ML20062H481

Summary of 901023 Meeting W/Util Re Control Room Emergency Filtration Sys.Proposed Change to TS 3/4.7.2 & Handout Encl

ML20062H481
Person / Time
Site:	Grand Gulf
Issue date:	11/28/1990
From:	Kintner L Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 9012040340
Download: ML20062H481 (12)

Text

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[<', 'h , UNITE D sT ATEs g NUCLEAR REGULATORY COMMISSION

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%,.....f November 28. 1990 Docket No. 50-416 LICENSEE: Entergy Operations, Inc.

FACILITY: Grand Gulf Nuclear Station, Unit 1 l I

SUMMARY

OF OCTOBER 23, 1990, MEETING REGARDING CONTROL ROOM EMERGENCY FILTRATION SYSTEM 1 l

The licensee met with NRC staff to discuss a proposed Technical Specification (TS) change regarding the control room emergency filtration system (CREFS).

Enclosure 1 lists the participants of the meeting. Enclosure 2 is the proposed change to TS 3/4.7.2 " Control Room Emergency Filtration System." Enclosure 3 is a handout prepared by the licensee.

The staff summarized the proposed TS change and related issues resulting from tho licensee's Licensee Event Report 90-005, " Single failure During Testing Could Cause Breach of Control Room Envelope " dated A)ril 4 1990. During a i review of the CREFS, the licensee found t1st the fres) airInletisolation dampers are not designed to be single failure proof. The dampers are closed during normal operation and during a design basis accident except that they are to be opened for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to supply filtered fresh air to the L isolated control room. In the event of a design basis accident and coincident loss of offsite pcwer, a single failure of one division of onsite power could result in failure of an open damper to close. The licensee also found that, althoughTS4.7.2.d.2(Enclosure valves subject to the surveillance, two 2)didnotspecificallyidentify)theisolation valves (F007-A and F016-B do not meet ,

the 4-second isolation valve closure time specified in the TS. These valves are motor operated with closing times of about 75 seconds.

By letter dated May 7, 1990, the licensee proposed a TS change in which the isolation valves with the 4 second closure time would be specifically identified. '

The licensee stated that the reason for not identifying valves F007-A and F016-B and specifying their closing times of 75 seconds in the TS was that F007-A and F016-D have no analytical closing times and their closing times are not used in any dose calculations.

The staff stated that the fresh air inlet valves in the CREFS are a part of the subsystemsthatarerequiredtobeoperableinTS3/4.7.2(Inclosure 2.) The staff questioned whether TS 4.7.2.d.2 could be changed to exclude valves F007-A and F016-B from the 4 second closure time but subject to the surveillance tests required in TS 4.7.2.d.2-for isolation valves. Surveillance tests for these two valves would then test the actuation circuits, including manual actuation, from the control room. The staff also questioned whether accident dose analyses for operations personnel had included the effect of single failures in the CREFS. For example, what would maximum doses be if valves F007-A and F008-A (which is interlocked to close when F007-A is opened and vice versa) failed in various positions and various times after a LOCA.

9012040340 90:3pe PDR N,

P ADOCK 05000416 PNV i k(-

4

, 2 The licensee summarized its position for deleting the two isolation valves (F007-A and F016 B) from the TS (See Enclosure 3, Sheet 1). The licensee stated they are normaly closed, and although they receive an isolation signal to close for a LOCA, the safety function is to ensure the valves remain closed for 10 minutes following a LOCA. The licensee stated that the siagle failure criterien applies only to active failures. A remote manual control switch in the control room is used to open and close the valves for their post-LOCA function of providing filtered fresh air for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> each 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for main-taining adequate air quality in the control room. The licensee stated that (L because they are not isolation valves, they do not belong in the TS. Further, La the licensee stated that its operating procedure for CREFS requires that action statements in TS 3/4.7.2 must be followed if the valves are found to be open.

The CREFS is required b/ TS to be operable for all operational conditions.

The staff position is that these two isolation dampers are part of the control r room isolation boundary. Whether they remain in the TS or not is dependent on the impact of the position of these valves on the dose calculations. The L licensee stated it did not know whether dose analyses had been made including the effect of a single feilure in the CREFS but that it would advise the staff regarding calculated doses.

1990meetingwiththestaff.)(OosecalculatlonswerepresentedinaNovember6, In another related matter, the design basis accident dose analyses for the

( Grand Gulf Unit I control room are based on an unfiltered control room inleakage specified in License Condition 2,C.(38), but periodic leakage tests are not specified and have not been performed. The staff advised the licensee of a pending generic letter on control room habitability. The staff suggested that the licensee pay particular attention to this generic letter when it is issued and notify the staff of its intentions +,0 address the means of determining compliance with the license condition on control room inleakage.

~^

g , bu AIA Lester L. Kintner, Senior Project Manager Project Directorate TV-1 Division of Reactor Projects lil/IV/V Office of Nuclear Reactor Regulation

=

. . , l Mr. W. T. Cottle Entergy Operations, Inc. Grand Gulf Nuclear Station cc:

Mr. Ted H. Cloninger Mr. C. R. Hutchinson j Vice President, Engineering GGNS General Manager  ;

Entergy Operations Inc. Entergy Operations, Inc.

P. O. Box 31995 P. O. Box 756 Jackson, Mississippi 39286-1995 Port Gibson, Mississippi 39150 Robert B. McGehee The Honorable William J. Guste, Jr.

Wise, Carter, Child & Caraway Attorney General  !

P. O. Box 651 Department of Justice Jackson, Mississippi 39205 State of Louisiana P. O. Box 94005 Baton Rouge, Louisiana 70804-9005 Nicholas S. Reynolds, Esquire Winston & Strawn Alton B. Cobb, M.D.

1400 L Street, N.W. - 12th Floor State Health Officer Washington, D.C. 20005-3502 State Board of Health P. O. Box 1700 Jackson, Mississippi 39205 Mr. Jim T. LeGros Manager of Quality Assurance Office of the Governor Entergy Operations, Inc. State of Mississippi P. O. Box 31995 Jackson, Mississippi 39201 Jackson, Mississippi 39286-1995 President, Mr. Jack McMillan, Director Claiborne County Board of Supervisors

Division of Solid Waste Management Port Gibson, Mississippi 39150 L

Mississippi Department of Natural Resources Regional Administrator, Region 11 l P. O. Box 10385 U.S. Nuclear Regulatory Commission Jackson, Mississippi 39209 101 Marietta St., Suite 2900 Atlanta, Georgia 30323 Mr. Michael J. Meisner Director, Nuclear Licensing Mike Morre, Attorney General l

Entergy Operations, Inc. Frank Spencer, Asst. Attorney General P. O. Box 756 State of Mississippi Port Gibson, Mississippi 39150 Post Office Box 22947 Jackson, Mississippi 39225 Mr. C. B. Hogg, Project Manager Bechtel Power Corporation Mr. Gerald W. Muench P. O. Box 2166 Vice President Ope Houston, Texas 77252-2166 EntergyOperatIons,rationsSupport Inc.

P. O. Box 31995 Mr. H. O. Christensen Jackson, Mississippi 39286-1995 l Senior Resident inspector U.S. Nuclear Regulatory Commission Mr. Donald C. Hintz, Executive Vice Route 2 Box 399 President & Chief Operating Officer Port Gibson, Mississippi 39150 Entergy Operations, Inc.

P. O. Box 31995 l - Jackson, Mississippi 39286-1995 l

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4 j ENCLOSURE 1 '

l Participants in October 23, 1990 Meeting between Entergy Operations, Inc. and NRC Name Affiliation N. Meisner Entergy Operations, Inc., Director of Licensing J. Fowler Entergy Operations, Inc., Manager, Licensing T. Quay NRR, Director, Project Directorate TV-1 C. Nichols NRR, Section Head, Plant Systems Branch J. Hayes NRR, Section Head, Radiation Protection Branch C. Moon NRR, Section Head, Technical Specification Branch L. Kintner NRR, Project Nanager - GGNS, Project Directorate IV-1

0

_ ENCLOSURE 2 PLANT $YSTEMS 3/4.7.2 CONTROL ROOM EMERGENCY FILTRATION SYSTEM  !

l LIMITING CONDITION FOR OPERATION 3.7.2 Two independent control room emergency filtration system subsystems shall be OPERABLE.

APPLICABILITY: All OPERATIONAL CONDITIONS and *.

MT10N:

a.

In OPERATIONAL CONDITION 1, 2 or 3 with one control room emergency filtration subsystem inoperable, restore the inoperable sutrsystem to OPEFABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHVTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. In OPERATIONAL CONDITION 4, 5 or *: '

1.

With one control room emergency filtration subsystem inoperable, restore the inoperable subsystem to OPERABLE status within 7 days or initiate and maintain operation of the OPERABLE subsystem in the isolation mode of operation. The provisions of Specifica-tion 3.0.4 are not applicable for entry into OPERATIONAL CONDI-TION 4 from 5.# .

2.

With both control room emergency filtration subiystems inoperable, suspend CORE ALTERATIONS, handling of irradiated fuel in the primary or secondary containment and operations with a potential for draining the reactor vessel, s c. The provisions of Specification 3.0.3 are not applicable in Operational Condition *.

SURVEILLANCE REQUIREMENTS

4. ) . 2 Each contro' room emergency filtration subsystem shall be demonstrated OPERA 0LE:

a.

At least ones per 31 days on a STAGGERED TEST BASIS ty inithting, from the contiol room, flow through the HEPA filters and charcoal adsorbers and verifying that the subsystem operates for at least -

10 continuous ho vs with the' heaters OPERABLE.

b. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the subsystem by:

1. '[0ELETED) .

"When irradiated fuel is being handled in the primary or secondary containment.

1. This exception is applicable until startup from the third refueling outage. l GRAND GULF-UNIT 1 3/4 7 5 . Amendment No. 53 MAR 1 e 1929

^

. ~ .

e PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 2.

Verifying that the subsystes satisfies the in place testing acceptance criteria and uses the test procedums of Regdesary Positions C 5.a. C.5.c and C 5.4 of Aegulatory Guide 1.52 Revision 2 March 1978, and the systes f1sw rate is 4000 cfm a 105.

3. i Verifying within 31 days after removal that a laboratory analysis of a repmsentative carbon sample obtained in accordance with Regulatory Position C.6.6 of Regulatory Guide 1.52, Revision 2 l

March 1978, meets the laboratory testing criteria of Regulatory ._

[ Position C.4.a of Regulatory Guide 1.52, Revision 2. March 1978.

t

4. Verifying a subsystem flow rate of 4000 cfm i 10% during subsystem operation when tested in accordance with AN5! N510-1975. ..

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying '

within 31 days after removal that a laboratory analysis of a repre-  ;

i

sentative carbon sample obtained in accordance with Regulatory *

Positen C.S.b of Regulatory Guide 1.52 Revisten 2. March 1974, seets the laboratory testing criteria of Aegulatory Position C.6.a of Regulatory Guide 1.52, Aevision 2 March 1978.

• d.

At least once per 18 months by: . .

1,n,,..

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsortper banks is less than 7.2 inches Water Gauge M,

F while operating the subsystes at a flow rate of 4000 cfm a 105.

2.

J'"

Verifying that the subsystem receives an appropriate isolation I actuation signal by each of the following test conditions. For i at least one of the test conditions, verify that the subsystes automatically switc to the isolation mode of operation and 3

the isolation valves psewithp4 seconds, (a) Highhighradiateni gpf a 4.d fo///p e o ts'f[a#1 ffitake duct,

, (b) High drywell pressure. ,

(c) Low low reactor water level, and  :

(d) Manual initiation from the Centrol Room.  ;

3. Verifying that the heaters dissipate 20.7 e 2.1 kW when tested  !

in accordance with ANSI N510 1975 (except for the phase balance criteria stated in Section 14.2.3).

