ML081760023

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Issuance of Amendment No. 178, Adoption of Technical Specifications Task Force (TSTF) Traveler No. 448, Revision 3, Control Room Envelope Habitability.
ML081760023
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 10/14/2008
From: Donohew J
Plant Licensing Branch IV
To:
Entergy Operations
Donohew J N, NRR/DORL/LPL4, 415-1307
Shared Package
ML081760021 List:
References
TAC MD6153
Download: ML081760023 (31)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 October 14, 2008 Vice President, Operations Entergy Operations, Inc.

Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 - ISSUANCE OF AMENDMENT RE: ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)

TRAVELER NO. 448, REVISION 3, "CONTROL ROOM ENVELOPE HABITABILITY" (TAC NO. MD6153)

Dear Sir or Madam:

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 178 to Facility Operating License No. NPF-29 for the Grand Gulf Nuclear Station, Unit 1. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated July 17, 2007 (GNRO-2007/00040), as supplemented by letters dated August 7,2007 (GNRO-2007/00050), and September 2,2008 (GNRO-2008/00049).

The amendment added a new license condition (43) on the control room envelope habitability program, revised TS requirements related to the control room envelope habitability in TS 3.7.3, "Control Room Fresh Air (CRFA) System," and added the new TS 5.5.13, "Control Room Envelope Habitability Program." These changes are consistent with the NRC-approved IndustrylTS Task Force (TSTF) Traveler TSTF-448, Revision 3. The availability of this TS improvement was published in the Federal Register on January 17, 2007 (72 FR 2022), as part of the Consolidated Line Item Improvement Process.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Jack N. Dono ew, ni r Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

1. Amendment No. 178 to NPF-29
2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY OPERATIONS, INC.

SYSTEM ENERGY RESOURCES, INC.

SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION ENTERGY MISSISSIPPI, INC.

DOCKET NO. 50-416 GRAND GULF NUCLEAR STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 178 License No. NPF-29

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

A. The application for amendment by Entergy Operations, Inc. (the licensee), dated July 17, 2007, as supplemented by letters dated August 7,2007 and September 2, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations 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.

Enclosure 1

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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-29 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix S, as revised through Amendment No. 178 are hereby incorporated in the license. Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. In addition, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(43) of Facility Operating License No. NPF-29 is hereby amended to read as follows:

(43) Control Room Habitability Upon implementation of Amendment No. 178 adopting TSTF-448, Revision 3, the determination of Control Room Envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), and the assessment of CRE habitability as required by Specification 5.5.13.c.(ii), shall be considered met.

Following implementation:

(a) The first performance of SR 3.7.3.4, in accordance with Specification 5.5.13.c.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 2005, the date of the most recent successful tracer gas test, as stated in the June 30, 2005 letter response to Generic Letter 2003-01 ,

or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.13.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 2005, the date of the most recent successful tracer gas test, as stated in the June 30, 2005 letter response to Generic Letter 2003-01 , or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic assessment of the CRE boundary, Specification 5.5.13.d, shall be within the next 18 months, plus the 136 days allowed by SR 3.0.2, as measured from the date of issuance of this amendment.

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4. This license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-29 and the Technical Specifications Date of Issuance: October 14, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 178 FACILITY OPERATING LICENSE NO. NPF-29 DOCKET NO. 50-416 Replace the following pages of the Facility Operating License No. NPF-29 and the 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.

Facility Operating License Remove 4 4 16 16 16a 16a Technical Specifications Remove 3.7-6 3.7-6 3.7-7 3.7-7 3.7-8 3.7-8 5.0-16a 5.0-16b

(b) SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii) the GGNS Unit 1 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No. 54.

In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.

C. The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Entergy Operations, Inc. is authorized to operate the facility at reactor core power levels not in excess of 3898 megawatts thermal (lOO percent power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.178 are hereby incorporated into this license. Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance Requirements (SRs) for Diesel Generator 12 contained in the Technical Specifications and listed below, are not required to be performed immediately upon implementation of Amendment No. 169.

The SRs listed below shall be successfully demonstrated at the next regularly scheduled performance.

SR 3.8.1. 9, SR 3.8.1.10, and SR 3.8.1.14 4 Amendment No.178

(41) Fire protection program Entergy Operations, Inc. shall implement and maintain in effect all provisions of the approved Fire Protection program as described in Revision 5 to the updated Final safety Analysis Report, and as approved in the safety Evaluations dated August 23, 1991, and september 29, 2006, subject to the following provisions:

The licensee may make changes to the approved Fire Protection Program without prior approval of the commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(42) Mitigation strategy License condition The Licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance
2. Assessment of mutual aid fire fi~hting assets
3. Designated staging areas for equlpment and materials
4. command and control
5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:
l. protection and use of personnel assets
2. communications
3. Minimizing fire spread
4. Procedures for implementing integrated fire response strategy
5. Identification of readily-available pre-staged equipment
6. Training on integrated fire response strategy
7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:
1. Water spray scrubbing
2. Dose to onsite responders (43) control Room Habitability upon implementation of Amendment NO. 178 adopting TSTF-448, Revision 3, the determination of control Room Envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), and the assessment of CRE habitability as required by specification 5.5.13.c.(ii), shall be considered met. Following implementation:

(a) The first performance of SR 3.7.3.4, in accordance with specification 5.5.13.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 2005, the date of the most recent successful tracer gas test, as stated in the June 30, 2005 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

16 Amendment NO. +/-+G, -1l8 Revised by Letter dated July 18, 2007

(b) The first performance of the periodic assessment of CRE habitability, specification 5.5.13.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 2005, the date of the most recent successful tracer gas test, as stated in the June 30, 2005 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic assessment of the CRE boundary, specification 5.5.13.d, shall be within the next 18 months, plus the 136 days allowed by SR 3.0.2, as measured from the date of issuance of this amendment.

