NG-05-0049, Response to NRC Generic Letter 2003-001: Control Room Habitability - Design Bases, Licensing Bases and Inleakage Testing Results

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Response to NRC Generic Letter 2003-001: Control Room Habitability - Design Bases, Licensing Bases and Inleakage Testing Results
ML050390308
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 01/28/2005
From: Peifer M
Nuclear Management Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-03-001, NG-05-0049
Download: ML050390308 (6)
v • d • e


Text

Committedto N MxCt e tOperated Duane Arnold Energy Center by Nuclear Management Company, LLC January 28, 2005 NG-05-0049 10 CFR Part 50 Appendix A, GDC 19 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket 50-331 License No.-DPR-49 Generic Letter 2003-01: Control Room Habitabilitv - Desiqn Bases, Licensing Bases and Inleakaae Testing Results

References:

1) U.S. Nuclear Regulatory Commission Letter to NMC, "NRC Generic Letter 2003-01: Control Room Habitability," dated June 12, 2003.

.; 2); .,NM4C Letter~to NIRC, Generic Letter 2003-01: Control Room Habitability 60-Day Respon'se," (NG-03-0579) dated August 11,

-.,i2003,ADAMS Accession No. ML032310414.

3) NM C Letter t' NRC)'Genric Ltt 2003 01: Control Room

,.; .: Habitability - Response To Commitments," dated November 25,

.,2003, ADAMS Accession No. ML033300162.

On June 12, 2003, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2003-01, "Control Room Habitability," requesting information on this subject (Reference 1). On August 11, 2003 (Reference 2), Nuclear Management Company, LLC (NMC) provided a partial response and proposed an alternative course of action for the 60-day response as pesctibediG2003:01 7This-response was-specifically for the Duane Arnold Energy Center (DAEC). On November 25, 2003 (Reference 3), NMC provided a schedule for the completion of the commitments related to compliance with GL 2003-01.

The Enclosure to this letter supplements.the responses to GL 2003-01 provided in Reference 2 and satisfies 4he folio'ing co mitments made in Reference 3:

upeform the ASTM741 tth requested response to Generic Letter Item 1(a)." ... .

"Verify by ASTME741,t, thatnthe .le~ae ai[g has been incorporated into the hazardous chemical assessments ( L 003-01 item 1(b) part 1)."

3277 DAEC Rbad Fai,-lolwa 52324-9785 Telephone: 319.851.7611

A.

USNRC Page 2 "Perform a smoke assessment (GL 2003-01 item 1(b) part 2)."

Summary of Commitments The Enclosure to this letter provides the response to the commitments made for DAEC associated with GL 2003-01. This letter makes no new commitments and revises the following commitment.

The existing commitment requires:

"Development of technical specification changes (and any associated plant modifications) to support requested information GL 2003-01 item 1(c)."

Schedule for Completion: T= September 2004, T+120 days (2)

(2) Technical Specification submittal dates are contingent on timely approval and issuance of the CLIIP for the Technical Specification Task Force (TSTF) - 448 traveler on control room habitability. Completion dates may change based upon any plant modifications determined to be necessary by the testing.

The revised commitment is as follows:

DAEC commits to submit to the NRC proposed changes to the Technical Specifications (and any associated plant modifications) based upon the final, approved version of Technical Specification Task Force (TSTF) - 448, adjusted, as needed, to account for plant-specific DAEC Control Room Envelope design and licensing basis, within 180 days following NRC approval of TSTF-448.

Mark A.

Site Vice President, Duane Arnold Energy Center Nuclear Management Company, LLC Enclosure cc: Administrator, Region IlIl, USNRC Project Manager, Duane Arnold, USNRC Resident Inspector, Duane Arnold, USNRC

Enclosure Duane Arnold Energy Center Response to NRC Generic Letter 2003-01 Design Bases, Licensing Bases and Inleakage Testing Results Generic Letter 2003-01 requests licensees to verify that the most limiting unfiltered in-leakage into the Control Buifding Envelope (CBE) is within the limits assumed in the safety analysis for Control Room Habitability (CRH) and that the most limiting unfiltered in-leakage value is used in the hazardous chemical analysis. It also requests a

