ML20155J950
| ML20155J950 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/19/1986 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM TAC-61289, NUDOCS 8605270253 | |
| Download: ML20155J950 (28) | |
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[briD Warns VccPrtw rt May 19, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation ATTN: Mr. Steven A. Varga Director, PWR-A Project Directorate No. 3 U.S. Nuclear Regulatory Commission Washington DC 20555
Dear Sir:
Control Room Habitability Mr. T. L. Chan's letter dated May 7, 1986 expressed concerns about the adequacy of the Trojan Control Room Emergency Ventilation System (CB-1) and requested additional information in order to assess control room habitability at Trojan. Attachment 1 is our response to the specific requests. As discussed with you, Mr. Chan, and Mr. Johnston, at recent meetings at Trojan and in our Corporate Headquarters, several items remain to be completely evaluated. As wall, a few selected items appear to be a change in a regulatory position for the Trojan Nuclear Plant and may need to be further evaluated under 10 CFR 50.109, the Backfit Rule. However, an attempt has been made to be responsive to each request.
Following the visits by NRC representatives on January 28-30, 1986 and February 25-27, 1986, PCE commenced a thorough investigation and evaluation of the CB-1 system. Although initiated early in March, the scope of this reassessment has been expanded many times to its present state. Several aspects of the program were provided in LER 86-02 dated March 18, 1986, as well as a description of the corrective actions taken or planned to be taken at that time. In addition, much of this program was discussed at a Regional Meeting in Walnut Creek, California on March 27, 1986. A summary of the Action Plan is included as Attachment 2. A schedule for completion and the status of each item is provided.
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L N Gerierd MCortyxuly Mr. Steven A. Varga May 19, 1986 Page 2 As can be seen on Attachment 2, a complete reanalysis of the NUREG-0737 III.D.3.4 requirements is being performed. It is expected that the III.D.3.4 analysis will be completed prior to startup.
As discussed in our meting of May 14, 1986, we will be happy to meet with you in the near futuro to further discuss our corrective actions.
Sincerely, r
Bart D. Withers Vice President Nuclear Attachments c: Mr. Lynn Frank, Director State of Oregon Department of Energy i
i Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 1 of 18 ATTACHMENT 1: TROJAN PLANT CONTROL ROOM DEFICIENCIES A. Radiological
- 1. As of January 28, 1986 1.a Unfiltered inleakage of 41 cfm existed through the drain pipe from V-141A and B cooling coils. The estimated dose would be approximately 90 rem to the thyroid based upon the original Trojan III.D.3.4 submittal.
Response
The drain line was capped to terminate this leakage path within one hour of the identification of this deficiency.
Although this was only a temporary fix, a permanent correction will be completed prior to December 31, 1986 (refer to LER 86-02). A dose of 90 rem would have been unacceptable.
1.b Manner in which the system operates was inconsistent with the Trojan III.D.3.4 analysis which calls for a pressurization flow of 150 cfm.
Response
Upon identification of this concern, additional measurements and review of procedures was performed. The outside makeup air flow rate was adjusted to $150 cfm within a few days of the initial measurement for Train B. Train A makeup flow was determined to already be 1150 cfm with the flow damper indi-cating full open. Disassembly and inspection of this damper during the current refueling outage revealed that the damper was rotated 90* from its indicating handle. This was the apparent reason for the flow difference between trains with both dampers indicating full open. However, the low value of makeup air flow in Train A (approximately 125 cfm) raised the question of the ability of Train A to pressurize the control room to 1/8 in. (see Items 1.d and 1.i holow). Flow measure-ment ports have been added to allow determination of the makeup flow rate in each train, and Plant procedures have been revised to measure makeup flow rate at least once every 18 months.
1.c Unknown quantity of inteakage existed from cross-connection of drain line between two filter trains.
Response
The cross-connected drain lines were immediately capped and subsequently separated with valves installed to terminate the
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Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 2 of 18 leakage path. Operators check these drains at least once per shift (once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) to verify there is no cooler coil leakage. Although these actions were temporary, permanent corrections (automatic drains) are scheduled for completion prior to December 31, 1986 (refer to Item 1.a above and LER 86-02).
1.d Probable inleakage existed from normal makeup damper, standby emergency train damper, and high volume (CB-12) special exhaust damper. This was demonstrated by the fact that during a control room pressurization test the control room could be made positive with all outside dampers closed.
Response
Because of the questions raised regarding pressurization of the control room, extensive inspection, testing, and evalua-tion of the system is being performed to ensure damper integrity, duct integelty, and control room envelope integrity. Several additional problems such as open and leaky penetrations have been found and are being corrected. A periodic testing and preventive maintenance program is being developed for these dampers. The sensor for measuring the differential pressure between the control room and outside air has been moved outside of the doghouse on the Control Building roof. This provides a more accurate determination of the differential pressure since the doghouse atmospheric pressure could be influenced by the operation of the HVAC systems taking suction from this location.
1.e With external dampirs all closed, control room envelope boundaries saw an unknown amount of inleakage because the control room was negative with respect to the surrounding boundaries.
Response
Procedures have been revised to require CB-1 makeup dampers to be open during radiological emergencies and closed during toxic gas emergencies. Extensive testing is being performed to identify and repale sources of possible control room boundary inleakage.
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Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 3 of 18 1.f Capability of charcoal was in question since technical speci-fications call for test at 130*C and show a removal of 90% for methyl radiolodine. The licensee assumed a removal efficiency of 95% in their III.D.3.4 submittal and the test should be conducted at 30*C.
