ML083440311
| ML083440311 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/26/2008 |
| From: | Graessle L H AmerenUE, Union Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| OL-1287, TAC MD8006, TSTF-448, Rev 3, ULNRC-05565 | |
| Download: ML083440311 (16) | |
Text
AmerenUE P0 Box 620 Callaway Plant Fulton, MO 65251 November 26, 2008 ULNRC-05565 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop PI-137 Washington, DC 20555-0001 WAmerenl 10 CFR 50.90 UF Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.FACILITY OPERATING LICENSE NPF-30 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CONTROL ROOM ENVELOPE HABITABILITY TECHNICAL SPECIFICATION REVISION IN ACCORDANCE WITH TSTF-448, REVISION 3 (OL-1287, TAC NO. M'D8006)
Reference:
- 1. AmerenUE letter ULNRC-05463, "Revision to Technical Specification Regarding Control Room Envelope Habitability in Accordance with TS'IT-448, Revision 3, Using the Consolidated Line Item Improvement Process (OL-1287)," dated January 14, 2008 In Reference 1 above AmerenUE requested a license amendment that would revise Callaway Technical Specification (TS) 3.7.10, "Control Room Emergency Ventilation System (CREVS)," and would add new TS 5.5.17, "Control Room Habitability Program." The proposed TS changes were based on Technical Specification Task Force (TSTF) traveler TSTF-448, Revision 3, "Control Room Habitability." From the NRC's ongoing review of the subject license amendment request (LAR), a request for additional information (RAI) was received electronically from the NRC on October 9, 2008. Attachment 1 provides a response to the request for additional information.
In responding to the NRC's RAI, it was determined that some changes should be made to the TS changes originally proposed per Reference
- 1. Therefore, a subsidiary of Ameren Corporation AJ(9,9 ULNRC-05565 November 26, 2008 Page 2 Attachment 2 provides revised/marked-up TS pages that supersede specific pages provided in Reference
- 1. Specifically, TS page 3.7-27 of Attachment 2 of this submittal replaces TS page 3.7-27 of Attachment 2 of Reference 1, and Insert 5.5.17 of Attachment 2 of this submittal replaces Insert 5.5.17 of Attachment 2 of Reference 1. Attachment 3 provides revised (clean) TS pages 3.7-28, 5.0-20, and 5.0-21.Corresponding revisions of the TS Bases changes originally provided (for information only) per Reference 1 are also proposed.
Thus, Attachment 4 provides revised marked-up TS Bases pages, for information only, that supersede specified pages provided in Reference
- 1. In particular, Insert B 3.7.10 BKG 2 of Attachment 4 of this submittal replaces Insert B 3.7.10 BKG 2 of Attachment 5 of Reference 1.Final TS Bases changes will be processed under Callaway's program for updates per TS 5.5.14, "Technical Specifications Bases Control Program," when the requested amendment is implemented.
AmerenUE is proposing one additional change to the proposed TS 5.5.17, based on TSTF-508, Revision 0, "Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation." This change is further discussed in Attachment 1.The proposed revisions to the originally proposed TS changes and the additional information provided in the Attachments to this letter do not impact the conclusions of the no significant hazards consideration determination published in the Federal Register on January 17, 2007 (72 FR 2022) as part of the Consolidated Line Item Improvement Process and which was incorporated into Reference 1.This revision to the amendment application was reviewed by the Onsite Review Committee and the Nuclear Safety Review Board. In accordance with 10 CFR 50.91, a copy of this amendment application, including the attachments, is being provided to the designated Missouri State official.This letter contains no commitments.
Please contact Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 573-676-6479 for any questions you may have regarding this issue.I declare under penalty of perjury that the foregoing is true and correct.Sincerely, E x ecu ted o n : It--a b -O 2 H .4G '/ ae ,s EukeH. Gaessle Director, Operations Support BFH/nls ULNRC-05565 Attachment I Page 3 Attachments:
1.2.3.4.Response to NRC Request for Additional Information Revised Proposed Technical Specification Changes (Mark-up)Revised (Clean) Technical Specification Pages Revised Proposed Technical Specification Bases Changes (Mark-up)
ULNRC-05565 November 26, 2008 Page 4 cc: Mr. Elmo E. Collins, Jr.Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E .Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8G14 Washington, DC 20555-2738 ULNRC-05565 November 26, 2008 Page 5 Index and send hardcopy to QA File A160.0761 Hardcopy: Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)
Electronic distribution for the following can be made via Responses and Reports ULNRC Distribution:
A. C. Heflin F. M. Diya T. E. Herrmann S. M. Maglio T. B. Elwood L. S. Sandbothe S. L. Gallagher L. M. Belsky (NSRB)Mr. Ron Reynolds, Director (SEMA)Mr. Edward Gray, Senior REP Planner (SEMA)Mr. John Campbell, REP Planner (SEMA)Ms. Diane M. Hooper (WCNOC)Mr. Dennis Buschbaum (TXU)Mr. Scott Bauer (Palo Verde)Mr. Stan Ketelsen (PG&E)Mr. Wayne Harrison (STPNOC)Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)Mr. Floyd Gilzow (DNR)
ULNRC-05565 Attachment 1 Page 2 based on the TS 5.5.17.d wording that states: "Measurement, at designated locations, of the ......" Based on the above discussion AmerenUE is revising the term "control room" to "CRE" in proposed TS Sections 5.5.17.d, 5.5.17.e, and 5.5.17.f, to be consistent with the intent of TSTF-448.Revised marked-up TS pages are provided in Attachment
2.2. Regarding
the title of Insert 5.5.17, in accordance with TSTF-448 the title of the program represented by section 5.5.17 should be "Control Room Envelope Habitability Program," instead of "Control Room Habitability Program." The difference is minor; however, the title in the TSTF more appropriately places emphasis on the control room envelope.
