ML20215M528

Provides Comments on Proposed Change to Unit 1 Control Room Habitability Sys Per Changes to Tech Specs & Regulatory Guides 1.52,1.78 & 1.95 Per

ML20215M528
Person / Time
Site:	Beaver Valley
Issue date:	05/11/1987
From:	Hayes J Office of Nuclear Reactor Regulation
To:	Jocelyn Craig Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.052, RTR-REGGD-01.078, RTR-REGGD-01.095, RTR-REGGD-1.052, RTR-REGGD-1.078, RTR-REGGD-1.095, TASK-3.D.3.4, TASK-TM NUDOCS 8705130293
Download: ML20215M528 (9)

Text

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May 11, 1987~

d MEMORANDUM FOR: JOHN.W. CRAIG,' ACTING BRANCH CHIEF DISTRIBUTION:

PLANT SYSTEMS BRANCH

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DIVISION OF ENGINEERING &

Local PDR SYSTEMS TECHNOLOGY EAdensam SVarga FROM:

JOHN J. HAYES, JR., PROJECT ENGINEER Glainas PROJECT DIRECTORATE 11-1 JHayes DIVISION OF REACTOR PROJECTS I/II JSniezek

SUBJECT:

REVIEW OF BEAVER VALLEY UNIT 1 CONTROL ROOM HABITABILITY SYSTEM CHANGES As agreed upon during our April 20, 1987 meeting between you and Elinor Adensam, by this memorandum I am providing my comments on the proposed changes to the Beaver Valley Unit 1 control room habitability systems. These changes cover the proposed design and operational changes, changes to the Unit 1 and Unit 2 technical specifications, and exceptions to Regulatory Guides 1.52, 1.78, and 1.95 which were described in a letter from Duquesne Light dated April 16, 1987. Enclosures 1 and 2 contain my comments on the technical specifications and the exceptions to the Regulatory Guides, respectively.

Also included with these comments are explanations as to why the licensee's proposals are not acceptable. In general, the proposals have been found unacceptable because they do agree with the standard technical specifications which are appropriate for the Beaver Valley Unit 1 design as approved by the staff in their SER on TMI Action Plan Item III.D.3.4 and based upon the proposed modifications to the Unit I control room habitability systems. I would like to emphasize that the licensing basis for the comon control room must be the same and that the criteria would be the present NRC criteria.

Therefore, unit 1 cannot have one criteria and unit 2 another. Also the appropriate NRC criteria is SRPs 6.4, 6.5.1 and 9.4.1 and Regualatory Guides 1.52, 1.78 and 1.95.

Based upon a discussion with Charlie Nichols of your staff I agreed to determine from other plants how system operability of isolation dampers could.

be maintained with one of the emergency diesel generators down for maintenance.

I contacted a utility with a design similar to Beaver Valley. This plant utilizes a bottled air system, has two reactors with a shared control room, and an emergency ventilation system. Based upon discussions with the utility, the solution may be for each motor-operated isolation dampir or valve to be connected to both a Unit 1 and Unit 2 diesel so that maintenance on one diesel does not render the system inoperable. For air-operated dampers or valves the source of power is the batteries. Again, each unit has its own power supply such that the system would remain operable with one battery unit down. Discussions with this utility indicated that the cross-connection of such power supplies would not be difficult especially if interconnections between Unit 1 and Unit 2 are already being made in terms of the radiation monitors and the toxic gas detectors. Based upon this information 8705130293 870511 PDR ADOCK 05000334 p

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I believe that the footnotes on Technical Specifications 3/4.7.7 and 3/4.9.15 would not be necessary.

As discussed with the licensee during previous meetings and telephone con-versations, both the present Unit 2 control room ventilation system and the Unit 1 system, with its intended modifications, are susceptible to single failures. The solution for Unit 1 is to install an additional manually operated butterfly valve on the piping to the emergency filtration system.

For Unit 2 the solution is to install an additional butterfly valve in series to each of the existing parallel butterfly valves which are located in the piping to the emergency filtration units. Each damper could then be powered by an emergency power source from each reactor and with a different source for each series damper as described in the preceding paragraph.