D. The facility required exemptions from certain requirements of Appendices A and J to 10 CFR Part 50 and from certain requirements of 10 CFR Part 100. These include: (a) exemption from General Design Criterion 17 of Appendix A until startup following the first refuelin9 outage, for (1) the emergency override of the test mode for the Divislon 3 diesel engine, (2) the second level undervoltage protection for the Division 3 diesel engine, and (3) the generator ground over current trip function for the Division 1 and 2 diesel generators (section 8.3.1 of SSER #7) and (b) exemption from the requirements of paragraph III.D.2(b)(ii) of Appendix J for the containment airlock testing following normal door opening when containment integrity is not required (section 6.2.6 of SSER #7). These exemptions are authorized by law and will not endanger life or property or the common defense and securit¥ and are otherwise in the public interest. In addition, by exemptlon dated December 20, 1986, the Commission exempted licensees from 10 CFR 100.11(a)(1) , insofar as it incorporates the definition of exclusion area in 10 CFR 100.3(a)i until April 30, 1987 regarding demonstration of authority to control a 1 activities within the exclusion area (safety evaluation accompanying Amendment No. 27 to License (NPF-29). This exemption is authorized by law, and will not present an undue risk to the public health and safety, and is consistent with the common defense and security. In addition, special circumstances have been found justifying the exemption.

Therefore, these exemptions are hereby granted pursuant to 10 CFR 50.12.

With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act and the rules and regulations of the Commission.

E. The licensee shall fully implement and maintain in effect all provision of the commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "phr,sical security, safeguards contingency and Training and Qualification Plan, ' and were submitted to the NRC on May 18, 2006.

16a Amendment No. 1+G, ~

Revised by Letter dated July 18, 2007

CRFA System 3.7.3 3.7 PLANT SYSTEM 3.7.3 Control Room Fresh Air (CRFA) System LCO 3.7.3 Two CRFA subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During operations with a potential for draining the reactor vessel (OPDRVS).

ACTIONS

NOTE-------------------------------------

The Control Room Envelope (CRE) boundary may be opened intermittently under administrative control.

CONDITION REQUIRED ACTION COMPLETION TIME A. One CRFA subsystem A.1 Restore CRFA 7 days inoperable for subsystem to OPERABLE reasons other than status.

condition B.

B. One or more CRFA B.1 Initiate action to Immediately subsystems inoberable implement mitigating due to inopera le CRE actions.

boundary in MODE 1, 2, or 3. AND B.2 Verify mitigating 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions ensure CRE occupant ex~osures to radiolo~ica chemical and smo e hazards wi 11 not exceed limits.

AND B.3 Restore CRE boundary 90 days to OPERABLE status.

(continued)

GRAND GULF 3.7-6 Amendment No. ~, -11B

CRFA System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and c.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated completion Time of Condition A or AND B not met in MODE 1, 2, or 3. c.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Required Action and D.1 Place OPERABLE CRFA Immediately associated completion subsystem in Time of Condition A isolation mode.

not met during OPDRVs.

OR 0.2 Initiate action to Immediately suspend OPDRVs.

(continued)

GRAND GULF 3.7-7 Amendment NO. ~, -lZ8

CRFA System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRFA subsystems E.l Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

F. TWo CRFA subsystems F.l Initiate action to Immediately inoperable during suspend OPDRVS.

OPDRVs.

OR One or more CRFA subsystems ino~erable due to inopera le CRE boundary duri ng OPDRVS.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CRFA subsystem for ~ 10 31 days continuous hours with the heaters operating.

SR 3.7.3.2 Perform required CRFA filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing program (VFTP).

SR 3.7.3.3 verify each CRFA subsystem actuates on an 18 months actual or simulated initiation signal.

SR 3.7.3.4 perform required CRE unfiltered air In accordance inleakage testing in accordance with the with the Control Room Envelope Habitability Control Room program. Envelope Habitability Program GRAND GULF 3.7-8 Amendment NO.~. 178

programs and Manuals 5.5 5.5 programs and Manuals (continued) 5.5.13 Control Room Envelope Habitability program A control Room Envelope (CRE) Habitability program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE control Room Fresh Air (CRFA) System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protectlon is provided to permit access and occupancy of the CRE under Design Basis Accident (DBA) conditions without personnel receivin9 radiation exposures in excess of 5 rem Total Effective Dose Equlvalent (TEDE) for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.
b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
c. Reguirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and c.2 of Regulatory guide 1.197, "Demonstrating control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003 and (ii) assessing CRE habitability at the Frequencies specified in Sections c.1 and C.2 of Regulatory Guide 1.197, Revision O.
d. Since the CRE is at a neutral pressure during isolation mode, the CRE will be maintained, including the following:
1. Plant maintenance activities such as modifications, rework, and preventive maintenance tasks on components that could affect the CRE shall be controlled under fleet, plant and system specific procedures to ensure that the CRE boundary is not degraded by such activities.
2. Testin9 of CRFA system sealin9 areas shall be performed followlng maintenance activitles (rework and preventative) and periodically to ensure ~ha~ ~he areas of negative pressures do not leak bypassing emergency filtration system components.
3. Fire damper inspection procedures that require opening of duct panels and doors shall ensure that upon restoration no leakage path exists.
4. The remainder of ducting components such as plenum access doors, duct access doors (rectangular and round),

flex connections (ventglass, etc.), plugs, and patches will be maintained per paragraph b.