Response
A Technical Specification change will be evaluated to determine the appropriateness of testing charcoal at 30*C and a removal efficiency of 195 percent. The evaluation will be completed prior to startup and any proposed Technical Specif1-cation changes will be provided by September 30, 1986.
1.g Flow of 3200 cfm +/-10% may result in a residence time in the adsorber of less than 1/2 second because the charcoal capabil-ity is based upon 3000 cfm. With a lower residence time adsorber efficiency would be significantly less than 95%.
Response
Actual flow rates through the adsorber have been determined to l have been less than 3000 cfm but greater than the 2880 cfm allowed by the Technical Specifications (3200 cfm 110 per-cent). Therefore, based upon past measurements, the residence !
time has been at least one-quarter of a second. The FSAR and Technical Specifications will be evaluated to determine if a design change and/or revised flow rate should be specified.
The radiological analysis has been revised to reflect the 3000 cfm flow. The evaluation will be completed prior to startup and any FSAR and/or Technical Specification changes will be provided by September 30, 1986.
1.h Actions taken when ARM-11 alarms (Control Room Radiation Alarms) may not be quick enough to prevent radiation exposure.
Response
The " alert" setpoint (audible and visual annunciation) occurs
' for ARM-11 at 1 mR/hr. ARM-11 automatically closes the C8-2 outside air dampers at the " alarm" setpoint of 10 mR/hr.
These setpoints are sufficiently low to ensure control room personnel do not receive a dose exceeding the CDC-19 limit of 5 rem. Plant Off-Normal Instruction ONI-12 requires manual actuation of CB-1 with the outside air makeup dampers open upon receipt of an ARM-11 alarm.
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Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 4 of 18 1.1 Because of the way the differential pressure is measured (control room versus the normal makeup intake), it remains to be seen whether the control room is positive with respect to the surrounding boundaries.
Response
Although pressurization of the control room to 1/8-in, was verified in 1975 in the Preoperational Test Program, several questions have been raised about the repeatability and accuracy of that measurement, particularly in light of the makeup flow found in Train B. Furthermore, the 1975 test and subsequent testing had been performed measuring the differen-tial pressure between the control room and outsida atmosphere, not the surrounding boundaries and it appears that the 1/8-in.
pressure may never have been consistently obtained. Currently, permanent test instruments have been installed to allow measuring of differential pressure with respect to the surrounding boundaries. Testing to demonstrate the control room emergency ventilation system will maintain a positive pressure of 1/8-in. with respect to outside air is being performed. The Trojan Technical Specifications currently specify that the 1/8-in. positive pressure is to be maintained in relation to outside air. A re-interpretation of this Technical Specification to require maintaining a 1/8-in.
positive pressure in relation to all adjacent areas may be a change to a regulatory position and may require significant design changes. Serious consideration is being given to relocation of the intake doghouse for CB-1 and installation of 2-in.-thick charcoal adsorbers in the makeup lines, allowing makeup flow to increase by a factor of 4 (to 600 cfm). How-ever, since design changes are considered a longer term resolution, they may not all be completed prior to startup.
1.j Outside dampers do not meet single failure criteria.
Response
The CB-1 outside dampers have been designed for and meet single-failure criteria except for one postulated scenario:
initiation of CB-1 with subsequent failure of one makeup fan (or motor) due to some means other than a loss of power. In this case, the outside makeup air flow damper for that train would remain open, preventing the control room from being pressurized because of a direct path to the outside atmosphere via the inoperable train. Upon a loss of power, these dampers will automatically close. A design change is being processed to correct this deficiency and should be completed prior to startup. Single-failure adequacy of the CB-2 outside dampers
Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 5 of 18 was addressed in our letter, Withers to Butcher, dated November 21, 1985. While CB-2 does not meet a strict interpretation of current single-failure requirements, the compensating measures discussed in the above letter are deemed an acceptable alternative. FSAR Section 3.1 provides a list of systems to which the single-failure criterion was applied in the original Trojan design. CB-2 is not included in that list. Application of the single-failure criterion to CB-2 would be a change to an established regulatory position, and should be evaluated as a backfit in accordance with 10 CFR 50.109. This was discussed in a meeting with the NRC on May 14, 1986 in Portland, Oregon.
- 2. As found February 25-27, 1986 2.a Makeup in Train B showed approximately 450 cfm versus 150 cfm assumed in the Trojan III.D.3.4 analysis. The estimated dose corresponding to this makeup is approximately 50 rem thyroid.
Train A unavailable for measurements.
Response
Measurements verified that the makeup air flow rate in the B train was 450 cfm, while the makeup air flow rate in the A train was 125 cfm. The makeup air flow rate was reduced to
<150 cfm in the B train within a few days of the measurement.
The makeup air flow rate in the A train was found to be due to a mispositioning of the makeup air flow damper and its indi-cating device. It has been repaired and the makeup air flow in the A train has been increased to 150 cfm. Increasing the makeup air flow rate following design changes is being evaluated (see 1.1 above). This evaluation will be completed prior to startup. See Item A.1.b above.
2.b Normal makeup air duct showed 600 cfm of flow. Direction was uncertain. If inleakage, the estimated thyroid dose would be 900 rem.
