ML20107J207

Informs That Current Design of Control Room Habitability Will Be Modified to Assure That Air Transport Time from Chlorine Detector to Isolation,Damper Greater than Isolation Time from Detection to Isolation,Per TMI Item II.D.3.4

ML20107J207
Person / Time
Site:	Brunswick
Issue date:	02/21/1985
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM NLS-85-054, NLS-85-54, NUDOCS 8502270421
Download: ML20107J207 (10)

Text

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i Cp&L -

Carolina Power & Light Company SERIAL: NLS-85-054 FEB 21 1985 I

Director of Nuclear Reactor Regulation Attention: Mr. D. B. Vassallo, Chief t Operating Reactors Branch No. 2

( Division of. Licensing j United States Nuclear Regulatory Commission Washington, DC 20555 t BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2

! DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 CONTROL ROOM HABITABILITY

Dear Mr. Vassallo:

In your letter of January 16,1985 you identified that Technical Specification 3/4.3.5.5 did not agree with the Final Safety Analysis Report (FSAR) or our NUREG-0737, Item lil.D.3.4 responses submitted on December 15,1980 and March 2,1983. Technical +

l Specification 3/4.3.5.5 indicates that there are two chlorine detectors which isolate the Control Room upon detection of high chlorine concentration, whereas the FSAR and the

, Ill.D.3.4 responses indicate that four detectors will isolate the Control Room.

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! Carolina Power & Light Company (CP&L) has reviewed this concern to determine what actions are required to resolve the discrepancies. This review included evaluating the following possible corrective actions:

1. Add the additional two detectors as identified in the FSAR and Ill.D.3.4 responses and submit a Technical Specification change request to reflect these additional detectors.

l 2. Relocate the chlorine car to a location outside the protected area where the need

. for the additional two detectors would not be required.

Installation of a system, utilizing non-gaseous blocide, to replace the chlorine

- 3.

system currently installed.

4. Modify, as required, the current design to assure that the air transport time from the chlorine detector to the isolation damper is greater than the isolation time from detection to isolation as allowed by Regulatory Guide 1.95.

Based on these evaluations, CP&L has decided to pursue Item No. 4, modification of the

- current design to ensure air transport time is greater than the isolation time. Final engineering, scheduling, and budgeting of this item is currently in progress.

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Mr. D. B. Vassallo Pega 2 The final schedule for completion of the chlorine detection system modification will be provided in our response for the control rooom 1/8-inch positive pressure concern to be submitted by April 15,1985. The justification for continued operation until these modifications can be performed was addressed in LER l-84-33 dated December 19,1984 and in a response to I&E Inspection Report 50-325/84-31 and 50-324/84-31 dated January 30,1985 (Attachment 1).

In addition to the requested information on the chlorine detector design, CP&L believes that further explanation of our January 16,1985 response on the 1/8-inch Control Room positive pressure is necessary and is provided in Attachment 2.

Should you have any questions concerning this matter, please contact Mr. Sherwood R.

Zimmerman at (919) 836-6242.

Yours very truly, hlb 0UXLLA.)l%

A. B. Cutter - Vice President Nuclear Engineering & Licensing ABC/ MAT /mf (ll70NLU)

Attachments cc: Dr. 3. Nelson Grace (NRC-RII)

Mr. D. O. Myers (NRC-BNP)

Mr. M. Grotenhuis (NRC)

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Carolina Power & Light Company D- -

Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461-0429 December 19, 1984 FILE: B09-13510C SERIAL: BSEP/84-2729 NRC Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20535 BRUNSWICK STEA!! ELECTRIC PLANT UNIT 1 DOCKRT NO. 50-325 LICENSE NO. DPR-71 LICENSEE EVENT REPORT 1-84-33 ,

Gentlemen:

, In accordance with Title 10 to the Code of Federal Regulations, the enclosed Licensee Event Report is submitted. This report fulfills the requirement for-a written report within thirty (30) days of a reportable occurrence and is in accordance with the format set forth in NUREG-1022, September 1983.

