[Federal Register Volume 72, Number 10 (Wednesday, January 17, 2007)]
[Notices]
[Pages 2022-2033]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E7-503]
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NUCLEAR REGULATORY COMMISSION
Notice of Availability of Technical Specification Improvement To
Modify Requirements Regarding Control Room Envelope Habitability Using
the Consolidated Line Item Improvement Process
AGENCY: Nuclear Regulatory Commission.
ACTION: Notice of Availability.
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SUMMARY: Notice is hereby given that the staff of the Nuclear
Regulatory Commission (NRC) has prepared and is making available a
model safety evaluation (SE) and a model no-significant-hazards-
consideration (NSHC) determination relating to the modification of
technical specification (TS) requirements regarding the habitability of
the control room envelope (CRE) for referencing in license amendment
requests (LARs). The NRC staff is also making available an associated
model LAR for use by licensees to prepare such LARs. The TS
modification is based on NRC staff approved changes to the improved
standard technical specifications (STS) (NUREGs 1430-1434) that were
proposed by the pressurized and boiling water reactor owners groups'
Technical Specifications Task Force (TSTF) on behalf of the commercial
nuclear electrical power generation industry, in STS change traveler
TSTF-448, Revision 3 (Rev 3). Previously, on October 17, 2006, drafts
of the model SE, model NSHC determination, and model LAR were published
in the Federal Register for public comment (71 FR 61075). Based on its
evaluation of the public comments received in response to that notice,
the NRC staff made appropriate changes to the models, and is including
the final versions of the models in this notice. This notice also
contains a description of each public comment and its disposition by
the NRC staff. Based on its evaluation of the public comments, the NRC
staff has decided to announce the availability of the model SE and
[[Page 2023]]
model NSHC determination to licensees for referencing in LARs to adopt
TSTF-448, Rev 3, using the consolidated line item improvement process
(CLIIP). An LAR that references the model SE and model NSHC
determination will permit the NRC to efficiently process a license
amendment that proposes to adopt the changes in TSTF-448, Rev 3.
Licensees of nuclear power reactors proposing to adopt these changes
should follow the guidance in the model LAR and confirm the
applicability of the model SE and model NSHC determination to their
reactors.
DATES: The NRC staff hereby announces that the attached model SE and
model NSHC determination (which differ only slightly from the versions
previously published) may be referenced in plant specific applications
to adopt the improved CRE habitability TS requirements. The staff has
also posted the model LAR (which also differs only slightly from the
versions previously published) on the NRC web site to assist licensees
in using the CLIIP to apply for the proposed TS change. The NRC staff
can most efficiently consider applications based upon the model
application if the application is submitted within a year of this
Federal Register Notice.
FOR FURTHER INFORMATION CONTACT: C. Craig Harbuck, Mail Stop: O-12H2,
Technical Specifications Branch, Division of Inspection and Regional
Support, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001, telephone 301-415-3140.
SUPPLEMENTARY INFORMATION
Background
Regulatory Issue Summary 2000-06, ``Consolidated Line Item
Improvement Process for Adopting Standard Technical Specification
Changes for Power Reactors,'' was issued on March 20, 2000. The
consolidated line item improvement process (CLIIP) is intended to
improve the efficiency of NRC licensing processes by processing
proposed changes to the improved standard technical specifications
(STS) (NUREGs 1430-1434) in a manner that supports subsequent license
amendment requests (LARs) from licensees. The CLIIP includes an
opportunity for the public to comment on a proposed change to the STS
after a preliminary assessment by the NRC staff and a finding that the
change will likely be offered for adoption by licensees. The CLIIP
directs the NRC staff to evaluate any comments received for a proposed
change to the STS and to either reconsider the change or announce the
availability of the change for adoption by licensees. Licensees opting
to apply for this TS change are responsible for reviewing the staff's
evaluation, referencing the applicable technical justifications, and
providing any necessary plant-specific information. Each LAR made in
response to the notice of availability will be processed and noticed in
accordance with applicable rules and NRC procedures.
The present notice makes available for adoption by licensees a
change to establish more effective and appropriate action,
surveillance, and administrative TS requirements related to ensuring
CRE habitability. This change was proposed for incorporation into the
STS by the owners groups participants in the Technical Specification
Task Force (TSTF) and is designated TSTF-448, Revision 3 (Rev 3). TSTF-
448, Rev 3, can be viewed on the NRC's Web page at http://www.nrc.gov/reactors/operating/licensing/techspecs.html.
Applicability
This proposal to modify the TS to establish more effective and
appropriate action, surveillance, and administrative requirements
related to maintaining CRE habitability, as proposed in TSTF-448, Rev
3, is applicable to all licensees.
To efficiently process incoming license amendment requests (LARs),
the staff requests that each licensee applying for the TS changes
proposed in TSTF-448, Rev 3, use the CLIIP. The CLIIP does not prevent
licensees from requesting an alternative approach or proposing the TS
changes without the requested TS bases and TS bases control program.
Variations from the approach recommended in this notice may require
additional review by the NRC staff, and may increase the time and
resources needed for the review. Significant variations from the
approach, or inclusion of additional changes to the license, will
result in staff rejection of the application. Instead, licensees
desiring significant variations and/or additional changes should submit
an LAR that does not request to adopt TSTF-448, Rev 3, using the CLIIP.
Evaluation of Public Comments on the Model Safety Evaluation, Model No
Significant Hazards Consideration Determination, and Model License
Amendment Request
The NRC staff evaluated the public comments received on the model
safety evaluation (SE), model no significant hazards consideration
(NSHC) determination, and model license amendment request (LAR)
published in the Federal Register on October 17, 2006 (71 FR 61075-
61084). Comments were received from Progress Energy (PE) (Agency-wide
Documents Access and Management System (ADAMS) Accession No.
ML063260063), Strategic Teaming and Resource Sharing (STARS) (ADAMS
Accession No. ML063340340), and the pressurized and boiling water
reactor owners groups' Technical Specification Task Force (TSTF) (ADAMS
Accession No. ML063260064). The NRC staff also had one comment. The NRC
staff's disposition of each comment follows.
1. (PE) Reference: Model SE Section 2.3, Paragraph 8 (71 FR 61078).
Comment: ``Other Technical Specifications currently exist that are
directly related to control room habitability (e.g., NUREG-1430, TS
3.3.16, ``Control Room Isolation--High Radiation,'' NUREG-1431, TS
3.3.7, ``CREFS Actuation Instrumentation,'' and NUREG-1432, TS 3.3.8,
``Control Room Isolation Signal (CRIS)''). It is recommended that the
paragraph be revised as follows: Prior to incorporation of TSTF-448,
Revision 3, the STS requirements addressing CRE boundary operability
resided only in the following CRE ventilation system specifications:
Disposition: The NRC staff accepted the comment and incorporated
the recommended change into the model SE.
2. (PE) Reference: Model SE Section 2.4, Paragraph 1 (71 FR 61078).
