GNRO-2003/00045, Day Response to NRC Generic Letter 2003-01: Control Room Habitability.

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Day Response to NRC Generic Letter 2003-01: Control Room Habitability.
ML032260616
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 08/11/2003
From: Roberts J
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-03-001, GNRO-2003/00045
Download: ML032260616 (9)
v • d • e


Text

~ ~ t Operations, e r ~ ~Inc.

Port Gbson BiiS 3975c

.71.1 601 437 6470 3irector Nuclear Satety Assiirmce GNRO-2003100045 August 1I, 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

60 Day Response to NRC Generic Letter 2003-01:

Control Room Habitability.

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCE:

Letter GNRI-2003100056from USNRC to All BWR License Holders, NRC Generic Letter 2003-01, Control Room Habitability, dated June 12,2003.

Dear Sir or Madam:

Entergy Operations, Inc. (EOI), as operator of the Grand Gulf Nuclear Station hereby submits a 60-day response to NRC Generic Letter 2003-01 (Reference I).

Entergy Operations, inc., has reviewed the actions requested by NRC Generic Letter 2003-01 and has determined that the 180-day completion schedule cannot be met at Grand Gulf Nuclear Station. Therefore, 01is submitting this 60-day response.

As requested by the Generic Letter, EOI is proposing an alternative course of action. details this proposal and includes the basis for this course of action. Attachment 1 also includes a schedule for the submittal of a response to Item 1 (subparts (a), (b), and (c)) and the responses to items 2 and 3 of the Generic Letter. summarizes the commitments in Attachment 1

GNRO-20 045 Page 2 of 2 Sincerely,

1. 60-day Res nse to NRC Generic Letter 2
2. List of ~ e g ~ l Ca o~~o~ ~i t ~ e n t § cc: U. S. Nuclear R e g u ~ a t o C~o ~ m i s s ~ ~ ~

Arljngto~,TX 760114005 U. S . Nuclear R e g ~ i a ~~ o m

~ m~ss~o~

~ ~ s h i n g t oD n,

r. Brian W. Amy,

~issjssippiDepartment of Health P. 0. Box 1700 Jackson, MS 39215-170 Resident rter)

Mr. N. S. Reynolds Mr. H. L. Thomas

. I rations, Inc. (EOl), RC Generic Letter 2003-01 and has d e t e ~ i n e dthat the 1 8 ~ - d completion a~ s ~ e cannot

~ ~be~meteat Grand Gulf Nuclear Station (GGNS), Unit 1.

As requested by the generic letter, ed a~tema~ve course of action via this response. ve course of action and a schedule for ~ m p f e t ~ o in This letter also provid s the responses to items 2 and neric Letter 2003-0~

2. PROPOSED CTlO EOl proposes to complete each of the i n ~ ~onetime al~ actions described in on 3 of ME1 99-03, Revision 1 (Reference 2) for GGNS. Specifically, these actions are:

Assemble CRH licensing and design bases (3.1.1)

Assemble CRH analyses (3.1.2)

Document CRH licensing and design bases and analyses (3.1-3) s ~ g nan Assess and evaluate ~ i ~ n s ~ n g ~ d ebases ana!yses (3.2.1)

Confirm that limit~ngDBA has been used to as CRH design (3.2.2)

Assess and evaluate potentia sources of ~azardousc chemicals surveys as necess 0 Assess and evatuate con L room in leakage (3.2.4) e Assess and evaluate con I room during smoke events (3.2.5) 0 Assess and evaluate the adequacy of existing control room erne ency ~entj~a~ion I specifications (3.2.6)

(The corresponding Section of 3, Rev. Iis sh will provide the technical and ii o d ~ i ~ t i o nTests, s,

Technical S ~ c ~ c a changes,

~ o n License Amendments, or Initial Actions Summary Report Following completion of the a report s u ~ m a r i z j n ~

the results and a plan and s disc$e~ncies or conditions adverse to quati parts 1(a), l(b) and 1(c), of Generic Letter

3. BASIS FOR ACCEPTA~ILI The GGNS control mom is a neutral pressure desj ith a recjrcu~ating maintain low airborne activity levels. irements are cu Operating License C o n d i ~ ~2 n during MODES 1 through 3 wi (not including ingresslegress leakage of 10 cfm). Before th source term in 1998, this inieakage limit was 590 cfm.

4000 cfm. These ~ n l e a k a rates

~ e are consistent it^ the analysis assumption inleakage of 2000 cfm.

