1 Control Room Habitability Program James A. Carlson, Omaha Public Power District, Author Deep Ghosh, Southern Nuclear Operating Greg Holbrooks, PE, Duke Energy

2 NHUG CRH Program Guide Control Room Habitability Program

3 Status The latest revision of the document will be available on NHUGweb.org The document has been reviewed at previous NHUG meetings and by others Comments were appropriately incorporated. Is a living document. Refinements should be done after it is used and lessons learned can be adopted.

4 Federal Register - CRE Habitability Program Federal Register / Vol. 72, No. 10 / Wednesday, January 17, 2007 / Notices, pages 2030 & TS 5.5.[18], CRE Habitability Program A CRE Habitability Program TS acceptable to the NRC staff requires the program to contain the following elements: 1. Definitions of CRE and CRE boundary…. 2. Configuration control and preventive maintenance of the CRE boundary. 3. Assessment of CRE habitability at the frequencies stated … of Regulatory Guide 1.197, Revision 0 … and measurement of unfiltered air leakage into the CRE in accordance with … Regulatory Guide 1.197…

5 Federal Register - CRE Habitability Program continued A CRE Habitability Program TS acceptable to the NRC staff requires the program to contain the following elements: 4. Measurement of CRE pressure with respect to all areas adjacent to the CRE boundary… 5. Quantitative limits on unfiltered inleakage…. 6. …the program states that the provisions of SR are applicable to the program frequencies for performing the activities… 7. …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 shall apply to program frequencies….

6 Guidance Documents Tech Specs Amendments & TSTF-448. RG guide assesses CRH configuration control. RG addresses testing of the Control Room Boundary. NEI to ensure CRH program meets regulatory guidance.

7 CRH Program Content is All Inclusive Purpose and Scope States Applicability Definitions Responsibilities CRH Evaluation CRH Program References Attachments

8 Comments on CRH Program Document The following slides address the comments and how they were incorporated. Comments are in Red. Responses are in Blue.

9 Conformance to NEI 99-03, Revision 0 is Complete Comment: NEI 99-03, Revision 0 is the only version that will be reviewed by NRC. Response: The Control Room Habitability Program is reconciled with Rev. 0 of NEI Regulatory Guide endorsed, with exceptions, NEI 99–03 Revision 0, dated June 2001 Many aspects of the CRH program are not covered in the NEI document, Rev. 0.

10 Scope Expanded to Discuss the Licensing Aspects. Comment: CRH Program to address RIS  “Inoperable” and “Operable but Degraded”. Scope was expanded to provide an explanation of mitigating actions versus compensatory actions. RG only uses compensatory actions which applies to Operable but Degraded. Mitigating actions added as alternate actions based on test results

11 Section 4: Responsibilities Comment: Where do we address impairment of the CRES. i.e., more than just the boundary? Response: The responsibilities address the program as a whole. The CRHP describes the responsibilities of each principal and functional group for implementing the requirements of this procedure.

12 Section 5: CRHP The Control Room Habitability Program consists of actions that demonstrate that systems and procedures are in place to meet the requirements in compliance Comment: we comply with regulations and conform to guidance. Done, terminology matches use.

13 Section 5.4 Comment: Does the evaluation not determine which chemicals represent reasonable threats and whether the CRE remains habitable? Response: No. This is way beyond the documents intent. Reference Regulatory Guide 1.78.

14 Section Training Requirements “Training is performed to ensure the level of understanding of … personnel.” Add Training to the CRH Program. RG 1.196, “NRC staff endorses training using only the sections of NEI that the staff has endorsed.” That’s it. RG does not provide any real guidance. No additional changes made. This is a site decision.

15 Section 5.5: Boundary Impairment Impairment Permit is always required whenever the boundary is penetrated. Chart is updated to reflect planned activities. Impairment Permit is a guidance control method. Each site to control as appropriate. Old Chart

16 Section 5.5.1: Limitations and Precautions has Questions Barriers with no design basis function (??) in any plant mode do not require a Barrier Impairment Checklist. Paragraph revised All doors may be manually held open for ____ (15) minutes (justification?) … Doors can be manually held open with a Barrier Impairment Checklist for repair up to ____ (14) days (justification?) 10% (are we solid ground??) of the door seal may be removed… Numbers removed and additional guidance provided to obtain values

17 Section 5.6.8: Inleakage Through Doors Analysis should include inleakage for ingress and egress of the Control Rooms (currently assumed as 10 cfm). … Ingress and egress of control rooms with vestibules can assume an unfiltered infiltration airflow rate of 0 cfm Comment: Basis for 0 cfm? Reference to the Reg Guide for the 0 cfm added

18 Section 5.9.2: Comparison to License Basis A system walk down shall be performed to ensure that the actual field configuration agrees with the plant drawings/design. To what extent? All drawings and all specs every assessment, or only those which have changed? – No changes were made. A determination for each site. How much credit is to be given to the design controls? – Allows flexibility. A determination for each site.

19 General Comments There is no mention of differential pressure monitoring in the document. Differential pressure monitoring is now mentioned. There is no mention of on-going local leak testing of penetrations. On-going quantifiable leak testing of penetrations is still not mentioned. Alternate testing guidance is provided and can be used for this.

20 General Comments Recommend we get someone with a licensing background to review this document. Performed by Brian Mann. Brian interfaced w/ NRC representing NEI on TSTF-448.

21 General Comments Comment: After reviewing the draft generic guide dated 4/21/07…we need two different versions. Some plants will adopt TSTF-448 into their Technical Specifications and some will not. This is a guidance document for the industry to use as appropriate for the site’s application of a CRH Program aligned with TSTF-448.

22 Control Room Habitability Program Document Status CONTROL ROOM HABITABILITY PROGRAM NHUG-G-001 : NHUG CRH Program NHUG CRH Program Document Status: Incorporating Comments Notify Jim, Deep or myself with comments. Jim Carlson, Greg Holbrooks, Deep Ghosh, After incorporation of comments, the document will be sent to NHUG Board for approval.

23 The End Jim Carlson deserves credit for a significant amount of work to assist the industry.