ML082730261

Issuance of Amendment Regarding Control Room Envelope Habitability

ML082730261
Person / Time
Site:	Watts Bar
Issue date:	10/08/2008
From:	Lamb J G Division of Operating Reactor Licensing
To:	Campbell W R Tennessee Valley Authority
Lamb John G./NRR/DORL, 415-3100
Shared Package
ML082730231	List: ML082730261
References
TAC MD7474
Download: ML082730261 (20)

Text

October 8, 2008

Mr. William R. Campbell, Jr.

Chief Nuclear Officer and

Executive Vice President Tennessee Valley Authority

6A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

SUBJECT:

WATTS BAR NUCLEAR PLANT, UNIT 1 C ISSUANCE OF AMENDMENT REGARDING CONTROL ROOM ENVELOPE HABITABILITY (TAC NO. MD7474)

Dear Mr. Campbell:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 70

to Facility Operating License No. NPF-90 for Watts Bar Nuclear Plant, Unit 1. This amendment

is in response to your application dated October 26, 2007 (ML073380948).

The amendment revises the Technical Specifications (TS) to adopt TS Task Force (TSTF)

Change Traveler TSTF-448, Revision 3, "Control Room Envelope Habitability." This technical

specification improvement was made avail able by the NRC on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process.

A copy of the safety evaluation is also enclosed. Notice of issuance will be included in the

Commission's biweekly Federal Register notice.

Sincerely, /RA/

John G. Lamb, Senior Project Manager Watts Bar Special Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-390

Enclosures:

1. Amendment No. 70 to NPF-90

2. Safety Evaluation

cc w/enclosures: See next page

ML082730261 PKG:M L082730231 TS:ML082730277 *via memorandum OFFICE LPWB/PM LPWB/LA ITSB/BC OGC - NLO LPWB/BC NAME JLamb BClayton RElliott* DRoth LRagahavan DATE 09 / 25 /2008 10 / 02 /2008 08/ 22 /2008 10/ 03 /2008 10/8/2008

William R. Campbell, Jr. Tennessee Valley Authority WATTS BAR NUCLEAR PLANT cc: Mr. Gordon P. Arent

New Generation Licensing Manager

Tennessee Valley Authority

5A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Mr. Ashok S. Bhatnagar

Senior Vice President

Nuclear Generation Development

and Construction

Tennessee Valley Authority

6A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Vice President

Nuclear Support

Tennessee Valley Authority

3R Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Mr. H. Rick Rogers

Vice President

Nuclear Engineering & Technical Services

Tennessee Valley Authority

3R Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

General Counsel

Tennessee Valley Authority

6A West Tower

400 West Summit Hill Drive

Knoxville, TN 37902

Mr. John C. Fornicola, Manager

Nuclear Assurance

Tennessee Valley Authority

3R Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Mr. Larry E. Nicholson, General Manager

Performance Improvement

Tennessee Valley Authority

3R Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Mr. Michael D. Skaggs

Site Vice President

Watts Bar Nuclear Plant

Tennessee Valley Authority

P. O. Box 2000

Spring City, TN 37381 Mr. Michael A. Purcell

Senior Licensing Manager

Nuclear Power Group

Tennessee Valley Authority 4X Blue Ridge

1101 Market Street

Chattanooga, TN 37402-2801

Ms. Beth A. Wetzel, Manager

Corporate Nuclear Licensing and

Industry Affairs

Tennessee Valley Authority 4X Blue Ridge

1101 Market Street

Chattanooga, TN 37402-2801

Mr. Masoud Bajestani, Vice President

Watts Bar Unit 2

Watts Bar Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Spring City, TN 37381

Mr. Michael K. Brandon, Manager

Licensing and Industry Affairs

Watts Bar Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Spring City, TN 37381

Mr. Michael J. Lorek, Plant Manager

Watts Bar Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Spring City, TN 37381

Senior Resident Inspector

Watts Bar Nuclear Plant

U.S. Nuclear Regulatory Commission

1260 Nuclear Plant Road

Spring City, TN 37381

County Executive

375 Church Street Suite 215 Dayton, TN 37321

County Mayor

P. O. Box 156

Decatur, TN 37322 Mr. Lawrence E. Nanney, Director

Division of Radiological Health

Dept. of Environment & Conservation

Third Floor, L and C Annex

401 Church Street

Nashville, TN 37243-1532

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-390 WATTS BAR NUCLEAR PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE