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O. R. D E C. R. Dietz, General !!anager Brunswick Steam Electric Plant

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1 I I I I I I  ! I I I I I I swtive ra6 arm, tot:rro n.. 3r, 2.. , , p ,, i svevis srcm it.$ 919 p., roma..re 12PECTED tviv.**rC4 C A rEl . ko l l l u.:t u cT n, , ,. ,. x a. . .u..... +, u,,.. .., . .. .,. m. .., n .1 W.ile performing a design review of the Control Building Emergency Ventilation y System (C3 IIVAC) following discussiens with the Resident NRC Inspector's office, it was determined that the chlarine isolation portien of the sys:em

• did not satisfy the design criteria esr :blished in the FSAR or the basis to. .

technical specifications. The basis to Technical Specifica:ica 3/4 3.5.5 (Chler.ine Detection System) states thct the Chlorine Detectica System is consistent with Regulatory Guide 1.95. Regulatory Guide 1.95 and the FSAR (Section 6.4.2.2) both indicate tha *the CB HVAC will be isolated by either a

'high chlorine signal at the Control Euilding air intake plenum or by a high chlorine signal at the chlorine storage location. Centrary to these requirements, the CE HVAC will only isolate on a hi;;h chlerine signal in the Centrol Building air intake plenum.

To correct this problem, a plant modifica icn will be implemented to bring the Chlorine Detection System into conformance with the required design criteria.

Until the plant ecdification is completed and made opera:icn21, addi:icnal surveillance requirements have been impcsed on the existing sys .c by the .

Plant Nuclear. Safety Committee (PSSC) to assure adequate chlorine pro:cc: ion

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010 0 l 2 0F 0l3 rixta, - ., - - e m_4.,nn While performing a design review of the Control Building Emergency Ventilation System (C3 HVAC) following discussions with the Resident NRC Inspector's office, it was determined that the chlorine isolation portion of the system did not satisfy the design criteria established in the FSAR or the basis to technical specifications. The basis to Technical Specification 3/4 3.5.5 (Chlorine Detectica System) states that the Chlorine Detection System is censistent with Regulatory Guide 1.95. Regulatory Guide 1.95 and the FSAR (Section 6.4.2.2) both indicate that the CB HVAC will be isolated by either a high chlorine signal at the Control Building air intake plenum or by a high chlorine signal at the chlorine s: crate locarion. Contrary to these requirements, the CB HVAC will only isolate on a high chlorine signal in the((~j, Centrol Building air intake plenum.

. Upon realization that the Chlorine Detection System did not meet the design ~~

criteria of the FSAR or the basis of technical specifications, a detailed review into the history of the Chlorine Isolation System was conducted. The following is a synopsis of that review:

1. March 1973: Response to FSAR Comment M14.5 commits Brunswick to install local and remote detectors having the capability of isolating the CB

.HVAC.

2. June 1974: Plant Piping & Instrument Diagram (PSID) drawings are revised showing logic for detectors 1(2)- X-AT-2979 (at the chlorine storage location) having isolation capability for the CB HVAC.

3. July 1974: Chlorine detectors 1(2)-X-AT-2977(C$airintakeplenum)are added to plant PLID drawings. Logic shows that the 1(2)-X-AT-2977 and the 1(2)-X-AT-2979 detectors have isolation capabilities.

4. August 1976: Preoperational test of the CB HVAC Syste= approved.

Isolation capability of the 1(2)-X-AT-2977 and the 1(2)-X-AT-2979 detectors was not verified. So design deficiencies were identified.

5. February 1982: A routine system review identifies a design deficiency with the Chlorine Isolation System--the system will not isolate if the Emergency Tiltration System control switch is in the "CS" position. So other design deficiencies identified (LER 2-E2-24) .

6. August 19E2: A design deficiency is identified in the Chlorine !sclatica System which prevents both makeup dampers from closing on a high chlorine signal. The architect / engineer determined that this was a design inadequacy during initial design (LER 2-52-84).