Comment: [The SE] characterizes the six year surveillance frequency for
demonstrating unfiltered leakage into the control room envelope (CRE)
is within limits as a relatively long test interval (frequency). When
compared with the 15 year test frequency justified for the integrated
leak rate test of containment, the six year frequency seems exceedingly
short. This is particularly true given the safety (risk) significance
of containment relative to the CRE boundary. Therefore, the bases for
the six year frequency should be included in the model safety
evaluation. Additionally, the model safety evaluation should allow
sites the option to justify a site specific test frequency based on
unique site characteristics using a risk-informed approach. (e.g.,
Regulatory Guide 1.177--An Approach for Plant-Specific, Risk-Informed
Decisionmaking: Technical Specifications)
Disposition: The NRC staff determined that explicitly suggesting in
the model LAR that an applicant propose longer test intervals based on
risk considerations is inappropriate because such a request would
exceed the scope of changes covered by TSTF-448, Rev 3, would require
staff
[[Page 2024]]
evaluation beyond that described in the model SE, and could not be
considered under the CLIIP. The proposed TS Bases for the in-leakage
surveillance gives the basis for the six-year frequency by referencing
the TS CRE Habitability Program, which requires this surveillance to be
performed ``in accordance with the testing methods and at the
Frequencies specified in Sections C.1 and C.2 of Regulatory Guide
1.197.'' However, the phrase ``relatively long'' in the model SE is
potentially misleading and has been removed.
3. (PE) Reference: Model SE Section 3.4 Paragraph 1 (71 FR 61081).
Comment: [The] model safety evaluation states: The program shall ensure
that adequate radiation protection is provided to permit access and
occupancy of the CRE under design basis accident (DBA) conditions * * *
The control room envelope boundary and programs to maintain it are
providing the necessary radiological protection for occupancy of the
control room. The program is independent of any ability to ``access''
the control room. Therefore, it is recommended that the sentence be
revised as follows: The program shall ensure that adequate radiation
protection is provided to permit occupancy of the CRE under design
basis accident (DBA) conditions * * *
Disposition: Occupancy of the CRE must account for any radiation
sources encountered outside the CRE while accessing (going to and from)
the CRE. The proposed CRE Habitability Program TS states, ``The program
shall ensure that adequate radiation protection is provided to permit
access and occupancy of the CRE under design basis accident (DBA)
conditions * * * .'' The recommendation is not accepted.
4. (PE) (TSTF) (STARS) Reference: Model LAR Section 3.2 (71 FR
61084). Comment: Section 3.2 of the model LAR requires that the
applicant make three commitments. Commitments 2 and 3 state:
2. [LICENSEE] will revise procedures to implement the
new surveillance and programmatic TS requirements related to CRE
habitability.
3. [LICENSEE] commits to Regulatory Positions C.1 and
C.2 of Regulatory Guide 1.197, ``Demonstrating Control Room Envelope
Integrity at Nuclear Power Reactors,'' Revision 0, May 2003, with
the following exceptions: [Add descriptions of proposed exceptions.]
In the case of commitment 2, 10 CFR 50, Appendix B, Criterion V,
``Instructions, Procedures, and Drawings,'' already requires that,
``Activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appropriate to the
circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings.''
In the case of commitment 3, the commitment is specifically
addressed by the wording that will be included in Technical
Specifications per Technical Specification Task Force 448 (TSTF-448)
Section 5.5.18c (5 .5.15c for boiling water reactors) which states:
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 0.
[The following are exceptions to Sections C.1 and C.2 of
Regulatory Guide 1.197, Revision 0: 1.; and]
Therefore, upon approval of the licensee's amendment request,
proposed commitments 2 and 3 will be addressed through legally binding
regulatory obligations (i.e., 10 CFR 50, Appendix B and Technical
Specifications) making regulatory commitments duplicative and an
unnecessary burden on the licensee. It is recommended that commitments
2 and 3 be deleted from the subject model LAR.
Disposition: The NRC staff accepts the recommendation and has
removed commitments 2 and 3 from Section 3.2 and Attachment 4 of the
model LAR.
5. (TSTF) Reference: In the Notice under ``Applicability,'' the
last sentence (71 FR 61076). Comment: Should a licensee submit an
application that requests adoption of TSTF-448 but includes significant
variations or additional changes, it would facilitate the NRC's review
for the licensee to acknowledge that the change is based on TSTF-448 so
that the NRC may use the model safety evaluation to the extent
possible. We recommend revising the [last] sentence as follows:
``Instead, licensees desiring significant variations and/or additional
changes should submit a license amendment request (LAR) that does not
request to adopt TSTF-448, Rev 3, under the Consolidated Line Item
Improvement Process.''
Disposition: The NRC staff accepted the comment and incorporated
the recommended change into the present notice.
6. (TSTF) Reference: Model LAR, Section 2.2 (71 FRN 61083).
Comment: We recommend that the NRC modify Section 2.2 of the Model
Application, ``Optional Changes and Variations,'' to request that
licensees describe which optional portions of the model Safety
Evaluation are applicable.
Disposition: The NRC staff accepted the comment and incorporated
the recommended change as a note at the end of the first paragraph of
Section 2.2 of the model LAR.
7. (TSTF) Reference: Model SE Section 2.3, first paragraph (71 FR
61077). Comment: Section 2.3, ``Regulations Applicable to Control Room
Habitability,'' lists General Design Criteria from 10 CFR 50, Appendix
A. Many licensees are not committed to the General Design Criteria and
the wording of this section may result in many plants proposing an
unnecessary variation in response to the required verification that the
published safety evaluation is applicable in Section 2.2 of the model
application. We recommend adding the following sentence to the first
paragraph prior to the last sentence, ``Any licensee commitments to
these criteria are described in the plant's licensing basis
documents.''
Disposition: The following optional sentence is added to the first
paragraph for use by applicants whose facilities are not licensed under
the General Design Criteria from 10 CFR 50, Appendix A. ``[Facilities
not licensed under the General Design Criteria from 10 CFR Part 50 are
licensed under similar plant-specific design criteria, as described in
the facility's licensing basis documents.]''
8. (TSTF) Reference: Model SE Section 3.3, Evaluation 5 (71 FR
61080). Comment: Remove Mode 4 from the sentence about the applicable
operational modes for new Action B of TS 3.7.[4] because the BWR/4 and
BWR/6 Applicability does not include Mode 4 for this action
requirement.
Disposition: The NRC staff replaced the subject sentence with
``This new condition in Action F is needed because proposed Action B
will only apply in Modes 1, 2, and 3.''
9. (TSTF) Reference: Model SE Section 3.3, Evaluation 6 (71 FR
61081). Comment: In Evaluation 6, the next to the last sentence is
overly specific concerning the wording of the licensee's Generic Letter
2003-01 response about the adequacy of existing surveillance
requirements to verify CRE boundary operability, and may lead to many
plants proposing an unnecessary variation in response to the required
verification that the published safety evaluation is applicable in
Section 2.2 of the model LAR. The acceptability of
[[Page 2025]]
the deletion of SR 3.7.[10].[4] is not dependent on the licensee's
Generic Letter response, but on the findings in the Generic Letter. We
propose revising the sentences to be consistent with the statements in
Section 1.0 of the model Safety Evaluation, such as ``In Generic Letter
2003-01 (Reference 1), licensees were alerted to findings that the
differential pressure surveillance is not a reliable method for
demonstrating CRE boundary operability. Based on the adoption of TSTF-
448, Revision 3, the licensee's proposal to delete SR 3.7.[10].[4] is
acceptable.''
Response: If the language of the model SE is not consistent with
the wording of the licensee's Generic Letter 2003-01 response, the
licensee should explain the inconsistency in its LAR to facilitate
evaluation of the inconsistency by the staff in the SE for the license
amendment. To account for the possibility of an inconsistency, the
model SE is revised by surrounding the sentence in brackets.
10. (TSTF) Reference: Model NSHC determination (71 FR 61082).
