ML040140041
| ML040140041 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/20/2004 |
| From: | Clark R NRC/NRR/DLPM/LPD1 |
| To: | Mecredy R Rochester Gas & Electric Corp |
| Clark R, NRR/DLPM, 415-2297 | |
| References | |
| TAC MB9123 | |
| Download: ML040140041 (9) | |
Text
January 20, 2004 Dr. Robert C. Mecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING R. E. GINNA NUCLEAR POWER PLANT LICENSE AMENDMENT REQUEST RELATING TO THE CONTROL ROOM EMERGENCY AIR TREATMENT SYSTEM MODIFICATION (TAC NO. MB9123)
Dear Dr. Mecredy:
By letter dated May 21, 2003, as supplemented on December 1, 2003, (two letters) Rochester Gas & Electric Corporation submitted a request to revise the Ginna Station Improved Technical Specifications to reflect design modifications to the Control Room Emergency Air Treatment System, and elimination of the requirements for the Containment Post Accident Charcoal Filters. The proposed design modifications are based on the use of the alternate source term.
The Nuclear Regulatory Commission (NRC) staff has reviewed the information and based on our review, we have determined that additional information is required in order for the staff to complete its review. Enclosed is the NRC staffs request for additional information (RAI). This RAI was discussed with your staff on December 18, 2003, and it was agreed that your response would be provided 45 days from the date of this letter.
Sincerely,
/RA/
Robert Clark, Project Manager, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
RAI cc w/encl: See next page
January 20, 2004 Dr. Robert C. Mecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING R. E. GINNA NUCLEAR POWER PLANT LICENSE AMENDMENT REQUEST RELATING TO THE CONTROL ROOM EMERGENCY AIR TREATMENT SYSTEM MODIFICATION (TAC NO. MB9123)
Dear Dr. Mecredy:
By letter dated May 21, 2003, as supplemented on December 1, 2003, (two letters) Rochester Gas & Electric Corporation submitted a request to revise the Ginna Station Improved Technical Specifications to reflect design modifications to the Control Room Emergency Air Treatment System, and elimination of the requirements for the Containment Post Accident Charcoal Filters. The proposed design modifications are based on the use of the alternate source term.
The Nuclear Regulatory Commission (NRC) staff has reviewed the information and based on our review, we have determined that additional information is required in order for the staff to complete its review. Enclosed is the NRC staffs request for additional information (RAI). This RAI was discussed with your staff on December 18, 2003, and it was agreed that your response would be provided 45 days from the date of this letter.
Sincerely,
/RA/
Robert Clark, Project Manager, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
RAI cc w/encl: See next page DISTRIBUTION:
PUBLIC PDI-1 R/F RLaufer SLittle RClark ACRS OGC PRebstock KParczewski JLee HWalker CBixler, R1 BHarvey EMarinos LLund RDennig Accession Number: ML040140041
- See previous concurrence OFFICE PDI-1/PM PDI-1/LA EEIB-A/SC*
EMCB-C/SC*
SPSB-C/SC*
PDI-1/SC NAME RClark SLittle EMarinos LLund RDennig RLaufer DATE 01/15/04 01/15/04 01/15/04 01/15/04 01/15/04 01/20/04 OFFICIAL RECORD COPY
R.E. Ginna Nuclear Power Plant cc:
Kenneth Kolaczyk, Sr. Resident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road Ontario, NY 14519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Peter R. Smith, Acting President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Daniel F. Stenger Ballard Spahr Andrews & Ingersoll, LLP 601 13th Street, N.W., Suite 1000 South Washington, DC 20005 Ms. Thelma Wideman, Director Wayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31 Lyons, NY 14489 Ms. Mary Louise Meisenzahl Administrator, Monroe County Office of Emergency Preparedness 1190 Scottsville Road, Suite 200 Rochester, NY 14624 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223
Enclosure REQUEST FOR ADDITIONAL INFORMATION R. E. GINNA NUCLEAR POWER PLANT CONTROL ROOM EMERGENCY AIR TREATMENT SYSTEM Rochester Gas & Electric Corporation proposed design modifications to the Control Room Emergency Air Treatment System (CREATS) and the Containment Post Accident Charcoal Filters are based on the full scope implementation of the alternate source term (AST). The Nuclear Regulatory Commission (NRC) staff has completed its preliminary review of the license amendment request and has determined that the following additional information is needed to complete its review.
1.