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O! 0 Ol 3 OF 0 13 rema m - . ~ ~ nne m e,nn During the course of this investigation. it could not be determined if the isclation logic fro = the 1(2)-X-AT-2979 detectors had ever been installed; although, as noted, the logic does appear on some plant drawings. The architect / engineer for Brunswick jCnited Engineers & Constructors (UELC), is being requested to investigate their in-house docu=entation in an attempt to determine the cause for the isolation design omission.

To correct this probic=, Carolina Power & Light Co=pany is undertaking the following actions:

1. As indicated above, UELC is being requested to investigate the cause of the design o=ission.

2. A plan: =odification will be written and i=plemented to bring the Chlorine Detection Syste= into co=pliance with design,co==it=ents.

3. A thorough design review of the Chlorine Detection System and its associated isolation logic will be perfor=ed and any required actica

. taken.

4. Until the Chlorine Detection System can be restored to the design ce==it=ents by a plant modification (s), the following actions have been or will be i=plemented to assure adequate chlorine protectica for Operations personnel in the Control Roo=:

a. Required surveillance on the Centrol Building air intake plenu:

de cctors (1(2)-X-AT-2977) will be perforced weekly vice =cnthly.

b. Power to these detectors will be verified on at Icas: a once per shift schedule (eight hours).

c. Standing instructions have been established to require the isolatien of the CE HVAC upon the receip: of a high chlorine ar.nunciation fro =

the 1(2)-X-AT-2975 chlorine detectors. These detectors are located in an area adjacent to the 1(2)-X-AT-2979 detectors and have an alar = function only. This isolation will be =aintained until the alar cicars and the inte;rity of the Chlorine Syste= is verified.

In additien, the week 1. surveillance identified in 4.a ateve will also be perfer=ed on the 1(2)-X-AT-297c detectors.

It should also be noted that the current design of the 1(2)-X-AT-2977 detecter isola: ion capability causes the Chlorine Detection Syste= to nc ecct signal-failure criteria in that the two operabic isolatien dete::::s share a cc==on power supply. Engineering evalus: ion has deter =ined that this does not cause a safety problem as these instru= cats will cause an isolatien en a loss of power (f alls safe) which has beer. verified by an opera:icnal cs:.

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Excerpt from CP& L's Response to I& E Inspection Report 50-325/84-31 and 50-324/84-31 (Serial: BSEP/85-0143 Dated January 30, 1985)

DEVIATION Based on the results of the NRC inspection conducted on October 15-November 30, 1984, certain of your activities appear to deviate from your commitments to the Commission as indicated below:

Appendix M, Responso M14.5, of the pre-1983 FSAR and Section 6.4.2.2 of the updated FSAR state that four chlorine detectors will cause a Control Room isolation upon sensing a high chlorine condition.

, . Contrary to the above, plant design is such that only two chlorine detectors will cause an isolation. This condition appears to have been the originsi plant design and not upgraded per the ccmmitments.

RESPONSE

A. Corrective Actions Regarding this Deviation To correct this event, Carolina Pcwor & Light Company has taken or is taking the following actions:

1. Complete L'ntil the Chlorine Detection System can be restored to design commitments, the following actions have been implemented to assure adequate chlorine protection for Operations personnel in the Control i, Room:

a. Required surveillance on the Control Duilding air intake plenum detectors (1(2]-X-AT+2977) is being performed weekly vice monthly.

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b. Standing instructions have been established to require the isolation of the CB HVAC upon the receipt of a high chlorine annunciation from the 1(2)-X-AT-2978 chlorine detectors. These detectors are located in the building adjacent to the chlorine storage tank car and have an alarm function only. This isolation will be maintained until the integrity of the Chlorine System is verified. In addition, the weekly surveillance identified in 1.a above will also be performed on the 1(2)-X-AT-2978 detectors.

c. *n investigation as to why the plant design did not reflect the cccmitment as made in the FSAR was performed by Carolina Power

& Light Company with assistance from the Brunswick AE, United Engineers & Constructors (UESC). This inve'stigation reveala?.

that the design of the Chlorine Detection System and its

' installation was directed by the mechanical discipline of UELC.