GRAND GULF 5.0-16a Amendment NO. -Lla

programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.13 Control Room Envelope Habitability program (continued)

5. An assessment of the CRE Boundary will be conducted every IS-months. The results of assessing items I through 4 shall be trended and used as part of the assessment of the CRE boundary as indicated in paragraph c.
e. The quantitative limits on unfiltered air inleakge into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testin~ described in paragraph c. The unfiltered air inleakage limlt for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and assessing the CRE boundary as required by paragraphs c and d, respectively.

GRAND GULF 5.0-16b Amendment No. ~

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 178 TO FACILITY OPERATING LICENSE NO. NPF-29 ENTERGY OPERATIONS, INC.. ET AL.

GRAND GULF NUCLEAR STATION. UNIT 1 DOCKET NO. 50-416

1.0 INTRODUCTION

By application dated July 17, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072060522). as supplemented by letters dated August 7, 2007, and September 2,2008 (ADAMS Accession Nos. ML072250092 and ML082470358, respectively),

Entergy Operations, Inc. (the licensee), requested changes to the Technical Specifications (TSs) for Grand Gulf Nuclear Station, Unit 1 (GGI\JS). The proposed changes are to adopt the U.S. Nuclear Regulatory Commission (NRC)-approved Industry/TS Task Force (TSTF) Traveler TSTF-448, Revision 3. The availability of this TS improvement was published in the Federal Register on January 17, 2007 (72 FR 2022), as part of the NRC Consolidated Line Item Improvement Process.

The proposed amendment would (1) add a new license condition (43) on the control room envelope habitability program, (2) revise the TS requirements related to the control room envelope habitability in TS 3.7.3, "Control Room Fresh Air (CRFA) System," and (3) add the new TS 5.5.13, "Control Room Envelope Habitability Program," to the administrative controls section of the TSs.

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 (STS) (NUREGs 1430-1434) on behalf of the industry (TSTF-448, Revisions 0, 1, and 2 were prior draft iterations). TSTF-448, Revision 3, is a proposal to establish more effective and appropriate action, surveillance, and administrative STS requirements related to ensuring the habitability of the control room envelope (CRE). Because GGNS is a boiling water reactor (BWR)-6, the STS for the plant is NUREG 1434, "Standard Technical Specifications General Electric Plants, BWR/6."

In NRC Generic Letter (GL) 2003-01, "Control Room Habitability," (Reference 1). NRC alerted licensees to findings at facilities that existing TS surveillance requirements (SRs) for the Control Room Envelope Emergency Ventilation System (CREEVS) may not be adequate. Specifically, the results of American Society for Testing and Materials (ASTM) E741 (Reference 2) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure Enclosure 2

-2 surveillance is not a reliable method for demonstrating CRE boundary operability. Licensees were requested to address their existing TSs as follows:

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

operability] of the CRE [boundary], and the assumed [unfiltered] inleakClge rates of potentially contaminated air. If you currently have a differential pressure surveillance requirement to demonstrate CRE [boundary] integrity, provide the basis for your conclusion that it remains adequate to demonstrate CRE integrity in light of the ASTM E741 testing results. If you conclude that your differential pressure surveillance requirement is no longer adequate, provide a schedule for:

1) revising the surveillance requirement in your technical specification to reference an acceptable surveillance methodology (e.g., ASTM E741), and
2) making any necessary modifications to your CRE [boundary] so that compliance with your new surveillance requirement can be demonstrated.

If your facility does not currently have a technical specification surveillance requirement for your CRE integrity, explain how and at what frequency you confirm your CRE integrity and why this is adequate to demonstrate CRE integrity.

To promote standardization and to minimize the resources that would be needed to create and process plant-specific amendment applications in response to the concerns described in the generic letter, the industry and the NRC proposed revisions to CRE habitability system requirements contained in the STS, using the STS change traveler process. This effort culminated in Revision 3 to traveler TSTF-448, "Control Room Habitability," which the NRC staff approved on January 17, 2007.

Consistent with the traveler as incorporated into NUREG-1434, the licensee proposed revising action and SRs in Specification 3.7.3, "Control Room Fresh Air (CRFA) System," and adding a new administrative controls program, Specification 5.5.13, "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.

In its review of the proposed amendment, the !\IRC staff also considered the licensee's responses to GL 2003-01 on control room habitability. These responses are the licensee's letters dated August 11, 2003, June 30, 2005, and July 25, 2005 (ADAMS Accession Nos.

ML032260616, ML051820396, and ML052070554, respectively).

The supplemental letters dated August 7,2007, and September 2,2008, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on September 25, 2007 (72 FR 54473).