__~-qualitative assessment-of-the-effect-on -CRH- for intemal and'extemal sm'oke events.-

Background

Duane Arnold Energy Center (DAEC) has a positive pressure control room and is required by Technical Specifications to maintain greater than or equal to 0.1 inches water gauge during emergency mode operation. Baseline Tracer Gas Testing of the Control Building Envelope (CBE) was performed to quantify unfiltered in-leakage through walls, ceilings, floors, doors, and penetrations during a postulated High Radiation event at DAEC. The Control Building Envelope at the DAEC consists of the HVAC Equipment Room, Control Room, Office, Computer and Back Panel Rooms, Cable Spreading Room, East and West Switchgear Rooms, and Battery Rooms. The basic test methodology used for the tracer gas tests was the constant injection method of ASTM E741. This test establishes conditions within the CBE consistent with those assumed in the accident analyses for the entire period following a design basis Loss-of-Coolant-Accident (LOCA). Generic Letter 2003-01 requests licensees to measure unfiltered inleakage to verify it is within limits assumed in the safety analysis.

At DAEC, this is up to 1000 cfm. To accomplish this testing, Special Test Procedure SpTP #207 was used.

Proto&Power-e-orporation-was-contrcacted to-perform the Engineeri~ng:Evaluation-of -

CRH for Toxic Gas and Smoke Events. The purpose of the evaluation was to perform

  • a screening of potential toxic chemical releases to identify those that may require further analysis for CRH, and to perform that analysis. The contractor also performed a qualitative assessment of the effect on CRH for intemnal or external smoke events.

Page 1 of 4

1. Radiological Consequences and Tracer Gas Testing Results Tracer Gas Testing was successfully completed at the DAEC by NUCON, International. Results were:

Emergency Mode Operation Unfiltered In-leakage Standby Filter Unit (SFU) A 85 +/-25 scfm Standby Filter Unit (SFU) B 84 +/-19 scfm For the Radiological Consequences safety analysis, normal unfiltered ventilation intake is assumed at 3150 scfm for the first four minutes of the Design Basis Accident-(DBA) LOCA at which-time the ventilation automaticallycshiftsaon high radiation to emergency filtered mode with one Standby Filter Unit at a nominal flow rate of 1000 (+/-100) scfm. Unfiltered in-leakage was analyzed between a range of 0- 1000 scfm, SFU mode.

Tracer Gas Testing determined unfiltered in-leakage to be 85 +/-25 scfm and 84

+/-19 scfm respectively for "A"SFU and 'B" SFU. Therefore, the Tracer Gas Test confirms unfiltered in-leakage is within analyzed limits.

Toxic Chemical analysis assumes Normal ventilation mode of 3150 scfm inflow plus 1000 scfm in-leakage, for a total of 4150 scfm, all unfiltered.

Tracer Gas Test in the 'Normal" mode of operation (Recirculation mode) was performed and total flow was 2848 +/- 81 scfm. Therefore, Normal ventilation mode total intake and in-leakage is within analyzed limits for toxic chemical analysis.

Fresh Air mode of control building ventilation operation was tested and determined to be 8392 +/- 240 scfm. This is not a normal mode of operation and is only used for short periods of time. Inthis mode, the system will automatically shift to SFU mode on high radiation. Procedures are in place for a toxic chemical event to shift ventilationtothe-normal.mode,A um.on .SFUs, or-isolate ventilation. Operation in this mode is not assumed in the safety analysis.

Conclusion Tracer Gas testing at DAEC confirmed unfiltered in-leakage in the SFU mode and "Normal" mode total intake are within analyzed limits.

Page 2 of 4

2. Hazardous Chemical Analysis Results Proto-Power Corporation's Engineering Evaluation 04-E09 documents NMC's hazardous chemical assessment at the DAEC. This evaluation was performed in accordance with guidance provided in RG 1.196. RG 1.196 instructs that the evaluation review CRE habitability for toxic gases in accordance with RG 1.78, Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release. Per RG 1.78, onsite hazardous chemicals and offsite stationary and mobile hazardous chemicals, within a 5-mile radius of DAEC, were identified and screened. Detailed analysis was subcontracted and performed by Numerical Applications, Inc (NAI).

_~~ - C ~ o-On-site hazardous chemicals identified by DAEC were screened to RG 1.78 criteria to determine the impact of each chemical on CRH during its release. Of the 28 chemicals screened, sulfuric acid, nitrogen, sodium hydroxide, hydrogen and propane were further evaluated for their impact on CRH. None of the chemical release scenarios analyzed exceeded Immediately Dangerous to Life and Health (IDLH) limits. Therefore, there are no on-site hazardous chemical sources that threaten CRH.

