AECM-90-0074, Application for Amend to License NPF-29,providing Clarification of Surveillance Requirement Re Control Room Emergency Filtration Sys

Application for Amend to License NPF-29,providing Clarification of Surveillance Requirement Re Control Room Emergency Filtration Sys

ML20042F751
Person / Time
Site:	Grand Gulf
Issue date:	05/07/1990
From:	Cottle W SYSTEM ENERGY RESOURCES, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20042F752	List: AECM-90-0074, Application for Amend to License NPF-29,providing Clarification of Surveillance Requirement Re Control Room Emergency Filtration Sys ML20042F751 ML20042F754
References
AECM-90-0074, AECM-90-74, NUDOCS 9005090348
Download: ML20042F751 (9)

Text

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Port Orbson, MS 3915o 7 ;;

7-Tel Got 437 6809

' t' s Wl'11am T. Cottle vice Presdeq N"*^' OP'^2*"5 U.S. Nuclear Regulatory Commission Mai1~ Station P1-137

9ashington, D.C..

20555

' Attention:

Document Control Desk Gentlemen:

SUBJECT:

Grand Gulf Nuclear Station J

Unit 1 Docket No. 50-416 License No. NPF-29 Control Room Emergency Filtration' System Requirements Proposed Amendment to the Operating

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License (PCOL-90/05)

.AECM-90/0074-t System Energy Resources, Inc. (SERI) is submitting by this letter a proposed amendment to.the Grand Gulf Nuclear Station (GGNS) Operating License.

This proposed amendment requests a change to-the GGNS Technical Specifications (TS) which would provide clarification of a TS Surveillance Requirement for the control room emergency filtration system. provides the technical justification and discussion to support the requested amendment,

, provides SERI's response to concerns raised by the'NRC l

during an April 13,:1990 telephone conference between SERI.and the_NRC.

The telephone conference was held to discuss several issues related to the proposed TS change.

In accordance with the provisions of 10CFR50.4, the signed original of the requested _ amendment is enclot,ed.

This amendment has been reviewed and accepted by both the Plant Safety Review Committee and the Safety Review Committee.

Based on the guidelines presented in 10CFR50.92, SERI has concluded that this proposed amendment involves no significant hazards considerations.

Yours truly, m 2r hm WTC:mte Attachments:

1.

Affirmation per 10CFR50.30 2.

GGNS PCOL-90/05 3.

Response to NRC Concerns cc:

(See Next Page)

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9005090348 900507 PDR ADOCK 05000416 i

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a AECM-90/0074 N'

Page)2

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-cc: Mr.-D'.C.LHintz(w/a)l_

Mr. T. H. Cloninger (w/a)

Mr. R.; B. McGehee (w/a).

t Mr. N..S. Reynolds (w/a)'

Mr. H. L. Thomas.(w/o)

Mr. H. 0. Christensen (w/a)

Mr.LStewart D. Ebneter (w/a)

Regional Administrator.

'U.S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W.,. Suite 2900

. Atlanta, Georgia 30323

),

Mr. L. L. Kintner,. Project Manager (w/a) l s

Office'of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail.Stup 14B20 Washington, D.C.

20555 Dr. Alton B. Cobb (w/a)

State' Health Oft'icer State Board of Health P.O. Box 1700 Jackson, Mississippi 39205 a

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-BEFORE THE-UNITED. STATES NUCLEAR REGULATORY COMMISSION LICENSE NO NPF-29 DOCKET NO. 50-416 d

IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM-ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION q

AFFIRMATION

'l I, W. T. Cottle,'being. duly sworn, state that I am Vice' President, 1

Nuclear Operations of System Energy Resources, Inc.; that on behalf of System Energy Resources, Inc., and South Mississippi-Electric Power Association I am:

authorized by System Energy Resources, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the 0perating License

-j of the Grand Gulf' Nuclear Station; that I-' signed this application as Vice 1

President, Nuclear Operations of System Energy Resources, Inc.; and-that the 0

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-statements-made and the matters set forth therein are true and correct to the, d

best'of my knowledge, information and belief.

M T~~' h j

W.-T. Cottle STATE OF MISSISSIPPI

' COUNTY OF CLAIBORNE i

SUBSCRIBED AND-SWORN T0 before me, a Notary Public, in and for the County and State above named, this

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day.of' M an

, 1990.

(SEAL) h m',.6 dbese6 nom l

Notary Publ Q ] -

f My commission expires:

My Commnsion Lxpues uf 1,1993 A9004181/SNLICFLR - 4

~ to'AECM-90/0074 a

.A'

. SUBJECT.

1.

NL-90/04 Control Room Emergency Filtration System Requirements 2.

Affected Technical Specification - Control Room Emergency Filtration System:

a.

Surveillance Requirement 4.7.2.d.2 - page 3/4 7-6.

B.

