ML081770004

Issuance of Amendment No. 207 Control Room Habitability in Accordance with TSTF-448-A, Rev 3

ML081770004
Person / Time
Site:	Columbia
Issue date:	06/30/2008
From:	Lyon C NRC/NRR/ADRO/DORL/LPLIV
To:	Parrish J Energy Northwest
Lyon, C F, NRR/DLPM, 415-2296
Shared Package
ML081770002	List: ML081770004 ML081770201
References
TAC MD6207
Download: ML081770004 (11)

Text

June 30, 2008

Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968

SUBJECT:

COLUMBIA GENERATING STATION- ISSUANCE OF AMENDMENT RE: CONTROL ROOM ENVELOPE HABITABILITY (TAC NO. MD6207)

Dear Mr. Parrish:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 207 to Facility Operating License No. NPF-21 for Columbia G enerating Station. The amendment consists of changes to the Technical Specifications (TS) in response to your application dated July 30, 2007.

The amendment revises the TS r equirements related to control room envelope habitability in accordance with TS Task Force (TSTF) traveler TSTF-448, "Control Room Habitability," Revision 3. This TS improvement was made available by the Commission on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process (CLIIP).

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

/RA/

Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-397

Enclosures:

1. Amendment No. 207 to NPF-21

2. Safety Evaluation

cc w/encls: See next page

PkgML081770003,(Amendment ML081770004, License/TS Pgs ML081770201) NRR-058 OFFICE NRR/LPL4/PM NRR/LPL4/LA ITSB/BC OGC NRR/LPL4/BC NAME FLyon GLappert RElliott* NOT REQUIRED THiltz DATE 6/26/08 6/26/08 5/16/2008 ML073130139 6/27/08 Columbia Generating Station

cc:

Chairman Energy Facility Site Evaluation Council P.O. Box 43172 Olympia, WA 98504-3172

Mr. Douglas W. Coleman (Mail Drop PE20)

Manager, Regulatory Programs Energy Northwest P.O. Box 968 Richland, WA 99352-0968

Chairman Benton County Board of Commissioners P.O. Box 190 Prosser, WA 99350-0190

Mr. William A. Horin, Esq.

Winston & Strawn 1700 K Street, N.W.

Washington, DC 20006-3817

Mr. Matt Steuerwalt Executive Policy Division Office of the Governor P.O. Box 43113 Olympia, WA 98504-3113

Ms. Lynn Albin Washington State Department of Health P.O. Box 7827 Olympia, WA 98504-7827Technical Services Branch Chief FEMA Region X 130 - 228th Street, SW Bothell, WA 98021-9796

Mr. Mike Hammond Department of Homeland Security FEMA/REP 130 - 228 th Street SW Bothell, WA 98021-9796

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125

Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 69 Richland, WA 99352-0069

Assistant Director Nuclear Safety and Energy Siting Division Oregon Department of Energy 625 Marion Street NE Salem, OR 97301-3742

Special Hazards Program Manager Washington Emergency Management Div.

127 W. Clark Street Pasco, WA 99301

ENERGY NORTHWEST DOCKET NO. 50-397 COLUMBIA GENERATING STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 207 License No. NPF-21

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

A. The application for amendment by Energy Northwest (the licensee), dated July 30, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the

public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-21 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 207 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented within 150 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Thomas G. Hiltz, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-21 and Technical Specifications

Date of Issuance: June 30, 2008 ATTACHMENT TO LICENSE AMENDMENT NO. 207 FACILITY OPERATING LICENSE NO. NPF-21 DOCKET NO. 50-397

Replace the following pages of the Facility Operat ing License No. NPF-21 and Appendix A, Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

Facility Operating License REMOVE INSERT 3 3 9a 9a

-- 9b Technical Specification REMOVE INSERT 3.7.3-1 3.7.3-1 3.7.3-2 3.7.3-2 3.7.3-3 3.7.3-3

---

3.7.3-4 5.5-13 5.5-13

---

5.5-14

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 207 TO FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397

1.0 INTRODUCTION

By application dated July 30, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072220152), Energy Northwest (the licensee) requested changes to Facility Operating License No. NPF-21 for Columbia Gener ating Station (CGS). The proposed changes would revise the Technical Specification (TS) requirements related to control room envelope habitability in accordance with TS Task Force (TSTF) traveler TSTF-448, "Control Room Habitability," Revision 3. This TS improvement was made available by the U.