Comment: In the evaluation of Criterion 2, add the word ``Accident''
before the word ``Previously'' in the title, and change ``an accident''
to ``any accident'' in the last sentence to match the wording of
Criterion 2 in 10 CFR 50.92(c)(2).
Disposition: The model NSHC determination was revised as suggested.
11. (TSTF) Reference: Model LAR title, second sentence (71 FR
61083). Comment: Revise the sentence by inserting the phrase ``Plant
Technical Specifications'' after the phrase ``to Revise'' and changing
``Tstf-448'' to ``TSTF-448.''
Disposition: The model LAR was revised as suggested.
12. (TSTF) Reference: Model LAR, Section 2.2, third paragraph (71
FR 61083). Comment: Change the date ``June 2003'' to ``June 2001.''
Disposition: The model LAR was revised as suggested.
13. (TSTF) (STARS) Reference: Model LAR, lists of Attachments in
cover letter, and Attachment 3 cover page title (71 FR 61083 and 4).
Comment: Place brackets around references to the revised TS pages in
the LAR cover letter and the Attachment 3 cover page title, and replace
``Proposed'' with ``Revised'' in the Attachment 3 cover page title.
Providing smooth revised TS pages should be optional in the LAR. Also,
make the Attachment 4 cover page title consistent with the title as
stated in the LAR cover letter by removing ``list of.''
Disposition: The model LAR was revised as suggested. Finally,
because the revised model LAR contains no list of regulatory
commitments, the NRC staff added brackets around appropriate text in
the model LAR to indicate that including regulatory commitments is
optional.
14. (TSTF) Reference: Model LAR cover letter, next to last
paragraph (71 FR 61083). Comment: Revise the oath or affirmation
statement to match the phrasing contained in Regulatory Issue Summary
(RIS) 2001-18, ``Requirements for Oath or Affirmation.''
Disposition: The model LAR was revised to match RIS 2001-18.
15. (TSTF) Reference: Model LAR, Section 3.2 (71 FR 61084).
Comment: Commitment 1 states, ``[LICENSEE] commits to the guidance of
NEI 99-03, Revision 0, ``Control Room Habitability Assessment
Guidance'' dated June 2001, which provides guidance and details on the
assessment and management of control room envelope (CRE)
habitability.''
This commitment should be deleted. A licensee general commitment to
NEI 99-03, Revision 0, is not relied upon in TSTF-448 or the model
Safety Evaluation as a basis for finding the proposed changes
acceptable. The analysis in the model Safety Evaluation does not
support a conclusion that the NRC Staff has a ``significant interest''
in the matter to warrant a commitment.
There are only two references to NEI 99-03 in TSTF-448 and in the
model Safety Evaluation:
a. The model SE, Section 3.4, ``TS 5.5.[18], CRE Habitability
Program,'' refers to NEI 99-03, Revision 0, as one of two documents
(with Regulatory Guide 1.196) containing guidance related to
configuration control and maintenance of the control room envelope
boundary. TSTF-448, Revision 3, proposed Specification 5.5.[18],
``Control Room Envelope Habitability Program,'' paragraph b, requires
that the licensee's Control Room Envelope Habitability Program include
requirements for maintaining the control room envelope boundary in its
design condition including configuration control and preventive
maintenance. NEI 99-03, Revision 0, discusses configuration control and
maintenance in Section 9.4, ``Configuration Control,'' which contains
only generic guidance applicable to any configuration control program
and which encompasses less than 2 pages of a 177 page document. A
generic commitment to all of NEI 99-03, Revision 0, for this purpose is
unnecessary and unjustified. The appropriate control is already
provided by the Technical Specifications and NEI 99-03, [Revision 0,
Section 9.4] is only one method of meeting the Technical Specification
requirement.
b. The proposed Bases for SR 3.7.[10].[4] (the inleakage test)
state, ``Compensatory measures are discussed in Regulatory Guide 1.196,
Section C.2.7.3, (Ref. 5) which endorses, with exceptions, NEI 99-03,
Section 8.4 and Appendix F (Ref. 6).'' This very specific reference in
the Technical Specification Bases to portions (8 pages of the 177 page
document) of NEI 99-03, [Revision 0] do not justify a generic
commitment to the entire document.
Disposition: The NRC staff revised the model application to remove
the commitment as suggested.
16. (STARS) Reference: Model LAR cover letter (71 FR 61083).
Comment: After the sentence ``Attachment 4 provides a summary of the
regulatory commitments made in this submittal.'' insert ``Attachment 5
provides the existing TS Bases pages marked up to show proposed change
and is for information only.'' For completeness, this adds information
related to Attachment 5 in the cover letter.
Disposition: The model LAR was revised by adding the sentence
``Attachment 5 provides existing TS Bases pages marked up to show the
proposed changes.'' The NRC staff expects that a licensee adopting a
TSTF change to the STS will also adopt associated changes to the STS
Bases or provide in its LAR a justification for any deviation.
17. (STARS) Reference: Model LAR, Attachment 1, Section 1.0,
paragraph 1 (71 FR 61083). Comment: Place the title of TS Section 5.5
in brackets to account for the possibility that some facilities may
have a different title.
Disposition: The model LAR was revised as suggested.
18. (STARS) Reference: Model LAR cover letter (71 FR 61083) and
Attachment 5 cover page (71 FR 61084). Comment: Include the phrase
``(For Information Only)'' to the title of Attachment 5.
Disposition: As noted in the disposition of Comment 16, the NRC
staff expects that a licensee adopting a TSTF change to the STS will
also adopt associated changes to the STS Bases or provide in its LAR a
justification for any deviation. Consequently, the suggested phrase is
not appropriate and is not adopted.
19. (NRC staff) Reference: Model SE Section 3.1, last paragraph (71
FR 61079); model LAR, Section 2.2, third paragraph (71 FR 61083); model
LAR Section 3.2 and Attachment 4, first commitment (71 FR 61083).
Comment: Remove option to follow guidance in March 2003 version of NEI
99-03 contingent upon showing that differences with the June 2001
version
[[Page 2026]]
do not conflict with staff positions in Regulatory Guide 1.196, because
the NRC has not endorsed the March 2003 version.
Disposition: The model SE and model LAR have been revised to remove
the option of referencing the March 2003 version of NEI 99-03, as
described in the disposition of Comment 15. The NRC staff recommends
that implementation of any guidance in NEI 99-03, Revision 0, dated
June 2001, that a licensee elects to follow, be consistent with the NRC
staff positions in Regulatory Guide 1.196.
Adoption of TSTF-448, Rev 3
Licensees wishing to adopt TSTF-448, Rev 3, must submit an LAR in
accordance with applicable rules and other regulatory requirements. For
each LAR, the NRC staff will publish a notice of consideration of
issuance of amendment to a facility operating license, a proposed NSHC
determination, and a notice of opportunity for a hearing. The NRC staff
will also publish a notice of issuance of an amendment to a facility
operating license to announce the modification of TS requirements
related to CRE habitability, for each plant that receives the requested
change.
Model Safety Evaluation
U.S. Nuclear Regulatory Commission; Office of Nuclear Reactor
Regulation
Consolidated Line Item Improvement; Adoption of Changes to Standard
Technical Specifications Under Technical Specifications Task Force
(TSTF) Change Number TSTF-448, Revision 3 Regarding Control Room
Envelope Habitability
1.0 Introduction
By application dated [ ] [as supplemented by letters dated [ and
]], [Name of Licensee] (the licensee) requested changes to the
Technical Specifications (TS) for the [Name of Facility]. [The
supplements dated [ and ], provided additional information that
clarified the application, did not expand the scope of the application
as originally noticed, and did not change the staff's original proposed
no significant hazards consideration determination as published in the
Federal Register on [Date (PM/LA will fill in FR information)] (XX FR
XXXX).]
