ML20211A754
| ML20211A754 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 09/11/1997 |
| From: | Donohew J NRC (Affiliation Not Assigned) |
| To: | Dewease J ENTERGY OPERATIONS, INC. |
| References | |
| RTR-REGGD-01.052, RTR-REGGD-1.052 TAC-M98367, TAC-M98368, TAC-M98369, TAC-M98370, TAC-M98371, NUDOCS 9709240376 | |
| Download: ML20211A754 (9) | |
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UNITED STATES
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U NUCLEAR RE^ULATORY GEMMISSION MM 5
I gy. /gg waswiwatou, o.c. somewooi
%.,, g September 11, 1997 67h-kN Mr. Jerrold G. Dewease Vice President, Operations Support Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995
SUBJECT:
INTERPRETATION OF FILTRATION UNIT FREQUENCY-OF-TESTING REQUIREMENTS SPECIFIED IN THE TECHNICAL SPECIFICATIONS AND REGULATORY GUIDE 1.52 FOR ARKANSAS NUCLEAR ONE, UNITS 1 AND 2, GRAND GULF NUCLEAR STATION, UNIT 1. RIVER BEND STATION, AND WATERFORD 3 STEAM ELECTRIC STATION (TACN05.M98367,M98368,M98369,M98370,ANDM98371)
Dear 11r. Dewease:
In your letter of March 20,1997(CNRO-97/00005), you requested a formal interpretation of the requirements on the frequency of testing filters in engineered safety feature (ESF) filtration systems, as specified in the Technical Specifications (TSs) for Arkansas Nuclear One, Units 1 and 2 (ANO-l&2), Grand Gulf Nuclear Station, Unit 1 (GGNS), River Bend Station (RBS),andWaterford3SteamElectricStation(WSES). The TSs (e.g.,
TS 3.6.4.3, ' Standby Gas Treatment (SGT) System,' for GGNS) require that the charcoal adsorber and high efficiency particulate air (HEPA) filters be tested at a frequency in accordance with the Ventilation Filter Testing Program (VFTP) and the VFTP specifies testing in accordance with Regulatory Guide (RG) 1.52, ' Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmospieric Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, ' Revision 2, dated March 1978 and ANSI N510-1975, " Testing of Nuclear Air Cleaning l
Systems.'
l Sections 5.c and 5.d, and note c to Table 2 of RG 1.52 state that HEPA and l
charcoal adsorber filter in-place leak testing, and laboratory testing of charcoal adsorber samples should be ennducted "following painting, fire, or chemical release in any ventilation zone communicating with the system.' The ANSI N510-1975 states, in Note 5.c of Table 1, that the HEPA and charcoal l
adsorber filter in-place leak testing, and laboratory testing of charcoal l
adsorber samples should be performed following exposure to solvents, paints, g3@J or other organic fumes or vapors which ould degrade the performance of the adsorber.
I You stated that RG 1.52 allows a technical justification to determine when HEPA and charcoal filters must be tested following ' painting, fire, or 0
chemical release in any ventilation zone comunicating with the system,' and Ik you requested that the Nuclear Regulatory Commission endorse the industry standards methods presented in the 21st and 24th Nuclear Air Cleaning and i
Treatment Conferences as such a justification for complying with the TS requirements for testing the charcoal filters.
This letter is our response 9709240376 970911 PDR ADOCK 05000313 hh((
P PDR
Jerrold G. Dewease :
to your request. Volatile organic materials circulated during painting, fire, or chemical releases can degrade the capability of the charcoal in filtration systems, if the materials are adsorbed by the charcoal.
This degradation may be sufficient to affect the potential filter efficiency of the systems for removing radioiodines from effluents during accidents and, therefore, may increase the potential radioiodine dose consequences for accidents where flitration systems are being taken credit for in accident analyses in Chmer 15 of the Updated Final Safety Analysis Report for the plant.
Therefore, testing of the charcoal is needed "following painting, fire, or chemical release in any ventilation zone communicating with'the system" to ensure that the filter efficiency assumed in the accident analysis will exist during an accident if the filtration system is called upon to mitigate the consequences of an accident. However, unnecessary testing of the charcoal following painting, fire, or chemical release will increase the inoperability of the systems (i.e., the system would be considered inoperable until the testing is completed and the required leak rate is verified) and may potentially subject the plant to unnecessary shutdowns.