It should be noted that the licensee has not presented in any correspondence received to date any description of the modifications they are making to the Unit I ductwork which involves removal of a portion of it and the changing of the Unit I system from an automatic to a manual system. This information would need to be documented, reviewed and approved prior to allowing Unit 1 to restart.

The April 16, 1987 letter from the licensee indicates that the limiting design basis accident, in terms of the dose to the thyroid of the control room operator, is the small line break outside containment and the Beaver Valley Unit 2 FSAR is referenced. My review of the FSAR shows that in Amendment 13, (issued by the licensee during January 1987), this accident became limiting. Prior to this time, the limiting design basis accident for the thyroid dose was the LOCA. A review of the SSERs issued by the staff and a discussion with Bob Fell of your staff indicates that no SER was ever issued covering this change in the Unit 2 design basis. My review of the proposed changes also revealed that numerous new exceptions to Regulatory Guide 1.52 were taken in Amendment 13. Again these exceptions, which should have been addressed in an SSER Section 6.5.1 on ESF filter units, were not. Discussion with Bob Fell again revealed that no SER has ever been prepared.

i With the Beaver Valley Unit 2 soon to be licensed, this situation appears l

to present a significant problem. Can the license be issued when the SER and the SSERs do not reflect the design presented in the applicant's FSAR or the applicant's comitments? How many other changes has the applicant made in Amendments 13-17, issued January 1987-May 1987, which alter the design basis of the unit and for which the staff has not issued a new SER? Has the applicant informed the staff that such design basis changes are occurring?

It is my understanding that licensees are obligated to identify significant design changes for FSAR submittals. Therefore, the types of changes that Duquesne l

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COMMENTS ON BEAVER VALLEY UNITS 1 AND 2 CONTROL ROOM VENTILATION SYSTEM TECHNICAL SPECIFICATIONS 3/4.7.7 CONTROL R OM EMERGENCY HABITABILITY SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.7.1

1. Item d should not reference a temperature, 88 F, but rather reference a systew. In this case it would be the Unit I and Unit 2 air handling units. The air handling units are two components required to operate as a part of the means for mitigating the consequences of an accident. The temperature presented is really a surveillance requirement. In addition, because a parameter is below a certain valve does not ensure that the component regulat-ing that parameter is operable.

Item d should read:

" Two air handling units, with their assosciated cooling equipment, are OPERABLE for Unit 1 and two for Unit 2.

APPLICABILITY

1. Item a. with its footnote seems to imply that you could have 2 emergency ventilation systems OPERABLE with 1 of the 2 without emergency power. The two which are OPERABLE should all have emergency power. (REFER TO THE DISCUSSION IN THE COVER MEMORANDUM.)

ACTION l

1. Item b.1 should have the units in a 3.0.3 situation unless the license demomstrates that some number of subsystems less than 4 i

can pressurize the control room to 1/8 inch water gauge relative to adjacent areas with their flow (e.g. 3 subsystems give 1/8 inch at600cfm).

2. With the control room temperature above 88 F a 7 day action statement could leave the control room operators with a false sense of security. Reference is made to the June 1984 event at l

the McGuire Station. This loss of cooling event was the subject l

of AE0D report and the subject of Information Notice 85-89. The l

control room temperature above 88 F, requires immediate operation to ensure protection of the solid-state and other control room instrumentation. A more appropriate action statement needs to be proposed for the air handling units referenced under the coment I

on the LCO above. Two proposed wordings that may be appropriate are:-

" d.1 With one of either the Unit 1 or the Unit 2 air handling units inoperable, restore the inoperable unit to the OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

d.2 With both of either the Unit 1 or the Unit 2 air handling units inoperable or the control room temperature exceeding the temperature in surveillance requirements 4.7.7.1.1.a and 4.7.7.1.2.a. provide auxiliary cooling to the

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control room without degrading the control room envelope integrity."

3. It would appear that the requirements of 3.0.4 are indeed appropriate and should not be deleted as proposed by the licensee.

