PLA-5916, Final Resolution to Generic Letter 2003-01 Control, Room Habitability
| ML051890066 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/28/2005 |
| From: | Mckinney B Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-03-001, PLA-5916 | |
| Download: ML051890066 (3) | |
Text
k I s
'.
- A Ik Brift T. McKlnnoy PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com P CT 3*..I JUN 2 8 2DD5 I
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OPI-17 Washington, DC 20555-0001 I .:..: ..
SUSQUEHANNA STEAM ELECTRIC STATION FINAL RESOLUTION TO GENERIC LETTER 2003-01 CONTROL ROOM HABITABILITY Docket Nos. 50-387 PLA-5916 and 50-388
References:
- 1) Generic Letter 2003-01 "ControlRoom Habitability," dated June 12, 2003.
- "RJspbozse-td Geric kLetter 2003-01 Control Room Habitability,"
dated August 11, 2003.
"Follow-up Response to Generic Letter 2003-01, Control Room Habitability,"
dated February3, 2004.
- 4) PLA-5861, R. A. Saccone (PPL) to USNRC Document Control Desk, "Follow-up Response to Generic Letter 2003-01, Control Roomn Habitability,"
dated Febnrary11, 2005.
The purpose of this letter is to provide the PPL Susquehanna, LLC (PPL) final resolution to Generic Letter (GL) 2003-01 "Control Room Habitability (CRH)."
Reference 4 provided updates of three commitments that had been completed and revised the completion dates of two commitments affected by the PPL plans for implementation of Extended Power Uprate (EPU).
Thus, this letter describes the commitments completed since issuance of Reference 4 and the schedule and plan for completion of the final commitment.
Document Control Desk PLA-5916 The two commitments completed are as follows:
"PPL commits to perform and transmit the results of an integrated tracer gas test using the standard test method described in American Society for Testing Materials (ASTM) Consensus Standard E741 "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution and the Results of the Corresponding Dose Consequence Analysis;"
and "PPL will perform an assessment of the AP Technical Specification and determine if changes to the Technical Specification are required."
Regarding the first commitment to perform a tracer gas test and transmit dose consequence analysis, PPL performed an integrated tracer gas test in December 2004 to determine the unfiltered air flow rate into the control room envelope (CRE). The tracer gas test was performed in accordance with ASTM E741. The integrated tracer gas test determined the unfiltered air flow rate into the CRE for the "A" division of Control
- m Room-ai abibility-Systems.(CRHSs) .tobe 150 +235.scfm and for-the "B" division of CRHSs to be 129 +/- 298 scfm.
The operability assessment performed a dose consequence analysis using these results (including the uncertainty band). The dose consequence analysis determined that the resulting dose consequences were within the applicable regulatory limits without crediting any compensatory measures. The dose consequence analysis used the current methodology described in the SSES FSAR. As a result, the CRHSs and CRE are considered OPERABLE.
One major contributor to the large uncertainty band in the tracer gas test is the accuracy
(+/- 3%) of the outside air make-up flow rate measurement. For SSES, the outside air make-up flow rate Technical Specification limit is less than 5810 cfm. This factor alone introduces a large uncertainty in the tracer gas test results. PPL currently assumes an unfiltered air flow rate of 10 scfm into the CRE for the DBA LOCA dose consequence analysis. Given the large uncertainty band associated with the tracer gas test, it is difficult to determine that the actual unfiltered air flow rate into the PPL control structure habitability boundary is within the assumed 10 scfm.
Regarding the commitment to assess the adequacy of the current Technical Specifications, PPL has determined that a conservative position would be to revise the PPL TSs. Currently, PPL confirms the integrity of the CRE by a AP surveillance
Document Control Desk PLA-5916 requirement (SSES Technical Specification Surveillance 3.7.3.4). The SSES CRE was designed to minimize unfiltered in-leakage into the CRE, which was confirmed by a design review. The ASTM E741 integrated tracer gas test performed at SSES determined that the unfiltered air flow rate into the CRE could be as low as 0 scfm or as high as 427 scfm. Given this result, the assumptions originally made regarding the unfiltered in-leakage rate of 10 scfm cannot be validated by a tracer gas test. To conservatively address this issue, SSES will propose changes to the Technical Specifications. Currently, an ongoing industry effort is underway to gain approval for a generic Technical Specification for the Control Room Habitability issue. PPL commits to submit to NRC a PPL Technical Specification change request that will implement the generic Technical Specification (TSTF-448) after it has been issued for use.
The one commitment that is not yet completed is as follows:
"PPL commits to providing a dose consequence submittal to the NRC, using the methodology described in Regulatory Guide 1.183, Alternative Radiological Source Terms For Evaluating Design Basis Accidents at Nuclear Power Reactors."
_PPL committed-to complete-this action by December-30,.2005 in.Reference 4 to allow _____
sufficient time for completion of one comprehensive AST analysis and AST license amendment request. This commitment will be met prior to December 30, 2005.
To assure that this dose consequence analysis remains conservative with respect to the integrated tracer gas test (including testing uncertainty), the submittal will encompass the integrated tracer gas test results plus the uncertainty error bands.
Any questions regarding this information should be directed to Mr. C. T. Coddington at (610) 774-4019.