Amendment No. 70 License No. NPF-90

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

A. The application for amendment by Tennessee Valley Authority (the licensee) dated October 26, 2007, complies with the standards and requirements of the

Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules

and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the

public, and (ii) that such activities will be conducted in compliance with the

Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility

Operating License No. NPF-90 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendices A and B, as revised

through Amendment No. 70, and the Environmental Protection Plan contained in

Appendix B, both of which are attached hereto, are hereby incorporated into this

license. TVA 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 no later than 60 days from the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/ L. Raghavan, Chief Watts Bar Special Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and

Technical Specifications

Date of Issuance: October 8, 2008

ATTACHMENT TO AMENDMENT NO. 70 FACILITY OPERATING LICENSE NO. NPF-90 DOCKET NO. 50-390

Replace Page 3 of Operating License NPF-90 with the attached Page 3.

Replace the following pages of the Appendix A Technical Specifications with the attached

pages. The revised pages are identified by amendment number and contain vertical lines

indicating the area of change.

Remove Pages Insert Pages

3.7-22 3.7-22 3.7-23 3.7-23 3.7-24 3.7-24 5.0-25 5.0-25 - 5.0-25a

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 70 TO FACILITY OPERATING LICENSE NO. NPF-90 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-390

1.0 INTRODUCTION

By letter dated October 26, 2007 (ML073380948), the Tennessee Valley Authority (TVA or the

licensee), submitted a request for changes to the Watts Bar Nuclear Plant (WBN), Unit 1, Technical Specifications (TSs). The requested changes would modify TS requirements related

to control room envelope habitability in accordance with Technical Specifications Task Force (TSTF) Revision 3, "Control Room Envelope Habitability." The staff's proposed no significant

hazards consideration determination was published in the Federal Register on August 29, 2008 (73 FR 51014).

On August 8, 2006, the commercial nuclear electrical power generation industry owners group

TSTF submitted a proposed change, TSTF-448, Revision 3, to the improved standard technical

specifications (STSs) (NUREGs 1430-1434) on behalf of the industry (TSTF-448, Revisions 0, 1, and 2 were prior draft iterations). TSTF-448, Revision 3, is a proposal to establish effective

and appropriate action, surveillance, and administrative STS requirements related to ensuring

the habitability of the control room envelope (CRE).

In NRC Generic Letter (GL) 2003-01,"Control Room Habitability," dated June 12, 2003 (ML031620248), licensees were alerted to findings at facilities that existing TS surveillance

requirements (SRs) for the Control Room En velope Emergency Ventilation System (CREEVS) may not be adequate. Specifically, the results of American Society for Testing and Materials (ASTM) E741, "Standard Test Method for Determining Air Change in a Single Zone by Means of

a Tracer Gas Dilution," 2000, tracer gas tests to measure CRE unfiltered inleakage at facilities

indicated that the differential pressure surveillance is not a reliable method for demonstrating

CRE boundary operability. Licensees were requested to address existing TS as follows:

Provide confirmation that your technical specifications verify the integrity [i.e.,

operability] of the CRE [boundary], and the assumed [unfiltered] inleakage rates

of potentially contaminated air. If you currently have a differential pressure surveillance requirement to demonstrate CRE [boundary] integrity, provide the

basis for your conclusion that it remains adequate to demonstrate CRE integrity

in light of the ASTM E741 testing results. If you conclude that your differential

pressure surveillance requirement is no longer adequate, provide a schedule for:

1) revising the surveillance requirement in your technical specification to

reference an acceptable surveillance methodology (e.g., ASTM E741), and

2) making any necessary modifications to your CRE boundary so that

compliance with your new surveillance requirement can be demonstrated.

If your facility does not currently have a technical specification surveillance requirement for your CRE integrity, explain how and at what frequency you

confirm your CRE integrity and why this is adequate to demonstrate CRE integrity.

To promote standardization and to minimize the resources that would be needed to create and

process plant-specific amendment applications in response to the concerns described in the

GL, the industry and the NRC proposed revisions to CRE habitability system requirements

contained in the STSs, using the STS change traveler process. This effort culminated in

Revision 3 to traveler TSTF 448, "Control Room Habitability," which the U.S. Nuclear Regulatory

Commission (NRC) staff approved on January 17, 2007.

Consistent with the traveler as incorporated into NUREG 1431, the licensee proposed revising

action and SRs in Specification 3.7.10, "C ontrol Room Emergency Ventilation System (CREVS)," and adding a new administrative controls program, Specification 5.2.7.20, "Control Room Envelope Habitability Program." The purpose of the changes is to ensure that CRE

boundary operability is maintained and verified through effective surveillance and programmatic

requirements, and that appropriate remedial actions are taken in the event of an inoperable

CRE boundary.

Some editorial and plant-specific changes were incorporated into this safety evaluation resulting

in minor deviations from the model safety evaluation text in TSTF-448, Revision 3.

2.0 REGULATORY EVALUATION

2.1 Control

Room and Control Room Envelope NRC Regulatory Guide 1.196, "Control Room Habitability at Light-water Nuclear Power

Reactors," Revision 0, May 2003 (ML031490611), uses the term "control room envelope" in

addition to the term "control room" and defines each term as follows:

Control Room: The plant area, defined in the facility licensing basis, in which actions can be taken to operate the plant safely under normal conditions and to maintain the reactor in a safe condition during accident situations. It encompasses the instrumentation and controls necessary for a safe shutdown of the plant and typically includes the critical document reference file, computer room (if used as an integral part of the emergency response plan), shift supervisor's office, operator wash room and kitchen, and other critical areas to which frequent personnel access or continuous occupancy may be necessary in

the event of an accident.

Control Room Envelope: The plant area, defined in the facility licensing basis, that in the event of an emergency, can be isolated from the plant areas and the environment external to the CRE. This area is served by an emergency ventilation system, with the intent of maintaining the habitability of the control room. This area encompasses the control room, and may encompass other

non-critical areas to which frequent personnel access or continuous occupancy is

not necessary in the event of an accident.

NRC Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear

Power Reactors," Revision 0, May 2003 (ML031490664), also contains these definitions, but

uses the term CRE to mean both. This is because the protected environment provided for operators varies with the nuclear power facility. At some facilities this environment is limited to the control room; at others, it is the CRE. In this safety evaluation, consistent with the proposed

changes to the 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 Emergency Ventilation System (CREVS)

The CREVS (the term used at WBN, Unit 1 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 CREVS is designed to maintain a habitable environment in the CRE for 30 days of

continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem total

effective dose equivalent (TEDE).

The CREVS consists of two independent, redundant trains, each capable of maintaining the

habitability of the CRE. Each CREVS train is considered operable when the individual

components necessary to limit CRE occupant exposure are operable. A CREVS train is

considered operable when the associated:

$ Fan is operable;

$ High efficiency particulate air (HEPA) filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration

functions;

$ Ductwork, valves, and dampers are operable, and air circulation can be maintained; and

$ CRE boundary is operable (the single boundary supports both trains).

The CRE boundary is considered operable when the measured unfiltered air inleakage is less

than or equal to the inleakage value assumed by the licensing basis analyses of design basis

accident consequences to CRE occupants.

2.3 Regulations

Applicable to Control Room Habitability In Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," General Design Criteria (GDC) 1, 2, 3, 4, 5, and 19 apply to CRE habitability. 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, A 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 Desi gn Bases," requires SSCs important to safety to be designed to accommodate the effects of and to be compatible with the environmental

conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents (LOCAs).

GDC 5, "Sharing of Structures, Systems, and Components," requires that SSCs important to safety not be shared among nuclear power units unless it can be shown that such sharing will

not significantly impair their ability to perform their safety functions, including, in the event of an

accident in one unit, the orderly shutdown and cooldown of the remaining units.

GDC 19, "Control Room," requires that a contro l room be provided from which actions can be taken to operate the nuclear reactor safely under normal conditions and to maintain the reactor

in a safe condition under accident conditions, including a LOCA. Adequate radiation protection

is to be provided to permit access and occupancy of the control room under accident conditions

without personnel receiving radiation exposures in excess of specified values.

Prior to incorporation of TSTF-448, Revision 3, the STS requirements addressing CRE

boundary operability resided only in the following CRE ventilation system specifications:

$ NUREG-1431, TS 3.7.10, "Control Room Emergency Filtration System (CREFS)."

In these specifications, 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

obtain differential pressure and flow meas urements satisfying the SR limits 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," (AL 98-10) states that "the discovery of an improper or

inadequate TS value or required action is considered a degraded or nonconforming condition,"

which is defined in NRC Inspection Manual Chapter 9900; see latest guidance in Regulatory

Issue Summary (RIS) 2005-20 (ML073440103).