In the letter, you made reference to the following as industry practices for complying with the surveillance requirements for testing ESF filtration systems "following painting, fire, or chemical release in any ventilation zone communicating with the system":
Ensure ESF flitration systems which exhaust an area are not operating during painting, chemical release, or fire in that area, and normal ventilation systems remove a sufficient amount of the volatile organics so that the remainder will not damage the charcoal in an ESF system when it is used. Communication is only considered to oerur when the filtration system is in operation.
If painting, a fire, or chemical rciease occurs during or just prior to the associated ESF filtration system being in operation, the effects of the event are evaluated to determine if the amount of volatile organics could have damaged the charcoal in the ESF system.
In preplanning painting or a chemical release, the amount of volatile organics expected to be released is evaluated to determine if the amount would damage the charcoal in an ESF system.
Reference was also made to industry data, that indicate that up to 10 percent by weight of the charcoal filter can be saturated by volatiles without decreasing the filter efficiency during an accident, in two papers, "A Study of the Effect of Coatings Opere ion on Radiciodine Removing Adsorbents" and
" Basis for and Practical Method of Controlling Paint Activities at Sequoyah Nuclear Plant," presented at the 21st and 24th Department of Energy (DOE)/NRC Nuclear Air Cleaning and Treatment Conferences, respectively.
It is these two papers that you requested that NRC endorse as criteria for determining when charcoal filter testing is required "following painting, fire. or chemical release in any ventilation zone communicating with the system." These papers could define the amount of volatile organics that would damage the charcoal in an ESF system.
Jerrold G. Dewease The staff does not typically endorse industry standard practices nor industry papers such as the two industry papers from the DOE /NP.C Nuclear Air Cleaning Conferences; however, the terms
- painting," " fires," " chemical release," and
" communicating" in RG 1.52 are subject to interpretation, and licensees are expected to develop interpretations of these terms to limit the HEPA and charcoal filter testing to situations which have a potential for degrading the ESF filtration system efficiency. However, these interpretations must be based on a well-documented, sound and conservative tachnical basis (i.e., the criteria should overestimate the potential damage to the charcoal).
In the course of performing inspections, the region may review these bases ad, if assistance by NRC headquarters is needed of a specific interprett A n the region will request such assistance. The licensee will document m interpretation in appropriate procedures and will apply its interpretation consistently in determining if HEPA and charcoal filter testing is required.
Because the system would be considered inoperable until the testing is completed, the licensee must plan for the contingency that an ESF filtration system may require HEPA and charcoal adsorber filter in-place leak testing, and laboratory testing of charcoal adsorber samples to be completed before the system is considered operable for continued plant operation.
It is the responsibility of the licensee to have criteria that defines these terms on a sound and conservative technical bash.
The bases for the criteria must be well-documented.
The staff considers that a painting, fire, or chemical release is not communicating with a ventilation system only if the ventilation system is not in operation and the isolacion dampers for the system are closed and leak tight thereby preventing air from passing through the filters.
If you have any questions, contact me, GGNS Project Manager, at 301-415-1307 or, via electronic mail, at jnd9nrc. gov. This closes out the staff's review under TAC Nos. M98367, M98368, M98369, M98370, AND M98371.
Sincerely, i
1 6C.UO.
\\
/ Jack N. Donohew, 'eni I roject Manager P
Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-368, 50-382, 50-416, and 50-458 cc:
See next page
Jerrold G. Dewease,
e The staff does not have any comments on the industry standard practices or e
two industry papers from the DOE /NRC Nuclear Air Cleaning Conferences; however, the terms " painting," " fires," " chemical release," and
" communicating" in RG 1.52 are subject to interpretation, and licens s are expected to develop interpretations of these terms to limit the H
. and charcoal filter testing to situations which have a potential fo degrading the ESF filtration system efficiency. However, these interpretat ns must be based on a well-documented, sound and conservative technica asis (i.e., the criteria should overestimate the potential damage to the arcoal).
The regions will review these bases and, if a review by NRC eadquarters is needed of a specific interpretation, the region will request e review. The licensee will document its interpretation in appropr ate procedures and will apply its interpretation consistently in determin g if HEPA and charcoal filter testing is required.
Because the system uld be considered inoperable until the testing is completed, the licensee m t plan for the contingency that an ESF filtration system may require HEP and charcoal adsorber filter in-place leak testing, and laboratory testi g of charcoal adsorber samples to be completed before the system is conside d operable for continued plant operation.
It is the responsibility of the lice ee to have criteria that defines these terms on a sound and conservative chnical basis. The bases for the criteria must be well-documented.
The staff considers that a pai ing, fire, or chemical release is not communicating with a ventila on system only if the ventilation system is not in operation and the isola on dampers for the system are closed and leak tight thereby preventing r from passing through the filters.