Although no explicit analyses have been p e oke event, the fo~lowi ConsideratjQns s.

Each redundant alternate shutdown panel is located in separate and a acent rooms that are separate fire areas located in the control bu~~ding three elevations below the control room and are outside the control room envelope.

  • ~ u ~ t i pegress le paths are available out of the ~ o n room ~ o to~ these afternate shutdown rooms. The cont m has mul~pleexits at least one exit th the east and west sides of the Outside of each exi re is a stairvvelf can be taken to levation of the alternate shut rooms. Access to each alternate shutdown room each of these stairwells is th separate fire areas.

The GGNS control room has been tested usi pressurization methods and d e m o n ~ ~ r a t ean d inleakage rate of 435 cfm. Consi s described in GL 2003- I, EOi cannot prQ~ide information that confirms the GG om meets the a p p l i ~ b l ~ ulatory requirements and is hereby respQnding to GL 2003-01 within days. However, e r e is no immediate safety concern because:

The GGNS control room has been tested usin pressuri~a~jon methods and demonstrated an inleakage rate of 435 cfm, whi is less than 25% of the 2000 cfm current design basis inleakage value.

The control room envelope is m a ~ n t a ~ n evia d an i n t e g ~p ~

which openings are control ince the ~ d i Q ~ ~ ~ ~ ~

assume infinite inleakage in rger openings are permitted in 5 consistent with the larger design basis inleakage assumptions 0 The ~ d j o l o g and

~ ~ ltoxic gas analyses tain many conservatisms such as worst-case m e t e o ~ l o g ~mnditions,

~l micals, core source terms, and m u ~ and HEPA filter e ~ ~ e n ~ ~ e s "

~ i n ~ charcual Considering the arguments posed by the NRC in GL 2003~00qregarding the inadequacy of pressurization test techniques, EOl commits to perForm the GGNS control room envelope using test methods in accordance with C e 3) and P e ~ Q f M an evaluation of the results. There is only a limited n ASTM E-741 (or equivalent^ tracer g a s tests. A the design basis review; to plan, scheduie and perform the test; a n report do~umentingthese results y June 30,2005.

integrity of the control roo will be included with the EOI wiii submit ~ r i ~ responses e n to items 1, I@), l(b) and 1 (c) later than June 30,2005. This res onse will include a summa^

and assessments described in Section 3 of NEl 99-03, Revision -.l The response will aka include plans and schedules for resoivjng s i g n j ~ i ~dnit~ c r e ~ a n ~adverse es, conditions, require mod~fications,and a control room h a b i t a b i ~

program,

~~ as necessary.

5. SURES No compensato~measures are necessary to demonstrate ~ n t room r ~h ~~b i t a b iatl ~GG

~

6. ILI L DESl GGNS is required to meet Ge C) 19 as d o ~ m ~ n t in e dSection 3.1.2.2.10 of the GGNS Upda Report (UFSAR). The control room vent~latio~ system is designed to maintain the control room nvironment for a 30-day continuous occupancy after a DBA per the requirements of GDC 19. T operation of that system i maintain~ng the control room envelope ~ a b f ~ a ~is id~ ~i ~ sy ~ insthe

~ GGNS d ~ F S A RS, e ~ j ~ ~

6.4.

G NR 0 - ~ ~ 0 3 / 0 0 Page 4 of 4

1. USNRC Generic Letter 2 , June 12,2003.
2. Nuclear Energy institute, El 99-03, Revision 1, Control Room ~ a b i ~ ~ bGui ili~y arch 2003.
3. American Society for Testing E74t Standard Test M e t ~ o d ~forl~y

~ e ~ e ~ i Air n ~Change n g in a Single Zone ans of a Tracer Gas ~ ~ ~ u ~ ~ n

~ i o n Traveler - 448, Control Room

4. lndustry/TSTF Standard Technical ~ p e ~ j f j ~Change Habitability

table i~ent~fiesthose adions corn a l rovided for informati statements in this s u b ~ i ~are . . ses and are not TYPE CO T I

EOI will prepare and submit to the NRC, a X June 30,2805 written report su~marizin i f

2. the results of the ~ n ~actions t ~ a ~ descri Section 3 of NE
2. results of the tracer gas test, and
3. proposed changes to the GGNS Technical Specifications.

EOI proposes to complete each of the initial, one-time actions described in Section 3 of 99-03, Revision 2 {Reference 2) for GGNS.