e. After each complete or partial replacement of a HEPA tilter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the 00P when they are tested in place in accotdance with AN51 N510-1975 while operating the systes at a flow rate of 4000 cfm a 105. a

f. After each complete er partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove 99.955 of a halogenated hydrocarbon refrigerant test gas when they are tested in place in accordance with ANSI N510-1978 while operating the systes at a flow rate of 4000 cfa a 105.

er b GRAND GULF-UNIT 1 3/4 7 6 Amendment No. 25 l DEC 3 1966 e

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CONTROL ROOM HVAC SYSTEM (Simplified Diagram) -

omme

• Air -

v outside --

outside g / F010 v Air 7 (Note 1) s-

@ g f Fo11 F007-A @

(N6e 2.3) 4 - (Note 1) l g _. . Fols-a

,. 6 ,. s,

, (Nhe 2,3)

FOOS-A F014-8 (Note 4) (Note 4)

Control Room i

Fator --

Train Envelope T~iin l A B

' ) (

m stoney a stoney Fresh Nr __ __ Fresh Air Unit Fon A FOO3 F001 Unit Fon B M # (Notes 1.5)

I  !

g_I, (Note roo. 1) g.. roo2 (Note 1) y (Notes 1.5) m Utsty 1 Exhaust To Fan Cochoi Bldg  !

Purge Fon i NOTES m '

1. Control Room isolation Signoi to Close Mt

2. Control Room isolation Signal to Prevent Opening for 10 Minutes G;

E

3. Opened for Post-Accident Fresh Air and IST Only

4. Opened for Recirc Only 5l i N

w

5. Opened Only to Exhoust Smoke, Noxious Vapors, etc.  !

1

. o .

~.' DESIGN OF F007/F016 l o PROVIDE POST-ACCIDENT FILTERED FRESH AIR WHEN DICTATED BY CONTROL ROOM O' OR C0' LEVELS o ADMINISTRATIVELY CONTROLLED CLOSED AT OTHER TIMES EXCEPT FOR SECTION XI STROKE TIME TESTING o RECEIVE A CONTROL ROOM ISOLATION SIGNAL TO PREVENT l INADVERTENT OPENING IN THE FIRST 10 MINUTES OF A DBA

{

o BOUNDARY VALVES AS DISTINGUI3HED FROM ISOLATION VALVES l (BECHTEL DESIGN CRITERIA MANUAL):

"EACH CONTROL ROOM BOUNDARY DUCTWORK PENETRATION TO BE ISOLATED DURING AND i SUBSEQUENT TO A LOSS-OF-COOLANT ACCIDENT I

IS PROVIDED WITH TWO AIR OPERATED

! FAIL-CLOSED, ISOLATION BUTTERFLY VALVES FOR FAST CLOSURE AND LEAKTIGHT SHUT 0FF.

l THE DUCTWORK PENETRATIONS CONTAINING L THESE DOUBLE ISOLATION VALVES ARE THE l NORMAL OUTSIDE AIR INTAKE, NORMA! EXHAUST, l AND SMOKE-AND FUME-PURGE EXHAUST DJCTWORK.

THE REMAINING BUTTERFLY VALVES AND DAMFERS ARE REQUIRED TO FUNCTION DURING POST-LOCA OPERATION AND THEREFORE ARE MOTOR OPERATED."

LER 90-005 (MAY, 1990) i

)

o REPORTED PLANT IN A CONDITION OUTSIDE DESIGN BASES (UNFILTERED INLEAKAGE PATH TO CONTROL ROOM) o POSTULATED:

LOCA .