SURVEILLANCE REQUIREMENTS 4.7.7.1.1 Beaver Valley Unit 1

1. Item b should demonstrate flow through the HEPA filters and charcoal adsorbers for a period of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> since the licensee is taking credit for heaters. This is part of the standard technical specifications and is called out in Regulatory Guide 1.52. The l

purpose of this 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> test is to demonstrate that the control room temperature can be maintained below its equipment qualification temperature with the system in its emergency mode of operation and the additional heat load of the heaters being added to the control room and to dry out the charcoal. Test should be conducted on a STAGGERED TEST BASIS as specified in the i

standard technical specifications. The licensee was to provide justification for the 15 minutes.

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2. Item c should be written such that the tests to be performed are l

performed:

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a. once per 18 months; or b efter 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation; or

c. af ter each complete or partial replacement of a charcoal adsorber bank or a HEPA filter; or

d. after any structural maintenance on the HEPA filter or charcoal adsorber housing; or

e. following any painting, fire, or chemical release in any l

ventilation zone communicating with the system.

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O o As presently proposed by the licensee, both conditions b and c above, or both b and d above, or both b and e above must occur before the tests denoted as c.1, c.2, and c.3 are performed. Our proposed correction makes tl:eir specifications consistent with the standard technical specifications.

3. Item c.1 should have the in-place test of the charcoal adsorbers and the HEPA filters performed in accordance with the test procedure guidance of regulatory positions c.5.a. c.5.c and c.5.d of Regulatory Guide 1.52. Because the staff's safety evaluation'and the licensee's accident analysis was based upon HEPA filter and charcoal adsorber efficiencies of Regulatory Guide 1.52, the acceptance criteria of the in-place test should be 0.05% penetration for both Unit I and Unit 2. This is consistent with the standard technical specifications and reference is made to regulatory positions c.5.c and c.5.d of Regulatory Guide 1.52 and the licensee's TMI Action Plan III.D.3.4 submittal and the staff's associated SERs.

4. Item c.1 and d.1 should have the flow rate specified as the maximum that the filter unit would be subjected to since the penetration and bypass would be greatest under those conditions.

Based upon the licensee's description of his system, this appears to be 1000 cfm.

5. Item c.2 should have the laboratory conditions specified as ASTM D3803 and not ANSI N510-1980. This is the direct reference. In addition, the sampling described under a and b of this item should be conducted in accordance with Appendix A of ANSI N509-1980,

6. Item d.3 should have the flow rate specified for the differential i

pressure and this flow rate should not be greater than the 800 i

cfm assumed for the bottled air system. In addition, the positive l

pressure should be with respect to all adjacent areas as denoted in SRP 6.4 and not only to outside atmosphere. The licensee previously committed to this in Section 1.8 of the Unit 2 FSAR.

7. Item d does not require a demonstration that the emergency ventilation system starts 60 minutes following the receipt of a toxic gas signal, a CIB signal or a hign radiation signal. This is because the unit design has been altered to incorporate a manually activated valve. Emergency operating procedures for the facility should ensure that guidance to the operator is provided so that the design basis analyses are not negated and the unit has flow through the emergency ventilation filter unit initiated 60 minutes after the signal is received.

4.7.7.1.2 Beaver Valley Unit 2

1. All the comments which were made for Unit 1 under surveillance requirement 4.7.7.1.1 are applicable to Unit 2. The numbering may be slightly different.

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4.7.7.2 Bottled Air System

1. Item b.2 should demonstrate that the control room can be pressurized for a period of I hour at 800 cfm relative to all adjacent areas as noted above. The test is similar to one required of North Anna. It is not a foregone conclusion that because a ventilation flow rate of 800 cfm demonstrates a positive pressure of 1/8 inch that similar flow from the bottled air system will do likewise. The operation of various air handling units and the point of injection of the bottled air relative to normal flow distribution and the location where emergency makeup air normally enters the control room envelope will all effect the capability of the control room envelope to be maintained at 1/8 inch. As an example, the bottled air system test also checks the integrity of the pressurization system.

