ML20140B915

Requests Formal Interpretation of TS Requirements by NRC

ML20140B915
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	03/20/1997
From:	Dewease J ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CNRO-97-00005, CNRO-97-5, NUDOCS 9704010499
Download: ML20140B915 (5)

Text

a Cnt:r:y Cperr.tiIna,Inc.

PO Box 31995

-::= ENTERGY aec soo.us a9288 >995 Tel 601368 5760 Fax 601368 5768 Jerrold G. Dewease vre Presdent Qcrgors Srpport March 20,1997 Document Control Desk United States Nuclear Regulatory Commission Mail Stop P1-37 Washington, DC 20555-0001 Subject Entergy Operations, Inc.

Request for interpretation of Filtration Unit Testing Requirements as Specified by the Technical Specifications and Regulatory Guide 1.52 Arkansas Nuclear One Grand Gulf Nuclear Station Units 1 & 2 Docket No. 50-416 Docket Nos. 50-313 & 50-368 License No. NPF-29 License Nos. DPR-51 & NPF-6 River Bend Station Waterford 3 Steam Electric Station Docket No. 50-458 Docket No. 50-382 License No. NPF-47 License No. NPF-38 CNRO-97/00005 Entergy Operations, Inc. (EOI) by this letter requests a formal interpretation of Technical Specification requirements by the NRC.

The details of EOl's request can be found in Attachment 1. Please address any comments or questions regarding this matter to Bryan Ford at (601) 368-5792.

Sincerely, JGD/SJB/BSF/baa cc:

Mr. J. L. Blount Mr. J. J. Hagan Mr. L. J. Callen Mr. C. R. Hutchinson Mr. J. G. Dewease Mr. G. Kalman Mr. J. N. Donohew Mr. J. R. McGaha Mr. C. M. Dugger Mr. C. P. Patel

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Mr. C. Grimes Mr. D. L. Wigginton i f AdoI Ik 9704010499 970320 PDR ADOCK 05000313 gg P

PDR i

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i to CNRO-97/00005 page1 Request for interpretation of Filtration Unit Testing Requirements as Specified by the Technical Specifications and Regulatory Guide 1.52 The Technical Specifications (TSs) for Grand Gulf Nuclear Station (GGNS) and Waterford 3 Power Plant (W-3) require that the Engineered Safety Feature filtration systems be tested at a frequency that is in accordance with Regulatory Guide 1.52, Revision 2 (RG 1.52). The surveillance frequency is specified at GGNS for ~.he Standby Gas Treatment (SGT) System, LCO 3.6.4.3, and the Control Room Fresh Mr (CRFA)

System, LCO 3.7.4, by reference to the Ventilation Filter Testing Program (VFTP) which requires the testing frequency be in accordance with RG 1.52. The surveillance frequency is specified at W-3 for the Control Room Emergency Air Filtration System (LCO 3.7.6.1), the Controlled Ventilation Area System (LCO 3.7.7), the Fuel Handling Building Ventilation System (LCO 3.9.12), and the Shield Building Ventilation System (LCO 3.6.6.1) by direct inclusion of the frequency specified in RG 1.52 into the surveillance requirement. The RG 1.52 states that:

" Adsorber leak testing should be conducted (1) initially, (2) at least once per 18 months thereafter, (3) following removal of an adsorber sample for laboratory testing if the integrity of the adsorber section is affected, and (4) following painting, fire, or chemical release in any ventilation zone communicating with the system."

RG 1.52 also states that testing should conform to guidance given in ANSI N510-1975,

" Testing of Nuclear Air Cleaning Systems"(ANSI N510). ANSI N510 states in Note 5.c of Table 1 (which refers to in-place testing) that testing should be performed following system exposure to solvents, paints, or other organic fumes or vapors which could degrade the performance of the adsorbent. EOl believes that the intent of RG 1.52 allows the use of technicaljustification to determine when conditions require performance of the stated Technical Specification surveillances.

The reason for the fourth frequency "following painting, fire, or chemical release in any ventilation zone communicating with the system" is the concern that volatile organic materials released by the painting, fire, or chemical release may decrease the filter efficiency. Subsequently, following organic saturation, the filter will allow elemental and organo-lodines to pass through untreated during an accident. Available industry data indicates that up to 10% by weight of the charcoal filter can be saturated by volatiles without decreasing the filter efficiency to unacceptable levels ("A Study of the Effect of Coatings Operation on Radiciodine Removing Adsorbents" and " Basis for and Practical Method of Controlling Paint Activities at Sequoyah Nuclear Plant", presented at the 21st and 24th DOE /NRC Nuclear Air Cleaning and Treatment Conferences, respectively).