-3 The licensee identified changes to the TS Bases in Attachment 3 to (1) its application and (2) its supplemental letter dated September 2,2008. These changes were submitted for information only because changes to the TS Bases are controlled and approved by TS 5.5.11, "Technical Specification (TS) Bases Control Program." However, because there are TS Bases accompanying the TSs in the NRC-approved TSTF-448, Revision 3, the NRC staff needs to review the identified TS Bases changes for this amendment to adopt TSTF-448, Revision 3, to make sure no problems are created by these changes.

2.0 REGULATORY EVALUATION

2.1 Control Room and Control Room Envelope (CRE)

NRC Regulatory Guide 1.196, "Control Room Habitability at Light-water Nuclear Power Reactors," Revision 0, May 2003 (Reference 4), uses the term "control room envelope (CRE)" 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 (Reference 5), also contains these definitions, but uses the term CRE to mean both. This is because the protected environment provided for operators varies with the nuclear power facility. At some facilities this environment is limited to the control room; at others, it is the CRE. In this safety evaluation, consistent with the proposed changes to the STS, the CRE will be used to designate both.

2.2 Control Room Fresh Air (CRFA) System The CRFA (the term used at GGNS 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.

- 4 The CRFA System is designed to maintain a habitable environment in the control room envelope for 30 days of continuous occupancy after a Design-Basis Accident (DBA) without exceeding a 5 rem (roentgen equivalent man) total effective dose equivalent (TEDE).

The CRFA System consists of two redundant subsystems, each capable of maintaining the habitability of the CRE. The CRFA System is considered operable when the individual components necessary to limit operator exposure are operable in both subsystems. A CRFA System subsystem is considered operable when the associated:

  • High efficiency particulate air (HEPA) filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions;
  • Heater, demister, ductwork, valves, and dampers are operable, and air circulation can be maintained; and
  • CRE boundary is operable (the single boundary supports both subsystems).

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 Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," General Design Criteria (GDC) 1, 2, 3, 4, 5, and 19 apply to CRE habitability. A summary of these GDC follows.

  • GDC 1, "Quality Standards and Records," requires that structures, systems, and components (SSCs) important to safety be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions performed.
  • GDC 2, "Design Bases for Protection Against Natural Phenomena," requires that SSCs important to safety be designed to withstand the effects of earthquakes and other natural hazards without loss of capability to perform their safety functions.
  • GDC 3, "Fire Protection," requires SSCs important to safety be designed and located to minimize the effects of fires and explosions.
  • GDC 4, "Environmental and Dynamic Effects Design Bases," requires SSCs important to safety to be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents (LOCAs).

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  • GOC 5, "Sharing of Structures, Systems, and Components," requires that SSCs important to safety not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, the orderly shutdown and cooldown of the remaining units.
  • GOC 19, "Control Room," requires that a control room be provided from which actions can be taken to operate the nuclear reactor safely under normal conditions and to maintain the reactor in a safe condition under accident conditions, including a LOCA. With regard to control room access and occupancy, adequate radiation protection shall be provided to ensure that radiation exposures shall not exceed 0.05 Sv (5 rem) total effective dose equivalent (TEOE), as defined in 10 CFR 50.2 for the duration of the accident.

Prior to incorporation of TSTF-448, Revision 3, the STS requirements addressing CRE boundary operability resided only in the following CRE ventilation system specifications:

  • I\IUREG-1432, TS 3.7.11, "Control Room Emergency Air Cleanup System (CREACS)";

System"; and

In these specifications, for the facilities that pressurize the CRE, the SR associated with demonstrating the operability of the CRE boundary requires verifying that one CRFA System subsystem can maintain a specific value of positive pressure, relative to the areas adjacent to CRE boundary during the pressurization mode of operation at a predetermined makeup flow rate. Facilities that pressurize the CRE during the emergency mode of operation of the CRFA System have similar SRs. Other facilities that do not pressurize the CRE, which is the case for GGNS, have only a system flow rate criterion for the emergency mode of operation. Regardless, the results of ASTM E741 (Reference 2) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance (or the alternative surveillance at non-pressurization facilities) is not a reliable method for demonstrating CRE boundary operability. That is, licensees were able to obtain differential pressure and flow measurements satisfying the SR limits even though unfiltered inleakage was determined to exceed the value assumed in the safety analyses.

In addition to an inadequate surveillance requirement, the action requirements of these specifications were ambiguous regarding CRE boundary operability in the event CRE unfiltered inleakage is found to exceed the analysis assumption. The ambiguity stemmed from the view that the CRE boundary may be considered operable but degraded in this condition, and that it would be deemed inoperable only if calculated radiological exposure limits for CRE occupants

-6 exceeded a licensing basis limit; Le., as stated in GOC 19, even while crediting compensatory measures.

NRC Administrative Letter (AL) 98-10, "Oispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," states that" [t]he 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 (Reference 3). AL 98-10 also states that "imposing administrative controls in response to an improper or inadequate TS is considered an acceptable short-term corrective action. The staff expects that, following the imposition of administrative controls, an amendment to the TS, with appropriate justification and schedule, will be submitted in a timely fashion."

Licensees that have found unfiltered inleakage in excess of the limit assumed in the safety analyses and have yet to either reduce the inleakage below the limit or establish a higher bounding limit through re-analysis, have implemented compensatory actions to ensure the safety of CRE occupants, pending final resolution of the condition, consistent with RIS 2005-20.