With the latter system in operation you are not checking the integrity of all of the isolation dampers.

3/4/.9.15 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMSI 3.9.15.1 LIMITING CONDITION FOR OPERATION

1. Footnotes would not seem to be appropriate. (REFER TO THE COVER MEMO.)

APPLICABILITY

1. No comments ACTION

1. Items b.1, and c.1 should both consider that all operations involving CORE ALTERATIONS or positive reactivity changes should be suspended like the standard technical specifications describe.

This has been neglected in ell of the proposed technical specifications action statements for this specification and 3/4.7.7.

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CO M ENTS ON DUUUES3E LIGHT SUBMITTAL SUPPORTING TECHNICAL SPECIFICATION CHANGES TO UNIT 1 CONTROL ROOM HABITABILITY SYSTEMS EXCEPTIONS TO REGULATORY GUIDE 1.52

1. Paragraph C.5.b

a. The licensee has indicated that the airflow and distribution test will be conducted in accordance with ANSI N509-1980 except that artificial resistance will be utilized in lieu of the recomendations of Paragraph 8.3.1.1. This paragraph of the standard has the components of the system installed. It is not clear why the licensee would not perform the test with the components installed. How could the tests be performed any other way?

b. Since artificial resistance is going to be utilized to perform the flow test why can't sufficient resistance be incorporated into the test to allow it to be performed at 1.25 times the design dirty filter pressure drop for the system.

c. The test called for in Paragraph 8.3.1.7 of the ANSI N510 standard should be performed at 50% of the pressure at which the test of Paragraph 8.3.1.5 was conducted.

2. Paragraphs C.S.c and C.S.d

a. Coments on the allowable penetration for the in-place test of i

the charcoal adsorbers and the HEPA filters were provided in the coments on the technical specifications. Acceptance criteria is 0.05%.

3. Paragraph C.5.d I

a. No justification has been provided for laboratory testing the charcoal at a frequency less than that recomended by l

Regulatory Guide 1.52 and that which is comon for the rest of the industry. Testing frequency should be consistent with the standard technical specifications.

EXCEPTIONS TO REGULATORY GUIDE 1.78

1. Paragraph C.9

a. The control room envelope should be at a positive pressure of 1/8 inch water gauge with respect to all adjacent areas and not just to atmosphere. This paragraph is clear. The licensee comitted to it with respect to all adjacent areas in the Unit 2 FSAR.

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2. Paragraph C.12

a. As stated tre this regulatory position, the release of the contents of a chlorine container during an earthqu'ake, flood, or a tornado is appropriate if the container facilities are not designed to withstand the effects of such a natural event.

It may also be appropriate to consider the release of such contents coincident with the radiological consequences of a loss-of-coolant accident if the container facilities are not designed to withstand the effects of an earthquake. This exception is not appropriate unless the chlorine is stored in containers designed to withstand the effects of the above mentioned natural events.

EXCEPTIONS TO REGULATORY GUIDE 1.95

1. Paragraph C.4

a. This paragraph is not addressing environmental qualification from a purely electrical equipment qualification standpoint i.e. 10 CFR 50.49 but rather from the standpoint, " Can the detector withstand the chemical environment, the thermal environment, and various other environmental conditions and still perform its intended function?". The question the licensee must answer is " Does it? ".

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O made should have been identified and if they were not, then Duquesne is failing to meet the intent of Regulation. By copy of this memorandum I am informing the Project Director responsible for Beaver Valley of this problem.

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John J. Hayes, Jr., Project Engineer Project Directorate 11-1 Division of Reactor Projects - I/II

Enclosures:

As stated

1. Comments on Beaver Valley Units 1 & 2 Control Room Ventilation Systems Technical Specifications

2. Comments on Duquesne Light Submittal Supporting Technical Specification Changes to Unit 1 Control Room Habitability Systems cc: J. Stolz E. Adensam S. Varga G. Lainas R. Pedersen F. Burrows C. Moon B. Boger PEj'PD1: PY JHayes/vag 05/// /87