A Imposing administrative controls in response to an improper or inadequate TS is considered an acceptable short-term corrective action. The NRC staff expects that, following the imposition of administrative controls, 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 implem ented 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(d)(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(d)(2), for the condition of not meeting the limiting condition for operation (LCO)

due to an inoperable CRE boundary. The action requirements should specify a reasonable

completion time to restore conformance to the LCO before requiring a facility to be shut down.

This completion time should be based on the benefits of implementing mitigating actions to

ensure CRE occupant safety and sufficient time to resolve most problems anticipated with the

CRE boundary, while minimizing the chance that operators in the CRE will need to use

mitigating actions during accident conditions.

2.4 Adoption

of TSTF-448 Revision 3 Adoption of TSTF-448, Revision 3, will assure that a facility's TS LCO for the CREVS is met by

demonstrating unfiltered leakage into the CRE is within limits (i.e., the operability of the CRE

boundary). In support of this surveillance, which specifies a test interval (frequency) described

in Regulatory Guide 1.197, TSTF-448 also adds TS administrative controls to assure the

habitability of the CRE between performances of the ASTM E741 test. In addition, adoption of

TSTF-448 will establish clearly stated and reasonable required actions in the event CRE

unfiltered inleakage is found to exceed the analysis assumption.

The changes made by TSTF-448 to the STS requirements for the CREVS and the CRE

boundary conform to 10 CFR 50.36(d)(2) and 10 CFR 50.36(d)(3). Their adoption will assure

that a plant's CRE will remain habitable during normal operation and DBA 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, Revision 3, which the NRC staff has found to satisfy applicable regulatory

requirements, as described above in Section 2.0. The emergency operational mode of the

CREVS at the WBN, Unit 1 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 Emergency Ventilati on System" and adding a new TS administrative controls program on CRE habitability. Accompanying the proposed TS changes are appropriate

conforming technical changes to the TS Bases. The proposed revision to the Bases also

includes editorial and administrative changes to reflect applicable changes to the corresponding

STS Bases, which were made to improve clarity, conform with the latest information and

references, correct factual errors, and achi eve more consistency among the STS NUREGs.

Except for plant-specific differences, all of thes e changes are consistent with STSs as revised by TSTF-448, Revision 3. The NRC staff compared the proposed TS changes to the STSs and the STS markups and evaluations in TSTF-448. The staff verified that differences from the

STSs were adequately justified on the basis of plant-specific design or retention of current

licensing basis. The NRC staff also reviewed the proposed changes to the TS Bases for

consistency with the STS Bases and the plant-specific design and licensing bases, although

approval of the Bases is not a condition for accepting the proposed amendment. However, TS 5.6, "Technical Specifications Bases Control Program," provides assurance that the licensee

has established and will maintain the adequacy of the Bases. The proposed Bases for TS 3.7.10 refer to specific guidance in Nuclear Energy Institute document NEI 99-03, "Control

Room Habitability Assessment Guidance," Revision 0, dated June 2001, which the NRC staff

has formally endorsed, with exceptions, through Regulatory Guide 1.196, A Control Room Habitability at Light-Water Nuclear Power Reactors,@ dated May 2003 (ML031490611).

3.2 Editorial

Changes

The licensee proposed editorial changes to TS 3.7.10, "Control Room Emergency Ventilation

System," to establish standard terminology, such as "control room envelope (CRE)" in place of "control room," except for the plant-specific name for the CREEVS (CREVS), and "radiological, chemical, and smoke hazards" in place of various phrases to describe the hazards that CRE

occupants are protected from by the CREVS. These changes improve the usability and quality

of the presentation of the TS, have no adverse impact on safety, and therefore, are acceptable.

3.3 TS 3.7.10, "Control Room Emergency Ventilation System"

The licensee proposed to revise the action requirements of TS 3.7.10, "Control Room

Emergency Ventilation System," to acknowledge that an inoperable CRE boundary, depending

upon the location of the associated degradation, could cause just one, instead of both CREVS

trains to be inoperable. This is accomplished by revising Condition A to exclude Condition B, and revising Condition B to address one or more CREVS trains, as follows:

o Condition A One required CREVS train inoperable for reasons other than Condition B.

o Condition B One or more CREVS 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 CREVS 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 B.2 requires the licensee to verify, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that

in the event of a DBA, CRE occupant radiological exposures will not exceed the calculated dose

of the licensing basis analyses of DBA cons equences, CRE occupant exposure to chemical hazards will not exceed limits, and that CRE o ccupants are protected from smoke hazards. New Required Action B.3 requires the licensee to restore CRE boundary to operable status within

90 days.