In your submittal, you stated that for the first 30 seconds, before control room ventilation is switched to the recirculating mode, that 2200 cfm of outside air is assumed to leak into the control room and that this in-leakage would be reduced to 300 cfm only after switch over. Please confirm that the HABIT Code analysis for the toxic gas concentration in the control room accounts for the high initial in-leakage rate (2200 cfm) during the first 30 seconds prior to switch over to the recirculating mode.
2.
There is an evident error in the calculated value for peak ammonia concentration.
31.9 g/m3 is an unrealistically high number, much higher than the toxic limit of 210 mg/m3.
3.
Hydrazine and ethanolamine are toxic chemicals with toxicity limits of 50 ppm and 30 ppm, respectively. When their solutions are spilled, toxic vapors released from the spills may pose some risk. Justify why, in spite of the potential risk, they do not need to be evaluated.
4.
In Section 9.0 of Attachment 1 of your submittal dated December 1, 2003, you analyzed the radiological consequence for the locked rotor accident. For this accident, a reactor coolant pump rotor is assumed to seize instantaneously causing a rapid reduction in the flow through the affected reactor coolant system (RCS) loop. The flow imbalance creates localized temperature and pressure changes in the core. If severe enough, these differences may lead to localized boiling and fuel damage. The radiological consequences are due to leakage of the contaminated reactor coolant to the steam generators (SGs) and then releases from the SGs to the environment.
Your radiological consequence analysis for this accident for the Exclusion Area Boundary (EAB) exceeded the dose acceptance criterion of 2.5 rem total effective dose equivalent (TEDE) specified in the Standard Review Plan (SRP) 15.0.1, Radiological Consequence Analyses Using Alternative Source Terms. You conservatively assumed that all of the fuel rods in the core are damaged and that all of its fuel gap activity is released to the RCS as a result of this accident. The NRC staff finds this assumption to be the most conservative based on the staffs experience in performing similar reviews for other reactor plants.
Estimate the percentage of fuel rods that will experience cladding perforation. You may use the minimum departure from nucleate boiling ratio or critical power ratio to estimate the fuel rod damage. Provide re-analyzed radiological consequence.
5.
Provide complete piping and instrument diagrams for the new control room emergency air filtration system to be installed at Ginna.
6.
A number of atmospheric dispersion factors were recalculated using onsite meteorological data collected for the years 1992, 1993, and 1994. The radiological analysis summary states that these data are considered to be typical of any time period and were used in prior submittals. What is the basis for the statement that the data for this 3-year period are typical for any time period and are still representative of site conditions today? For what other previous submittals were these data used?
7.
Identify how stability class was determined. If the stability class is based on onsite delta-temperature measurements, indicate which measurements levels on the tower were used.
8.
A review of the ARCON96 meteorological data input files reveals that the wind speed data are reported in m/sec in increments of 0.0, 0.3, 0.5, 0.8, 1.0, 1.3, 1.5, 1.8, etc. In addition, the joint frequency distribution provided as input to PAVAN shows no occurrences of wind speeds in the 0.6-0.7 m/sec and 1.6-1.7 m/sec ranges. This seems to imply that the wind speed data are being recorded to the nearest 0.25 m/sec (0.56 mph). Explain the data recording and processing procedures that apparently results in reporting wind speed data to the nearest 0.25 m/sec.
9.
A review of the ARCON96 meteorological data input files also shows an unusually low occurrence of unstable conditions (A through C stability classes) during 1994 (5.8% for 1994) as compared to an average of 21.4% for 1992 and 1993. At the same time, there was an unusually high occurrence of E stability during 1994 (47.5%) as compared to an average of 28.7% for 1992 and 1993. Explain what might have caused these differences in atmospheric stability frequency distributions between 1994 and 1992-1993.
10.
A comparison of the overall 1992-1994 wind direction frequency distributions between the ARCON96 meteorological data input files and the PAVAN joint frequency distribution input file shows good agreement (+/-0.1%) for 12 of the 16 sectors (NE clockwise to WNW). However, the following discrepancies occur in the remaining four sectors:
Input File 1992-1994 Wind Direction Frequency Distribution NW NNW N
NNE ARCON96 5.1%
2.4%
3.6%
3.4%
PAVAN 5.3%
2.9%
2.6%
3.6%
Explain what might have cause these discrepancies in the wind direction frequency distributions between these input files, especially for the N and NNW sectors.
11.
The loss-of-coolant accident and the waste gas decay tank rupture accident both assume leakage from the auxiliary building. This release pathway is modeled as a vertical area source for the Control Room (CR) /Q values, which implies the release is homogeneously distributed throughout the auxiliary building and the release rate from the north auxiliary building wall facing the CR intake will be reasonably constant over the surface of the wall. Since leakage is most likely to occur at a penetration, verify that there are no auxiliary building penetrations from which there would be a more limiting (non-area source) release.
