[Federal Register: October 17, 2006 (Volume 71, Number 200)]
[Notices]
[Page 61075-61084]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr17oc06-133]
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NUCLEAR REGULATORY COMMISSION
Notice of Opportunity To Comment on Model Safety Evaluation on
Technical Specification Improvement To Modify Requirements Regarding
Control Room Envelope HabitabilityUsing the Consolidated Line Item
Improvement Process
AGENCY: Nuclear Regulatory Commission.
ACTION: Request for comment.
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SUMMARY: Notice is hereby given that the staff of the Nuclear
Regulatory Commission (NRC) has prepared a model safety evaluation (SE)
and model application relating to the modification of technical
specification (TS) requirements regarding the habitability of the
control room envelope (CRE). The NRC staff has also prepared a model
no-significant-hazards-consideration (NSHC) determination relating to
this matter. The purpose of these models is to permit the NRC to
efficiently process amendments that propose to revise the CRE emergency
ventilation system TS action and surveillance requirements for the CRE
boundary, and to add a new TS administrative controls program,
``Control Room Envelope Habitability Program.'' Licensees of nuclear
power reactors to which the models apply could then request amendments,
confirming the applicability of the SE and NSHC determination to their
reactors. The NRC staff is requesting comment on the model SE and model
NSHC determination prior to announcing their availability for
referencing in license amendment applications.
DATES: The comment period expires November 16, 2006. Comments received
after this date will be considered if it is practical to do so, but the
Commission
[[Page 61076]]
is able to ensure consideration only for comments received on or before
this date.
ADDRESSES: Comments may be submitted either electronically or via U.S.
mail. Submit written comments to Chief, Rulemaking, Directives, and
Editing Branch, Division of Administrative Services, Office of
Administration, Mail Stop: T-6 D59, U.S. Nuclear Regulatory Commission,
Washington, DC 20555-0001. Hand deliver comments to: 11545 Rockville
Pike, Rockville, Maryland, between 7:45 a.m. and 4:15 p.m. on Federal
workdays. Copies of comments received may be examined at the NRC's
Public Document Room, 11555 Rockville Pike (Room O-1F21), Rockville,
Maryland. Comments may be submitted by electronic mail to
CLIIP@nrc.gov.
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 standard technical specifications (STS) in a
manner that supports subsequent license amendment applications. 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. This notice solicits comments on a proposed change to
establish more effective and appropriate action, surveillance, and
administrative TS requirements related to maintaining CRE habitability.
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 amendment application made in response to the notice of
availability will be processed and noticed in accordance with
applicable rules and NRC procedures.
This notice involves 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 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 the incoming license amendment applications,
the staff requests that each licensee applying for the changes proposed
in TSTF-448, Rev 3, use the CLIIP. The CLIIP does not prevent licensees
from requesting an alternative approach or proposing the 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 submittal. Instead, licensees desiring significant variations and/
or additional changes should submit a license amendment request (LAR)
that does not claim to adopt TSTF-448, Rev 3.
Public Notices
This notice requests comments from interested members of the public
within 30 days of the date of publication in the Federal Register.
After evaluating the comments received as a result of this notice, the
staff will either reconsider the proposed change or announce the
availability of the change in a subsequent notice (perhaps with some
changes to the safety evaluation or the proposed no significant hazards
consideration determination as a result of public comments). If the
staff announces the availability of the change, licensees wishing to
adopt the change must submit an application in accordance with
applicable rules and other regulatory requirements. For each
application the staff will publish a notice of consideration of
issuance of amendment to facility operating licenses, a proposed no
significant hazards consideration determination, and a notice of
opportunity for a hearing. The staff will also publish a notice of
issuance of an amendment to an operating license to announce the
modification of TS requirements related to CRE habitability, for each
plant that receives the requested change.
Dated at Rockville, Maryland, this 4th day of October, 2006.
For the Nuclear Regulatory Commission.
Timothy J. Kobetz,
Chief, Technical Specifications Branch, Division of Inspection and
Regional Support, Office of Nuclear Reactor Regulation.
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
[[Page 61077]]
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-143xx, 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.
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.