However, based on GL 2003-01 and AL 98-10, the NRC staff expects each licensee to propose TS changes that include a surveillance to periodically measure CRE unfiltered inleakage in order to satisfy 10 CFR 50.36(d)(3), which requires a facility's TS to include SRs, which it defines as

"[r]equirements 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.

Because the design of the plant is not being changed by the proposed amendment, the plant continues to meet GOCs 1, 2, 3, 4, and 5. Because the proposed addition to TS 5.5.11 requires the dose requirements in GOC 19 to be met, GOC 19 will also continue to be met by the plant.

2.4 Regulation Applicable to TS Changes Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of SSCs that are required to protect the health and safety of the public. The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36 that requires that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plant's TSs. As stated in 10 CFR 50.36(d)(2)(i), the "[(]imiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the

-7 technical specifications ..." SRs are, in accordance with 10 CFR 50.36(d)(3), "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 the limiting conditions for operation will be met.

2.5 Adoption of TSTF-448, Revision 3 Adoption of TSTF-448, Revision 3, will assure that the facility's TS LCO for the CRFA System 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 CRFA System and the CRE boundary conform to 10 CFR 50.36(d)(2) and 10 CFR 50.36(d)(3). Their adoption will better assure that the CRE will remain habitable during normal operation and design basis accident conditions. These changes are, therefore, acceptable from a regulatory standpoint in that they meet 10 CFR 50.36.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the proposed changes against the corresponding changes made to the STS by TSTF-448, Revision 3, which the NRC staff has found to satisfy applicable regulatory requirements, as described above in Section 2.0. The emergency operational mode of the CRFA system at GGNS does not pressurize the CRE to minimize unfiltered air inleakage. The proposed changes are consistent with this design. The proposed changes are to add a condition to the operating license and to revise the TSs.

3.1 Proposed Changes to the Operating License 3.1.1 Condition Added to the License The following new condition is to be added to the license as condition number (43):

(43) Control Room Habitability Upon implementation of Amendment No. 178 adopting TSTF-448, Revision 3, the determination of Control Room Envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), shall be considered met. Following implementation:

(a) The first performance of SR 3.7.3.4, in accordance with Specification 5.5.13.c.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 2005, the date of the most recent successful tracer gas test, as stated in the June 2005 letter response to Generic Letter 2003-01 , or within the next 18 months if

-8 the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.13.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 2005, the date of the most recent successful tracer gas test, as stated in the June 30, 2005 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic assessment of the CRE boundary, Specification 5.5.13.d, shall be within the next 18 months, plus the 136 days allowed by SR 3.0.2, as measured from the date of issuance of this amendment.

3.1.2 Proposed Changes to the TSs 3.1.2.1 Changes to TS 3.7.3 on the CRFA System In its application and supplemental letters, the licensee proposed the following changes to the existing requirements on the CRFA system in TS 3.7.3:

1. Add a note to LCO 3.7.3 stating that "The control room envelope (CRE) boundary may be opened intermittently under administrative controls."
2. The phrase "for conditions other than Condition B" is added to Condition A in the Actions for LCO 3.7.3. The existing required actions and completion time for Condition A are not being changed.
3. A new Condition B for "One or more CRFA subsystems inoperable due to inoperable CRE boundary in MODE 1, 2, or 3" is added to the Actions for LCO 3.7.3.
4. For the new Condition B, new Required Actions B.1 , B.2, and B.3 and their associated completion times are also added to the TSs. These new required actions and completion times are the following: (1) initiate action to immediately implement mitigating actions, (2) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the mitigating actions ensure that the exposure of occupants within the CRE envelope will not exceed regulatory limits, and (3) restore within 90 days the CRE boundary to being operable.
5. The existing Condition B is re-number Condition C and the phrase "or B" is added to the condition to state "Required Action and associated Completion Time of Condition A or B not met in MODE 1,2, or 3." The added phrase is in bold. The existing required actions and completion times for the existing Condition B are not being changed, and they will be the required actions and completion times for the new Condition C.

-9

6. The existing Condition C is re-numbered Condition D with no changes to either the condition or the associated required actions and completion times for that condition.
7. The existing Condition D is re-numbered Condition E and the phrase "for reasons other than Condition B" is added to the condition to state "Two CFRA subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B." The added phrase is in bold. The existing required action and completion time for the existing Condition D are not being changed, and they will be the required action and completion time for the new Condition E.
8. The existing Condition E is re-numbered Condition F and a new condition "one or more CRFA subsystems inoperable due to inoperable CRE boundary during OPDRVs [operations with a potential for draining the reactor vessel]" is added.

The re-numbered Condition F will then state "Two CRFA subsystems inoperable during OPDRVs OR one or more CRFA subsystems inoperable due to inoperable CRE boundary during OPDRVs." The added condition is in bold with the logical operator "OR" so that for either condition the licensee is required to perform the required actions within the specified completion time. The existing required action and completion time for the existing Condition E are not being changed, and they will be the required action and completion time for the new Condition F.

9. A new SR 3.7.3.4 is added to TS 3.7.3 to require the licensee to perform required CRE unfiltered air inleakage testing in accordance with the control room envelope habitability program. The proposed surveillance frequency is in accordance with the control room envelope habitability program. This program is a new program to be added to the Administrative Controls of the TSs and is addressed in the next subsection.