Forty-two identified off-site hazardous chemicals, both stationary and mobile, were also screened to RG 1.78 criteria. Hazardous chemicals that were further evaluated for their impact on CRH are two mobile sources, a cargo tanker carrying anhydrous ammonia traveling on Iowa Highway 94 and a cargo tanker carrying chlorine traveling on Interstate Highway 1-380. None of the chemical release scenarios analyzed exceeded IDLH limits. Therefore, there are no off-site stationary or mobile hazardous chemical sources that threaten CRH.

Conclusion As stated above, there are no on-site or off-site stationary or mobile hazardous

.-...... chemical.sourceshthat-threaten.CRH.,------

Page 3 of 4

3. Qualitative Assessment for Smoke Events RG 1.196 instructs that the habitability assessment for smoke and products of combustion be performed in accordance with Appendix E of NEI-99-03, Control Room Habitability Assessment Guidance. Eight Assessment items per Section 2.6 of RG 1.196 were addressed. Proto-Power Corporation's Engineering Evaluation 04-E09 documents NMC's Qualitative Assessment of Smoke Events at the DAEC.

No items that would impede habitability or prevent operation of the remote shutdown panels and controls for a fire/smoke event originating in the HVAC Equipment Room, Control Room or Cable Spreading Room were identified. For fires external to the Control Room, current procedures allow for Control Room evacuation should conditions exist that threaten CRH. Smoke from a single

... crcredible on:site.fire-will.not enter-both.the.Control and Reactor-Buildings where remote shutdown panels are located. Inthe event of minor smoke intrusion, Operators may use SCBAs, shutdown the Control Room HVAC systems and/or evacuate the Control Room.

Engineering Evaluation 04-E09 identified several recommendations to be reviewed.

These recommendations have been entered into DAEC's Corrective Action Program for evaluation.

Conclusion Assessment items per Section 2.6 of RG 1.196 were addressed in Engineering Evaluation 04-E09, 'Evaluation of CRH Toxic Gas and Smoke Events in Response to NRC GL 2003-01" and concluded that no items were identified that would impede habitability or prevent operation of the remote shutdown panels and controls for a fire/smoke event originating in the HVAC Equipment Room, Control Room or Cable Spreading Room.

Page 4 of 4

Text

Committedto N MxCt e tOperated Duane Arnold Energy Center by Nuclear Management Company, LLC January 28, 2005 NG-05-0049 10 CFR Part 50 Appendix A, GDC 19 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket 50-331 License No.-DPR-49 Generic Letter 2003-01: Control Room Habitabilitv - Desiqn Bases, Licensing Bases and Inleakaae Testing Results

References:

1) U.S. Nuclear Regulatory Commission Letter to NMC, "NRC Generic Letter 2003-01: Control Room Habitability," dated June 12, 2003.

.; 2); .,NM4C Letter~to NIRC, Generic Letter 2003-01: Control Room Habitability 60-Day Respon'se," (NG-03-0579) dated August 11,

-.,i2003,ADAMS Accession No. ML032310414.

3) NM C Letter t' NRC)'Genric Ltt 2003 01: Control Room

,.; .: Habitability - Response To Commitments," dated November 25,

.,2003, ADAMS Accession No. ML033300162.

On June 12, 2003, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2003-01, "Control Room Habitability," requesting information on this subject (Reference 1). On August 11, 2003 (Reference 2), Nuclear Management Company, LLC (NMC) provided a partial response and proposed an alternative course of action for the 60-day response as pesctibediG2003:01 7This-response was-specifically for the Duane Arnold Energy Center (DAEC). On November 25, 2003 (Reference 3), NMC provided a schedule for the completion of the commitments related to compliance with GL 2003-01.

The Enclosure to this letter supplements.the responses to GL 2003-01 provided in Reference 2 and satisfies 4he folio'ing co mitments made in Reference 3:

upeform the ASTM741 tth requested response to Generic Letter Item 1(a)." ... .

"Verify by ASTME741,t, thatnthe .le~ae ai[g has been incorporated into the hazardous chemical assessments ( L 003-01 item 1(b) part 1)."

3277 DAEC Rbad Fai,-lolwa 52324-9785 Telephone: 319.851.7611

A.