This design and installation was predicated on an analysis.

which did not require remote isolation requirements. The ccmmitment as identified in the FSAR was apparently generated by the electrical discipline of UE&C following their review of a draft Regulatory Guide (later to be Regulatory Guide 1.95).

Inadequate communication between the two disciplines led to the system being designed to one specification and a commitment te design it to a different specification.

d. A thorough review of the Chlorine Detection System has been performed. This was conducted by plant Engineering with the assistance of the chlorine detector vendor as required. No additional design problems were identified which were in conflict with the FSAR.

2. In Progress

a. Plant modifications are currently in progress'on the Control Building intake plenum detectors to improve the reliability of these chlorine detectors. These include rerouting the detector suctions and changing the suction piping per vendor recemmendations,

b. Plant Engineering is developing a proj2ct plan *to ensure that the design of the Chlorine Detection System meets applicable codos, regulations, and commitments. This plan will define the final work scope required to correct the design deviation and a schedule for completion. This plan will incorporate outside engineering and vendor assistance as required.

B. Actions Taken to Avoid Further Deviations

1. The FSAR update in 1982 placed the question and answer section (Appendix M) in the appropriate chapters of the FSAR. This action assures that when a system is to be modified and the FSAR is reviewed for design requirements, those requirements can be readily located in the appropriate chapter and not hidden in an appendix.

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2. Plant operating procedures and 10CFR50.59 require that design changes to the facility must be reviewed against the FSAR and appropriate evaluations made as to design changes. Based on these required evaluations on plant modifications and the improved reformatted / updated FSAR, future plant design changes should not deviate from the FSAR, except as allowed by regulations.

C. Dates When Actions Were or Will be Completed

1. The items identified in A.1 were completed on January 25, 1985.

Items A.l.a and b were completed by December 19, 1984

2. Item A.2.a is expected to be completed by February 4, 1985.

3. Item A.2.b is expected to be completed by February 22, 1985. This date is dependent on additional input to be received from UE&C.

Additonal information on this event can oc found in LER l-84-33 for the Brunswick facility.

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ATTACHMENT 2 TO NLS-35-054 1/8-INCH CONTROL ROOM POSITIVE PRESSURE (1170NLU/mf)

INTRODUCTION By letter dated March 2,1981 addressing NUREG-0737, item III.D.3.4, Control Room Habitability, CP&L committed to revise the existing periodic test acceptance criteria to quantify the positive pressure in the control room during operation of the Control Room Emergency Ventilation system. This procedure was revised as required. However, during performance of the periodic test on June 15,1984, the acceptance criteria of 1/8-inch water gauge positive pressure could not be achieved. This is the first such periodic test to be performed since the test acceptance criteria was revised to address the control room positive pressure. The NRC was notified of this in a letter dated October 3,1984.

Although unable to achieve the 1/8-inch water gau;',e positive pressure, the system did demonstrate a positive pressure as required by the Brunswick Technical Specifications.

Additionally, a review of the Brunswick Control Room Habitability Evaluation indicated that no credit was taken for the 1/8-inch pressure (i.e., the habitability evaluation and its conclusions are still valid), thus the control room ventilation system is considered operable in accordance with existing Technical Specification requirements.

An assessment of the inability to achieve 1/8-inch water gauge positive pressure was conducted by Brunswick Technical Support personnel. Using the services of the original HVAC vendor, the Bahnson Company, the following major areas of air exfiltration were identified:

1. Floor penetrations

2. Access doors

3. Duct work outside the control room envelope

4. Cinderblock walls

5. Duct work penetrations

6. The Shif t Operating Supervisor's of fice in addition, minor air exfiltration was noted at light switches and receptacles, damper blade gaskets, HVAC system instrument and control penetrations, and structural steel beam penetrations. These findings were consistent with problems noted at other utilities inspected by the Bahnson Company.

INVESTIGATION Additional testing was conducted in an ef fort to: 1) quantify the amount of make-up air required to achieve a 1/8-inch positive pressure, and 2) identify the major areas of exfiltration. The quantity of make-up air was determined to be approximately 6000 CFM using the method described in Regulatory Guide 1.95, Revision 1, Regulatory Position 5.