3.1.2,2 New Administrative Controls Program A new program is proposed to be added to TS 5.5, "Programs and Manuals," of the TSs to be established. implemented, and maintained at GGNS. The new program is TS 5.5.13, "Control Room Envelope Habitability Program." The proposed program is the following:

A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure the CRE habitability is maintained such that, with an OPERABLE Control Room Fresh Air (CRFA) System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under Design Basis Accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem Total Effective Dose Equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.

- 10

b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision O.
d. Since the CRE is at a neutral pressure during isolation mode, the CRE will be maintained, including the following:
1. Plant maintenance activities such as modifications, rework, and preventive maintenance tasks on components that could affect the CRE shall be controlled under fleet, plant and system specific procedures to ensure that the CRE boundary is not degraded by such activities.
2. Testing of CRFA system sealing areas shall be performed following maintenance activities (rework and preventative) and periodically to ensure that the areas of negative pressures do not leak bypassing emergency filtration system components.
3. Fire damper inspection procedures that require opening of duct panels and doors shall ensure that upon restoration no leakage path exists.
4. The remainder of ducting components such as plenum access doors, duct access doors (rectangular and round), flex connections (ventglass, etc.), plugs, and patches will be maintained per paragraph b.
5. An assessment of the CRE Boundary will be conducted every 18 months, the results of assessing items 1 through 4 shall be trended and used as part of the assessment of the CRE boundary as indicated in paragraph c.
e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

- 11

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and assessing the CRE boundary as required by paragraphs c and d, respectively.

3.2 The Proposed Changes The proposed amendment would strengthen CRE habitability TS requirements by changing TS 3.7.3 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 TS Bases also includes editorial and administrative changes to reflect applicable changes to the corresponding STS Bases, which were made to improve clarity, conform to the latest information and references, correct factual errors, and achieve more consistency among the STS NUREGs. Except for plant specific differences, all of these changes are consistent with STS as revised by TSTF-448, Revision 3.

The NRC staff compared the proposed TS changes to the STS and the STS markups and evaluations in TSTF-448. The NRC staff verified that differences from the STS 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. Approval of the identified TS Bases change is through TS 5.5.11, "Technical Specification (TS) Bases Control Program." This provides assurance that the licensee has established correct Bases for the TSs, is not changing the licensing basis of the plant without NRC review and approval, and will maintain the adequacy of the Bases. The proposed Bases for TS 3.7.3 refer to specific guidance in NEI 99-03, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001 (Reference 6), which the NRC staff has formally endorsed, with exceptions, through Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," dated May 2003 (Reference 4).

Based on its review of the changes to the Bases, the NRC staff has not identified any problems with the changes.

3.3 Editorial Changes The licensee proposed editorial changes to TS 3.7.3 to establish standard terminology, such as "control room envelope (CRE)" in place of "control room," except for the plant-specific name for the CREEVS (Control Room Fresh Air (CRFA) System), and "radiological, chemical, and smoke hazards" in place of various phrases to describe the hazards that CRE occupants are protected from by the CRFA System. These changes improve the usability and quality of the presentation of the TSs, have no negative impact on safety, and meet 10 CFR 50.36. Therefore, the NRC staff concludes that these changes are acceptable.

- 12 3.4 Evaluation of Changes to TS 3.7.3 for the CRFA System 3.4.1 Evaluation for Facilities That Have Not Yet Adopted the CRFA System TS LCO NOTE and Action B of TSTF-287, Rev. 5 (Evaluation 2(1))

The licensee proposed to establish new action requirements in TS 3.7.3 for an inoperable CRE boundary. Currently, if one CRFA subsystem is determined to be inoperable due to an inoperable CRE boundary, existing Action A would apply and require restoring the subsystem (and the CRE boundary) to operable status in 7 days. If two subsystems are determined to be inoperable due to an inoperable CRE boundary, existing Action D specifies no time to restore the subsystems (and the CRE boundary) to operable status, but requires immediate entry into the shutdown actions of LCO 3.0.3. These existing Actions are more restrictive than would be appropriate in situations for which CRE occupant implementation of compensatory measures or mitigating actions would temporarily afford adequate CRE occupant protection from postulated airborne hazards. To account for such situations, the licensee proposed to revise the action requirements to add a new Condition B, "One or more CRFA subsystems inoperable due to inoperable CRE boundary in MODE 1, 2, or 3." New Action B.3 would allow 90 days to restore the CRE boundary (and consequently, the affected CRFA System subsystems) to operable status, provided that mitigating actions are immediately implemented (Action B.1) and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are verified to ensure, that in the event of a DBA, CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke (Action B.2).

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. 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, and their Completion Times, are acceptable.

To distinguish new Condition B from the existing condition for one CRFA System subsystem inoperable, Condition A is revised to state, "One CRFA subsystem inoperable for reasons other than Condition B." To distinguish new Condition B from the existing condition for two CRFA System subsystems inoperable, Condition D (renumbered as Condition E) is revised to state, "Two CRFA subsystems inoperable during MODE 1, 2, or 3 for reasons other than Condition B."

The changes to existing Conditions A and D are less restrictive because these Conditions will no longer apply in the event one or two CRFA subsystems are inoperable due to an inoperable CRE boundary during unit operation in Mode 1, 2, or 3. This is acceptable because the new Actions B.1, B.2 and B.3 establish adequate remedial measures in this condition. With the addition of a new Condition B, existing Conditions B, C, D, and E are re-designated C, D, E, and F, respectively.