If you have any questi ns, contact me, GGN', Project Manager, at 301-415-1307 or, via electron $ m 1, at jnd9nrc. gov. This closes out the staff's review under TAC Nos. M98 7, M98368, M98369. V.98370, AND M90371.
Sincereiy, Jack N. Donohew, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Dock Nos. 50-313, 50-368, 50-382, 50-416, and 50-458 c:
See next page DISTRIBUTION:
Docket File PUBLIC PD4-1 r/f C. Hawes J. Rce E. Adensam (EGA1)
J. Donohew W. Beckner T. Gwynn, RIV ACRS OGC (15B18)
L. Marsh H. Walker J. Clifford Document Name: GG98367.LTR Y
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DATE k/
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COPY YES/NO YES/No YES/NO YES/NO YES/NO YES/No 0FFICIAL RECORD COPT
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Jerrold~G.- Dewease- _
September 11, 1997 The staff does not typically endorse industry standard practices nor industry papers such as the two industry papers from the DOE /NRC Nuclear Air Cleaning Conferences; however, the terms " painting," " fires," " chemical release," and
" communicating" in RG 1.52 are subject to interpretation, and licensees are expected to develop interpretations of these ter,is to limit the HEPA and charcoal filter testing to situations which have a potential for degrading the ESF filtration system efficiency. However, these interpretations must be based on a well-documented, sound and conservative technical basis (i.e., the criteria should overestimate he potential-damage to the charcoal).
In the course of performing inspections, the region may review these bases and, if assistance by NRC headquarters is needed of a specific interpretation, the region will request such assistance.
The licensee will document its interpretation in appropriate procedures and will apply its interpretation consistently in determining if HEPA and charcoal filter testing is required.
Because the system would be considered inoperable until the testing is completed, the licensee must plan for the contingency that an ESF filtration system may require HEPA and charcoal adsorber filter in-place leak testing, and laboratory testing of charcoal adsorber samples to be completed before the system is_ considered operable for continued plant operation.
It is the responsibility of the licensee to have criteria that defines these terms on a sound and conservative technical basis, The bases for the criteria must be well-documented.
The staff considers that a painting, fire, or chemical release is not communicating with a ventilation system only if the ventilation system is not in operation and the isolation dampers for the system are closed and leak tight thereby preventing air from passing through the filters.
If you have any questions, contact me, GGNS Project Manager, at 301-415-1307 or, via electronic mail, at jnd@nrc. gov. This closes out the staff's review under TAC Nos. M98367, M98368, M98369, M98370, AND M98371.
in rely ac onohew enior rojec Manager
' Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-368, 50-382, 50-416, and 50-458 cc:
See next page
'3 STRIBUTION:
[Dilcket Filty PUBLIC FD4-1 r/f C. Hawes J. Roe E. Adensam (EGAl)
J. Donohew W. Beckner T. Gwynn, RIV ACRS OGC (15B18)
L. Marsh H. Walker J. Clifford Document Name: GG98367.LTR-S previous concurrene.
0*C PM/PO4 h LA/PO4 1 BC/SPLB*d-RC/ FACB
- BC/TSBlv0$
P0/PO4 1 CHawedf}N LNataly E
von WBeckner JClifford NAME JDords 9 / N /97 9 / } /97
^E W 08/2s/97 9 / f /97 9/ // for cAtt YESh COPY YES/NO YES/NO YE5/NO YES/NO YES/NO OFFICIAL RECORD COPT
Entergy Operations, Inc.
Arkansas Nuclear One, Units 1 & 2 cc:
Executive Vice President Vice President, Operations Support
& Chief Operating Officer Entergy Operations, Inc.
Entergy Operations, Inc.
P. O. Box 31995 P. O. Box 31995 Jackson, MS 39286-1995 Jackson, MS 39286-1995 Director, Division of Radiation Wise, Carter, Child & Caraway Control and Emergency Management P. O. Box 651 Arkansas Department of Health Jackson, MS 39205 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Mr. C. Randy Hutchinson Vice President Operations, ANO Entergy Operations, Inc.
Winston & Strawn 1448 S. R. 333 1400 L Street, N.W.
Russellville, AR 72801 Washington, DC 20005-3502 Manager, Rockville Nuclear Licensing Framatone Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801 I
~,
Entergy Operations, Inc.
Grand Gulf Nuclear Station cc:
Executive Vice President General Manager, GGNS
& Chief Operating Officer Entergy Operations, Inc.
Entergy Operations, Inc.