LOP SINGLE FAILURE OF ESF POWER DIVISION CONCURRENT WITH TESTING (STROKING) EITHER F007 OR F016 o FEW, IF ANY, SAFETY SYSTEMS CAN SUCCESSFULLY PERFORM SAFETY FUNCTION WHEN TESTING IS POSTULATED COINCIDENT WITH LOCA/ LOP / SINGLE FAILURE o THE SITUATION DESCRIBED IN LER 90-005 IS EI REPORTABLE AS A CONDITION OUTSIDE THE PLANT DESIGN BASIS l

i o PRA CONFIRMS LACK OF SAFETY SIGNIFICANCE:

l t

LOCA/ LOP - - 10

t ESF FAILURE - - 5 X 10

TESTING - - 3 X 10

(4 MIN. QUARTERLY)

1. 5 X 10'"

l l

l

l

= +. l APPLICABILITY OF REVIEW CRITERIA l SINGLE EALLUE o F007/F016 ARE PASSIVE COMPONENTS (CLOSED) UNDER CONDITIONS REQUIRED FOR ANALYSIS I

o SINGLE FAILURE CRITERION APPLIES TO ACTIVE FAILURES me o , NO CREDIT IS TAKEN FOR F007/F016 IN SAFETY ANALYSES

! o TSIP CRITERIA (E.G. PART OF THE PRIMARY SUCCESS PATH) -

DO NOT APPLY o CONTROL ROOM HVAC DESIGN HAS BEEN REVIEWED AGAINST l

APPLICABLE GDCS (2,4,5,19) AND OTHER GUIDANCE (RGS 1.26, 1.29, 1.95, 1.117, BTP ASB 3-1) AND FOUND ACCEPTABLE - GGNS SER 1

l

t e

CONCLUSIONS INCLUSION OF F007/FOI6 IN THE TS IS INAPPROPRIATE.

1 GGNS SUBMITTAL SHOULO BE APPROVED AS AN ADMINISTRATIVE CHANGE CLARIFYING THE CONTROL ROOM ISOLATION VALVES TO WHICH TS 3/4.7.2 APPLIES.

l l

l l

+

n . .

2- November 28, 1990 The licensee sumarized its position for deleting the two isolation valves (F007-A and F016.B) from the TS (See Enclosure 3, Sheet 1). The licensee stated they are normaly closed, and although they receive an isolation signal to close for a LOCA, the safety function is to ensure the valves remain closed for 10 minutes following a LOCA. The licensee stated that the single failure criterion applies only to active failures. A remote manual control switch in the control room is used to open and close the valves for their post-LOCA function of providing filtered fresh air for L hours each 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for main-taining adequate air quality in the control room. The licensee stated that because they are not isolation valves, they do not belong in the TS. Further, the licensee stated that its operating procedure for CREFS requires that action statements in TS 3/4.7.2 must be followed if the valves are found to be open.

The CREFS is required by TS to be operable for all operational conditions.

The staff position is that these two isolation dampers are part of the control room isolation boundary. Whether they remain in the TS or not is dependent on the impact of the position of these valves on the dose calculations. The licensee stated it did not kr:ow whether dose analyses had been made including the effect of a single failure in the CFsEF , but that it would advise the staff regarding calculated doses. (Dose calculations we presented in a November 6, 1990 meeting with the staff.)

In another related matter, the design basis accident dose analyses for the Grand Gulf Unit 1 control room are based on an unfiltered control room inleakage specified in License Condition 2.C.(38), but periodic leakage tests are not specified and have not been performed. The staff advised the licensee of a pending generic letter on control room habitability. The staff suggested that the licensee pay particular attention to this generic letter when it is issued and notify the staff of its intentions to address the means of determining compliance with the license condition on control room inleakage.

ORlr-INAL SIGNED BY:

Lester L. Kintner, Sonior Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/IV/V Office of Nuclear Reactor Regulation DISTRIBUTION Docket F He PD4 1 Reading File T. Quay NRC PDR L. Berry Local POR L. Kintner 0CG MS15B18 M. Virgilio MS 13E4 E. Jordan MNBB 3701 l ACRS(10)MSP-315 PD4 1 Plant File 0FC :PD4-1/PM :PD4 1/D  :  :  :  :

PD4-1/L('

NAME LBerryh- -- ::LKi.-.9h..--..:.....

1h :TQuay Q[q.  :  :  :

DATE:d/h/90  : W /90 :0/p/90  :  :  :  :

0TTICIAL RECORD COPY Occument Name: GGN5 MEETING

SUMMARY

10/23