JAFP-04-0159, Entergy Nuclear Operations, Inc., NRC Generic Letter 2003-01, Control Room Habitability, Initial Summary Actions Report

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Entergy Nuclear Operations, Inc., NRC Generic Letter 2003-01, Control Room Habitability, Initial Summary Actions Report
ML042810225
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 09/27/2004
From: Ted Sullivan
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-03-001, JAFP-04-0159
Download: ML042810225 (17)
v • d • e


Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP Entergy P.O. Box 11 0 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 T.A. Sullivan September 27, 2004 Site Vice President - JAF JAFP-04-0159 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

Subject:

Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 NRC Generic Letter 2003-01 Control Room Habitability, Initial Summary Actions Report

References:

1. NRC Generic Letter 2003-01, "Control Room Habitability," dated June 12, 2003.
2. Entergy Nuclear Operations Inc., Letter to USNRC (JPN-03-019) dated August 6, 2003, Regarding NRC Generic Letter 2003-01 "Control Room Habitability", 60-Day Response.
3. Nuclear Energy Institute, NEI 99-03, Revision 1, "Control Room Habitability Guidance," March 2003.

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. (ENO), as operator of the James A. FitzPatrick Nuclear Power Plant (JAF), hereby submits its second response to NRC Generic Letter 2003-01 (Reference 1).

ENO committed to submit this report in its 60-day response to Generic Letter 2003-01 (Reference 2). summarizes the results of initial 'one-time" actions outlined in Section 3 of NEI 99-03, Revision 1 (Reference 3). These initial actions provide the technical and licensing basis for additional actions, such as modifications, tests, technical specification changes, license amendments, or further analyses. Attachment I also addresses the information requested, including subparts 1(a),1 (b) and 1(c), by Generic Letter 2003-01, and summarizes the plans and schedules for the resolution of any significant discrepancies or conditions adverse to quality identified during these initial actions.

summarizes ENO's commitment contained in Attachment 1.

Should you have any questions concerning this letter, please contact Mr. Richard A. Plasse, Regulatory Compliance Manager, at (315) 349-6793.

Respectfully, Iv n Site Vice President Attachments:

1. Initial Summary Actions Report - NRC Generic Letter 2003-01, 'Control Room Habitability"
2. Summary of Commitments cc:

Mr. Samuel J. Collins Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Patrick Milano, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop MS-8-C21 Washington, DC 20555-0001 Office of Resident Inspector James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission P. 0. Box 136 Lycoming, New York 13093 State Contact Office of Nuclear Facility Safety - NY State Department of Nuclear Safety

IAttachment 1 to JAFP-04-0159 Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability Page 1 of 13

"<Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability TABLE OF CONTENTS

1.0 INTRODUCTION

2.0

SUMMARY

OF INITIAL ACTIONS 2.1 ASSEMBLE CONTROL ROOM HABITABILITY (CRH) LICENSING AND DESIGN BASES 2.2 ASSEMBLING THE CRH ANALYSES 2.3 DOCUMENT CRH LICENSING AND DESIGN BASES AND ANALYSES 2.4 ASSESS AND EVALUATE LICENSING/DESIGN BASES AND OPERATOR DOSE ANALYSES 2.5 CONFIRM THAT LIMITING DBA HAS BEEN USED To ASSURE ADEQUACY OF CRH DESIGN 2.6 ASSESS AND EVALUATE POTENTIAL SOURCES OF HAZARDOUS CHEMICALS. UPDATE HAZARDOUS CHEMICALS SURVEYS AS NECESSARY 2.7 ASSESS AND EVALUATE CONTROL ROOM IN-LEAKAGE 2.8 ASSESS AND EVALUATE CONTROL ROOM DURING SMOKE EVENTS 2.9 ASSESS AND EVALUATE THE ADEQUACY OF EXISTING CONTROL ROOM EMERGENCY VENTILATION TECHNICAL SPECIFICATIONS 3.0 RESPONSE TO GENERIC LETTER 2003-001 ITEMS 1, 2 AND 3 3.1 RESPONSE To ITEMS 1(a), 1(b), AND 1(C) 3.2 RESPONSE To ITEM 2 3.3 RESPONSE To ITEM 3 4.0