Viewing industry practices, the frequency "following painting, fire, or chemical release in any ventilation zone communicating with the system" is implemented in one or more of the following methods:

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t to CNRO-97/00005 page 2 4

1. Ensuring that Engineered Safety Feature filtration systems which exhaust an area are not operating during the painting, chemical release, or fire. Also, assuring that the normal ventilation systems have time to remove a sufficient amount of the volatile organics that the amount of volatile organics introduced into Engineered Safety Feature filtration systems could not damage the charcoal units when they start.

Communication is only considered to occur when the filtration system is in operation.

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2. If painting, a fire or unexpected chemical release occurs during or just prior to the associated Engineered Safety Feature filtration systems being in operation, there may be insufficient time for the normal ventilation systems to remove the volatile organics from the area. The effects of the event are evaluated to determine if the j

amount of volatile organic material introduced into Engineered Safety Feature filtration systems could have damaged the charcoal units.

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3. If the painting or chemical release is pre-planned to occur during a time when the associated Engineered Safety Feature filtration systems are expected to be i

operating, the amount of volatile organics expected to be released is reviewed to ensure that the amount of volatile organics introduced into Engineered Safety j

Feature filtration systems could not damage the charcoal units.

1 The above examples are methods used within the industry to comply with the TS surveillance requirements for testing the Engineered Safety Feature filtration systems i

"following painting, fire, or chemical release in any ventilation zone communicating with the system."

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An example of the application of the philosophy that engineering evaluation is an acceptable means of complying with the intent of this surveillance requirement can be found in the Technical Specifications of the E.l. Hatch plant. In the E. l. Hatch Ventilation Filter Testing Program (Specification 5.5.7) there is the following note:

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Tests and evaluations have determined the impact on the Standby Gas imatment (SGT) System filters of certain types of painting, buffing and grinding, and weiding. The use of water based paints and the performance of metal grinding, buffing, or welding are not detrimental to the charcoal filters of the SGT System, either prior te er during operation. These activities will not require surveillance of the system tipon their conclusion. This applies to all types of welding conducted at Plant Hatch, and tracking of the quantity of weld material used in not necessary."

Attachm:nt 1 to CNRO-97/00005 l

page 3 l

l Recently, at GGNS and W-3 a concern has been raised by NRC Resident inspectors that the words of RG 1.52 or the TS surveillance, as applicable, does not allow the use of any technicaljustification or analysis to determine when testing is required. In other r

words, the NRC is questioning if the surveillances are required to be performed and the systems are inoperable until they are performed after any of the following:

1. Painting (from touching up a sign to painting the entire building)in an area exhausted by the filtration system with no consideration given to the amount of volatile organics contained in the paint.

2. Any chemical release (including any possible interpretation of what a chemical release is) involved in an area exhausted by the filtration system with no regard for the amount of any volatile organics that may have been were released.

3. A fire (potenti&y including welding, arcing, or shorting in a circuit) in an area exhausted by the filtration system.

4. Any painbng, chemical release, or fire in the area exhausted by the filtration system wnether or not another ventilation system had been previously used to exhaust the area and regardless of the amount of time prior to the operation of the filtration l

system.

Essentially, this interpretation of the surveillance requirement will result in an increase in the amount of testing of the systems, as well as, increase in the technical inoperability of the systems. This is considered to be an increase in risk caused by the increased potential for subjecting the plant to shut down transients due to the technical inoperability of the system with no corresponding increase in safety.

EOl believes that ANSI N510 must be considered when determining the testing of filtration units as required by RG 1.52 and the TS. As a result, EOl believes that the intent is to require testing when organic fumes or vapors could degrade the performance of the adsorbent. Therefore, technical engineering justification is appropriate in determining whether the exposure which occurred could have degraded the filtration units' components. This evaluation is based upon the quantity of volatiles that couM have communicated with filtration unit components, any removal of the volathes by normal ventilation systems, and the quantity of filter media. EOl believes that the industry methods described above are adequate to determine when the TS aurveillance requirements for testing the Engineered Safety Feat. ire filtration systems "foliowing painting, fire, or chemical release in any ventilation zone conim.micating with the system" must be initiated.

Attachm:nt 1 to CNRO-97/00005

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page 4 Since the acceptability of our position has been questioned at two of the EOl sites and since EOl believes that this issue has a very broad applicability, EO'. requests that the i

NRC formally endorse the industry standard methods described ai,0ve for complying with the RG 1.52 and TS surveillance requirements for testing the Engineered Safety.

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- Feature filt rifon systems "following painting, fire, or chemical release in any l

l VentilMion zone".

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