The 24-hour Completion Time of new Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions as

directed by Required Action B.1. The 90-day Completion Time of new Required Action B.3 is

reasonable based on the determination that the mitigating actions will ensure protection of CRE

occupants within analyzed limits while limiting the probability that CRE occupants will have to

implement protective measures that may adversely affect their ability to control the reactor and

maintain it in a safe shutdown condition in the event of a DBA. The 90-day Completion Time is

a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems

with the CRE boundary. Therefore, proposed Actions B.1, B.2, and B.3 are acceptable.

To distinguish new Condition B from the existing condition for two CREVS trains inoperable, Condition F (renumbered as Condition G), is revised to state, "Two CREVS trains inoperable

during MODE 1, 2, 3, or 4 for reasons other than Condition B or E." The changes to existing

Condition F are less restrictive because these Conditions will no longer apply in the event one

or two CREVS trains are inoperable due to an inoperable CRE boundary during unit operation in

Mode 1, 2, 3, or 4. This is acceptable because the new Action B establishes adequate remedial

measures in this condition. With the addition of a new Condition B, existing Condition B, C, D, E, and F are re-designated C, D, E, F, and G, respectively.

The licensee also proposed to modify the CREVS LCO by adding a NOTE allowing the CRE

boundary to be opened intermittently under administrative controls. As stated in the LCO

Bases, this NOTE only applies to openings in the CRE boundary that can be rapidly restored to

the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit

through doors, the administrative controls of t he opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of

stationing a dedicated individual at the opening who is in continuous communication with

operators in the CRE. This individual will have a method to rapidly close the opening and to

restore the CRE boundary to a condition equivalent to the design condition when a need for

CRE isolation is indicated." The allowance of this NOTE is acceptable because the

administrative controls will ensure that the opening will be quickly sealed to maintain the validity

of the licensing basis analyses of DBA consequences.

The licensee proposed to add a new condition to Action E (renumbered as Condition F) of

TS 3.7.10 that states, "One or more CREVS 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 CREVS 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

". 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 Modes 5 and 6 and during

refueling. Therefore, this change is administrative and acceptable.

In the emergency mode of operation, the CREVS isolates unfiltered ventilation air supply

intakes, filters the emergency ventilation air supply to the CRE, and pressurizes the CRE to

minimize unfiltered air inleakage past the CRE boundary. The licensee proposed to delete the

CRE pressurization SR. This SR requires verifying that one CREVS train, operating in the

emergency mode, can maintain a pressure of 0.125 inches water gauge, relative to the outside atmosphere and adjacent areas during the pressurization mode of operation at a makeup flow rate of 711cfm and a recirculation flow rate 2960 and 3618 cfm. The deletion of this SR is proposed because measurements of unfiltered air leakage into the CRE at numerous reactor facilities demonstrated that a basic assumption of this SR, an essentially leak-tight CRE

boundary, was incorrect for most facilities. Hence, meeting this SR by achieving the required

CRE pressure is not necessarily a conclusive indication of CRE boundary leak tightness (i.e., CRE boundary operability). In its response to GL 2003-01, the licensee reported in a letter

dated August 4, 2004 (ML042230173) that it had determined the WBN CRE pressurization

surveillance, SR 3.7.10.4, was not adequate to demonstrate the operability of the CRE

boundary, and proposed to replace it with an inleakage measurement SR and a CRE

Habitability Program in TS Section 5.2.7.20, in accordance with the approved version of

TSTF-448. Based on the adoption of TSTF-448, Revision 3, the licensee's proposal to delete

SR 3.7.10.4 is acceptable.

The proposed CRE inleakage measurement SR states, "Perform required CRE unfiltered air

inleakage testing in accordance with the Control Room Habitability Program." The CRE

Habitability Program TS, proposed TS 5.2.7.20, 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 Regulatory Guide 1.197, Revision 0 (ML031490664). 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 5.5.14, "Control Room Envelope Habitability Program"

The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Revision 3. In combination with SR 3.7.10.4, this program is intended to ensure the

operability of the CRE boundary, which as part of an operable CREVS will ensure that CRE

habitability is maintained such that CRE occupants can control the reactor safely under normal

conditions and maintain it in a safe condition following a radiological event, hazardous chemical

release, or a smoke challenge. The program shall ensure that adequate radiation protection is

provided to permit access and occupancy of the CRE under DBA conditions without personnel

receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident.