Response
Although we have been unable to duplicate the 600 cfm measure-ment obtained by the NRC, problems were found with other Control Building HVAC systems that could have created a significant amount of inleakage. The location at which that measurement was performed is not necessarily indicative of control room boundary leakage, but could be influenced by the operation of other Control Building HVAC systems, eg, CB-5, and CB-10. As discussed in Items A.1.d and A.1.e above,
. s Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 6 of 18 testing is being performed to identify and repair sources of control room boundary inleakage. If inleakage had been as high as 600 cfm, unacceptable doses could have resulted.
2.c Same comments as those denoted in A.1 above.
Response
Several of the observations noted during the second NRC visit were similar to those of the first visit. Although it may have appeared that PCs was unresponsive between visits, that was not the case. The seriousness and magnitude of the deficiencies were probably not determined until after the second visit. However, PGs had taken several steps and actions to investigate and correct problems with CB-1.
Therefore, for responses to this item, please refer to the responses to A.1 above.
B. Toxic Cas
- 1. Operation of V-141A and B. VC-148 and V-142A and B may result in an extremely negatively pressurized control room. Pressure exerted on outside dampers could be significant. Measurements should be made to verify system inleakage.
Response
Plant Off-Normal Instruction ONI-54 has been revised to require securing CB-2 (VC-141A & B) during a toxic gas event and starting CB-1 (VC-142A & B) on recirculation with the outside air dampers closed. Measurements will be taken to determine control room pressure with CB-1 operating on recire and CB-2 operating on recire (VC-148). ONI-54 already specifies that CB-3 and CB-4 should be verified to have automatically stopped. As a short-term solution, ONI-54 will be revised to manually stop CB-5 and CB-10 also. A design change will be implemented to automatically stop CB-5 and CB-10 as a permanent solution.
- 2. Continued supplying of air to the lunch room, toilet and laboratory with CB-3 and CB-4 off could result in these rooms being positively pressurized with respect to the control room. This would provide a potential source of inleakage to the control room.
i
Response
i CB-3 and CB-4 are automatically stopped upon a high radiation signal or a toxic gas signal. ONI-54 requires that CB-2 be turned off, which eliminates the potential for a high positive pressure
Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 7 of 18 with respect to the control room and, therefo , minimizes a potential source of in-leakage to the control room. In addition, ,
I a design evaluation of toxic gas protection associated with the operation of CB-3 and CB-4 is being performed.
- 3. Operators do not put on a mask upon a toxic gas challenge but must rely upon their own sensing capability or securing a monitor to measure the toxic gases inside and outside the control room. Operator action is not immediate. Timing could be critical.
Response
ONI-54 requires the control room operators to don self-contained breathing apparatus if a toxic gas alarm is received. However, the procedure does not require the face mask to be worn unless toxic gas concentrations approach the toxic gas limits. This i procedure is considered acceptable. Use of face masks can impede control room communications. Therefore, this response ensures operators have the mask available, as toxic gas is hazardous, yet minimizes the impact on control and response for
, serious alarms. These actions are consistent with Regulatory Guide 1.78 and Regulatory Guide 1.95, which simply specify that Plant Procedures define criteria for use of protective breathing apparatus.
- 4. Same comments as noted in A.1.a. A.1.c, A.1.d, A.1.1, and A.1.j but the impact must be considered in terms of toxic gas.
Response
Refer to the previous discussions on A.1.a. A.1.c A.I.d, and A.1.j . With regard to Item A.1.1, the toxic gas analysis did not assume a pressurized control room. The control room is operated in a recirculation mode on the presence of toxic gas.
! As previously discussed, CB-5 and CB-10 will be evaluated to detenmine if they should be stopped also to minimize potential positive pressures in areas surrounding the control room.
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Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986
- License NPFel Attachment 1 Pate 8 of 18 ATT.ACHMENT 2: COMMENTS ON TROJAN TECHNICAL s o SPECIFTCATEONS Technical Specification 3.3.3.6 - iblorine Detection System
- 1. It would seem reasonable that C12 detectors should he operable during all modes.
Response
A Technical Specification change revising the applicability to specify all modes will be provided by September 30, 1986.
- 2. III.D.3.4 analysis indicates that the' control room isolates in 3 seconds at a concentration of,1 ppe. Technical specifications show actuation at less than or equal to 5 ppm.
Response
us PICT 25-2,Section VIII, and the associated I&C data she66 specifies 1 ppm os the actuation setpoint. Chlorine detectors
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have been cested at this setpoint as assumed in th'a III.D 3.4 analysis. Although the Technical Specification limit of 15 ppm is met by an actual setpoint of 1 ppm, either a revision to the Technical Specifications will be submitted to reflect the lower setpoint or the toxic gas analysis will be revised, utilizing the higher 5 ppm setpoint. A proposed Technical Specification change or a revised toxic gas analysis will be completed.by September 30, 1986.
- 3. The C12 detector does not appear to have a channel functional test f
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' Response ~ -
Alth9ugh Technical Specification 4.3.3.6frequires a channel calibration, not a channel functional test, Technical Specifica-
. tion 4.7.6.1.d.2 requires a functional test. The requirements j of these two Technical Specifications are satisfied by PICT 25-2 4 and a new procedure, PET 10-4, " Test of Control Room Isolation for Toxic Cas and Radiation". ' \
Technical Specification 3.3.3.12 - SO2 Detection System
- 1. Same comment as item 1 above for the C12 detectors.
Response
The Technical Specification wilU bo revised to specify an applicability of all modes.
b
Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 9 of 18 Technical Specification 3.7.6.1 - Control Room Emergency Ventilation System
- 1. Ventilation system should be operable under all modes. The degree of operability varies between modes 1-4 and 5-6.
Response
Since Trojan was licensed with CB-1 required to be operable only in Modes 1-4, this appears to be a change to an established regulatory position but will be evaluated as a potential Technical Specification change. The basis for CB-1 is to meet CDC-19. With the Plant in Mode 5, an accident could not occur that would lead to doses from which CB-1 would be required. No accidents in Mode 5 could be postulated. In Mode 6, a fuel handling accident could occur, but it would happen in either containment or the Fuel Building and then only during fuel movement. This will be resolved with the other Technical Specification changes by September 30, 1986,
- 2. Laboratory tests for charcoal should be conducted at 30*C rather than 130*C, should utilize ASTM method D3803-1979, and should be conducted at 70% relative humidity if the heaters are always energized. That means on and not energized to cycle on when relative humidity reaches 70%. If the preheaters are deleted from the system the laboratory test should be conducted with the relative humidity at 95%.
Response
The appropriateness of a 30*C test temperature as opposed to 130*C is being further evaluated (refer to A.1.f above). A laboratory charcoal test humidity of 95 percent is more conservative than 70 percent and satisfies our commitment to Regulatory Cuide 1.52. If the preheaters are deleted, the laboratory charcoal test will still be performed at 95 percent humidity, which would be consistent with Regulatory Guide 1.52.
- 3. In-place DOP and freon tests acceptance criteria should be based upon 0.05% penetration not 1%.
Response
Technical Specification 4.7.6.1.e and f require testing to assure removal of >99 percent of the DOP or hydrocarbons. This equates to a penetration of 1 percent. Changing the penetration to 0.05 percent would require a 99.95 percent removal efficiency.
Although this change will be further evaluated, it is requested that reasons for this change in criteria be provided.
Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 10 of 18
- 4. Laboratory tests of charcoal should show a removal efficiency greater than that assumed in the III.D.3.4 analysis. A 95%
adsorption efficiency corresponds to a penetration of 1%.
Response
A Technical Specification change will be evaluated to determine the appropriateness of a 195 percent removal efficiency (refer to A.1.f above).
- 5. System should be directing its inlet and recirculation flow through the HEPA filters and charcoal adsorbers on a high radiation signal in addition to the safety injection signal.
Response
This item appears to be a change to an established regulatory position and should be considered a backfit in accordance with 10 CFR 50.109. It is not immediately apparent that an auto-start of CB-1 and the resultant introduction of 150 cfm of makeup air via CB-1 is an appropriate method for operating CB-1 for all potential incidents involving high radiation, in the absence of a safety injection signal. As described in the Standard Review Plan, Section 6.4, the design response should be evaluated in relation to the characteristics of each potential accident that requires a system function. A waste gas decay tank rupture can result in the release of noble gases that would be unfilterable by CB-1. Isolation followed by manual control is the preferred option in the SRP for this type of event. As discussed in response to Item A.1.h, the ARM-11 Setpoint is considered adequate to allow manual actuation of CB-1. Plant Off-Normal Instruction ONI-12 will be revised by December 31, 1986 to provide this degree of guidance to the operators. The question of backfits was discussed in a meeting with the NRC on May 14, 1986 in Portland, Oregon.
- 6. Control room pressure should be demonstrated positive with respect to surrounding areas and not to the outside atmosphere.
Response
As discussed in response to Item A.1.1, permanent test instruments have been installed to allow measuring the differential pressure with respect to surrounding areas.
Sealing of leaks and testing are being performed to demonstrate this feature.
Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 11 of 18
- 7. Control room equipment temperature is monitored at an incorrect location.
Response
Although Technical Specification 4.7.6.1.a requires that control room air temperature be measured, an evaluation is being performed to determine the effects of high temperatures on control room equipment. The present air temperature measurement is accomplished via POT 20-1, using a hand-held temperature instrument. The results of the temperature effects study will be used to determine the proper measurement location for control room temperature measurements and may result in a request for a Technical Specification change.
- 8. Heaters should demonstrate kW rating if they are going to be incorporated into the control room ventilation system.
Response
Testing will be performed to demonstrate heater capability. The application of heaters in CB-1 is being further evaluated.
There appears to be a need for a technical specifiention addressing the NH4 detectors.
Response
With regard to the ammonia detectors, an analysis to show that ammonia detectors may not be required for control room habitability is being performed. This analysis will be completed by August 31, 1986.
ATTACHMENT 3: COMMENTS ON PROCEDURES AND OFF-NORMAL INSTRUCTIONS PET 10-1
- 1. MP-9-1 section II.B.6 seems to indicate that the critical pressure drop in HEPA filters and charcoal adsorbers is 3" W. G.
while surveillance requirements 4.7.6.1.d.1 indicates 6" W. G.
This should be clarified. Refer to 5.1 of PET-10-1.
Response
MP 9-1 will be revised to be consistent with PET 10-1 and 10-2.
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O Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 12 of 18
- 2. PET-10-1 would seem to require that TS 4.3.3.6 and 4.3.3.12 be included in Section 2.
Response
The applicable procedure for verifying compliance with Technical Specifications 4.3.3.6 and 4.3.3.12 is not PET 10-1, but rather PICT 25-2 for Technical Specification 4.3.3.6, and PICT 25-1 for Technical Specification 4.3.3.12. Both Technical Specifications are referenced in the appropriate procedure.
- 3. Section 8.2.1.2 of PET-10-1 seems to imply that the containment charcoal is replaced rather than a laboratory test performed.
ANSI N510-1975, Table 1, is quite specific in requiring a test of charcoal prior to installing it (Containment System).
Response
e Both PET 10-1 and 10-2 will be revised to incorporate sampling I carbon at the time of installation.
- 4. CB-1 is designed for 3000 cfm (ie, 3 HEPA filters at 1000 cfm per filter and 9 charcoal adsorber trays at 333 cfm/adsorber tray). System design is 3200 cfm. Design flow +/- 10% would cause residence time to be reduced from an assumed 0.25 seconds to approximately 0.20 seconds. Consequently, the adsorption efficiency would decrease.
Response
f
'A review of historical data indicates the flow has always been less than 3000 cfm, indicating the residence time has been adequate (2.0.25 seconds) (refer to the response to A.1.g).
- 5. Air flow capacity test (8.2.2.4 of PET-10-1) should be ,
demonstrated with the dampers DM-10251 A (B) opened in one case and closed in the other.
Response
Procedures will be revised to perform an airflow capacity test
- with Dampers DM 10251A and B opened in one case, and closed in the other. This test will be performed prior to startup.
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Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 13 of 18
- 6. When you remove charcoal from the spent fuel pool exhaust treatment system by taking a sample from the tray then the integrity of the system has been broken and a new in-place freon test is required (PET-10-1, Section 8.2.3.2).
Response
When a carbon sample is removed, it is immediately replaced with fresh carbon. The integrity of the frames, trays, etc, is not effected by the sampling. Therefore, there is no technical basis for performing in-place filter testing. This item was specifically discussed during the 1985 Harvard short-course on in-place filter testing. Industry experts, including Ron Bellamy of the NRC, agree that in-place testing after sampling is not required as long as this approach is taken.
- 7. Acceptance criteria in 9.9 of PET-10-1 should be 0.125" W. G.
not 0.10".
Response
A new procedure PET 10-3, " Verification of Spent Fuel Pool and Control Room Differential Precsure", is used in performing the differential pressure test instead of PET 10-1 and specifies an acceptance criterion of 1/8-in. water gauge pressure.
- 8. Acceptance criteria 9.10 of PET-10-1 should also include responding to a safety injection signal.
Response
Response to an SIS signal is tested by POT 25-2, not PET 10-1.
- 9. Step 8.5 of PET-10-1 should specify which of the DM-10250 dampers are to be open.
Response
PET 10-4 now performs damper testing and will be revised to specify the appropriate damper position for the DM-10250 series of dampers.
- 10. What is VP-142 in Step 8.5 of PET-10-1?
Response
VP-142 is a chilled water booster pump. It is normally running I
when CB-2 is running and should stop when CB-2 is secured.
s Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 14 of 18
- 11. Step 8.5A of MP-10-A should delete DM-10504 since this line has been capped off. Dampers DM-10251A and B should be verified as closed along with DM-10503 on Step 1 and DM-10251A and B are opened.
Response
DM-10504 is used, DM-10502 is not used. This line will be verified as capped and it will be deleted. Dampers DM-10251A and B are now checked in new Procedure PET 10-4.
- 12. Step 8.5 should also be demonstrated using a safety injection signal.
Response
This item is checked by POT 25-2.
- 13. It would appear that step 8.5B of Data Sheet 8 of PET-10-1 should include a closure of the inner redundant damper of outside air intake. This will be completed prior to startup.
Response
The new procedure, PET 10-4, will be revised to verify closure of the inner redundant damper of the outside air intake.
- 14. System components verified as operating in Step 8.5A of Data Sheets 9, 10 and 14 (PET-10-1) should be the same as Data Sheet 8. Appropriate components which stop are similar.
Response
The operational status of the system components is different.
High radiation stops CB-2. Toxic gas only stops CB-2 outside makeup air. However, new procedure PET 10-4, will be revised to list all appropriate components and their operating status on each data sheet to avoid confusion.
- 15. Data Sheet 11, page 4 of 4, the item dealing with CB-1 and the S02 test requirement, should refer to Technical Specification 4.3.3.12.
Response
The new procedure, PET 10-4, which tests toxic gas interlocks, will be revised to include Technical Specification references.
This will be completed prior to startup.
s Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 15 of 18
- 16. Data Sheet 12, CB-1 control room positive pressure test, should have V-141 A and B instead of VC-141 A and B. DM-10251 A (B) should be opened with the other closed when the test is run.
DM-10503 should be closed.
Response
PET 10-3 is used to perform control room differential pressure tests. It will be revised to correct the typographical errors specified. This will be completed prior to startup.
- 17. The visual inspection described in Data Sheet 15 should conform to Appendix A on ANSI N510-1975 as required by the Technical Specification.
Response
Vendor data sheets have been used in the past to verify conformance with ANSI N510. The appropriate PET data sheets will be used in the future. PET 10-1 will be revised to include all Appendix A requirements.
- 18. It would appear from Data Sheet 9 of PET-10-1 that the operation of the fans V-141 A and B and VC-148 is uncertain. It is not clear whether they are operating in the normal configuration and continue to operate after the cl2 signal or whether they are not operating. The status of these fans should be addressed in Data Sheets 9 and 10.
Response
PET 10-4 data sheets will be revised to include all components (refer to 14 above).