S. Nuclear Regulatory Commission (NRC) on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process (CLIIP).

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 appropr iate action, surveillance, and administrative STS require ments related to ensuring the habitability of the control room envelope (CRE).

In 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 CRE unfiltered inleakage at facilit ies indicat ed 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 require ment 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 surveillanc e requirement for your CRE integrity, explain how and at what frequency you confirm your CRE integrity and why this is adequate to demonstrate CRE integrity.

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

Consistent with the traveler as incorporated into NUREG-1433 and NUREG-1434, the licensee proposed revising action and surveillance requirements in Specific ation 3.7.3, "Control Room Emergency Filtration (CREF) System" and adding a new administrative controls program, Specification 5.5.14, "Control Room Envelope Habitability Program." The purpose of the changes is to ensure that CRE boundary operability is maintained and verified through effective surveillance and programmatic requirements, and that appropriate remedial actions are taken in the event of an inoperable CRE boundary.

Some editorial and plant specific changes were incorporated into this safety evaluation resulting in minor deviations from the model safety evaluation text in TSTF-448, Revision 3.

2.0 REGULATORY EVALUATION

2.1 Control Room and Control Room Envelope

NRC Regulatory Gui de 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 lic ensing 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 Emergency Filtration System

The Control Room Emergency Filtration (CREF) system (the term used at CGS for the Control Room Envelope Emergency Ventilation System, 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 CREF system is designed to maintain a habitable environment in the control room envelope for 30 days of continuous occupancy after a Design Basis Accident (DBA) without personnel exceeding radiation exposures of 5 rem total effective dose equivalent (TEDE) dose.

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

• Filter unit 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

• Control Room recirculation fan is operable; and

• CRE boundary is operable (the single boundary supports both subsystems).

The CRE boundary is considered operable when the measured unfiltered air inleakage is less than or equal to the inleakage value assumed by the licensing basis analyses of design basis accident consequences to CRE occupants.

2.3 Regulati ons 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 Utilizati on Facilities," General Desi gn Criteria (G DC) 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 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 Control Room Emergency Filtration subsystem can maintain a positive pressure of 1/8 inches of water, relative to the areas adjacent to the CRE during the pressurization mode of operation at a flow rate of 1000 cubic feet per minute. Facilities that pressurize the CRE during the emergency mode of operation of the Control Room Ventilation System have similar surveillance r equirements. 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 differ ential 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 surv eillance requirement, the ac tion 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). AL 98-10 further states that "Imposing administrative controls in response to an improper or inadequate TS is considered an acceptable short-term corrective action. The staff expects that, following the imposition of administrative controls, an amendment to the TS, with appropriate justification and schedule, will be submitted in a timely fashion."

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

However, based on GL 2003-01 and AL 98-10, the staff expects each licensee to propose TS changes that include a surveillance to periodically measure CRE unfiltered inleakage in order to satisfy 10 CFR 50.36(d)(3), which requires a facility's TS to include 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 fac ilities to propose unambiguous remedi al actions, consistent with 10 CFR 50.36(d)(2), for the condition of not meeting the limiting condition for operation (LCO) due to an inoperable CRE boundary. The action requirements should specify a reasonable

completion time to restore conf ormance to the LCO bef ore requiring a facility to be shut down. The 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 CGS

Adoption of TSTF-448, Revision 3, will assure that the facility's TS LCO for the CREF system is met by demonstrating unfiltered leakage into the CRE is within limits; i.e., the operability of the CRE boundary. In support of this surveillance, which specifies the test interval (frequency) described in Regulatory Guide 1.197, TSTF-448 also adds TS administrative controls to assure the habitability of the CRE between performances of the CRE unfilter ed inleakage test. In addition, adoption of TSTF-448 will establish clearly stated and reas onable requi red 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 CREF system and the CRE boundary conform to 10 CFR 50.36(d)(2) and 10 CFR 50.36(d)(3). Their adoption will better assure that the CGS CRE will remain habi table duri ng normal oper ation 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 pressurization mode of the CREF system at CGS pressurizes the CRE to minimize unfiltered air inleakage. The proposed changes are consistent with this design.