12.
The tornado missile accident assumes that a utility pole, propelled by the wind, penetrates the Auxiliary Building roof and impacts fuel stored in the spent fuel pool (SFP). Two cases are evaluated:
Case 1: All activity is released over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The activity released over the first hour is dispersed assuming tornado conditions; the activity released over the second hour is dispersed assuming normal atmospheric conditions.
Case 2: All activity is released over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> assuming tornado conditions.
The CR and EAB /Q values for tornado conditions, 4.36E-5 sec/m3 and 1.74E-6 sec/m3, respectively, were generated using the CONHAB module of the HABIT computer code, assuming F stability and a wind speed of 24.5 m/sec. The wind speed used was apparently based on the maximum hourly wind speed recorded onsite during 1992.
The CR and EAB /Q values used to represent normal atmospheric conditions were 1.45E-3 sec/m3 and 4.8E-4 sec/m3, respectively.
The initiating event for this accident is the occurrence of a tornado which generates a missile and damages fuel in the SFP. The tornado itself is an isolated event, and it is unlikely that high wind speeds associated with the tornado will persist for the assumed 1-hour duration of the release after the tornado strikes. Re-evaluate the CR and EAB
/Q values used to disperse the activity during the first hour of this release utilizing more realistic (bounding) wind speed conditions. Also provide the basis for the CR /Q value of 1.45E-3 sec/m3 which was used to represent normal atmospheric conditions during the second hour of this release.
13.
In Section 5.5.10.b, Control Room Emergency Air Treatment System of the Ginna Administrative Controls you proposed to change the demonstration requirement of the pressure drop across the combined high efficiency particulate air filters, the pre-filters, the charcoal absorbers, and the post-filters to less than 14 inches of water from less than 3 inches of water at a design flow rate. Provide the technical basis for the proposed 14 inches of water. You may find appropriate guidance in Section 8.0, Airflow Capacity, Distribution, and Residence Time Tests of American National Standards Institute, N510-1975, The Testing Of Nuclear Air-Cleaning Systems.
14.
In Section 5.5.10, Ventilation Filter Testing Program (VFTP) of the Ginna Administrative Controls, you stated that the test method will be in accordance with Regulatory Guide (RG) 1.52, Revision 2. In Sections 5.5.10.a, Containment Recirculating Fan Cooler Systems, and 5.5.10.b, Control Room Emergency Air Treatment System, you proposed an in-place Freon test of the charcoal absorber bank to show a penetration and system bypass less than 1% when tested under ambient conditions. This proposal is contrary to the guidance provided (less than 0.05%) in RG 1.52. Discuss the difference. For instances, where 1% bypass is assumed, the credited filter efficiency should be reduced by 1%.
15.
Please indicate whether or not the proposed CREATS and the associated controls and actuation system will involve any digital electronics other than inputs from the new control room air intake radiation monitoring system and, possibly, outputs to a digital monitoring system (such as the plant computer). Please clarify whether or not any digital electronics other than the control room air supply radiation monitors will have any influence over the operation or the operability of the proposed CREATS.
16.
If the proposed system and the associated controls and actuation circuits do involve digital electronics, please describe the digital electronics in detail, including the intended and limiting influence that they might exert over the operation and operability of the proposed system, controls, and actuation circuits. Please show that all associated hardware and software have been subjected to appropriate Verification & Validation (V&V). Please provide copies of the associated Failure Modes and Effects Analyses.
Please note that the requirements concerning such digital electronics would be similar to those applicable to the CREATS control room air intake radiation monitors.
17.
Please confirm that the proposed modifications will have no impact upon the digital system hardware and software for the recently-accepted control room air intake radiation monitors. Alternatively, if it is intended that there be some interface with the digital system other than by connection to digital system signal output contacts, describe the interface in detail and show that the alterations have received appropriate V&V.
Note that any such alteration could invalidate the existing Safety Evaluation Report for that system and require re-evaluation.
- 18., page 1 indicates that chlorine monitors will initiate isolation of the Control Room Exclusion Zone (CREZ) in the event of a chlorine release, and that unrestricted influx of chlorine will occur for less than 30 seconds prior to the isolation. Please explain how it is ensured that isolation would be accomplished within the indicated time limit.
19.