PICT 25-1
- 1. It would appear that PICT-25-1 should demonstrate a channel functional test and a channel calibration test.
Response
PICT 25-1 in conjunction with PET 10-4 demonstrates a channel functional test for the SO2 detectors. The vendor technical manual is used for the channel calibration test. This is consistent with the Administrative Controls established for the Trojan Nuclear Plant.
s Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 16 of 18
- 2. PICT-25-1 and PICT-25-2 do not agree. The former says that its purpose is to assure that the detector will cause the control room ventilation damper to isolate while the latter indicates its purpose is to assure that the detector system will shif t the control room ventilation system to the emergency ventilation recirculation mode. Data Sheet 9 of PET-10-1 indicates that the normal control system operates in the recirculation mode on a C12 signal.
Response
Although both procedures are inconsistent, closure of the dampers does in fact result in a shifting of the control room ventilation system to the recirculation mode and stops makeup fan VC-141. Corrections will be made to ensure the purpose of both procedures agree to avoid confusion.
ONI-54. Rev. 2
- 1. Under immediate operator actions DM-10251 A and B should already be closed unless a radiation challenge has occurred to the control room. Therefore, verifying that they are closed seems to be the appropriate action. The operator should put the face mask on since he or she has no way of knowing what the concentrations are and whether they are life threatening.
Response .
Plant procedures have been revised to specify that the dampers
- are automatically opened on a CB-1 start. ONI-54 requires the l damper control switches to be placed in the closed position l prior to starting CB-1 (refer to B.3 above).
l 2. Why are both emergency fans 142 A and 142 B started in the l recirculation mode? Why wouldn't just one be started?
l
Response
Starting both fans provides: (1) maximum cooling, (2) maximum recirculation of any toxic gases, and (3) greater assurance of
. operability. If the evaluation discussed in Item B.1 indicates that a large negative pressure is generated under this condi-tion, ONI-54 will be revised to specify starting only one train.
l l
l
4 Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 17 of 18
- 3. Dampers associated with VC-141, CB-3 and CB-4 should be shown to be closed also.
Response
ONI-54 will be revised to verify that the dampers associated with these fans are closed and the fans do, in fact, sto;.
ONI-12
- 1. Based upon reading this instruction it appears that the operators should initiate the CB-1 system and the dampers associated with the system.
Response
This procedure was recently revised to clarify instructions to the operators regarding operation of CB-1 and the dampers associated with the system (refer to A.1.h above for further details).
PICT 25-2
- 1. The objective (VII) should be to demonstrate that the C12 detection system will detect a C12 concentration less than or equal to 5 ppm and not at a concentration greater than 5 ppm.
Response
This is an editorial error which will be corrected.
I POT 20-1. Rev. 16
- 1. How is it determined that the preheat coil will initiate at 70%
l relative humidity? What test has demonstrated that they l initiate at this relative humidity?
Response
I
! The humidistat is included in the normal calibration routines.
l The vendor manual specifies the appropriate method for testing
, and verifying the adequacy of the humidistat. The humidistat's i function over the 20 percent to 100 percent humidity range is checked.
l
w w
Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 1 Page 18 of 18
- 2. POT 20-1 does not satisfy the Technical Specification because the heaters are not on during emergency ventilation system operation.
Response
POT 20-1 has been revised to specify a 70 percent humidity setting for the heaters during the first 10-hr phase of this test. This test demonstrates the capability of CB-1 to maintain the control room 1110*F. Since the heaters are set at 70 percent in the event of an accident, a lower setting that would keep the heaters on during POT 20-1 would not be representative of the system alignment during an accident.
Furthermore, preliminary indications are that the heaters may not even be necessary due to the high volume of relatively low humidity recirculation air which is mixed with the low volume of outside makeup air upstream of the heaters. Bechtel is performing ar. evaluation of this aspect of the design, which will be completed by June 20, 1986.
As in the past, the second 10-hr phase of POT 20-1 still requires that CB-1 be operated with the heaters energized to satisfy the charcoal drying function recommended in Regulatory Guide 1.52. Regulatory Cuide 1.52 is still considered to be the basis of the monthly 10-hr test and associated Trojan Technical Specification.
i BLK/mr/0569P
Trajan Nuclear Plant Mr. Steven A. Varga ,
Docket 50-344 May 19, 1986 License NPF-1 Attachment 2 Page 1 of 8 CB-1 ACTION PLAN Responsible Completion Action Item Basis Engineer Schedule Actions / Comments
- 1) Correct FSAR a) Section 12.3.3.2.3 LER 86-02 Kershul July 1, 1986 LDCR 86-07 (Annual FSAR Update) will to require makeup air close this item.
damper open.
b) Figure 9.4-3 to LER 86-02 Kershul July 1, 1986 LDCR 86-07 (Annual FSAR Update) will specify a heater close this item.
setting of 70%.
c) Misc. cross-reference LER 86-02 Kershul July 1, 1986 LDCR 86-07 (Annual FSAR Update) will errors. close this item.
- 2) Revise Procedures a) POT 20-1. LER 86-02 Goldmann Complete POT 20-1, Rev. 17, requires the dampers to be closed during the test.
b) POT 20-1. LER 86-02 Coldmann Complete Outside air makeup dampers open during LOCA. POT 20-1, Rev. 17, requires the dampers to be placed in auto-after-open following completion of the tests.
OI 10-2, Rev. 7, requires the dampers to be in auto-after-open. EI-0 requires operators to check SI status lights.