Additional make-up air was provided by throttling open a supply duct access door to the atmosphere until the 1/8-inch positive pressure was maintained. This indicated an exfl!tration rate six times greater than the 1000 CFM make-up provided during periods of Emcegency Filtration System operation.

To identify the major area of exfiltration, the access doors and the elevator shaf t were sealed with fire-retardant plastic and duct tape. The increase in pressurization was minimal, indicating that the c ile penetrations were the primary contributor of air exfiltration. The control room HVAC system was then balanced and no significant change was noted in pressurization.

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CORRECTIVE ACTION

1. Floor Penetrations it was determined that the majcrity of the air exfiltration could be attributed to

• ? cable penetratiens beneath the control room back panel enclosures and the ntrol room computers. Discussions were held with the Engineering Staff and other utilities to resolve the issue.

The Bisco Company was contacted to provide technical direction on the issue.

(Bisco has completed retrofit work on similar cable penetrations at 16 dif ferent nuclear generating stations since 1974.) The technical representative inspected the barriers and determined that air exfiltration did exist. It was recommended that a sealant be placed over the existing penetrations to provide a leak tight seal. This practice has been conducted at several other plants.

2. Access Doors The access doors were inspected and noted as leaking around the gaskets. The gaskets were readjusted and the leakage was reduced, but not eliminated.

3. Ductwork Outside the Control Room Envelope Inspections showed areas of exfiltration at duct work joints and along damper blade gaskets. Repairs were completed by Bahnson personnel to the extent possible, limited by the fact that a major percentage of the work would require shutdown of the control room HVAC system. This can only be accomplished during a dual unit shutdown.

4. Cinderblock Walls Air exfiltration occurs through cinderblock walls that are not sealed with a water-proof coating. An area of major concern is the elevator shaf t. Painting of these walls should be conducted during conditions such that paint fumes do not communicate with the Emergency Filtration System's charcoal beds.

5. Shif t Operating Supervisor's (SOS) Of fice The SOS's offit.e communicates directly with the control room. The access door leading to the stairwell (outside the control room envelope) has a gap beneath the door that adds to the air exfiltration.

RECOMMENDATIONS The following encompasses the recommendations associated with corrective action such that an 1/8-inch water gauge positive pressure can be obtained in the control room envelope:

1. Floor Penetrations Seal the existing cable penetrations beneath the back panels and computer with a scalant. Access to the vital NSSS back panels and computer should be obtained during unit shutdown since a potential for inducing scram conditions will exist.

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2. Access Doors A plant modification should be developed to either: 1) modify the existing door seals or 2) change the three control room doors to an airtight type. This work can be completed without an outage.

3. Duct Work Outside the Control Room Envelope Access must be gained to the interior of the duct work to provide an adequate repair. As such, a partial shutdown of the control room HVAC system is required resulting in an 8-hour LCO on both units. A dual unit outage is recommended for this work. Repair will consist of sealing or replacement of duct work and replacement of fan flex connectors.

4. Cinderblock Walls Cinderblock walls should be coated with a water-proof sealant. In order to prevent paint fume contamination of the Emergency Ventilation System, it is recommended that this task be performed during a dual unit outage.

5. Duct Work Penetrations Sealant with RTV or equivalent material is recommended. Access to some areas may require partial shutdown of the control room HVAC System. A dual unit outage is recommended for completion of this work.

6. Shif t Operating Supervisor's Of fice It is recommended that the door to the SOS's office be replaced with an airtight type. This is a non-outage item.

7. Other Those areas associated with minor air exfiltration (light switches, receptacles, etc.)

can be sealed as a non-outage item.

SUMMARY

The recommendations and corrective actions identified are currently in the planning and scheduling stages. As identified in our letter of January 16,1985, a firm completion schedule and a progress report will be submitted by April 15,1985. In addition to those actions currently being reviewed and evaluated, CP&L is also evaluating the need and requirement to maintain an 1/8-inch positive pressure in the control room. Based on the results of this evaluation, CP&L may be able to justify maintaining a lower positive pressure in the control room, thus potentially reducing the scope of work to resolve this item.

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