HNP-03-089, Response to Generic Letter 2003-01, Control Room Habitability, Sixty-Day Response
| ML032260531 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/11/2003 |
| From: | Scarola J Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-03-001, HNP-03-089 | |
| Download: ML032260531 (4) | |
Text
Progress Energy Vice President Harris Nuclear Plant Progress Energy Carolinas, Inc.
AUG 1 1 2003 Serial: HNP03-089 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / LICENSE NO. NPF-63 GENERIC LETTER 2003-01, "CONTROL ROOM HABITABILITY" SIXTY-DAY
RESPONSE
Ladies and Gentlemen:
The Requested Response section of Generic Letter 2003-01, "Control Room Habitability" provides the following guidance for 60-day responses:
If an addressee cannot provide the information or cannot meet the requested completion date, the addressee should submit a written response indicating this within 60 days of the date of this generic letter. The response should address any alternative course of action the addressee proposes to take, including the basis for the acceptability of the proposed alternative course of action and the schedule for completing the alternative course of action.
The Harris Plant (HNP) is submitting this 60-day response because certain requested information will not be available for submittal by the 180-day response date.
With the exception of the confirmations provided by inleakage testing, HNP plans to provide confirmation by the 180-day response date that the HNP control room meets the applicable habitability regulatory requirements and that the Control Room Habitability System (CRHS) is designed, constructed, configured, operated, and maintained in accordance with the design and licensing bases. Also, HNP plans to provide in the 180-day response, a schedule for applicable revisions to our technical specifications. The proposed schedule for submitting the inleakage testing results, and the justification for the proposed schedule are provided below.
P0. Box 165 New Hill, NC 27562 T> 919.362.2502 F> 919.362.2095 p lV a
U. S. Nuclear Regulatory Commission Serial: HNP03-089 Page 2 Requested Information Item l(a) states:
That the most limiting unfiltered inleakage into your [control room envelope] CRE (and the filtered inleakage if applicable) is no more than the value assumed in your design basis radiological analyses for control room habitability. Describe how and when you performed the analyses, tests, and measurements for this confirmation.
Requested Information Item 1(b) states in part:
That the most limiting unfiltered inleakage into your CRE is incorporated into your hazardous chemical assessments. This inleakage may differ from the value assumed in your design basis radiological analyses.
In order to quantify the most limiting inleakage, control room air inleakage testing is necessary. HNP anticipates tracer gas testing in the first quarter of 2004, with submittal of the requested information from 1(a) and 1(b) above to the NRC shortly thereafter, not later than July 31, 2004. Inleakage testing will be performed using the method provided in ASTM E741, "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution."
This schedule is justified based on the availability of the preferred testing vendor and the expectation that the tracer gas testing will demonstrate compliance with the HNP CRHS design bases. (Furthermore):
- The preferred vendor is not available until first quarter, 2004.
- HNP has adopted the Alternate Source Term for dose calculations which increased the allowed unfiltered inleakage from 3 to 300 cfm.
- In preparation for tracer gas testing, a walk down of the control room envelope boundary has been conducted with the tracer gas testing vendor.
- The vintage of the HNP CRE and equipment and HNP's maintenance of that equipment is such that a successful test is expected.
o The CRE ductwork is welded construction with companion angle flanges with gaskets.
o Intake valves are "zero leakage" design.
- Per the existing licensing basis, there is not a toxic gas threat and therefore no toxic gas calculations that assume an inleakage value that could potentially be too low.
@ ^- t -I U. S. Nuclear Regulatory Commission Serial: HNP 03-089 Page 3 The enclosure to this letter provides a list of regulatory commitments being made in this submittal. Please refer any questions regarding this submittal to Mr. John R. Caves, Supervisor - Licensing/Regulatory Programs, at (919) 362-3137.
Sincerely, James Scarola James Scarola, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief, and the sources of his information are employees, contractors, and agents of Progress Energy Carolinas, Inc.
D&kb-rJJ54 -
U Notary (Seal)
My commission expires: Q-', /- Cv O S JS/rgh
Enclosure:
List of Regulatory Commitments c: Mr. R. A. Musser (NRC Senior Resident Inspector)
Mr. C. P. Patel (NRR Project Manager, NRC)
Mr. L. A. Reyes (NRC Regional Administrator, Region II)
HNP 03-089 Enclosure Page 1 of 1 LIST OF REGULATORY COMMITMENTS Those actions committed to by Progress Energy Carolinas, Inc. (PEC) in this document are identified below. Any other actions discussed in this submittal represent intended or planned actions by PEC. They are described for the NRC's information and are not regulatory commitments.