Sincerely, 19,' W B. T. McKinney copy: NRC Region I Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector
Text
k I s
'.
- A Ik Brift T. McKlnnoy PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com P CT 3*..I JUN 2 8 2DD5 I
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OPI-17 Washington, DC 20555-0001 I .:..: ..
SUSQUEHANNA STEAM ELECTRIC STATION FINAL RESOLUTION TO GENERIC LETTER 2003-01 CONTROL ROOM HABITABILITY Docket Nos. 50-387 PLA-5916 and 50-388
References:
- 1) Generic Letter 2003-01 "ControlRoom Habitability," dated June 12, 2003.
- "RJspbozse-td Geric kLetter 2003-01 Control Room Habitability,"
dated August 11, 2003.
"Follow-up Response to Generic Letter 2003-01, Control Room Habitability,"
dated February3, 2004.
- 4) PLA-5861, R. A. Saccone (PPL) to USNRC Document Control Desk, "Follow-up Response to Generic Letter 2003-01, Control Roomn Habitability,"
dated Febnrary11, 2005.
The purpose of this letter is to provide the PPL Susquehanna, LLC (PPL) final resolution to Generic Letter (GL) 2003-01 "Control Room Habitability (CRH)."
Reference 4 provided updates of three commitments that had been completed and revised the completion dates of two commitments affected by the PPL plans for implementation of Extended Power Uprate (EPU).
Thus, this letter describes the commitments completed since issuance of Reference 4 and the schedule and plan for completion of the final commitment.
Document Control Desk PLA-5916 The two commitments completed are as follows:
"PPL commits to perform and transmit the results of an integrated tracer gas test using the standard test method described in American Society for Testing Materials (ASTM) Consensus Standard E741 "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution and the Results of the Corresponding Dose Consequence Analysis;"
and "PPL will perform an assessment of the AP Technical Specification and determine if changes to the Technical Specification are required."
Regarding the first commitment to perform a tracer gas test and transmit dose consequence analysis, PPL performed an integrated tracer gas test in December 2004 to determine the unfiltered air flow rate into the control room envelope (CRE). The tracer gas test was performed in accordance with ASTM E741. The integrated tracer gas test determined the unfiltered air flow rate into the CRE for the "A" division of Control
- m Room-ai abibility-Systems.(CRHSs) .tobe 150 +235.scfm and for-the "B" division of CRHSs to be 129 +/- 298 scfm.
The operability assessment performed a dose consequence analysis using these results (including the uncertainty band). The dose consequence analysis determined that the resulting dose consequences were within the applicable regulatory limits without crediting any compensatory measures. The dose consequence analysis used the current methodology described in the SSES FSAR. As a result, the CRHSs and CRE are considered OPERABLE.
One major contributor to the large uncertainty band in the tracer gas test is the accuracy
(+/- 3%) of the outside air make-up flow rate measurement. For SSES, the outside air make-up flow rate Technical Specification limit is less than 5810 cfm. This factor alone introduces a large uncertainty in the tracer gas test results. PPL currently assumes an unfiltered air flow rate of 10 scfm into the CRE for the DBA LOCA dose consequence analysis. Given the large uncertainty band associated with the tracer gas test, it is difficult to determine that the actual unfiltered air flow rate into the PPL control structure habitability boundary is within the assumed 10 scfm.
Regarding the commitment to assess the adequacy of the current Technical Specifications, PPL has determined that a conservative position would be to revise the PPL TSs. Currently, PPL confirms the integrity of the CRE by a AP surveillance
Document Control Desk PLA-5916 requirement (SSES Technical Specification Surveillance 3.7.3.4). The SSES CRE was designed to minimize unfiltered in-leakage into the CRE, which was confirmed by a design review. The ASTM E741 integrated tracer gas test performed at SSES determined that the unfiltered air flow rate into the CRE could be as low as 0 scfm or as high as 427 scfm. Given this result, the assumptions originally made regarding the unfiltered in-leakage rate of 10 scfm cannot be validated by a tracer gas test. To conservatively address this issue, SSES will propose changes to the Technical Specifications. Currently, an ongoing industry effort is underway to gain approval for a generic Technical Specification for the Control Room Habitability issue. PPL commits to submit to NRC a PPL Technical Specification change request that will implement the generic Technical Specification (TSTF-448) after it has been issued for use.
The one commitment that is not yet completed is as follows:
"PPL commits to providing a dose consequence submittal to the NRC, using the methodology described in Regulatory Guide 1.183, Alternative Radiological Source Terms For Evaluating Design Basis Accidents at Nuclear Power Reactors."
_PPL committed-to complete-this action by December-30,.2005 in.Reference 4 to allow _____
sufficient time for completion of one comprehensive AST analysis and AST license amendment request. This commitment will be met prior to December 30, 2005.
To assure that this dose consequence analysis remains conservative with respect to the integrated tracer gas test (including testing uncertainty), the submittal will encompass the integrated tracer gas test results plus the uncertainty error bands.
Any questions regarding this information should be directed to Mr. C. T. Coddington at (610) 774-4019.
Sincerely, 19,' W B. T. McKinney copy: NRC Region I Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector