specific actuation signal or without reference to specific component movements (consistent with the ISTS). The details on specific component actuation and actuation signals are moved to the TS Bases.

23. BVPS-1 SR 4.7.7.1.1.d.3 phrase one emergency ventilation subsystem is replaced with each CREVS train. The surveillance interval is revised to 36 months on a STAGGERED TEST BASIS. Also, the word system is deleted and the words at a flow rate of 800 - 1000 cfm are added following the word operation. As the test frequency is changed to 36 months on a staggered basis, the SR is moved to SR 4.7.7.1.e.

24. BVPS-2 SR 4.7.7.1.e.4 phrase the pressurization filtration is replaced with each CREVS train. The surveillance interval is revised to 36 months on a STAGGERED TEST BASIS. Also, the word system is deleted and the words at a flow rate of 800 -

1000 cfm are added following the word operation. As the test frequency is changed to 36 months on a staggered basis, the SR is moved to SR 4.7.7.1.f.

25. Various information in the existing BVPS-1 and 2 TSs are relocated to the expanded TS Bases to implement the changes described above and to make the scope and content of the proposed CREVS TSs more consistent with the corresponding ISTS 3.7.10.

The licensee stated that these proposed changes that replace the more detailed current TS requirements with CREVS train are acceptable because they do not eliminate any prior requirements, and, in some cases, may impose additional requirements due to the enlarged scope implicit by referencing the whole CREVS train, rather than explicitly described certain components within the train. The NRC staff agrees with this assessment and finds that these

requested changes (group 3) do not change the intent of the TSs and are substantially editorial changes. Those changes that are not clearly or completely editorial (such as item 3) have been found acceptable because the proposed changes clarified or simplified an existing TS or have been determined to be consistent with the ISTS which have been reviewed and found acceptable by the staff. In all cases, the requested changes have been found consistent with the BVPS current licensing bases.

In change number 4 (group 4), the licensee addresses BVPS-1 TS SR 4.7.7.1.2 which is replaced in its entirety by a requirement to comply with the applicable BVPS-2 SR (4.7.7.1).

The current BVPS-1 TSs can credit any two of the three available BVPS-1 or 2 CREVS trains to meet the current BVPS-1 LCO 3.7.7.1. The current BVPS-2 TSs credit the two CREVS trains associated with the BVPS-2 side of the common control room to meet the BVPS-2 LCO 3.7.7.

The current BVPS-1 SR 4.7.7.1.2 addresses the operability of the BVPS-2 CREVS trains. The current BVPS-1 SR 4.7.7.1.2 reiterated the criteria within the BVPS-2 TS SR 4.7.7.1. For consistency between the units, the BVPS-1 SR is revised to reference the BVPS-2 TS SR 4.7.7.1 to ensure that the same surveillance criteria are applied to the BVPS-2 CREVS trains.

The proposed change is acceptable because the change continues to assure that the BVPS-2 CREVS are adequately tested to demonstrate operability. The proposed change continues to maintain a reference within the BVPS-1 TSs that requires compliance with the appropriate BVPS-2 surveillances. The proposed BVPS-1 requirement continues to ensure that the required surveillances will be performed on BVPS-2 components when the BVPS-2 CREVS is credited by BVPS-1 to meet the BVPS-1 LCO.

Based on this analyses by the licensee, it is the NRC staffs finding that this change will maintain a reference in the BVPS-1 TSs that will require BVPS-1 to comply with BVPS-2 SR 4.7.7.1, and that this reference will ensure that the required CREVS surveillances will be performed on both BVPS-1 and 2.

By letter dated August 22, 2006, the licensee provided a supplement to their application dated February 17, 2005, to further clarify the intent of the requested change to apply to recently irradiated fuel and to clarify the charcoal adsorber and HEPA filter efficiency requirements to require a penetration and bypass leakage acceptance criteria of less than 0.05 percent rather than removal capability of greater than or equal to 99.5 percent. The NRC staff has determined that the requested supplemental change does not change the way the surveillance is to be conducted at either BVPS-1 or 2, and it does not change the intent of the SRs. Therefore, the NRC staff finds that this is an editorial change and is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. 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 change 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding (70 FR 21458). 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.

Principal Contributor: H. Walker Date: September 25, 2006