USNRC Page 2 "Perform a smoke assessment (GL 2003-01 item 1(b) part 2)."

Summary of Commitments The Enclosure to this letter provides the response to the commitments made for DAEC associated with GL 2003-01. This letter makes no new commitments and revises the following commitment.

The existing commitment requires:

"Development of technical specification changes (and any associated plant modifications) to support requested information GL 2003-01 item 1(c)."

Schedule for Completion: T= September 2004, T+120 days (2)

(2) Technical Specification submittal dates are contingent on timely approval and issuance of the CLIIP for the Technical Specification Task Force (TSTF) - 448 traveler on control room habitability. Completion dates may change based upon any plant modifications determined to be necessary by the testing.

The revised commitment is as follows:

DAEC commits to submit to the NRC proposed changes to the Technical Specifications (and any associated plant modifications) based upon the final, approved version of Technical Specification Task Force (TSTF) - 448, adjusted, as needed, to account for plant-specific DAEC Control Room Envelope design and licensing basis, within 180 days following NRC approval of TSTF-448.

Mark A.

Site Vice President, Duane Arnold Energy Center Nuclear Management Company, LLC Enclosure cc: Administrator, Region IlIl, USNRC Project Manager, Duane Arnold, USNRC Resident Inspector, Duane Arnold, USNRC

Enclosure Duane Arnold Energy Center Response to NRC Generic Letter 2003-01 Design Bases, Licensing Bases and Inleakage Testing Results Generic Letter 2003-01 requests licensees to verify that the most limiting unfiltered in-leakage into the Control Buifding Envelope (CBE) is within the limits assumed in the safety analysis for Control Room Habitability (CRH) and that the most limiting unfiltered in-leakage value is used in the hazardous chemical analysis. It also requests a

__~-qualitative assessment-of-the-effect-on -CRH- for intemal and'extemal sm'oke events.-

Background

Duane Arnold Energy Center (DAEC) has a positive pressure control room and is required by Technical Specifications to maintain greater than or equal to 0.1 inches water gauge during emergency mode operation. Baseline Tracer Gas Testing of the Control Building Envelope (CBE) was performed to quantify unfiltered in-leakage through walls, ceilings, floors, doors, and penetrations during a postulated High Radiation event at DAEC. The Control Building Envelope at the DAEC consists of the HVAC Equipment Room, Control Room, Office, Computer and Back Panel Rooms, Cable Spreading Room, East and West Switchgear Rooms, and Battery Rooms. The basic test methodology used for the tracer gas tests was the constant injection method of ASTM E741. This test establishes conditions within the CBE consistent with those assumed in the accident analyses for the entire period following a design basis Loss-of-Coolant-Accident (LOCA). Generic Letter 2003-01 requests licensees to measure unfiltered inleakage to verify it is within limits assumed in the safety analysis.

At DAEC, this is up to 1000 cfm. To accomplish this testing, Special Test Procedure SpTP #207 was used.

Proto&Power-e-orporation-was-contrcacted to-perform the Engineeri~ng:Evaluation-of -

CRH for Toxic Gas and Smoke Events. The purpose of the evaluation was to perform

  • a screening of potential toxic chemical releases to identify those that may require further analysis for CRH, and to perform that analysis. The contractor also performed a qualitative assessment of the effect on CRH for intemnal or external smoke events.

Page 1 of 4

1. Radiological Consequences and Tracer Gas Testing Results Tracer Gas Testing was successfully completed at the DAEC by NUCON, International. Results were:

Emergency Mode Operation Unfiltered In-leakage Standby Filter Unit (SFU) A 85 +/-25 scfm Standby Filter Unit (SFU) B 84 +/-19 scfm For the Radiological Consequences safety analysis, normal unfiltered ventilation intake is assumed at 3150 scfm for the first four minutes of the Design Basis Accident-(DBA) LOCA at which-time the ventilation automaticallycshiftsaon high radiation to emergency filtered mode with one Standby Filter Unit at a nominal flow rate of 1000 (+/-100) scfm. Unfiltered in-leakage was analyzed between a range of 0- 1000 scfm, SFU mode.

Tracer Gas Testing determined unfiltered in-leakage to be 85 +/-25 scfm and 84

+/-19 scfm respectively for "A"SFU and 'B" SFU. Therefore, the Tracer Gas Test confirms unfiltered in-leakage is within analyzed limits.