We are requesting that the licensee change the name of the program to be consistent with the TSTF.AmerenUE Response Consistent with the response to question 1 above, AmerenUE is revising "Control Room Habitability Program" to "Control Room Envelope Habitability Program." This will also require revising the proposed changes to SR 3.7.1 0.4 and associated TS Bases.Revised marked-up TS pages are provided in Attachment
- 2. Revised marked-up TS Bases pages are provided in Attachment
4.3. Section
5.5.17.e of your submittal is also inconsistent with TSTF-448, Rev. 3, in that there is no discussion of CRE occupants' exposure to hazardous chemicals such as is reflected in the REQUIRED ACTION of TS 3.7.10.B.2, where there is assurance that the CRE occupants are protected from hazardous chemicals regardless of quantities stored on site now or in the future. The NRC staff is aware of the discussion provided in section 2.2.3 of attachment 1 of the licensee's submittal and believes that discussion does not adequately address the intent of TSTF-448.
Therefore we are requesting that you update section 5.5.17.e of your submittal to address CRE occupants' exposure to hazardous chemicals consistent with the intent of TSTF-448 Rev. 3, section 5.5.17.e.AmerenUE Response AmerenUE proposed to eliminate the TSTF-448, Revision 3, phrase from TS Section 5.5.17.e regarding unfiltered air inleakage limits for hazardous chemicals and CRE occupants' exposure to hazardous chemicals based, on the licensing basis not requiring quantitative limits for hazardous chemicals.
Nevertheless, AmerenUE agrees to incorporate the TSTF-448, Revision 3 wording,"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 ULNRC-05565 Attachment 1 Page 3 basis." While we are agreeing to incorporate this wording, it is recognized that this program requirement is satisfied in that hazardous chemicals are not stored or used onsite in quantities sufficient to necessitate CRE protection as required by Regulatory Guide 1.78, Rev. 0. The proposed wording to the TS 3.7.10 Bases (in letter ULNRC-05463) provides clarifying information regarding this program requirement.
Revised marked-up TS pages are provided in Attachment 2.Additional Proposed TS Change By letter dated July 3, 2008 (Accession Number ML081850420) the TSTF submitted TSTF-508, Revision 0, "Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation," to the NRC. TSTF-508 included a proposed change to NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Specification 5.5.17, paragraph d, in which the last sentence of this paragraph is changed from "The results shall be trended and used as part of the[ 18] month assessment of the CRE boundary" to "The results shall be trended and used as part of the periodic assessment of the CRE boundary." The Technical Analysis in TSTF-508 supporting this change, states: In order to be consistent with paragraph c of the Control Room Envelope Habitability Program, the last sentence of paragraph d is revised to use the term"periodic" in lieu of the bracketed phrase "18 month." The model TS indicates that periodic CRE relative pressure measurements shall "be trended and used as part of the [18 month] assessment of the CRE boundary." However, the only periodic assessment required by the TSTF-448 model TS occurs at intervals specified in Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Section C.1, as specified by paragraph c.This assessment is normally performed every 36 months, but the 36-month frequency appears only in the Regulatory Guide and does not appear in the TS. In discussions between the NRC and the TSTF, it was determined that the inclusion of the phrase "18-months" in this sentence was an error. Therefore, to be consistent with the remainder of the program, the bracketed phrase "[18 months]" is replaced with the word "periodic." This substitution resolves the inconsistency between these two requirements in a manner consistent with the published regulatory guidance.AmerenUE is revising the proposed change to TS 5.5.17.d to state, "The results shall be trended and used as part of the periodic assessment of the CRE boundary." This change is being proposed consistent with TSTF-508 to prevent unnecessary additional assessments of the CRE boundary and for consistency with regulatory guidance.Other changes proposed in TSTF-508 may be pursued subsequent to NRC staff approval of TSTF-508.