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
[[Page 61078]]
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 control room habitability 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);''
REG-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 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 relatively long 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
[[Page 61079]]
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 reference NEI 99-03, ``Control
Room Habitability Assessment Guidance,'' Revision 1, dated March 2003,
which the NRC staff has not formally endorsed. However, NEI 99-03,
Revision 0 (Reference 6), dated June 2001, has been endorsed through
Regulatory Guide 1.196, ``Control Room Habitability at Light-Water
Nuclear Power Reactors,'' dated May 2003 (Reference 4). Listing
Revision 1 instead of Revision 0 is acceptable because the NRC staff
reviewed the descriptions and justifications of the differences between
Revision 0 and Revision 1, provided in the licensee's application, and
has determined that referencing Revision 1 does not conflict with the
endorsement of Revision 0, as stated in RG 1.196.]
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 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.
< 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.
[[Page 61080]]
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.
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.
The licensee proposed to add a new condition to Action E of TS
3.7.10 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) < for B&W plants if
Evaluation 3 is used>], 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.
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 actions condition 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 refueling and
OPDRVs. Therefore, this change is administrative and acceptable.
[[Page 61081]]
< 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 is adequate for
satisfying 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 NEI 99-03 (Reference 6) and Regulatory Guide
1.196 (Reference 4). Maintaining the CRE boundary in its design
condition provides assurance that its leak-tightness will not
significantly degrade between CRE inleakage determinations.
Assessment of CRE habitability at the frequencies stated in
Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0 (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
[[Page 61082]]
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 xxxx]. 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,'' 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, Revision 0, ``Control Room Habitability Assessment
Guidance'' datedJune 2001.
Principal contributors: C. Harbuck.
Proposed 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.
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 theProbability 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 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
[[Page 61083]]
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 an 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 4 day of October, 2006.
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 Example Of An Application 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 According To Tstf-448, Revision 3,
Technical Specifications Regarding Control Room Envelope Habitability
Using Cliip. Licensees Remain Responsible For Ensuring That Their
Actual Application Fulfills Their 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 change, the
requested confirmation of applicability, and plant-specific
verifications. Attachment 2 provides the existing TS pages marked up to
show the proposed change. Attachment 3 provides revised (clean) TS
pages. Attachment 4 provides a summary of the regulatory commitments
made in this submittal.
[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 under penalty of perjury under the laws of the United
States of America that I am authorized by [LICENSEE] to make this
request and 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
3. Revised Technical Specification Pages
4. Regulatory Commitments
5. Proposed Technical Specification Bases Changes
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.
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 NRC staff's
model safety evaluation dated [DATE].
[Note: The Applicant should choose one of the following.]
[LICENSEE] proposes to reference NEI 99-03, Revision 0, dated June
2001, in the TS bases for TS 3.7.[10], instead of Revision 1, dated
March 2003, because the NRC has not formally endorsed Revision 1.
[LICENSEE] proposes to reference NEI 99-03, Revision 1, dated March
2003, in the TS bases for TS 3.7.[10], and provides the following
descriptions and justifications of the differences with Revision 0,
dated June 2003. These justifications demonstrate that referencing
Revision 1 does not conflict with the positions taken by the NRC staff
in its endorsement of Revision 0 as stated in Regulatory Guide 1.196,
``Control Room Habitability at Light-Water Nuclear Power Reactors,''
dated May 2003.
[Insert descriptions and justifications for differences between
Revision 0 and Revision 1 here.]
[[Page 61084]]
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 Verification and Commitments
As discussed in the notice of availability published in the Federal
Register on [DATE] for this TS improvement, plant-specific
verifications were performed as follows:
1. [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.
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.]
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--Proposed Technical Specification Pages
Attachment 4--List of 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
------------------------------------------------------------------------
[LICENSEE] commits to the guidance of NEI [Ongoing or implement with
99-03, Revision 0, ``Control Room amendment].
Habitability Assessment Guidance'' dated
June 2001, which provides guidance and
details on the assessment and management
of control room envelope (CRE)
habitability.
[LICENSEE] will revise procedures to [Implement with amendment].
implement the new surveillance and
programmatic TS requirements related to
CRE habitability.
[LICENSEE] commits to Regulatory Positions [Implement with amendment].
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.]
------------------------------------------------------------------------
Attachment 5--Proposed Changes to Technical Specification Bases Pages
[FR Doc. E6-17246 Filed 10-16-06; 8:45 am]
BILLING CODE 7590-01-P