Toxic Chemical analysis assumes Normal ventilation mode of 3150 scfm inflow plus 1000 scfm in-leakage, for a total of 4150 scfm, all unfiltered.

Tracer Gas Test in the 'Normal" mode of operation (Recirculation mode) was performed and total flow was 2848 +/- 81 scfm. Therefore, Normal ventilation mode total intake and in-leakage is within analyzed limits for toxic chemical analysis.

Fresh Air mode of control building ventilation operation was tested and determined to be 8392 +/- 240 scfm. This is not a normal mode of operation and is only used for short periods of time. Inthis mode, the system will automatically shift to SFU mode on high radiation. Procedures are in place for a toxic chemical event to shift ventilationtothe-normal.mode,A um.on .SFUs, or-isolate ventilation. Operation in this mode is not assumed in the safety analysis.

Conclusion Tracer Gas testing at DAEC confirmed unfiltered in-leakage in the SFU mode and "Normal" mode total intake are within analyzed limits.

Page 2 of 4

2. Hazardous Chemical Analysis Results Proto-Power Corporation's Engineering Evaluation 04-E09 documents NMC's hazardous chemical assessment at the DAEC. This evaluation was performed in accordance with guidance provided in RG 1.196. RG 1.196 instructs that the evaluation review CRE habitability for toxic gases in accordance with RG 1.78, Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release. Per RG 1.78, onsite hazardous chemicals and offsite stationary and mobile hazardous chemicals, within a 5-mile radius of DAEC, were identified and screened. Detailed analysis was subcontracted and performed by Numerical Applications, Inc (NAI).

_~~ - C ~ o-On-site hazardous chemicals identified by DAEC were screened to RG 1.78 criteria to determine the impact of each chemical on CRH during its release. Of the 28 chemicals screened, sulfuric acid, nitrogen, sodium hydroxide, hydrogen and propane were further evaluated for their impact on CRH. None of the chemical release scenarios analyzed exceeded Immediately Dangerous to Life and Health (IDLH) limits. Therefore, there are no on-site hazardous chemical sources that threaten CRH.

Forty-two identified off-site hazardous chemicals, both stationary and mobile, were also screened to RG 1.78 criteria. Hazardous chemicals that were further evaluated for their impact on CRH are two mobile sources, a cargo tanker carrying anhydrous ammonia traveling on Iowa Highway 94 and a cargo tanker carrying chlorine traveling on Interstate Highway 1-380. None of the chemical release scenarios analyzed exceeded IDLH limits. Therefore, there are no off-site stationary or mobile hazardous chemical sources that threaten CRH.

Conclusion As stated above, there are no on-site or off-site stationary or mobile hazardous

.-...... chemical.sourceshthat-threaten.CRH.,------

Page 3 of 4

3. Qualitative Assessment for Smoke Events RG 1.196 instructs that the habitability assessment for smoke and products of combustion be performed in accordance with Appendix E of NEI-99-03, Control Room Habitability Assessment Guidance. Eight Assessment items per Section 2.6 of RG 1.196 were addressed. Proto-Power Corporation's Engineering Evaluation 04-E09 documents NMC's Qualitative Assessment of Smoke Events at the DAEC.

No items that would impede habitability or prevent operation of the remote shutdown panels and controls for a fire/smoke event originating in the HVAC Equipment Room, Control Room or Cable Spreading Room were identified. For fires external to the Control Room, current procedures allow for Control Room evacuation should conditions exist that threaten CRH. Smoke from a single

... crcredible on:site.fire-will.not enter-both.the.Control and Reactor-Buildings where remote shutdown panels are located. Inthe event of minor smoke intrusion, Operators may use SCBAs, shutdown the Control Room HVAC systems and/or evacuate the Control Room.

Engineering Evaluation 04-E09 identified several recommendations to be reviewed.

These recommendations have been entered into DAEC's Corrective Action Program for evaluation.

Conclusion Assessment items per Section 2.6 of RG 1.196 were addressed in Engineering Evaluation 04-E09, 'Evaluation of CRH Toxic Gas and Smoke Events in Response to NRC GL 2003-01" and concluded that no items were identified that would impede habitability or prevent operation of the remote shutdown panels and controls for a fire/smoke event originating in the HVAC Equipment Room, Control Room or Cable Spreading Room.

Page 4 of 4

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