A CRE Habitability Program TS acceptable to the NRC staff requires the program to contain the

following elements:

Definitions of CRE and CRE boundary.

This element is intended to ensure that these definitions accurately describe the plant

areas that are within the CRE, and also the interfaces that form the CRE boundary, and

are consistent with the general definitions discussed in Section 2.1 of this safety

evaluation. Establishing what is meant by the CRE and the CRE boundary will preclude

ambiguity in the implementation of the program.

Configuration control and preventive maintenance of the CRE boundary.

This element is intended to ensure the CRE boundary is maintained in its design condition. Guidance for implementing this element is contained in Regulatory

Guide 1.196, which endorsed, with exceptions, NEI 99-03, Rev. 0. Maintaining the CRE boundary in its design condition provides assurance that its leak-tightness will not significantly degrade between CRE inleakage determinations. Assessment of CRE habitability at the frequencies stated in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0, and measurement of unfiltered air leakage into the CRE in accordance with the testing methods and at the frequencies stated in Sections C.1 and C.2 of Regulatory

Guide 1.197.

This element is intended to ensure that the plant assesses CRE habitability consistent

with Sections C.1 and C.2 of Regulatory Guide 1.197. Assessing CRE habitability at the

NRC accepted frequencies provides assurance that significant degradation of the CRE

boundary will not go undetected between CRE inleakage determinations. Determination

of CRE inleakage using test methods acceptable to the NRC staff assures that test

results are reliable for ascertaining CRE boundary operability. Determination of CRE

inleakage at the NRC accepted frequencies provides assurance that significant

degradation of the CRE boundary will not occur between CRE inleakage determinations.

Measurement of CRE pressure with respect to all areas adjacent to the CRE boundary at designated locations for use in assessing the CRE boundary at a frequency of 18 months on a

staggered test basis (with respect to the CREVS trains).

This element is intended to ensure that CRE differential pressure is regularly measured

to identify changes in pressure warranting evaluation of the condition of the CRE

boundary. Obtaining and trending pressure data provides additional assurance that

significant degradation of the CRE boundary will not go undetected between CRE

inleakage determinations.

Quantitative limits on unfiltered inleakage.

This element is intended to establish the CRE inleakage limit as the CRE unfiltered

infiltration rate assumed in the CRE occupant radiological consequence analyses of

design basis accidents. Having an unambiguous criterion for the CRE boundary to be

considered operable in order to meet LCO 3.7.10 will ensure that associated action

requirements will be consistently applied in the event of CRE degradation resulting in

inleakage exceeding the limit.

Consistent with TSTF-448, Revision 3, the program states that the provisions of SR 3.0.2 are applicable to the program frequencies for performing the activities required by program paragraph number c, parts (i) and (ii) (assessment of CRE habitability and measurement of CRE inleakage), and paragraph d (measurement of CRE differential pressure).

This statement is needed to avoid confusion. SR 3.0.2 is applicable to the surveillance

that references the testing in the CRE Habitability Program. However, SR 3.0.2 is not

applicable to Administrative Controls unless specifically invoked. Providing this

statement in the program eliminates any confusion regarding whether SR 3.0.2 is applicable, and is acceptable. Consistent with TSTF-448, Revision 3, proposed TS 5.5.14 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 5.5.14, which is consistent with the model program TS approved by the NRC staff in

TSTF-448, Revision 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 c onsistent with the model application, and are acceptable.

3.6 Adoption

of TSTF-448 Revision 3 by the WBN, Unit 1 The changes made by TSTF-448 to the STS requirements for the CREVS and the CRE

boundary conform to 10 CFR 50.36(d)(2) and 10 CFR 50.36(d)(3). The proposed plant-specific

adoption of the changes also conform to regulatory requirements of 10 CFR 50.36(d)(2) and

10 CFR 50.36(d)(3) and will better assure that the WBN'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 WBN, Unit 1.

4.0 STATE CONSULTATION

In accordance with the Commission

=s regulations, the Tennessee state official was notified of the proposed issuance of the amendment.