The analysis summary for ammonia (Attachment 2, page 2) does not indicate the existence or application of ammonia monitors, but the draft final safety analysis report, Section 6.4.6 (in Attachment 8), indicates that such monitors are present and do initiate automatic CREZ isolation and CREATS actuation. Please clarify whether or not automatic CREZ isolation and CREATS actuation is assumed in the analysis presented in Attachment 2, and indicate the response time considerations applicable to these monitors.
- 20. for limiting condition for operation (LCO) 3.3.6 Condition A: Please include a definition of Emergency Mode in sufficient detail to ensure successful implementation.
21.
Show that the control room air intake radiation monitor sensitivity, response time, and accuracy remain adequate in spite of the change in operating point due to the application of the new source terms.
22.
Calculation DA-EE-2001-013, Revision 0 computes the Analytical Limit (AL) for the in-duct exposure rate as a fixed fraction of the AL for the control room exposure rate.
The AL for the control room exposure rate is derived from the General Design Criteria 19 limit on exposure for control room personnel. The computed values of the exposure rates are based upon some particular set of relative concentrations of various isotopes.
The control room atmosphere is assumed to build to the same isotopic concentrations as the in-duct atmosphere, since isolation might not occur at exposure rates significantly below the AL. The in-duct exposure rate is lower than the control room exposure rate because the in-duct geometry differs significantly from the control room geometry.
Please show that the application of the AST, which will result in changes in the relative isotopic concentrations, will not alter the computed ratio of control room exposure rate to in-duct exposure rate, or revise the calculation as necessary to account for the AST.
23.
Please explain why the exposure ratios computed in Section 7.2.4 of the above-referenced calculation are based upon seemingly random combinations of Dose Equivalent Rate and Exposure Rate data. It would seem more reasonable to combine similar types of data. If types are to be mixed, then why is every possible combination not computed and tested? Note that using Dose Equivalent data alone, the computed ratio of 15.64 would change to 17.07. Using all possible combinations, the ratio would change to 18.62 (Exposure Rate for control room, Dose Equivalent rate for in-duct at 26 inches).
- 24. for Surveillance Requirements (SRs) 3.6.6.8 and SR 3.6.6.9 (changed to
...7 &...8 in this request), specify minimum content and concentration requirement for the NaOH tank. Please indicate how the volume and concentration are to be determined.
- 25. for LCO 3.7.9 (revised numbering): Please confirm that Control room boundary inoperable (Condition B) means both CREATS trains inoperable (see Condition A), and clarify what is meant by compensatory measures in Required Action B.1. Please explain why the entire boundary should be permitted to remain inoperable for longer than a single train is permitted to be inoperable. Please explain why an inoperability of the mechanical equipment should be tolerated longer than inoperability of the associated instrumentation (see LCO 3.3.6).
- 26., Section 7 lists various interfacing systems. Please describe the nature of the signal and electrical interfaces, and specify the nature of the signals. Show that adequate separation and isolation will be maintained. A block diagram sketch showing signal and power connections, separation, and isolation would be helpful.
- 27., Paragraph 13.2.3 accepts the connection of non-safety cables and loads to safety power sources provided only that the connection be isolated in accordance with the requirements of Institute of IEEE [Electrical and Electronics Engineers]
384-1981. Please indicate the specific isolation device types and design provisions that will be applied to such electrical signal and power connections. Please indicate the specific CREATS instrumentation connections that will involve such safety/nonsafety connections.
- 28., Section 16 indicates that various instruments and control devices are to be associated with the new system (such as new control room thermostats per 16.3.1, new charcoal filter discharge temperature sensors per 16.3.3, and the new and existing control switched per 16.4). Please identify all new and existing devices to be incorporated into the CREATS or connected to CREATS equipment, and confirm that each one will be or has been specified and purchased to a Quality Level and qualification requirements appropriate to the application. Please also confirm that each one, along with all associated wiring and accessories, will be or has been installed, separated, and isolated as appropriate from all devices and wiring in other separation groups. Please describe the quality, separation, and isolation provisions applicable to each device.
- 29., Section 18.2 explicitly allows violation of electrical separation criteria.
Please indicate precisely where such violations will occur and why they should be considered acceptable. Show how cross-channel fault propagation and common-cause multichannel failures would be adequately suppressed in the proposed design.
- 30., page 5 indicates that there are no ducts or doors penetrating the South or West walls of the Control Building at the CREZ elevation. The new CREATS will require at least two new wall penetrations to the exterior of the building, and the CREZ is to be extended to include two existing stairwells. Please revise or confirm the Attachment 9 statement concerning ducts and door penetrations in the light of these changes.