EOI commits to petfon a tracer June 30,2005 GGNS control room envelope us methods in (Reference results.

Text

~ ~ t Operations, e r ~ ~Inc.

Port Gbson BiiS 3975c

.71.1 601 437 6470 3irector Nuclear Satety Assiirmce GNRO-2003100045 August 1I, 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

60 Day Response to NRC Generic Letter 2003-01:

Control Room Habitability.

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCE:

Letter GNRI-2003100056from USNRC to All BWR License Holders, NRC Generic Letter 2003-01, Control Room Habitability, dated June 12,2003.

Dear Sir or Madam:

Entergy Operations, Inc. (EOI), as operator of the Grand Gulf Nuclear Station hereby submits a 60-day response to NRC Generic Letter 2003-01 (Reference I).

Entergy Operations, inc., has reviewed the actions requested by NRC Generic Letter 2003-01 and has determined that the 180-day completion schedule cannot be met at Grand Gulf Nuclear Station. Therefore, 01is submitting this 60-day response.

As requested by the Generic Letter, EOI is proposing an alternative course of action. details this proposal and includes the basis for this course of action. Attachment 1 also includes a schedule for the submittal of a response to Item 1 (subparts (a), (b), and (c)) and the responses to items 2 and 3 of the Generic Letter. summarizes the commitments in Attachment 1

GNRO-20 045 Page 2 of 2 Sincerely,

1. 60-day Res nse to NRC Generic Letter 2
2. List of ~ e g ~ l Ca o~~o~ ~i t ~ e n t § cc: U. S. Nuclear R e g u ~ a t o C~o ~ m i s s ~ ~ ~

Arljngto~,TX 760114005 U. S . Nuclear R e g ~ i a ~~ o m

~ m~ss~o~

~ ~ s h i n g t oD n,

r. Brian W. Amy,

~issjssippiDepartment of Health P. 0. Box 1700 Jackson, MS 39215-170 Resident rter)

Mr. N. S. Reynolds Mr. H. L. Thomas

. I rations, Inc. (EOl), RC Generic Letter 2003-01 and has d e t e ~ i n e dthat the 1 8 ~ - d completion a~ s ~ e cannot

~ ~be~meteat Grand Gulf Nuclear Station (GGNS), Unit 1.

As requested by the generic letter, ed a~tema~ve course of action via this response. ve course of action and a schedule for ~ m p f e t ~ o in This letter also provid s the responses to items 2 and neric Letter 2003-0~

2. PROPOSED CTlO EOl proposes to complete each of the i n ~ ~onetime al~ actions described in on 3 of ME1 99-03, Revision 1 (Reference 2) for GGNS. Specifically, these actions are:

Assemble CRH licensing and design bases (3.1.1)

Assemble CRH analyses (3.1.2)

Document CRH licensing and design bases and analyses (3.1-3) s ~ g nan Assess and evaluate ~ i ~ n s ~ n g ~ d ebases ana!yses (3.2.1)

Confirm that limit~ngDBA has been used to as CRH design (3.2.2)

Assess and evaluate potentia sources of ~azardousc chemicals surveys as necess 0 Assess and evatuate con L room in leakage (3.2.4) e Assess and evaluate con I room during smoke events (3.2.5) 0 Assess and evaluate the adequacy of existing control room erne ency ~entj~a~ion I specifications (3.2.6)

(The corresponding Section of 3, Rev. Iis sh will provide the technical and ii o d ~ i ~ t i o nTests, s,

Technical S ~ c ~ c a changes,

~ o n License Amendments, or Initial Actions Summary Report Following completion of the a report s u ~ m a r i z j n ~

the results and a plan and s disc$e~ncies or conditions adverse to quati parts 1(a), l(b) and 1(c), of Generic Letter

3. BASIS FOR ACCEPTA~ILI The GGNS control mom is a neutral pressure desj ith a recjrcu~ating maintain low airborne activity levels. irements are cu Operating License C o n d i ~ ~2 n during MODES 1 through 3 wi (not including ingresslegress leakage of 10 cfm). Before th source term in 1998, this inieakage limit was 590 cfm.

4000 cfm. These ~ n l e a k a rates

~ e are consistent it^ the analysis assumption inleakage of 2000 cfm.

Although no explicit analyses have been p e oke event, the fo~lowi ConsideratjQns s.