(1)

Evaluation numbers correspond to the numbers in the Notice of Availability in the Federal Register on January 17, 2007 (72 FR 2022).

- 13 Based on the above evaluation of the proposed changes to the conditions in TS 3.7.3, except for the proposed change to Condition F, the NRC staff concludes that the proposed changes meet 10 CFR 50.36 and are, therefore, acceptable. The proposed change to Condition F is addressed in Section 3.4.2 of this safety evaluation.

The licensee also proposed to modify the CRFA System LCO by adding a NOTE allowing the CRE boundary to be opened intermittently under administrative controls. As stated in the LCO Bases changes in Attachment 3 to the application, 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 control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be procedural zed 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 and it meets 10 CFR 50.36.

3.4.2 Evaluation for Boiling-Water Reactor (BWR)4 and BWR6 Control Room Fresh Air (CRFA) System TSs (Evaluation 5)

The licensee proposed to add a new second condition to renumbered Action F of TS 3.7.3 that states, "One or more CRFA subsystems inoperable due to an inoperable CRE boundary during OPDRVs." OPDRVs are operations with a potential for draining the reactor vessel. The specified Required Actions proposed for this condition are the same as for the eXisting condition for renumbered Action F, which states, "Two CRFA subsystems inoperable during OPDRVs."

Accordingly, the new condition is stated with the other condition in Action F using the logical connector "OR". The practical result of this presentation in format is the same as specifying two separately numbered Actions, one for each condition. Its advantage is to make the TS Actions table easier to use by avoiding having an additional numbered row in the Actions table. This new condition in Action F is needed because proposed Action B will only apply in Modes 1, 2, and 3. As such, this change will ensure that the Actions table continues to specify a condition for an inoperable CRE boundary during refueling and OPDRVs. Therefore, this change is administrative, is not changing any requirements in the TSs, and meets 10 CFR 50.36. Based on this, the NRC staff concludes the proposed change is acceptable.

3.4.3 Evaluation for Facilities That Do Not Have a Pressurized CRE The emergency mode of operation of the CRFA System is described in Attachment 3 to the licensee's application. The CRFA System proVides a protected environment from which control room occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke into the control room. The safety related function of the CRFA System used to control radiation exposure consists of redundant isolation valves in each inlet and exhaust flow path and two independent and redundant high efficiency air filtration subsystems for treatment of recirculated air or outside supply air and a CRE boundary that limits the inleakage of unfiltered air. The CRFA System is designed to maintain the CRE environment for a 30 day continuous occupancy after a DBA. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

- 14 Because the CRE is not pressurized in an emergency, TS 3.7.3 does not have a surveillance on pressurizing the CRE, which might be some indication of air inleakage into the CRE. The licensee addressed the CRE not being pressurized in its supplemental letter dated September 2, 2008.

The licensee proposed to add a SR related to the air inleakage and a CRE Habitability Program in TS Section 5.5, in accordance with the approved version of TSTF-448.

The proposed CRE inleakage measurement SR states, "Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program." The CRE Habitability Program TS, proposed TS 5.5.13, paragraph c, 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 (Reference 5). This guidance references ASTM E741 (Reference 2) as an acceptable method for ascertaining the unfiltered leakage into the CRE. The licensee has proposed to follow this method. Therefore, the proposed CRE inleakage measurement SR is acceptable and meets 10 CFR 50.36. Based on this, the NRC staff concludes that the proposed change to the TSs are acceptable.

3.5 TS 5.5.13, CRE Habitability Program The proposed administrative controls program TS 5.5.13 is consistent with the model program TS in TSTF-448, Revision 3, except for the paragraph d on the measurement of CRE pressure relative to adjacent external areas. In combination with SR 3.7.3.4, this program is intended to ensure the operability of the CRE boundary, which as part of an operable CRFA System will ensure that CRE habitability is maintained such that CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under DBA conditions without personnel receiving radiation exposures in excess of 5 rem TEDE per GDC 19 for the duration of the accident.

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

Definitions of CRE and CRE boundary. This element is intended to ensure that these definitions accurately describe the plant areas that are within the CRE, and also the interfaces that form the CRE boundary, and are consistent with the general definitions discussed in Section 2.1 of this safety evaluation. Establishing what is meant by the CRE and the CRE boundary will preclude ambiguity in the implementation of the program.

Configuration control and preventive maintenance of the CRE boundary. This element is intended to ensure the CRE boundary is maintained in its design condition. Guidance for implementing this element is contained in Regulatory Guide 1.196 (Reference 4), which endorsed, with exceptions, t\lEI 99-03 (Reference 6). Maintaining the CRE boundary in its design condition provides assurance that its leak-tightness will not significantly degrade between CRE inleakage determinations.

- 15 Assessment of CRE habitability at the frequencies stated in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0 (Reference 5), and measurement of unfiltered air leakage into the CRE in accordance with the testing methods and at the frequencies stated in Sections C.1 and C.2 of 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.

There is no proposed measurement of CRE pressure with respect to all areas adjacent to the CRE boundary at designated locations for use in assessing the CRE boundary because it is not practical since the control room is not pressurized in an emergency. In its September 2, 2008, supplemental letter, the licensee explained how the licensee maintains low unfiltered air inleakage for its unpressurized control room. The licensee proposed an alternative to the paragraph on measuring CRE pressure in TSTF-448, Revision 3, based on how it maintains the CRE. The licensee will assess the condition of the CRE at a frequency of 18 months on a staggered test basis (with respect to the CRFA System subsystems).