3.1 Proposed Changes

The proposed amendment would strengthen CRE habitability TS requirements by changing TS 3.7.3, "Control Room Emergency Filtration System," and adding a new TS administrative

controls program on CRE habitability. Accompanying the proposed TS changes are appropriate conforming technical changes to the TS Bases. The proposed revision to the Bases also includes editorial and administrative changes to reflect applicable changes to the corresponding STS Bases, which were made to improve clarity, conform with the latest information and references, correct factual errors, and achieve more consistency among the STS NUREGs.

Except for plant specific differences, all of these changes are consistent with STS as revised by TSTF-448, Revision 3.

The NRC staff compared the proposed TS changes to the STS and the STS markups and evaluations in TSTF-448. The NRC staff verified that differences from the STS were adequately justified on the basis of plant-specific design or retention of current licensing basis. The NRC staff also reviewed the proposed changes to the TS Bases for consistency with the STS Bases and the plant-specific design and licensing bases, although approval of the Bases is not a condition for accepting the proposed amendment. However, TS 5.5.10, "TS Bases Control

Program," prov ides assurance t hat the licensee has established and will maintain the adequacy of the Bases. The proposed Bases for TS 3.7.3 refer to specific guidance in NEI 99-03, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001 (Reference 6), which the NRC staff has formally endorsed, with exceptions, through Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," dated May 2003 (Reference 4).

3.2 Editorial Changes

The licensee proposed editorial changes to TS 3.7.3, "Control Room Emergency Filtration," to establish standard terminology, such as "control room envelope (CRE)" in place of "control room," except for the plant-specific name for the CREF. The licensee also proposed "radiological, chemical, and smoke hazards (or challenges)" in place of various phrases to describe the hazards that CRE occupants are protected from by the CREF. The changes improve the usability and quality of the presentation of the TS, have no impact on safety, and therefore, are acceptable.

3.3 TS 3.7.3, "Control Room Emergency Filtration System"

The licensee proposed to revise the action requirements of TS 3.7.3, "CREF," to acknowledge that an inoperable CRE boundary, depending upon the location of the associated degradation, could cause just one, instead of both CREF subsystems to be inoperable. This is accomplished by revising Condition A to exclude Condition B, and revising Condition B to address one or more CREF subsystems, as follows:

• Condition A One CREF subsystem inoperable for reasons other than Condition B.

• Condition B One or more CREF subsystems inoperable due to inoperable CRE boundary in MODE 1, 2, or 3.

The change clarifies how to apply the action requirements in the event just one CREF subsystem 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 present ation 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that in the event of a DBA, CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA 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 duri ng this time period, and the use of miti gating actions as directed by Required Action B.1. The 90-day Completion Time of new Required Action B.3 is

reasonable based on the determinati on 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.

The licensee proposed to add a new condition to Action F of TS 3.7.3 that states, "One or more CREF subsystems inoperable due to an inoperable CRE boundary during OPDRVs [operations with a potential for draining the reactor vessel]." The licensee stated that this change is consistent with Section 3.3 - Evaluation 5 of the TSTF-448, Revision 3 Model Safety Evaluation, with one minor difference. TSTF-448, Revision 3 includes the phrase "during movement of irradiated fuel assemblies." By letter dated November 27, 2006 (Reference 8), NRC issued License Amendment No. 199 to the licensee approving the use of an alternative source term (AST) in design basis radiological analyses pursuant to 10 CFR 50.67 at CGS. As the revised Fuel Handling Accident (FHA) analysis no longer credits CREF for mitigation, the need to ensure CREF operability during fuel handling activities is not required. Reference to TS controls on CREF operability during fuel movement was eliminated as part of AST implementation. This has also resulted in minor differences within the proposed CGS TS Bases language when compared to TSTF-448 TS Bases language. The specified Required Actions proposed for this condition are the same as for the other existing condition for Action F, which states, "Two CREF subsystems inoperable 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. The 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 t he Actions table continues to specify a condition for an inoperable CRE boundary during refueling and OPDRVs. Therefore, this change is administrative and acceptable.