ULNRC-05565 Attachment I Page 4 Marked-up TS pages are provided in Attachment
- 2. As noted in the cover letter, these mark-up TS pages supersede the mark-up TS pages originally provided in AmerenUE's January 14, 2008 license amendment request.
Attachment 2 to ULNRC-05565 Page 1 REVISED PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)
Attachment 2 to ULNRC-05565 Page 2 CREVS 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREVS train pressurization filter unit 31 days for > 10 continuous hours with the heaters operating and each CREVS train filtration filter unit for>_ 15 minutes.SR 3.7.10.2 Perform required CREVS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). VFTP SR 3.7.10.3 Verify each CREVS train actuates on an actual or 18 months simulated actuation signal.SR 3.7.10.4 Verify one CREVS train can maintain a positive 18 months on a pressure of > 0.125 inches water gauge, relative to STAGGERED the outside atmosphere during the CRVIS mode of TEST BASIS operation.
CALLAWAY PLANT 3.7-27 Amendment No. 176 Attachment 2 to ULNRC-05565 Page 3 Insert 5.5.17 5.5.17 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge.
The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body for the duration of the accident.
The program shall include the following elements: a. The definition of the CRE, CRE boundary, control building envelope (CBE), and the CBE Boundary.b. Requirements for maintaining the CRE and CBE boundaries in their design condition, including configuration control and preventive maintenance.
- c. Requirements for (i) determining the unfiltered air inleakage past the CRE and CBE boundaries in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197,"Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.The following exception is taken to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0: 1. The Tracer Gas Test based on the Brookhaven National Laboratory Atmospheric Tracer Depletion (ATD) Method is used to determine the unfiltered air inleakage past the CRE and CBE boundaries.
The ATD Method is described in AmerenUE letters dated December 15, 2004 (ULNRC-05104), June 6, 2006 (ULNRC-05298), July 16, 2007 (ULNRC-05427), and October 30, 2007 (ULNRC-05448).
- d. Measurement, at designated locations, of the CRE pressure relative to the outside atmosphere during the pressurization mode of operation by one train of the CREVS, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the periodic assessment of the CRE boundary.
Attachment 2 to ULNRC-05565 Page 4 Insert 5.5.17 Continued e. The quantitative limits on unfiltered air inleakage into CRE and CBE.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 leakage 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 and CBE unfiltered inleakage, and measuring CRE pressure and assessing CRE and CBE as required by paragraphs c and d, respectively.
Attachment 3 to ULNRC-05565 Page I REVISED (CLEAN) TECHNICAL SPECIFICATION PAGES Attachment 3 to ULNRC-05565 Page 2 CREVS 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREVS train pressurization filter unit 31 days for > 10 continuous hours with the heaters operating and each CREVS train filtration filter unit for> 15 minutes.SR 3.7.10.2 Perform required CREVS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.10.3 Verify each CREVS train actuates on an actual or 18 months simulated actuation signal.SR 3.7.10.4 Perform required unfiltered air inleakage testing of the In accordance with CRE and CBE boundaries in accordance with the the Control Room Control Room Envelope Habitability Program. Envelope Habitability Program I CALLAWAY PLANT 3.7-28 Amendment No. ###
Attachment 3 to ULNRC-05565 Page 3 Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.17 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge.
The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body for the duration of the accident.
The program shall include the following elements: a. The definition of the CRE, CRE boundary, control building envelope (CBE), and the CBE Boundary.b. Requirements for maintaining the CRE and CBE boundaries in their design condition, including configuration control and preventive maintenance.
- c. Requirements for (i) determining the unfiltered air inleakage past the CRE and CBE boundaries in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197,"Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.The following exception is taken to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0: 1. The Tracer Gas Test based on the Brookhaven National Laboratory Atmospheric Tracer Depletion (ATD) Method is used to determine the unfiltered air inleakage past the CRE and CBE boundaries.
The ATD Method is described in AmerenUE letters dated December 15, 2004 (ULNRC-05104), June 6, 2006 (ULNRC-05298), July 16, 2007 (ULNRC-05427), and October 30, 2007 (ULNRC-05448).
- d. Measurement, at designated locations, of the CRE pressure relative to the outside atmosphere during the pressurization mode of operation by one train of the CREVS, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the periodic assessment of the CRE boundary.(continued)
CALLAWAY PLANT 5.0-20 Amendment
Attachment 3 to ULNRC-05565 Page 4 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.17 Control Room Habitability Program (continued)
- e. The quantitative limits on unfiltered air inleakage into CRE and CBE.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 leakage 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 and CBE unfiltered inleakage, and measuring CRE pressure and assessing CRE and CBE as required by paragraphs c and d, respectively.
CALLAWAY PLANT 5.0-21 Amendment