The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes 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 changes

surveillance requirements. The NRC staff has determined that the amendment involves no

significant increase in the amounts and no significant change in the types of any effluents that

may be released offsite, and that there is no significant increase in individual or cumulative

occupational radiation exposure. The Commission has previously issued a proposed finding

that the amendment involves no-significant-hazards considerations, and there has been no

public comment on the finding Federal Register dated August 29, 2008 (73 FR 51014).

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in

10 CFR 51.22(c)(9) and (c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact

statement or environmental assessment need be prepared in connection with the issuance of

the amendment.

6.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION

6.1 Background

The Commission issued a "Notice of Consideration of Issuance of Amendment to Facility

Operating License, Proposed No Significant Hazards Consideration Determination and

Opportunity for a Hearing" for the proposed amendment in the Federal Register on August 29, 2008 (73 FR 51014). This Notice provided 60 days for the public to request a

hearing.

The Commission's regulations in 10 CFR 50.91(a)(2)(i) state that:

The Commission may publish in the Federal Register under §2.105 an individual notice of proposed action for an amendment for which it makes a proposed

determination that no significant hazards consideration is involved . . . .

Pursuant to 10 CFR 50.91(a)(2)(ii), the notice will contain the staff's proposed 10 CFR 50.92

determination, provide a brief description of the amendment and the facility involved, solicit

public comments thereon, and provide for a 30-day comment period. The Commission issued a

"Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No

Significant Hazards Consideration Determination and Opportunity for a Hearing" for the

proposed amendment in the Federal Register on August 29, 2008 (73 FR 51014). There were no comments received.

Pursuant to 10 CFR 50.91(a)(3), the Commission does not publish a final determination on no

significant hazards consideration, unless it receives a request for a hearing.

The Commission's regulations in 10 CFR 50.91(a)(4) state that:

Where the Commission makes a final determination that no significant hazards

consideration is involved and that the amendment should be issued, the

amendment will be effective on issuance, even if adverse public comments have been received and even if an interested person meeting the provisions for

intervention called for in §2.309 of this chapter has filed a request for a hearing.

The Commission need hold any required hearing only after it issues an

amendment, unless it determines that a significant hazards consideration is

involved, in which case the Commission will provide an opportunity for a prior

hearing.

The Commission's regulations in 10 CFR 50.92(c) state that the Commission may make a final

determination that a proposed license amendment involves no significant hazards consideration (NSHC) if the operation of the facility in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an

accident previously evaluated; or (2) Create the possibility of a new or different

kind of accident from any accident prev iously evaluated; or (3) Involve a significant reduction in a margin of safety.

Pursuant to 10 CFR 50.91, the NRC staff made a proposed determination that the WBN, Unit 1

amendment request involves NSHC. A "Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration Determination and

Opportunity for a Hearing" was issued in the Federal Register on August 29, 2008 (73 FR 51014). The notice provided a 30-day opportunity for public comment. The NRC staff did

not receive comments on the proposed NSHC determination.

6.2 Final

NSHC Determination

The NRC staff has completed its evaluation of the licensee's proposed amendment as

discussed above. Based on its evaluation, the staff has made a final determination that the

proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated; does not create the possibility of a new or different kind of accident from any accident previously evaluated; and does not involve a significant reduction in a margin of safety. The following evaluation in relation to the three standards of 10 CFR

50.92(c) explains the staff's final NSHC determination.

6.3 First

Standard

Does the proposed amendment involve a significant increase in the probability or consequences

of an accident previously evaluated?

Response: No

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 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 vent ilation system, which is a mitigation system designed to 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 t he 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.

6.4 Second

Standard

Does the proposed amendment create the possibility of a new or different kind of accident from

any accident previously evaluated?

Response: No

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 surveillanc e or following the new program. The proposed change does not involve a physical alteration of the plant (i.e

., 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 acci dent from any accident previously evaluated.

6.5 Third

Standard

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

Response: No

The proposed change does not alter the manner in whic h safety limits, limit ing safety system settings or limiting conditions for operation as 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.

6.6 Conclusion

On the basis of the above evaluation, the NRC staff has made a final determination that the

proposed amendment does not involve a significant hazards consideration.

7.0 CONCLUSION

The Commission has concluded, on the basis of the considerations discussed above, that

(1) there is reasonable assurance that the health and safety of the public will not be endangered

by operation in the proposed manner, (2) such activities will be conducted in compliance with

the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the

common defense and security or to the health and safety of the public.

Principal contributor: Matthew E. Hamm

Date: October 8, 2008