On August 8, 2006, the commercial nuclear electrical power
generation industry owners group Technical Specifications Task Force
(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).
In United States Nuclear Regulatory Commission (NRC) Generic Letter
2003-01 (Reference 1), licensees were alerted to findings at facilities
that existing TS surveillance requirements for the [Control Room
Envelope Emergency Ventilation System (CREEVS )] may not be adequate.
Specifically, the results of ASTM E741 (Reference 2) tracer gas tests
to measure control room envelope (CRE) unfiltered inleakage at
facilities indicated that the differential pressure surveillance is not
a reliable method for demonstrating CRE boundary operability. Licensees
were requested to address existing TS as follows:
Provide confirmation that your technical specifications verify
the integrity [i.e., operability] of the CRE [boundary], and the
assumed [unfiltered] inleakage rates of potentially contaminated
air. If you currently have a differential pressure surveillance
requirement to demonstrate CRE [boundary] integrity, provide the
basis for your conclusion that it remains adequate to demonstrate
CRE integrity in light of the ASTM E741 testing results. If you
conclude that your differential pressure surveillance requirement is
no longer adequate, provide a schedule for: (1) Revising the
surveillance requirement in your technical specification to
reference an acceptable surveillance methodology (e.g., ASTM E741),
and (2) making any necessary modifications to your CRE [boundary] so
that compliance with your new surveillance requirement can be
demonstrated.
If your facility does not currently have a technical
specification surveillance requirement for your CRE integrity,
explain how and at what frequency you confirm your CRE integrity and
why this is adequate to demonstrate CRE integrity.
To promote standardization and to minimize the resources that would
be needed to create and process plant-specific amendment applications
in response to the concerns described in the 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 [month
dd, 2006].
Consistent with the traveler as incorporated into NUREG-143[0], the
licensee proposed revising action and surveillance requirements in
[Specification 3.7.10, ``Control Room Envelope Emergency Ventilation
System (CREEVS),''] and adding a new administrative controls program,
[Specification 5.5.18, ``CRE 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.
2.0 Regulatory Evaluation
2.1 Control Room and Control Room Envelope
NRC Regulatory Guide 1.196, ``Control Room Habitability at Light-
water Nuclear Power Reactors,'' Revision 0, May 2003, (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. For consistency,
facilities should use the term CRE with an appropriate facility-
specific definition derived from the above CRE definition.
[[Page 2027]]
2.2 [Control Room Envelope Emergency Ventilation System (CREEVS)]
The [CREEVS] provides a protected environment from which operators
can control the unit, during airborne challenges from radioactivity,
hazardous chemicals, and fire byproducts, such as fire suppression
agents and smoke, during both normal and accident conditions.
The [CREEVS] 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 whole body dose
or its equivalent to any part of the body] [5 rem total effective dose
equivalent (TEDE)].
The [CREEVS] consists of two redundant trains [subsystems], each
capable of maintaining the habitability of the CRE. The [CREEVS] is
considered operable when the individual components necessary to limit
operator exposure are operable in both trains [subsystems]. A [CREEVS]
train [subsystem] is considered operable when the associated:
Fan is operable;
High efficiency particulate air (HEPA) filters and
charcoal adsorbers are not excessively restricting flow, and are
capable of performing their filtration functions;
Heater, demister, ductwork, valves, and dampers are
operable, and air circulation can be maintained; and
CRE boundary is operable (the single boundary supports
both trains [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 10 CFR Part 50, ``Domestic Licensing of Production and
Utilization Facilities,'' General Design Criteria (GDC) 1, 2, 3, 4, 5,
and 19 apply to CRE habitability. A summary of these GDCs follows.
[Facilities not licensed under the GDC from 10 CFR Part 50 are licensed
under similar plant-specific design criteria, as described in the
facility's licensing basis documents.]
GDC 1, ``Quality Standards and Records,'' requires that structures,
systems, and components (SSCs) important to safety be designed,
fabricated, erected, and tested to quality standards commensurate with
the importance of the safety functions performed.
GDC 2, ``Design Basis for Protection Against Natural Phenomena,''
requires that structures, systems, and components (SSCs) important to
safety be designed to withstand the effects of earthquakes and other
natural hazards.
GDC 3, ``Fire Protection,'' requires SSCs important to safety be
designed and located to minimize the effects of fires and explosions.
GDC 4, ``Environmental and Dynamic Effects Design Bases,'' requires
SSCs important to safety to be designed to accommodate the effects of
and to be compatible with the environmental conditions associated with
normal operation, maintenance, testing, and postulated accidents,
including loss-of-coolant accidents (LOCAs).
GDC 5, ``Sharing of Structures, Systems, and Components,'' requires
that SSCs important to safety not be shared among nuclear power units
unless it can be shown that such sharing will not significantly impair
their ability to perform their safety functions, including, in the
event of an accident in one unit, the orderly shutdown and cooldown of
the remaining units.
GDC 19, ``Control Room,'' requires that a control room be provided
from which actions can be taken to operate the nuclear reactor safely
under normal conditions and to maintain the reactor in a safe condition
under accident conditions, including a LOCA. Adequate radiation
protection is to be provided to permit access and occupancy of the
control room under accident conditions without personnel receiving
radiation exposures in excess of specified values.
Prior to incorporation of TSTF-448, Revision 3, the STS
requirements addressing CRE boundary operability resided only in the
following CRE ventilation system specifications:
NUREG-1430, TS 3.7.10, ``Control Room Emergency
Ventilation System (CREVS);''
NUREG-1431, TS 3.7.10, ``Control Room Emergency Filtration
System (CREFS);''
NUREG-1432, TS 3.7.11, ``Control Room Emergency Air
Cleanup System (CREACS);''
NUREG-1433, TS 3.7.4, ``[Main Control Room Environmental
Control (MCREC)] System;'' and
NUREG-1434, TS 3.7.3, ``[Control Room Fresh Air (CRFA)]
System.''
In these specifications, the surveillance requirement associated
with demonstrating the operability of the CRE boundary requires
verifying that one [CREEVS] train [subsystem] can maintain a positive
pressure of [0.125] inches water gauge, relative to the adjacent
[turbine building] during the pressurization mode of operation at a
makeup flow rate of [3000] cfm. Facilities that pressurize the CRE
during the emergency mode of operation of the [CREEVS] have similar
surveillance requirements. Other facilities that do not pressurize the
CRE 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 exceeded a licensing
basis limit; e.g., as stated in GDC-19, even while crediting
compensatory measures.
NRC Administrative Letter 98-10, ``Dispositioning of Technical
Specifications That Are Insufficient to Assure Plant Safety,'' (AL 98-
10) states that `` the discovery of an improper or inadequate TS value
or required action is considered a degraded or nonconforming
condition,'' which is defined in [NRC Inspection Manual Chapter 9900;
see latest guidance in RIS 2005-20 (Reference 3)]. ``Imposing
administrative controls in response to an improper or inadequate TS is
considered an acceptable short-term corrective action. The [NRC] staff
expects that, following the imposition of administrative controls, an
amendment to the [inadequate] TS, with appropriate justification and
schedule, will be submitted in a timely fashion.''