TM 86-036 modified makeup damper position status light.
c) POT 20-1. LER 86-02 Coldmann Complete POT 20-1, Rev. 17, requires CB-3&4 to be off during the test, i . _ _ _ _ _ _
Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 2 Page 2 of 8 CB-1 ACTION PLAN Responsible Completion 4 Action Item Basis Engineer Schedule Actions / Comments d) EI-0. LER 86-02 Goldmann Complete CB-3&4 off during LOCA. EI-0 deviated (D86-030) to Jequire that CB-3&4 be verified off by local observation.
e) POT 20-1. LER 86-02 Coldmann Complete Heaters set at 70% instead of 100%.
POT 20-1, Rev. 17, specifies a 70%
setting during the first 10-hr phase of this test during which the capability of CB-1 to maintain the control room 1110*F is confirmed. POT 20-1, Rev. 17 specifies a 20% setting during the second 10-hr phase of this test when the charcoal filters are dried.
f) POT 20-1. LER 86-02 Goldmann Complete Heaters cet at 70% during LOCA.
POT 20-1, Rev. 17, requires the heaters be set at 70% following completion of the test, g) PET 10-2. Internal Goldmann Prior to startup Correct typos to specify 130*C and 30*C, not 130% and 30%.
h) PICT 25-2. May 7, 1986 Bennett Prior to startup Specify 15 ppm, not >5 ppm.
NRC letter
- 1) New PET. PGE May 19, Goldmann December 31, 1986 NRC May 7, 1986 letter, Attachment 2, 1986 letter TS 3.7.6.1, Item 8: Demonstrate heater capability.
j) MP 9-1. PGE May 19, Goldmann December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1 Item 1: Make MP 9-1 consistent with PETS 10-1, 10-2.
I i
Trajan Nuclear Plant Mr. Steven A. Varga -
Dscket 50-344 May 19, 1986 License NPF-1 Attachment 2 Page 3 of 8 CB-1 ACTION PLAN Responsible Completion Action Item Basis Engineer Schedule ,
Actions / Comments k) PETS 10-1 and 10-2. PGE May 19, Goldmann December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1, Item 3: Require sampling carbon at time of installation.
- 1) Air flow tests. PGE May 19, Goldmann December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1, Item 5: Damper positions for tests.
m) PET 10-4. PGE May 19, Goldmann December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1, Item 9: Specify which dampers are open.
n) PET 10-4. PCE May 19, Goldrtann December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1, Item 11: Check Dampers DM-10251 A&B.
o) PET 10-4. PCE May 19, Goldmann Prior to startup NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1, Item 13: Check closure of inner redundant damper.
p) PET 10-4. PGE May 19, Goldmann December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1, Item 14: List all appropriate components.
q) PET 10 4 PGE May 19, Goldmann Prior to startup NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1, Item 15: Include TS references.
c) PET 10-3. PGE May 19, Goldmann Prior to startup NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1, Item 16: Correct typographical errors.
Trojan Nuclear Plant Mr. Steven A. Varga
- Docket 50-344 May 19, 1986 License NPF-1 Attachment 2 Page 4 of 8 CB-1 ACTION PLAN Responsible Completion Action Item Basis Engineer Schedule Actions / Comments s) PET 10-1. PCE May 19, Goldmann December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter PET 10-1, Items 1/ and 18: Revise PET data sheets.
t) PICTs 25-1 and 25-2. PCE May 19, Bennett December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter PICT 25-1, Item 2: Make procedures consistent.
u) ONI-54. PCE May 19, Goldmann December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter ONI-54, Items 2 and 3: Starting both emergency fans, damper closure, v) PICT 25-2. PGE May 19, Bennett December 31, 1986 NRC May 7, 1986 letter, Attachment 3, 1986 letter PICT 25-24, Item 1: Correct editorial i
- errors.
I w) ONI-12. PGE May 19, Goldmann December 31, 1986 NRC May 7, 1986 letter, Attachment 2, t 1986 letter TS 3.7.6.1, Item 5: Provide guidance.
- 3) Verify line Damper PCE May 19, Goldmann Prior to startup NRC May 7, 1986 letter, Attachment 3, DM-10502 is capped off. 1986 letter PET 10-1, Item 11: Check Dampers DM-10251A&B.
4
- 4) Evaluate TS Changes.
a) Evaluate TS change to PGE May 18, Kershul December 31, 1986 NRC May 7, 1986 letter, Items A.1.f.
require charcoal test- 1986 letter TS 3.7.6.1, Item 2.
ing at 30*F and removal efficiency I
of >95%.
I
e Trojan Nuclear Plant Mr. Steven A. Varga -
Docket 50-344 May 19, 1986 License NPF-1 Attachment 2 Page 5 of 8 CB-1 ACTION PLAN Responsible Completion Action Item Basis Engineer Schedule Actions / Comments b) Applicability of C12 PGE May 19 Kershul September 30, 1986 NRC May 7, 1986 letter, Attachment 2, and SO2 detectors. 1986 letter TS 3.3.3.6, Item 1: Determine operable modes.
c) Isolation levels and PGE May 19, Kershul September 30, 1986 Nhc May 7, 1986 letter, Attachment 2, time for C1 2. 1986 letter TS 3.3.3.6 Item 2.
d) >95% adsorption PCE May 19, Kershul September 30, 1986 NRC May 7, 1986 letter, Attachment 2, efficiency. 1986 letter TS 3.7.6.1, Item 4.
e) Surveillance testing Internal Kershul September 30, 1986 Revise LCA 120.
requirements.
