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Control Room Habitability Program

James A. Carlson, Omaha Public Power District, Author

Deep Ghosh, Southern Nuclear Operating Greg Holbrooks, PE, Duke Energy

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NHUG CRH Program Guide

Control RoomHabitability

Program

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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.

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Federal Register - CRE Habitability Program

Federal Register / Vol. 72, No. 10 / Wednesday, January 17, 2007 / Notices, pages 2030 & 2031

3.4 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…

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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

3.0.2 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 3.0.2 shall apply to program frequencies….

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Guidance Documents

Tech Specs Amendments & TSTF-448. RG 1.196 guide assesses CRH

configuration control. RG 1.197 addresses testing of the

Control Room Boundary. NEI 99-03 to ensure CRH program

meets regulatory guidance.

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CRH Program Content is All Inclusive

Purpose and Scope States Applicability Definitions Responsibilities CRH Evaluation CRH Program References Attachments

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Comments on CRH Program Document

The following slides address the comments and how they were incorporated.

Comments are in Red. Responses are in Blue.

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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 99-03. Regulatory Guide 1.196 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.

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Scope Expanded to Discuss the Licensing Aspects. Comment: CRH Program to

address RIS 2005-20 “Inoperable” and “Operable but Degraded”. Scope was expanded to provide an

explanation of mitigating actions versus compensatory actions.

RG 1.196 only uses compensatory actions which applies to Operable but Degraded.

Mitigating actions added as alternate actions based on test results

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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.

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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.

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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.

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Section 5.4.6 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 99-03 that the staff has endorsed.” That’s it.

RG 1.196 does not provide any real guidance. No additional changes made. This is a site decision.

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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.

Barrier is Impaired

Section I: Control Room Boundary

Impairment Permit is Required?

Section II: Compensatory

Actions required?

No

NoYes

Yes

Section IV: Control Room

Boundary Impairment

Permit Approved

Section V: Implement

Compensatory Actions

Section VI: Work Group

Restore Barrier And Test As

RequiredSection VII: Work

Activities Completed And Approved

Exit Control Room Boundary

Impairment Permit

Perform Safety Review

Determination

Section VIII: Remove

Compensatory Actions And Update Log

Old Chart

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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

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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

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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.

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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.

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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.

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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.

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Control Room Habitability Program Document Status

CONTROL ROOM HABITABILITY PROGRAM NHUG-G-001 : NHUG CRH Program 1-7-08

Document Status: Incorporating Comments Notify Jim, Deep or myself with comments. Jim Carlson, jacarlson@oppd.com Greg Holbrooks, gjholbrooks@duke-energy.com Deep Ghosh, dghosh@southernco.com

After incorporation of comments, the document will be sent to NHUG Board for approval.

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The EndJim Carlson

deserves credit for a significant amount of work to assist the industry.