Licensees that have found unfiltered inleakage in excess of the
limit assumed in the safety analyses and have yet to either reduce the
inleakage below the limit or establish a higher bounding limit through
re-analysis, have
[[Page 2028]]
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 staff expects each
licensee to propose TS changes that include a surveillance to
periodically measure CRE unfiltered inleakage in order to satisfy 10
CFR 50.36(c)(3), which requires a facility's TS to include surveillance
requirements, which it defines as ``requirements relating to test,
calibration, or inspection to assure that the necessary quality of
systems and components is maintained, that facility operation will be
within safety limits, and that limiting conditions for operation will
be met.'' (Emphasis added.)
The NRC staff also expects facilities to propose unambiguous
remedial actions, consistent with 10 CFR 50.36(c)(2), for the condition
of not meeting the limiting condition for operation (LCO) due to an
inoperable CRE boundary. The action requirements should specify a
reasonable completion time to restore conformance to the LCO before
requiring a facility to be shut down. This completion time should be
based on the benefits of implementing mitigating actions to ensure CRE
occupant safety and sufficient time to resolve most problems
anticipated with the CRE boundary, while minimizing the chance that
operators in the CRE will need to use mitigating actions during
accident conditions.
2.4 Adoption of TSTF-448, Revision 3, by [facility name]
Adoption of TSTF-448, Revision 3, will assure that the facility's
TS LCO for the [CREEVS] 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) of 6 years, 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
[CREEVS] and the CRE boundary conform to 10 CFR 50.36(c)(2) and 10 CFR
50.36(c)(3). Their adoption will better assure that [facility name]'s
CRE will remain habitable during normal operation and design basis
accident conditions. These changes are, therefore, acceptable from a
regulatory standpoint.
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 [CREEVS] at [facility name] [pressurizes] [isolates but does not
pressurize] the CRE to minimize unfiltered air inleakage.] The proposed
changes are consistent with this design.
3.1 Proposed Changes
The proposed amendment would strengthen CRE habitability TS
requirements by changing TS [3.7.10, CREEVS] and adding a new TS
administrative controls program on CRE habitability. Accompanying the
proposed TS changes are appropriate conforming technical changes to the
TS Bases. The proposed revision to the Bases also includes editorial
and administrative changes to reflect applicable changes to the
corresponding STS Bases, which were made to improve clarity, conform
with the latest information and references, correct factual errors, and
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 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. However, TS 5.5.[11], ``TS Bases
Control Program,'' provides assurance that the licensee has established
and will maintain the adequacy of the Bases. The proposed Bases for TS
3.7.[10] refer to specific guidance in 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).
3.2 Editorial Changes
The licensee proposed editorial changes to TS [3.7.10, ``CREEVS,'']
to establish standard terminology, such as ``control room envelope
(CRE)'' in place of ``control room,'' except for the plant-specific
name for the [CREEVS], and ``radiological, chemical, and smoke hazards
(or challenges)'' in place of various phrases to describe the hazards
that CRE occupants are protected from by the [CREEVS]. [The licensee
also proposed to correct a typographical error by replacing
``irradiate'' with ``irradiated'' in TS 3.7.10 Condition E.] These
changes improve the usability and quality of the presentation of the
TS, have no impact on safety, and therefore, are acceptable.
3.3 TS [3.7.10, CREEVS]
< Evaluation 1--for facilities that have adopted the [CREEVS] TS LCO
Note and Action B of TSTF-287, Rev. 5 >
The licensee proposed to revise the action requirements of TS
[3.7.10, ``CREEVS,''] to acknowledge that an inoperable CRE boundary,
depending upon the location of the associated degradation, could cause
just one, instead of both [CREEVS] [trains] to be inoperable. This is
accomplished by revising Condition A to exclude Condition B, and
revising Condition B to address one or more [CREEVS] [trains], as
follows:
Condition A One [CREEVS] [train] inoperable for reasons
other than Condition B.
Condition B One or more [CREEVS] [trains] inoperable due
to inoperable CRE boundary in MODE 1, 2, [or] 3[, or 4].
This change clarifies how to apply the action requirements in the
event just one [CREEVS] [train] is unable to ensure CRE occupant safety
within licensing basis limits because of an inoperable CRE boundary. It
enhances the usability of Conditions A and B with a presentation that
is more consistent with the intent of the existing requirements. This
change is an administrative change because it neither reduces nor
increases the existing action requirements, and, therefore, is
acceptable.
The licensee proposed to replace existing Required Action B.1,
``Restore control room boundary to OPERABLE status,'' which has a 24-
hour Completion Time, with Required Action B.1, to immediately initiate
action to implement mitigating actions; Required Action B.2, to verify,
within 24 hours, 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
[[Page 2029]]
and smoke; and Required Action B.3, to restore CRE boundary to operable
status within 90 days.
The 24-hour Completion Time of new Required Action B.2 is
reasonable based on the low probability of a DBA occurring during this
time period, and the use of mitigating actions as directed by Required
Action B.1. The 90-day Completion Time of new Required Action B.3 is
reasonable based on the determination that the mitigating actions will
ensure protection of CRE occupants within analyzed limits while
limiting the probability that CRE occupants will have to implement
protective measures that may adversely affect their ability to control
the reactor and maintain it in a safe shutdown condition in the event
of a DBA. The 90-day Completion Time is a reasonable time to diagnose,
plan and possibly repair, and test most anticipated problems with the
CRE boundary. Therefore, proposed Action B is acceptable.
< End of Evaluation 1 >
< Evaluation 2--for facilities that have not yet adopted the [CREEVS]
TS LCO Note and Action B of TSTF-287, Rev. 5 >
The licensee proposed to establish new action requirements in TS
[3.7.10, ``CREEVS,''] for an inoperable CRE boundary. Currently, if one
[CREEVS] [train] is determined to be inoperable due to an inoperable
CRE boundary, existing Action A would apply and require restoring the
[train] (and the CRE boundary) to operable status in 7 days. If two
[trains] are determined to be inoperable due to an inoperable CRE
boundary, existing Action [E] specifies no time to restore the [trains]
(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 [CREEVS] [trains] inoperable due to
inoperable CRE boundary in MODE 1, 2, [or] 3[, or 4].'' New Action B
would allow 90 days to restore the CRE boundary (and consequently, the
affected [CREEVS] [trains]) to operable status, provided that
mitigating actions are immediately implemented and within 24 hours 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.
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 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 of new Required Action
B.3 is a reasonable time to diagnose, plan and possibly repair, and
test most anticipated problems with the CRE boundary. Therefore,
proposed Action B is acceptable.
To distinguish new Condition B from the existing condition for one
[CREEVS] [train] inoperable, Condition A is revised to state, ``One
[CREEVS] [train] inoperable for reasons other than Condition B.'' To
distinguish new Condition B from the existing condition for two
[CREEVS] [trains] inoperable, Condition [E] (renumbered as Condition
[F]) is revised to state, ``Two [CREEVS] [trains] inoperable during
MODE 1, 2, [or] 3[, or 4] for reasons other than Condition B.'' The
changes to existing Conditions A and [E] are less restrictive because
these Conditions will no longer apply in the event one or two [CREEVS]
[trains] are inoperable due to an inoperable CRE boundary during unit
operation in Mode 1, 2, [or] 3[, or 4]. This is acceptable because the
new Action B establishes adequate remedial measures in this condition.
With the addition of a new Condition B, existing Conditions B, C, D,
and E are re-designated C, D, E, and F, respectively.