DISCUSSION BACKGROUND On April 3, 1990 during a review of the Inservice, Testing (IST) Program per Generic Letter 89-04 and in conjunction with an operations evaluation of an annunciator problem on a motor operated valve thermal overload

.1 protection device, a discrepancy between the stroke times-listed in UFSAR 1

Table 18.1-2 and the.IST Program for valves 251-F007 and Z51-F016 was-

.i noted.

In addition, it was observed that Technical Specification (TS) j Surveillance Requirement 4.7.2.d.2 did not specify the isolation valves a

subject to the surveillance. Therefore, it was not clear as to whether i

Z51-F007 and Z51-F016 were intended to be tested per TS 4.7.2.d.2.

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The two motor operator valves, Z51-F007 and Z51-F016, are the standby q

fresh air makeup valves associated with the two redundant divisionally separated recirculation units of the control room emergency filtration system and are maintained closed during normal plant operation, h

REP _0RTABLE_ CONDITION.

In dispositioning the above described inconsistency, a-reportable condition was identified on April 26, 1990.

The reportable condition involves the performance of quarterly ASME Section XI stroke time 4

surveillances of the standby fresh air intake valves, Z51-F007 and

l 251-F016 during Operational Conditions 1, 2 or'3.

ASME Section XI-i requires these two valves to be stroke time tested once per quarter j

unless it is impractical.

The control room standby fresh ~ air intake j

valves, 251-F007 and 251-F016 are designed to be remote manually opened j

and closed under administrative controls post-accident.

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Attachment:

2 to AECM-90/0074 The valves must be closed during normal plant operation to ensure the ability to isolate the control room.

Z51-F007 and Z51-F016 are.

appropriately interlocked such that as they are. opening the associated recirculation intake damper is closing.

Considering a coincidentL loss-of-coolant accident with loss-of-offsite-power and the single failure of the associated division _ of-ESF power while stroking either of L

the valves,- Z51-F007 or Z51-F016, the-recirculation intake damper on that train could be partially open with the standby fresh air intake valve partially closed.

Therefore, an unfiltered inleakage path _to the control room could exist. This condition was reported pursuant to 10CRF50.73(a)(2)(v) in LER 90-005-00 dated May 4, 1990.

TS 3/4.7.2 requires two independent control. room emergency filtration -

system subsystems to be operable in all Operational' Conditions and "*"

("*" specifying the condition of when irradiated fuel'is being handled in i

the primary or' secondary containment). The operability of the control room emergency filtration system ensures that the control room will remain habitable for control room. personnel during and following all design basis accidents.

The operability of the system in conjunction with control room design provisions is based on limiting the radiation.

exposure to control room personnel to below the limits of General Design Criterion 19.

Since there is no time during which this system is not required to be operable, surveillances must be performed to appropriately minimize the consequences of potential accidents.

Therefore, the most prudent time to perform stroke time surveillances is during shutdown conditions.

Specifically, surveillances on the 251-F007 and 251-F016 standby fresh air intake valves will be changed to allow performance of them only in Operational Conditions 4 or 5 when core alterations, handling of irradiated fuel in the primary or secondary containment and operations with a potential for draining the reactor vessel are not in progress. Under these circumstances, the probability'of design basis accidents and abnormal operational transients is significantly reduced and the risks associated with an ' inoperable filtration system are negligible.

t TS 3.7.2 requires that when the control room standby fresh air intake valves are less than fully closed both of the control room emergency filtration subsystems are inoperable.

This requirement further minimizes the possibility of having unfiltered inleakage entering the control roolh.

Action a which is applicable in Operational Conditions 1, 2 or 3 does not require modification because the standby fresh air intake valves are normally closed in these Operational Conditions.

If the valves were to be less than fully closed, both subsystems-of the control room emergency filtration system would be inoperable. With both subsystems inoperable -

the provisions of TS 3.0.3 would apply and the plant would be required to be placed into cold shutdown. Once the plant is in cold shutdown, Action b.2 would become applicable.

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TS 3.7.2 Action b.2 requires that if both subsystems are inoperable

'during Operational Conditions 4, 5 or "*".then core alterations,' handling of. irradiated fuel and operations with the potential for draining the reactor must be suspended.

Action b.2 further minimizes the poter.tial for unfiltered -inleakage into the control room by significantly reducing

.the probability of having an accident when the control room emergency filtration system would not be available.

=Therefore.-the above TS for the control room emergency filtration system c

is adequate to maintain the control room boundary.

SYSTEM DESIGN AND FUNCTION Automatic isolation of the control room and initiation of the emergency filtration' unit fans are accomplished by the following signals:

a.

High radiation in the outside air intake' duct q

b.

Loss-of-coolant accident as indicated by:

1) High drywell pressure, or 1

2) Low reactor vessel water level c.

Manual' isolation' Each control room boundary ductwork penetration to be isolated in this 9

manner is provided with two air operated, fail-closed isolation butterfly i

valves for fast closure. The ductwork pene_trations containing these double _ isolation valves are the normal outside air intake, normal exhaust, and smoke-and fume-purge exhaust ductwork.