P. O. Box 756 P. O. Box 31995 Port Gibson, MS 39150 Jackson, MS 39286-1995 Attorney General Wise, Carter, Child & Caraway Department of Justice P. O. Box 651 State of Louisiana Jackson, MS 39205 P. O. Box 94005 Baton Rouge, LA 70804-9005 Winston & Strawn 1400 L Street, N.W. - 12th Floor State Health Officer Washington, DC 20005-3502 State Board of Health P. O. Box 1700 Director Jackson, MS 39205 Division of Solid Waste Management Mississippi Department of Natural Office of the Governor Resources State of Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 Attorney General President, Asst. Attorney General Claiborne County Board of Supervisors State of Mississippi P. O. Box 339 P. O. Box 22947 Port Gibson, MS 39150 Jackson, MS 39225 Regicnal Administrator,' Region IV Vice President, Operations Support U.S. Nuclear Regulatory Commission Entergy Operations, Inc.
611 Ryan Plaza Drive, Suite 1000 P.O. Box 31995 Arlington, TX 76011 Jackson, MS 39286-1995 Senior Resident Inspector Director, Nuclear Safety U. S. Nuclear Regulatory Comission and Regulatory Affairs Route 2, Box 399 Entergy Operations, Inc.
Port Gibson, MS 39150 P.O. Box 756 Port Gibson, MS 39150 Manager of Operations Bechtel Power Corporation P.O. Box 2166 Houston, TX 77252-2166 Mr. Joseph J. Hagan Vice President, Operations GGNS Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 7
a.
Entergy Operations, Inc.
River Bend Station CC:
Winston & Strawn Executive Vice. President and 1400 L Street, N.W.
Chief Operating Officer Washington, DC -20005-3502 Entergy Operations, Inc.
P.-0. Box 31995 Manager - Licensing Jackson, MS 39286 Entergy Operations, Inc.
River Bend Station General Manager - Plant Operations P. O. Box 220 Entergy Operations, Inc.
St. Francisville, LA 70775 River Bend Station
- P. O. Box 220 Director St. Francisville, LA -70775 Joint Operations Cajun 10719 Airline Highway Director - Nuclear Safety P. O. Box 15540 Entergy Operations, Inc.
Baton Rouge, LA 70895 River Bend Station P. O. Box 220 Senior Resident Inspector St. Francisville, LA 70775 P. O. Box-1050 St. Francisville, LA 70775 Vice President - Operations Support Entergy Operations, Irc.
President of West Feliciana P. O. Box 31995 Police Jury Jackson, MS 39286-1995 i
P. O. Box 1921 St. Francisville, LA 70775 Attorney General State of Louisiana Regional Administrator, Region IV P. O. Box 94095 U.S. Nuclear Regulatory Commission Baton Rouge, LA 70804-9095 611 Ryan Plaza Drive. Suite 1000 Arlington, TX 76011 Wise, Carter, Child & Caraway P. O. Box 651 Ms. H. Anne Plettinger Jackson, MS 39205 3456 Villa Rose Drive Baton Rouge, LA 70806 Vice President & Controller Cajun Electric Power Cooperative Administrator 10719 Airline Highway Louisiana Radiation Protection Division P.O. Box 15540 P. O. Box 82135-Baton Rouge, LA 70895 Baton Rouge, LA 70884-2135 Mr. John R. McGaha Vice President - Operations Entergy Operations, Inc.
River Bend Station P.O. Box 220 St. Francisville, LA 70775 1
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Entergy Operations, Inc.
Waterford 3
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Administrator Regional Administrator, Region IV Louisiana. Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884-2135 Arlington, TX 76011 Vice President, Operations Resident Inspector /Waterford NPS Support Post Office Box 822 Entergy Operations, Inc.
K111ona, LA 70066 P. O. Box 31995 Jackson, MS 39286 Parish President Council St. Charles Parish Director P. O. Box 302 Nuclear Safety & Regulatory Affairs Hahnville, LA 70057 Entergy Operations, Inc.
P. O. Box B Executive Vice-President Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.
Wise, Carter, Child & baraway P. O. Box 31995 P. O. Box 651 Jackson, MS 39286-1995 Jackson, MS 39205 Chairman General Manager Plant Operations Louisiana Public Service Commission Entergy Operations, Inc.
One American Place, Suite 1630 P. O. Box B Baton Rouge, LA 70825-1697 Killona, LA 70066 Licensing Manager Vice President Operations Entergy Operations, Inc.
Entergy Operations, Inc.
P, O. Box B P. O. Box B K111ona, LA 70066 K111ona, LA 70066 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502
._