The licensee also proposed to modify the [CREEVS] LCO by adding a
note allowing the CRE boundary to be opened intermittently under
administrative controls. As stated in the LCO Bases, this Note ``only
applies to openings in the CRE boundary that can be rapidly restored to
the design condition, such as doors, hatches, floor plugs, and access
panels. For entry and exit through doors, the administrative control of
the opening is performed by the person(s) entering or exiting the area.
For other openings, these controls should be proceduralized and consist
of stationing a dedicated individual at the opening who is in
continuous communication with operators in the CRE. This individual
will have a method to rapidly close the opening and to restore the CRE
boundary to a condition equivalent to the design condition when a need
for CRE isolation is indicated.'' The allowance of this note is
acceptable because the administrative controls will ensure that the
opening will be quickly sealed to maintain the validity of the
licensing basis analyses of DBA consequences.
< End of Evaluation 2 >
< Evaluation 3--for B&W CREVS TS >
The existing TS 3.7.10 condition for two control room emergency
ventilation system (CREVS) trains inoperable during refueling,
Condition E, is revised to also apply during plant operation in Modes 5
and 6. It will state, ``Two CREVS trains inoperable [in MODE 5 or 6,
or] during movement of [recently] irradiated fuel assemblies.'' This
change clarifies the applicability of this condition for dual unit
facilities when the unit is in Mode 5 or 6, and the other unit is
moving [recently] irradiated fuel assemblies. Similarly, Condition D,
for failing to meet Action A during movement of [recently] irradiated
fuel assemblies, is revised to also apply in Modes 5 and 6. These
changes are administrative because they only clarify the intended
applicability of the existing conditions, and are, therefore,
acceptable. Required Actions D.2 and E.1, to immediately suspend
movement of [recently] irradiated fuel assemblies, ensures that a fuel
handling accident cannot occur while the unit is in these conditions.
With only one CREVS train inoperable, Required Action D.1 specifies an
alternative to immediately suspending fuel movement; it requires
immediately placing the operable CREVS train in its emergency operating
alignment, or mode, to minimize the chance the train will fail to
properly switch to this mode if called upon in response to a fuel
handling accident, or other airborne hazards challenge.
< End of Evaluation 3 >
< Evaluation 4--for B&W, CE, and W [CREEVS] TS >
The licensee proposed to add a new condition to Action E of TS
3.7.1[0] that states, ``One or more [CREEVS] trains inoperable due to
an inoperable CRE boundary [in Mode 5 or 6, or] during movement of
[recently] irradiated fuel assemblies.'' The specified Required Action
proposed for this condition is the same as for the existing condition
of Action E [(revised as discussed previously) ], which states ``[Two [CREEVS] trains inoperable
[in MODE 5 or 6, or] during movement of [recently] irradiated fuel
assemblies.'' Accordingly, the new condition is stated with the other
condition in Action E using the logical connector ``OR'' in accordance
with the STS writer's guide (TSTF-GG-05-01, ``Writer's Guide for Plant-
Specific Improved Technical Specifications,'' June 2005). The practical
result of this presentation in format is the same as specifying two
separately numbered Actions, one for each condition. Its advantage is
to make the TS Actions table easier to use by avoiding having an
additional numbered row in the Actions table. The new condition in
Action E is needed because proposed Action B will only apply in Modes
1, 2, 3, and 4. As such, this change will ensure that the Actions table
continues to specify a condition for an inoperable CRE boundary during
Modes 5 and 6 and during refueling. Therefore, this change is
administrative and acceptable.
< End of Evaluation 4 >
< Evaluation 5--for BWR4 and BWR6 [CREEVS] TS >
The licensee proposed to add a new condition to Action F of TS
3.7.[4] that states, ``One or more [CREEVS] subsystems inoperable due
to an inoperable CRE boundary during movement of [recently] irradiated
fuel assemblies in the [[primary or] secondary] containment or during
operations with a potential for draining the reactor vessel (OPDRVs).''
The specified Required Actions proposed for this condition are the same
as for the other existing condition for Action F, which states, ``Two
[CREEVS] subsystems inoperable during movement of [recently] irradiated
fuel assemblies in the [secondary] containment or during OPDRVs.''
Accordingly, the new condition is stated with the other condition in
Action F using the logical connector ``OR'' in accordance with the STS
writer's guide (TSTF-GG-05-01, ``Writer's Guide for Plant-Specific
Improved Technical Specifications,'' June 2005). 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 and acceptable.
< End of Evaluation 5 >
< Evaluation 6--for facilities that have a CRE pressurization
surveillance requirement >
In the [emergency radiation state] of operation, the [CREEVS]
isolates unfiltered ventilation air supply intakes, filters the
emergency ventilation air supply to the CRE, and pressurizes the CRE to
minimize unfiltered air inleakage past the CRE boundary. The licensee
proposed to delete the CRE pressurization surveillance requirement
(SR). This SR requires verifying that one [CREEVS] [train][subsystem],
operating in the [emergency radiation state], can maintain a pressure
of [0.125] inches water gauge, relative to the adjacent [turbine
building] during the pressurization mode of operation at a makeup flow
rate of [3000] cfm. The deletion of this SR is proposed because
measurements of unfiltered air leakage into the CRE at numerous reactor
facilities demonstrated that a basic assumption of this SR, an
essentially leak-tight CRE boundary, was incorrect for most facilities.
Hence, meeting this SR by achieving the required CRE pressure is not
necessarily a conclusive indication of CRE boundary leak tightness,
i.e., CRE boundary operability. [In its response to GL 2003-01, [dated
month, dd, yyyy], the licensee reported that it had determined that the
[facility name] CRE pressurization surveillance, SR 3.7.[10].[4], was
inadequate to demonstrate the operability of the CRE boundary, and
proposed to replace it with an inleakage measurement SR and a CRE
Habitability Program in TS Section 5.5, in accordance with the approved
version of TSTF-448.] Based on the adoption of TSTF-448, Revision 3,
the licensee's proposal to delete SR 3.7.[10].[4] is acceptable.
The proposed CRE inleakage measurement SR states, ``Perform
required CRE unfiltered air inleakage testing in accordance with the
Control Room Envelope Habitability Program.'' The CRE Habitability
Program TS, proposed TS 5.5.[18], 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 [, however, not] proposed to
follow this method. [The NRC staff reviewed the licensee's proposed
alternative method for measuring CRE inleakage to ensure it meets the
criteria for such methods given in RG 1.197.] [Insert plant-specific
technical evaluation by the staff of the alternative method.] [The NRC
staff finds that the proposed alternative method satisfies the criteria
of RG 1.197.] Therefore, the proposed CRE inleakage measurement SR is
acceptable.
3.4 TS 5.5.[18], CRE Habitability Program
The proposed administrative controls program TS is consistent with
the model program TS in TSTF-448, Revision 3. In combination with SR
3.7.[10].[4], this program is intended to ensure the operability of the
CRE boundary, which as part of an operable [CREEVS] 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
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] [5 rem total effective dose equivalent (TEDE)]
for the duration of the accident.
A CRE Habitability Program TS acceptable to the NRC staff requires
the program to contain the following elements:
Definitions of CRE and CRE boundary. This element is intended to
ensure that these definitions accurately describe the plant areas that
are within the CRE, and also the interfaces that form the CRE boundary,
and are consistent with the general definitions discussed in Section
2.1 of this safety evaluation. Establishing what is meant by the CRE
and the CRE boundary will preclude ambiguity in the implementation of
the program.