- 5) Correct Drawing M-239 PGE Puntenney Complete M-239, Rev. 16, issued on April 22, 1986 and any associated April 21, with correct information. No M-500 draw-M-500 series drawing 1986 letter ings identified with discrepancies.
to specify a heater setting of 70% and correct other discrepancies.
- 6) Design evaluation LER 86-02 Wehage Prior to startup Bechtel is performing the design of CB-3&4. evaluation.
- 7) Evaluate toxic gas LER 86-02 Wehage Prior to startup Bechtel is performing the evaluation, protection for CB-1 when performing POT 20-1.
-t Trojan Nuclear Plant Mr. Steven A. Varga .*
Docket 50-344 May 19, 1986 License NPF-1 Attachment 2 Page 6 of 8 CB-1 ACTION PLAN Responsible Completion Action Item Basis Enzineer Schedule Actions / Comments
- 8) Evaluate control room LER 86-02 temperature design basis:
a) 110*F basis. Wehage Complete Bechtel letter dated April 18, 1986.
b) Safety-related Davis Prior to startup Evaluation is in progress to determine equipment. capability of instrumentation to withstand 110*F (or-greater).
- 9) Operator check-outs on Internal Goldmann Prior to startup Appears to be complete but still need SCBAs. to verify.
- 10) 1/8" positive pressure Inspection Satisfactorily demonstrating a 1/8" posi-in relation to Report 86-06 tive pressure in the control room is the adjacent areas: most important CB-1 related action to be completed this outage. A failure of a) Seal door and Irlandez May 30, 1986 this test could dolay Plant startup.
ceiling leaks. Therefore, sealing of leaks and per-formance of the test must be done early b) Install permanent Wehage Complete in the outage. This will allow cor-test instrumentation.
rective measures to be implemented before scheduled Plant startup in the c) Prepare test event of a test failure. NCR 86-040 procedure / perform Goldmann May 30, 1986 and PCC 86-536 have been issued to test. resolve Item a). PCC 86-535 has been issued to resolve Item b).
- 11) Add instrumentation Inspection Puntenney Prior to startup NCR 86-043 issued to resolve this.
ports to measure air Report 86-06 flow rates.
- y
(
Trojan Nuclear Plant Mr. Steven A. Varga Docket 50-344 May 19, 1986 License NPF-1 Attachment 2 Page 7 of 8 CB-1 ACTION PLAN Responsible Completion Action Item Basis Engineer Schedule Actions / Comments
- 12) Administrative control Memo Goldmann Prior to startup The appropriate A0 will be revised.
on opening penetrations JWL-88-86M into control room envelope.
- 13) Flow measurement Inspection Rupe Prior to startup T. Y. Chen (Bechtel) will be assisting disparities. Report 86-06 in completing this task.
- 14) Evaluate feasibility Internal Wehage May 30, 1986 Bechtel is performing the evaluation, of chiller for CB-1.
- 15) Control room heat load Internal Rupe May 30, 1986 Control room temperature measurements and data. service water inlet and outlet tempera-ture are to be provided to Bechtel.
- 16) Evaluate leakage Internal Wehage Prior to startup Bechtel is performing the evaluation.
characteristics of dampers isolating control room envelope from non-safety-related HVAC systems.
- 17) Re-evaluate NUREG-0737, May 7, 1986 Kershul Prior to startup Dose analysis has been completed, other III.D.3.4, contcol room NRC letter aspects underway.
habitability submittal.
- 18) Permanent fix to drain PGE May 19, Puntenney Prior to startup NRC May 7, 1986 letter, Items A.1.a and lines from V-141A&B. 1986 letter A.1.c.
r Trojan Nuclear Plant Mr. Steven A. Varga e Docket 50-344 May 19, 1986 License NPF-1 Attachment 2 Page 8 of 8 CB-1 ACTION PLAN Responsible Completion Action Item Basis Engineer Schedule Actions / Comments
- 19) Revise Plant procedures PGE May 19, Goldmann Complete NRC May 7, 1986 letter, Item A.1.b.
to measure makeup air 1986 letter flow rate every 18 months.
- 20) Evaluate design change PGE May 19, Puntenney Prior to startup NRC May 7, 1986 letter, Item A.1.g.
and/or TS change regard- 1986 letter ing CB-1 flow rate.
- 21) Design changes:
a) Relocation of intake PGE May 19, Seibel Prior to startup NRC May 7, 1986 letter, Item A.1.1.
doghouse. 1986 letter b) Installation of char- PGE May 19, Seibel Prior to startup NRC May 7, 1986 letter, Item A.1.1.
coal adsorber in 1986 letter makeup line.
c) CB-1 makeup dampers. PGE May 19 Davis Prior to startup NRC May 7, 1986 letter, Item A.1.J.
1986 letter d) Increase makeup air PGE May 19, Seibel Prior to startup NRC May 7, 1986 letter, Item A.2.a.
flow rate. 1986 letter e) Evaluate automatically PGE May 19, Davis Prior to startup NRC May 7, 1986 letter, Items B.2 stopping CD-5 and 1986 letter and B.4.
CB-10 on toxic gas, f) Delete CB-1 Internal Seibel December 31, 1986 PGE May 19, 1986 letter, response to preheaters. is 3.7.6.1, Item 2.
GAZ/kal 0830W.586
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