Quantitative limits on unfiltered inleakage. This element is intended to establish the CRE inleakage limit as the CRE unfiltered infiltration rate assumed in the CRE occupant radiological consequence analyses of design basis accidents. Having an unambiguous criterion for the CRE boundary to be considered operable in order to meet LCO 3.7.3, will ensure that associated action requirements will be consistently applied in the event of CRE degradation resulting in inleakage exceeding the limit.

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 number d (assessment of CRE boundary). 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 meets 10 CFR 50.36. Based on this, the proposed change is acceptable.

Consistent with TSTF-448, Revision 3, proposed TS 5.5.13 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 5.5.13, which is consistent with the model program TS approved by the NRC staff in TSTF-448, Revision 3, is acceptable and meets 10 CFR 50.36.

Based on this, the proposed change is acceptable.

- 16 3.6 Proposed Amendment In its application and supplemental letters, the licensee proposed changes to the TSs to incorporate TSTF-448, Revision 3. These changes are identified in Section 3.1 and are adding a license condition and changing the TSs. These changes are evaluated in Sections 3.2 through 3.5 of this safety evaluation. Based on the conclusions in these sections and Section 2.3, the NRC staff concludes the proposed changes meet GDCs 1, 2, 3, 4, 5, and 19, and 10 CFR 50.36. Based on this, the NRC staff concludes that the proposed changes to the TSs are acceptable.

3.7 License Conditions and Implementation of New Surveillance and Assessment Requirements by the Licensee The following 3 new surveillances will be required to be performed by the licensee because of the amendment: (1) the new SR 3.7.3.4, which requires performing CRE unfiltered air inleakage in accordance with the CRE habitability program, (2) the periodic assessment of CRE habitability, Specification 5.5.13.c.(ii), and (3) the new periodic assessment of the CRE boundary, Specification 5.5.13.d. To specify when the first performance of these surveillances is required, the licensee proposed the license conditions addressed in Section 3.1.1 of this safety evaluation. 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 the proposed license conditions. The proposed plant-specific license conditions are consistent with the model application, and are, therefore, acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Louisiana 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 installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. 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 consideration, and there has been no public comment on such finding published in the Federal Register on September 25, 2007 (72 FR 54473). 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.

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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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. NRC Generic Letter 2003-01, "Control Room Habitability," dated June 12, 2003 (GL 2003-01).
2. ASTM E741-00, "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution," 2000 (ASTM E741).
3. NRC Regulatory Issue Summary 2005-20: Revision to Guidance Formerly Contained in NRC Generic Letter 91-18," Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," dated September 26,2005 (RIS 2005-20).
4. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, dated May 2003.
5. Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003.
6. NEI 99-03,"Control Room Habitability Assessment Guidance," Revision 0, dated June 2001.

Principal Contributors: H. Walker A. Lewin J. Donohew Date: October 14, 2008

October 14, 2008 Vice President, Operations Entergy Operations, Inc.

Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150 SUB"IECT: GRAND GULF NUCLEAR STATION, UNIT 1 - ISSUANCE OF AMENDMENT RE: ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)

TRAVELER NO. 448, REVISION 3, "CONTROL ROOM ENVELOPE HABITABILITY," (TAC NO. MD6153)

Dear Sir or Madam:

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 178 to Facility Operating License No. NPF-29 for the Grand Gulf Nuclear Station, Unit 1. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated July 17, 2007 (GNRO-2007/00040), as supplemented by letters dated August 7,2007 (GNRO-2007/00050), and September 2,2008 (GNRO-2008/00049).

The amendment added a new license condition (43) on the control room envelope habitability program, revised TS requirements related to the control room envelope habitability in TS 3.7.3, "Control Room Fresh Air (CRFA) System," and added the new TS 5.5.13, "Control Room Envelope Habitability Program." These changes are consistent with the NRC-approved IndustrylTS Task Force (TSTF) Traveler TSTF-448, Revision 3. The availability of this TS improvement was published in the Federal Register on January 17, 2007 (72 FR 2022), as part of the Consolidated Line Item Improvement Process.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRAI Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

1. Amendment No. 178 to NPF-29
2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDorlLpl4 Resource RidsRgn4MailCenter Resource LPLIV r/f RidsNrrDssScvb Resource ALewin, NRR/DIRS/ITSB RidsAcrsAcnw_MailCTR Resource RidsNrrLAJBurkhardt Resource HWalker NRRlDSS/SCVB RidsNrrDirsltsb Resource RidsNrrPMJDonohew Resource GHill, OIS (2)

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, See previous concurrence ADAMS Accession NO ML081760023 OFFICE NRRlLPL4/PM NRRlLPL4/LA A NRRlDIRS/ITSB NRRlDSS/SCVB OGC NRRlLPL4/BC (A) NRRlLPL4/PM NAME JDonohew JBurkhard\ ~\l.';t) REIliott' RDennig' RvHomes MMarkley JDonohew DATE 9/16/08 10/14/08 (! 09/05/2008 09/15/2008 9123108 10/9/08 10/9/08 OFFICIAL RECORD COPY

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