Each redundant alternate shutdown panel is located in separate and a acent rooms that are separate fire areas located in the control bu~~ding three elevations below the control room and are outside the control room envelope.

  • ~ u ~ t i pegress le paths are available out of the ~ o n room ~ o to~ these afternate shutdown rooms. The cont m has mul~pleexits at least one exit th the east and west sides of the Outside of each exi re is a stairvvelf can be taken to levation of the alternate shut rooms. Access to each alternate shutdown room each of these stairwells is th separate fire areas.

The GGNS control room has been tested usi pressurization methods and d e m o n ~ ~ r a t ean d inleakage rate of 435 cfm. Consi s described in GL 2003- I, EOi cannot prQ~ide information that confirms the GG om meets the a p p l i ~ b l ~ ulatory requirements and is hereby respQnding to GL 2003-01 within days. However, e r e is no immediate safety concern because:

The GGNS control room has been tested usin pressuri~a~jon methods and demonstrated an inleakage rate of 435 cfm, whi is less than 25% of the 2000 cfm current design basis inleakage value.

The control room envelope is m a ~ n t a ~ n evia d an i n t e g ~p ~

which openings are control ince the ~ d i Q ~ ~ ~ ~ ~

assume infinite inleakage in rger openings are permitted in 5 consistent with the larger design basis inleakage assumptions 0 The ~ d j o l o g and

~ ~ ltoxic gas analyses tain many conservatisms such as worst-case m e t e o ~ l o g ~mnditions,

~l micals, core source terms, and m u ~ and HEPA filter e ~ ~ e n ~ ~ e s "

~ i n ~ charcual Considering the arguments posed by the NRC in GL 2003~00qregarding the inadequacy of pressurization test techniques, EOl commits to perForm the GGNS control room envelope using test methods in accordance with C e 3) and P e ~ Q f M an evaluation of the results. There is only a limited n ASTM E-741 (or equivalent^ tracer g a s tests. A the design basis review; to plan, scheduie and perform the test; a n report do~umentingthese results y June 30,2005.

integrity of the control roo will be included with the EOI wiii submit ~ r i ~ responses e n to items 1, I@), l(b) and 1 (c) later than June 30,2005. This res onse will include a summa^

and assessments described in Section 3 of NEl 99-03, Revision -.l The response will aka include plans and schedules for resoivjng s i g n j ~ i ~dnit~ c r e ~ a n ~adverse es, conditions, require mod~fications,and a control room h a b i t a b i ~

program,

~~ as necessary.

5. SURES No compensato~measures are necessary to demonstrate ~ n t room r ~h ~~b i t a b iatl ~GG

~

6. ILI L DESl GGNS is required to meet Ge C) 19 as d o ~ m ~ n t in e dSection 3.1.2.2.10 of the GGNS Upda Report (UFSAR). The control room vent~latio~ system is designed to maintain the control room nvironment for a 30-day continuous occupancy after a DBA per the requirements of GDC 19. T operation of that system i maintain~ng the control room envelope ~ a b f ~ a ~is id~ ~i ~ sy ~ insthe

~ GGNS d ~ F S A RS, e ~ j ~ ~

6.4.

G NR 0 - ~ ~ 0 3 / 0 0 Page 4 of 4

1. USNRC Generic Letter 2 , June 12,2003.
2. Nuclear Energy institute, El 99-03, Revision 1, Control Room ~ a b i ~ ~ bGui ili~y arch 2003.
3. American Society for Testing E74t Standard Test M e t ~ o d ~forl~y

~ e ~ e ~ i Air n ~Change n g in a Single Zone ans of a Tracer Gas ~ ~ ~ u ~ ~ n

~ i o n Traveler - 448, Control Room

4. lndustry/TSTF Standard Technical ~ p e ~ j f j ~Change Habitability

table i~ent~fiesthose adions corn a l rovided for informati statements in this s u b ~ i ~are . . ses and are not TYPE CO T I

EOI will prepare and submit to the NRC, a X June 30,2805 written report su~marizin i f

2. the results of the ~ n ~actions t ~ a ~ descri Section 3 of NE
2. results of the tracer gas test, and
3. proposed changes to the GGNS Technical Specifications.

EOI proposes to complete each of the initial, one-time actions described in Section 3 of 99-03, Revision 2 {Reference 2) for GGNS.

EOI commits to petfon a tracer June 30,2005 GGNS control room envelope us methods in (Reference results.

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