Configuration control and preventive maintenance of the CRE
boundary. This element is intended to ensure the CRE boundary is
maintained in its design condition. Guidance for implementing this
element is contained in Regulatory Guide 1.196 (Reference 4), which
endorsed, with exceptions, NEI 99-03 (Reference 6). Maintaining the CRE
boundary in its design condition provides assurance that its leak-
[[Page 2031]]
tightness will not significantly degrade between CRE inleakage
determinations.
Assessment of CRE habitability at the frequencies stated in
Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0 (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. [The licensee proposed
the following exception[s] to Sections C.1 and C.2 of Regulatory Guide
1.197, to be listed in the TS with this program element.] [Insert
plant-specific evaluation of licensee's proposed exceptions.] 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 [and NRC
approved exceptions]. Assessing CRE habitability at the NRC accepted
frequencies provides assurance that significant degradation of the CRE
boundary will not go undetected between CRE inleakage determinations.
Determination of CRE inleakage using test methods acceptable to the NRC
staff assures that test results are reliable for ascertaining CRE
boundary operability. Determination of CRE inleakage at the NRC
accepted frequencies provides assurance that significant degradation of
the CRE boundary will not occur between CRE inleakage determinations.
Measurement of CRE pressure with respect to all areas adjacent to
the CRE boundary at designated locations for use in assessing the CRE
boundary at a frequency of [18] months on a staggered test basis (with
respect to the [CREEVS] trains). This element is intended to ensure
that CRE differential pressure is regularly measured to identify
changes in pressure warranting evaluation of the condition of the CRE
boundary. Obtaining and trending pressure data provides additional
assurance that significant degradation of the CRE boundary will not go
undetected between CRE inleakage determinations.
Quantitative limits on unfiltered inleakage. This element is
intended to establish the CRE inleakage limit as the CRE unfiltered
infiltration rate assumed in the CRE occupant radiological consequence
analyses of design basis accidents. Having an unambiguous criterion for
the CRE boundary to be considered operable in order to meet LCO
3.7.[10], will ensure that associated action requirements will be
consistently applied in the event of CRE degradation resulting in
inleakage exceeding the limit.
Consistent with TSTF-448, Revision 3, the program states that the
provisions of SR 3.0.2 are applicable to the program frequencies for
performing the activities required by program paragraph number c, parts
(i) and (ii) (assessment of CRE habitability and measurement of CRE
inleakage), and paragraph number d (measurement of CRE differential
pressure). This statement is needed to avoid confusion. SR 3.0.2 is
applicable to the surveillance that references the testing in the CRE
Habitability Program. However, SR 3.0.2 is not applicable to
Administrative Controls unless specifically invoked. Providing this
statement in the program eliminates any confusion regarding whether SR
3.0.2 is applicable, and is acceptable.
Consistent with TSTF-448, Revision 3, proposed TS 5.5. [18] 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.[18], which
is consistent with the model program TS approved by the NRC staff in
TSTF-448, Revision 3, is acceptable.
4.0 State Consultation
In accordance with the Commission's regulations, the [ ] State
official was notified of the proposed issuance of the amendment. The
State official had [(1) no comments or (2) the following comments--with
subsequent disposition by the staff].
5.0 Environmental Consideration
The amendments change a requirement with respect to the
installation or use of a facility component located within the
restricted area as defined in 10 CFR Part 20 and change surveillance
requirements. The NRC staff has determined that the amendments involve
no significant increase in the amounts and no significant change in the
types of any effluents that may be released offsite, and that there is
no significant increase in individual or cumulative occupational
radiation exposure. The Commission has previously issued a proposed
finding that the amendments involve no-significant-hazards
considerations, and there has been no public comment on the finding [xx
FR xxxxx]. Accordingly, the amendments meet 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 amendments.
6.0 Conclusion
The Commission has concluded, on the basis of the considerations
discussed above, that (1) there is reasonable assurance that the health
and safety of the public will not be endangered by operation in the
proposed manner, (2) such activities will be conducted in compliance
with the Commission's regulations, and (3) the issuance of the
amendments 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 E 741-00, ``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: C. Harbuck.
Model No-Significant-Hazards-Consideration Determination
Description of Amendment Request: A change is proposed to the
standard technical specifications (STS) (NUREGs 1430 through 1434) and
plant specific technical specifications (TS), to strengthen TS
requirements regarding control room envelope (CRE) habitability by
changing the action and surveillance requirements associated with the
limiting condition for operation operability requirements for the CRE
emergency ventilation system, and by adding a new TS administrative
controls program on CRE habitability. Accompanying the proposed TS
change are appropriate conforming technical changes to the TS Bases.
The proposed revision to the Bases also includes editorial and
administrative changes to reflect applicable changes to the
corresponding STS Bases, which were made to improve clarity, conform
with the latest information and references, correct factual errors, and
achieve more consistency among the STS NUREGs. The proposed revision to
the TS and associated Bases is consistent with STS as revised by TSTF-
448, Revision 3.
[[Page 2032]]
Basis for proposed no significant hazards consideration
determination: As required by 10 CFR 50.91(a), an analysis of the issue
of no significant hazards consideration is presented below:
Criterion 1--The Proposed Change Does Not Involve a Significant
Increase in the Probability or Consequences of an Accident Previously
Evaluated
The proposed change does not adversely affect accident
initiators or precursors nor alter the design assumptions,
conditions, or configuration of the facility. The proposed change
does not alter or prevent the ability of structures, systems, and
components (SSCs) to perform their intended function to mitigate the
consequences of an initiating event within the assumed acceptance
limits. The proposed change revises the TS for the CRE emergency
ventilation system, which is a mitigation system designed to
minimize unfiltered air leakage into the CRE and to filter the CRE
atmosphere to protect the CRE occupants in the event of accidents
previously analyzed. An important part of the CRE emergency
ventilation system is the CRE boundary. The CRE emergency
ventilation system is not an initiator or precursor to any accident
previously evaluated. Therefore, the probability of any accident
previously evaluated is not increased. Performing tests to verify
the operability of the CRE boundary and implementing a program to
assess and maintain CRE habitability ensure that the CRE emergency
ventilation system is capable of adequately mitigating radiological
consequences to CRE occupants during accident conditions, and that
the CRE emergency ventilation system will perform as assumed in the
consequence analyses of design basis accidents. Thus, the
consequences of any accident previously evaluated are not increased.
Therefore, the proposed change does not involve a significant
increase in the probability or consequences of an accident
previously evaluated.
Criterion 2--The Proposed Change Does Not Create the Possibility of a
New or Different Kind of Accident from any Accident Previously
Evaluated
The proposed change does not impact the accident analysis. The
proposed change does not alter the required mitigation capability of
the CRE emergency ventilation system, or its functioning during
accident conditions as assumed in the licensing basis analyses of
design basis accident radiological consequences to CRE occupants. No
new or different accidents result from performing the new
surveillance or following the new program. The proposed change does
not involve a physical alteration of the plant (i.e., no new or
different type of equipment will be installed) or a significant
change in the methods governing normal plant operation. The proposed
change does not alter any safety analysis assumptions and is
consistent with current plant operating practice. Therefore, this
change does not create the possibility of a new or different kind of
accident from any accident previously evaluated.
Criterion 3--The Proposed Change Does Not Involve a Significant
Reduction in the Margin of Safety
The proposed change does not alter the manner in which safety
limits, limiting safety system settings or limiting conditions for
operation are determined. The proposed change does not affect safety
analysis acceptance criteria. The proposed change will not result in
plant operation in a configuration outside the design basis for an
unacceptable period of time without compensatory measures. The
proposed change does not adversely affect systems that respond to
safely shut down the plant and to maintain the plant in a safe
shutdown condition. Therefore, the proposed change does not involve
a significant reduction in a margin of safety.
