ML032260616

Day Response to NRC Generic Letter 2003-01: Control Room Habitability

ML032260616
Person / Time
Site:	Grand Gulf
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)

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Operations, Inc.

Port Gbson BiiS 3975c

.71.1 601 437 6470 3irector Nuclear Satety Assiirmce GNRO-2003100045 August 1 I, 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-2003100056 from 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, 01 is 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 a ~ o ~

C o ~ ~ i t ~ e n t § cc:

U. S. Nuclear Regu~ato~

C o ~ m i s s ~ ~ ~

Arljngto~, TX 7601 14005 U. S. Nuclear R e g ~ i a ~ o ~

~ o m m ~ s s ~ o ~

~~shington, D

r. Brian W. Amy,

~issjssippi Department 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 dete~ined that the 1 8 ~ - d a ~

completion s

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e cannot be met at Grand Gulf Nuclear Station (GGNS), Unit 1.

As requested by the generic letter, action via this response.

schedule for ~mpfet~on i

ed a~tema~ve course of ve course of action and a 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 ~ ~ a l ~

onetime actions described in 99-03, Revision 1 (Reference 2) for GGNS. Specifically, these actions are:

on 3 of ME1 0

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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)

Assess and evaluate ~i~ns~ng~des~gn bases an Confirm that limit~ng DBA has been used to as Assess and evaluate potentia sources of ~azardous c chemicals surveys as necess Assess and evatuate con L room in leakage (3.2.4)

Assess and evaluate con I room during smoke events (3.2.5)

Assess and evaluate the adequacy of existing control room erne ency ~entj~a~ion ana!yses (3.2.1)

CRH design (3.2.2)

I specifications (3.2.6)

(The corresponding Section of will provide the technical and ii Technical S ~ c ~ c a ~ o n changes, License Amendments, or 3, Rev. I is sh od~i~tions,

Tests, Initial Actions Summary Report Following completion of the the results and a plan and s conditions adverse to quati and 1(c), of Generic Letter a report su~marizjn~

disc$e~ncies or parts 1(a), l(b)

3.

BASIS FOR ACCEPTA~ILI The GGNS control mom is a neutral pressure desj maintain low airborne activity levels.

Operating License C o n d i ~ ~ n 2

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.

ith a recjrcu~ating irements are cu

4000 cfm. These ~ n l e a k a ~ e rates are consistent it^ the analysis assumption inleakage of 2000 cfm.

Although no explicit analyses have been pe ConsideratjQns

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oke event, the fo~lowi 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 p l e egress paths are available out of the ~ o n ~ o ~

room to these afternate shutdown rooms. The cont m has mul~ple exits at least one exit th the east and west sides of the can be taken to rooms. Access to each alternate shutdown room separate fire areas.

Outside of each exi re is a stairvvelf levation of the alternate shut each of these stairwells is th

• The operators are trained in the use of se staged in the control room envelope.

The GGNS control room has been tested usi inleakage rate of 435 cfm. Consi information that confirms the GG and is hereby respQnding to GL 2003-01 within concern because:

pressurization methods and demon~~rated an s described in GL 2003-I, EOi cannot prQ~ide om meets the a p p l i ~ b l ~ ulatory requirements days. However, ere is no immediate safety 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 which openings are control assume infinite inleakage in is ma~nta~ned via an i n t e g ~ ~

p ince the ~

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rger openings are permitted in 5 consistent with the larger design basis inleakage assumptions The ~ d j o l o g ~ ~ l and toxic gas analyses tain many conservatisms such as worst-case m e t e o ~ l o g ~ ~ l mnditions, micals, core source terms, and

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charcual and HEPA filter e ~ ~ e n ~ ~ e s "

0 Considering the arguments posed by the NRC in GL 2003~00q regarding the inadequacy of pressurization test techniques, EOl commits to perForm the GGNS control an evaluation of the results. There is only a limited n ASTM E-741 (or equivalent^ tracer gas tests. A review; to plan, scheduie and perform the test; an report do~umenting these results y June 30,2005.

room envelope using test methods in accordance with C e 3) and Pe~QfM the design basis

integrity of the control roo will be included with the EOI wiii submit ~ r i ~ e n responses 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 signj~i~nt di~cre~an~es, adverse conditions, require mod~fications, and a control room habitabi~~~

program, as necessary.

5.

SURES No compensato~ measures are necessary to demonstrate ~

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room h ~ b i t a b i l ~ ~

at GG

6.

ILI L DESl GGNS is required to meet Ge 3.1.2.2.10 of the GGNS Upda 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 maintain~ng the control room envelope ~ a b f ~ a ~ i ~ i ~ y is d ~ s ~ s ~ d in the GGNS ~FSAR, S

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6.4.

C) 19 as d o ~ m ~ n t e d in Section Report (UFSAR). The control room operation of that system i

G N R0-~~03/00 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 ~ ~ b i l i ~ y Gui arch 2003.

3. American Society for Testing E74t Standard Test M e t ~ o d ~ l ~ y for

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

4. lndustry/TSTF Standard Technical ~ p e ~ j f j ~ ~ i o n Change Traveler - 448, Control Room Habitability

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

I written report su~marizin f

X i

EOI will prepare and submit to the NRC, a

2. the results of the ~ n ~ t ~ a ~

actions 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 GGNS control room envelope us methods in (Reference results.

June 30,2805 June 30,2005