Committed Item Date Due PEC will complete inleakage testing, performed in accordance July 31, 2004 with American Society for Testing and Materials (ASTM) E741, "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution," and submit the results of this testing.
Text
Progress Energy Vice President Harris Nuclear Plant Progress Energy Carolinas, Inc.
AUG 1 1 2003 Serial: HNP03-089 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / LICENSE NO. NPF-63 GENERIC LETTER 2003-01, "CONTROL ROOM HABITABILITY" SIXTY-DAY
RESPONSE
Ladies and Gentlemen:
The Requested Response section of Generic Letter 2003-01, "Control Room Habitability" provides the following guidance for 60-day responses:
If an addressee cannot provide the information or cannot meet the requested completion date, the addressee should submit a written response indicating this within 60 days of the date of this generic letter. The response should address any alternative course of action the addressee proposes to take, including the basis for the acceptability of the proposed alternative course of action and the schedule for completing the alternative course of action.
The Harris Plant (HNP) is submitting this 60-day response because certain requested information will not be available for submittal by the 180-day response date.
With the exception of the confirmations provided by inleakage testing, HNP plans to provide confirmation by the 180-day response date that the HNP control room meets the applicable habitability regulatory requirements and that the Control Room Habitability System (CRHS) is designed, constructed, configured, operated, and maintained in accordance with the design and licensing bases. Also, HNP plans to provide in the 180-day response, a schedule for applicable revisions to our technical specifications. The proposed schedule for submitting the inleakage testing results, and the justification for the proposed schedule are provided below.
P0. Box 165 New Hill, NC 27562 T> 919.362.2502 F> 919.362.2095 p lV a
U. S. Nuclear Regulatory Commission Serial: HNP03-089 Page 2 Requested Information Item l(a) states:
That the most limiting unfiltered inleakage into your [control room envelope] CRE (and the filtered inleakage if applicable) is no more than the value assumed in your design basis radiological analyses for control room habitability. Describe how and when you performed the analyses, tests, and measurements for this confirmation.
Requested Information Item 1(b) states in part:
That the most limiting unfiltered inleakage into your CRE is incorporated into your hazardous chemical assessments. This inleakage may differ from the value assumed in your design basis radiological analyses.
In order to quantify the most limiting inleakage, control room air inleakage testing is necessary. HNP anticipates tracer gas testing in the first quarter of 2004, with submittal of the requested information from 1(a) and 1(b) above to the NRC shortly thereafter, not later than July 31, 2004. Inleakage testing will be performed using the method provided in ASTM E741, "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution."
This schedule is justified based on the availability of the preferred testing vendor and the expectation that the tracer gas testing will demonstrate compliance with the HNP CRHS design bases. (Furthermore):
- The preferred vendor is not available until first quarter, 2004.
- HNP has adopted the Alternate Source Term for dose calculations which increased the allowed unfiltered inleakage from 3 to 300 cfm.
- In preparation for tracer gas testing, a walk down of the control room envelope boundary has been conducted with the tracer gas testing vendor.
- The vintage of the HNP CRE and equipment and HNP's maintenance of that equipment is such that a successful test is expected.
o The CRE ductwork is welded construction with companion angle flanges with gaskets.
o Intake valves are "zero leakage" design.
- Per the existing licensing basis, there is not a toxic gas threat and therefore no toxic gas calculations that assume an inleakage value that could potentially be too low.
@ ^- t -I U. S. Nuclear Regulatory Commission Serial: HNP 03-089 Page 3 The enclosure to this letter provides a list of regulatory commitments being made in this submittal. Please refer any questions regarding this submittal to Mr. John R. Caves, Supervisor - Licensing/Regulatory Programs, at (919) 362-3137.
Sincerely, James Scarola James Scarola, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief, and the sources of his information are employees, contractors, and agents of Progress Energy Carolinas, Inc.
D&kb-rJJ54 -
U Notary (Seal)
My commission expires: Q-', /- Cv O S JS/rgh
Enclosure:
List of Regulatory Commitments c: Mr. R. A. Musser (NRC Senior Resident Inspector)
Mr. C. P. Patel (NRR Project Manager, NRC)
Mr. L. A. Reyes (NRC Regional Administrator, Region II)
HNP 03-089 Enclosure Page 1 of 1 LIST OF REGULATORY COMMITMENTS Those actions committed to by Progress Energy Carolinas, Inc. (PEC) in this document are identified below. Any other actions discussed in this submittal represent intended or planned actions by PEC. They are described for the NRC's information and are not regulatory commitments.
Committed Item Date Due PEC will complete inleakage testing, performed in accordance July 31, 2004 with American Society for Testing and Materials (ASTM) E741, "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution," and submit the results of this testing.