In the pressurization mode of operation, the CREF System 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). The SR requires verifying that one CREF subsystem, operating in the [emergency radiation state], can maintain a pressure of 1/8 inches water gauge, relative to the adjacent rad waste and turbine buildings during the pressurization mode of operation at a makeup flow rate of 1000 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 fa cilities. 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 the licensee' s response to GL 2003-01, dated March 2, 2007, the licensee reported that it had determined t hat the CGS CRE pressurization surveillance, SR 3.7.3.4, 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 Se ction 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 the current SR 3.7.3.4 is acceptable.

The proposed CRE inleakage measurement SR (new SR 3.7.3.4) states, "Perform required CRE unfiltered air inleakage testing in accordance wi th the Control Room Envelope Habitability Program." The CRE Habitability Program TS, proposed TS 5.5.14, r equires 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). The guidance references ASTM E741 (Reference 2) as an acceptable method for ascertaining the unfiltered leakage into the CRE. The licensee has proposed to follow this method. Therefore, the proposed CRE inleakage measurement SR is acceptable.

3.4 TS 5.5.14, "Control Room Envelope Habitability Program"

The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Revision 3. In combination with the new proposed SR 3.7.3.4, this program is

intended to ensure the operability of the CRE boundary, which as part of an operable Control Room Emergency Filter System will ensure that CRE habitability is mainta ined such that CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under DBA conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident.

A CRE Habitability Program TS acceptable to the NRC staff requi res 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 assu rance 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. This element is intended to

ensure that t he plant assesses CRE habitability consistent with Sections C.1 and C.2 of Regulatory Guide 1.197. Assessing CRE habitability at the NRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not go undetected between CRE inleakage determinations. Determination of CRE inleakage using test methods acceptable to the NRC staff assures that test results are reliable for

ascertaining CRE boundary operability. Determination of CRE inleakage at the NRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not occur between CRE inleakage det erminations.

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 24 months on a staggered test basis (with respect to the CREF System subsystems). 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 oper able in order to meet LCO 3.7.3, will ensure that associ ated 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.

5.14 states that (1) a CRE Habitability Program shall be established and implemented, (2) the program shall include all of the NRC-staff required elements, as described above, and (3) the provisions of SR 3.0.2 shall apply to program frequencies. Therefore, TS 5.5.14, which is consistent with the model program TS approved by the NRC staff in TSTF-448, Revision 3, is acceptable.

3.5 Implementation of New Surveillance and Assessment Requirements by the Licensee

The licensee has proposed license conditions regarding the initial performance of the new surveillance and assessment requirements. The new license conditions adopted the conditions in section 2.3 of the model application published in the Federal Register on January 17, 2007 (72 FR 2022). Plant specific changes were made to these proposed license conditions. The proposed plant specific license conditions are consistent with the model application, and are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Washington State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding

published August 28, 2007 (72 FR 49573). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there

is reasonable assurance that the health and safety of the public will not be endangered by operation in the pr oposed manner, (2) such activities will be conducted in compliance with the Commission's regul ations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. NRC Generic Letter (GL) 2003-01, "Control Room Habitability," dated June 12, 2003.

2. American Society for Testing and Materials (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, Rev.1: Revision to NRC Inspection Manual Part 9900 Technical Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded and Nonconforming Conditions Adverse to Quality or Safety,"

dated April 16, 2008.

4. Regulatory Gui de (RG) 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, dated May 2003.

5. RG 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003.

6. Nuclear Energy In stitute (NEI) 99-03, "C ontrol Room Habitability Assessment Guidance," Revision 0, dated June 2001.

7. Energy Northwest letter to NRC, Final Response to NRC GL 2003-1, "Control Room Habitability," dated March 2, 2007.

8. NRC Letter, "Columbia Generating Station - Issuance of License Amendment No. 199 Re: Changes to Technical Specifications to Replace the Current Accident Source Term Used in Design basis Radiological Analyses," dated November 27, 2006

Principal Contributor: M. Hamm

Date: June 30, 2008