Based upon the reasoning presented above and the previous
discussion of the amendment request, the requested change does not
involve a no-significant-hazards consideration.
Dated at Rockville, Maryland, this 9th day of January, 2007.
For the Nuclear Regulatory Commission.
Timothy J. Kobetz,
Branch Chief, Technical Specifications Branch, Division of Inspection
and Regional Support, Office of Nuclear Reactor Regulation.
The following model License Amendment Request (LAR) was prepared
by the NRC staff to facilitate use of the Consolidated Line Item
Improvement Process (CLIIP). The model provides the expected level
of detail and content for an application to revise plant technical
specifications according to TSTF-448, ``Control Room Habitability,''
Revision 3, using the CLIIP. Each licensee remains responsible for
ensuring that its actual application fulfills its administrative
requirements as well as Nuclear Regulatory Commission regulations.
U.S. Nuclear Regular Commission,
Document Control Desk,
Washington, DC 20555.
Subject: Plant Name
Docket No. 50-
Application To Revise Technical Specifications Regarding Control
Room Envelope Habitability in Accordance With TSTF-448, Revision 3,
Using the Consolidated Line Item Improvement Process
Gentlemen:
In accordance with the provisions of 10 CFR 50.90 [LICENSEE] is
submitting a request for an amendment to the technical
specifications (TS) for [PLANT NAME, UNIT NOS.].
The proposed amendment would modify TS requirements related to
control room envelope habitability in accordance with TSTF-448,
Revision 3.
Attachment 1 provides a description of the proposed changes, the
requested confirmation of applicability, and plant-specific
verifications. Attachment 2 provides the existing TS pages marked up
to show the proposed changes. [Attachment 3 provides revised (clean)
TS pages.] [Attachment [4] provides a summary of the regulatory
commitments made in this submittal.] Attachment [5] provides
existing TS Bases pages marked up to show the proposed changes.
[LICENSEE] requests approval of the proposed License Amendment
by [DATE], with the amendment being implemented [BY DATE OR WITHIN X
DAYS].
In accordance with 10 CFR 50.91, a copy of this application,
with attachments, is being provided to the designated [STATE]
Official.
I declare [or certify, verify, state] under penalty of perjury
that the foregoing is true and correct. (Note that request may be
notarized in lieu of using this oath or affirmation statement).
If you should have any questions regarding this submittal,
please contact [NAME, TELEPHONE NUMBER].
Sincerely,
[Name, Title]
Attachments:
1. Description and Assessment
2. Proposed Technical Specification Changes (Mark-Up)
[3. Revised Technical Specification Pages]
[[4]. Regulatory Commitments]
[5]. Proposed Technical Specification Bases Changes (Mark-Up)
cc: NRC Project Manager
----NRC Regional Office
----NRC Resident Inspector
----State Contact
Attachment 1--DESCRIPTION AND ASSESSMENT
1.0 Description
The proposed amendment would modify technical specification (TS)
requirements related to control room envelope habitability in TS
3.7.[10], [``Control Room Envelope Emergency Ventilation System
(CREEVS)''] and TS Section 5.5, [``Administrative Controls--
Programs.'']
The changes are consistent with Nuclear Regulatory Commission
(NRC) approved Industry/Technical Specification Task Force (TSTF)
STS change TSTF-448 Revision 3. The availability of this TS
improvement was published in the Federal Register on [DATE] as part
of the consolidated line item improvement process (CLIIP).
2.0 Assessment
2.1 Applicability of Published Safety Evaluation
[LICENSEE] has reviewed the safety evaluation dated [DATE] as
part of the CLIIP. This review included a review of the NRC staff's
evaluation, as well as the supporting information provided to
support TSTF-448. [LICENSEE] has concluded that the justifications
presented in the TSTF proposal and the safety evaluation prepared by
the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this
amendment for the incorporation of the changes to the [PLANT] TS.
[[Page 2033]]
2.2 Optional Changes and Variations
[LICENSEE] is not proposing any variations or deviations from
the TS changes described in the TSTF-448, Revision 3, or the
applicable parts of the NRC staff's model safety evaluation dated
[DATE].
Note: The Applicant should state which parts of Section 3.0 of
the model SE are applicable to its facility, since these sections
contain variations based on the plant-specific design and existing
TS requirements.
]2.3 License Condition Regarding Initial Performance of New
Surveillance and Assessment Requirements
[LICENSEE] proposes the following as a license condition to
support implementation of the proposed TS changes:
Upon implementation of Amendment No. xxx adopting TSTF-448,
Revision 3, the determination of control room envelope (CRE)
unfiltered air inleakage as required by SR 3.7.[10].[4], in
accordance with TS 5.5.[18].c.(i), the assessment of CRE
habitability as required by Specification 5.5.[18].c.(ii), and the
measurement of CRE pressure as required by Specification 5.5.[18].d,
shall be considered met. Following implementation:
(a) The first performance of SR 3.7.[10.5], in accordance with
Specification 5.5.[18].c.(i), shall be within the specified
Frequency of 6 years, plus the 15-month allowance of SR 3.0.2, as
measured from [date], the date of the most recent successful tracer
gas test, as stated in the [date] letter response to Generic Letter
2003-01, or within the next 15 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.[18].c.(ii), shall be within 3
years, plus the 9-month allowance of SR 3.0.2, as measured from
[date], the date of the most recent successful tracer gas test, as
stated in the [date] 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 measurement of CRE
pressure, Specification 5.5.[18].d, shall be within [18] months,
plus the [138] days allowed by SR 3.0.2, as measured from [date],
the date of the most recent successful pressure measurement test, or
within [138] days if not performed previously.
3.0 Regulatory Analysis
3.1 No Significant Hazards Consideration Determination
[LICENSEE] has reviewed the proposed no significant hazards
consideration determination (NSHCD) published in the Federal
Register as part of the CLIIP. [LICENSEE] has concluded that the
proposed NSHCD presented in the Federal Register notice is
applicable to [PLANT] and is hereby incorporated by reference to
satisfy the requirements of 10 CFR 50.91(a).
[3.2 Commitments]
[Note: The Applicant should state regulatory commitments
proposed in support of this LAR, if any, in this section, and
restate them in optional Attachment 4.]
4.0 Environmental Evaluation
[LICENSEE] has reviewed the environmental evaluation included in
the model safety evaluation dated [DATE] as part of the CLIIP.
[LICENSEE] has concluded that the staff's findings presented in that
evaluation are applicable to [PLANT] and the evaluation is hereby
incorporated by reference for this application.
Attachment 2--Proposed Technical Specification Changes (Mark-Up)
[Attachment 3--Revised Technical Specification Pages]
[Attachment 4--Regulatory Commitments]
The following table identifies those actions committed to by
[LICENSEE] in this document. Any other statements in this submittal
are provided for information purposes and are not considered to be
regulatory commitments. Please direct questions regarding these
commitments to [CONTACT NAME].]
------------------------------------------------------------------------
REGULATORY COMMITMENTS DUE DATE/EVENT
------------------------------------------------------------------------
------------------------------------------------------------------------
Attachment 5--Proposed Changes to Technical Specification Bases Pages
(Mark-Up)
[FR Doc. E7-503 Filed 1-16-07; 8:45 am]
BILLING CODE 7590-01-P