TS Surveillance Requirement 4.7.2.d.2 requires that,the_ control room boundary isolation valves be tested periodically to verify a' closure time of 4' seconds or less-upon receipt of a system isolation actuation signal.

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I These valves are:

Z51F001 control room purge fan isolation l

Z51F002 control room purge fan isolation

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Z51F003 control room utility exhaust fan Z51F004 control room utility exhaust fan 251F010 control room outside air intake

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Z51F011 control room outside air intake Once the control room isolation signal is on, the following actions occur i

automatically:

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-a.

All open outside air makeup isolation butterfly valves close.

b.

The control room utility exhaust fan shuts down, and the associated isolation butterfly valves close.

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c.

Both control room standby fresh air unit fans start and recirculate a portion of the control room air through the standby fresh air units.

I The remaining butterfly valves and dampers are required to function during post-accident operation and are, therefore', motor operated.

Two normally' closed motor operated valves (Z51F007 and Z51F016) are part of the control' room boundary but are not required to isolate in response to this signal, since the valves are designed to be opened only following an i solation event in order to provide filtered fresh air makeup.

The standby fresh air makeup valves' associated with the two redundant-divisionally separated recirculation units 'are closed during all normal operating conditions-to ensure the required isolation function of the control room.

F.

PROPOSED TS CHANGE p

The following-TS change is proposed in response to the above described L

inconsistency:

Surveillance Requirement 4.7.2.d.2 is revised to include a listing of the isolation valves which are required to close in 4-'

seconds. The revision is proposed in order to clarify the design of the control room isolation within the TS by clearly 9

specifying which valves are required to close within the j

specified time interval of TS 4.7.2.d.2.

i Attached.is the affected TS page showing the proposed change.

C.

JUSTIFICATION TS 4.7.2.'d.2 rc.luires that every 18 months each control room emergency filtration subsystem be verified to automatically switch to the isolation mcde of operation and-the isolation valves close within four seconds upon receipt of an appropriate isolation actuation signal.

The proposed addition to TS 4.7.2.d.2 of specifying which valves are required to'close-i within four seconds will clarify the applicability of the TS Surveillance requirement.

r The proposed TS change is administrative in nature because the method and scope of testing required by TS 4.7.2.d.2 remains unchanged.

The isolation valves proposed to be listed (Z51-F001, Z51-F002, Z51-F003, Z51-F004,-Z51-F010 and Z51-F011) are those necessary to close within four seconds consistent with the design of the control room emergency filtration system. The post-accident dose to control personnel remains unchanged by the proposed TS change.

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D.

NO SIGNIFICANT. HAZARDS CONSIDERATION EVALUATION SERI is proposing with this amendment request a revision to TS 4.7.2.d.2 which would clarify a Surveillance Requirement on the control room emergency filtration system.

The Commission has provided standards for determining whether a no significant hazards consideration exists as stated in 10CFR50.92(c). A proposed amendment to an operating license involves no significant hazards' consideration if operation of the facility in accordance with the proposed amendment would not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any.

accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

SERI has evaluated the no significant hazards consideration in its request for a license amendment.

In accordance with 10CFR50.91(a), SERI is providing the analysis of the proposed amendment against the three standards in.10CFR50.92:

1.

No significant increase in the probability or consequences of an accident previously evaluated results from this change, a.

The operability of the control room emergency filtration system j

ensures that the control room remains habitable-for control room

.l personnel during and following design basis accidents. The proposed change will not alter the method by which the system is verified to be operable but will only clarify within the TS which valves are required to be tested'to isolate'within the specified limits of the TS.

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b.

The proposed change is consistent with the design of the system and the assumptions used in calculating the post accident dose to operations personnel.

It will neither change the design-of l

the system nor the way the system is operated.

c.

Because the control room emergency filtration system functions to mitigate the consequences of an accident, not to' prevent an accident, the proposed change to the TS cannot increase the probability of a previously evaluated accident.

i d.

Because the proposed change will.not permit the system to be operated in a manner in which the operator dose wi11 be greater than the limits previously calculated, the proposed change cannot increase the consequences of an accident previously evaluated.

e.

Therefore, there is no significant increase in the probability or consequences of previously analyzed accidents due to the proposed changes.

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This change would not create the possibility of a new or different j

kind;of accident from any previously analyzed.'-

i' a.

The proposed change does not involve a physical l change in the system configuration nor the mode in which the-system.is operated.

b.

The control room emergency filtration system functions only to-

t mitigate the consequences of a postulated accident by limiting the radiological exposure'of operations personnel inhabiting the control room._

c.--Therefore, the proposed change does not. create the possibility' of a new or different kind of accident from any previously' evaluated, o

3.

This change would.not involve a significant reduction in the margin i

of safety.-

a. 'The proposed change to TS 4.7.2.d.2 is administrative'in nature and does not modify the testing methods or scope of testing currently required by TS 4.7.'2.d.2.

b.. Therefore, the proposed change will not involve a significant t

reduction in the' margin of safety.

Therefore, based on the above evaluation, operation in accordance with the proposed amendment involves no significant hazards consideration..

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