SUMMARY

OF PLANS AND SCHEDULES

5.0 REFERENCES

Page 2 of 13

Attachment I to JAFP-04-0159i Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability

1.0 INTRODUCTION

ENO has followed a systematic approach to assess and evaluate Control Room Habitability (CRH) at the James A. FitzPatrick Nuclear Power Plant (JAF). ENO used Section 3 of NEI 99-03, 'Control Room Habitability Guidance", Revision 1 (Reference 5.3) and Regulatory Guide 1.196, 'Control Room Habitability at Light-Water Nuclear Power Reactors" (Reference 5.13) as guidance. The following initial, "one-time actions" were part of these assessments, as necessary and appropriate:

  • Assemble CRH licensing and design bases (3.1.1);
  • Assembling the CRH analyses (3.1.2);
  • Document CRH licensing and design bases and analyses (3.1.3);
  • Assess and evaluate licensing/design bases and operator dose analyses (3.2.1);
  • Confirm that limiting Design Bases Accident (DBA) has been used to assure adequacy of CRH design (3.2.2);
  • Assess and evaluate potential sources of hazardous chemicals. Update hazardous chemicals surveys as necessary (3.2.3);
  • Assess and evaluate control room in leakage (3.2.4);
  • Assess and evaluate control room during smoke events (3.2.5); and

(NOTE: The corresponding Section of NEI 99-03, Revision. 1 is shown in parenthesis.)

These initial actions provide the technical and licensing basis for additional actions such as modifications, tests, Technical Specifications changes, license amendments, or further analyses.

This report summarizes the results of these initial actions. It also addresses Section 1, including subparts 1(a), 1(b), and 1(c), of Generic Letter 2003-01 (Reference 5.1).

Page 3 of 13

Attachment 1 to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 2.0

SUMMARY

OF INITIAL ACTIONS 2.1 ASSEMBLE CRH LICENSING AND DESIGN BASES ENO utilized NEI 99-03, Revision 1 as the guideline for completing the evaluation of Engineering Request (ER) No. 04-17574, "Support NRC Generic Letter 2003-001 On Control Room Habitability Through Action Plan JENG-APL-03-012 And The Corresponding Project Plan", (Reference 5.4). This ER summarizes the analyses and reviews completed to respond to NRC Generic Letter 2003-01.

The regulatory commitment to NUREG-0737, Item III.D.3.4, "Control Room Habitability" (Reference 5.5), requires JAF to "assure that control room operators will be adequately protected against the effects of accidental releases of toxic and radioactive gases and that the nuclear power plant can be safely operated or shut down under design basis accident conditions." This definition, expanding on the radiological requirements in General Design Criterion (GDC) 19 of Appendix A to 10 CFR Part 50, "Control Room", establishes the requirements for CRH. Engineering Request No. ER 04-17574 summarizes the licensing and design basis issues associated with CRH.

NEI 99-03, Revision I presents a structured process for the assessment of CRH at individual facilities. The process generally consists of the following steps:

  • Assemble licensing and design bases;
  • Assemble available CRH analyses;
  • Compare as-built plant conditions to the licensing and design bases;
  • Compare operating and maintenance practices and procedures to the licensing and design bases;
  • Evaluate applicability of industry issues;
  • Selection of limiting DBA for radiological analysis of CRH;
  • Toxic gas infiltration to the CRE;
  • Perform baseline testing to determine unfiltered in-leakage for radiological and toxic gas events;
  • Demonstrate conformance of baseline testing results with licensing and design bases; and
  • Implement a plant specific program to manage CRH.

Engineering Request No. ER 04-17574 follows the NEI suggested steps to address Control Room Habitability issues identified by industry and the NRC based on experiences with operating plants.

Page 4 of 13

B I to JAFP-04-0159*

  • .'Attachment Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 2.2 ASSEMBLING CRH ANALYSES The assembly of CRH analyses was performed during the preparation of ER 04-17574. The analyses are identified in the ER references and are retrievable for review.

2.3 DOCUMENT CRH LICENSING AND DESIGN BASES AND ANALYSES Engineering Request ER 04-17574 includes a summarization of these analyses. ER 04-17574 is a comprehensive summary prepared using NEI 99-03, Revision 1 guidance to ensure that all CRH related information is recorded and retrievable.

2.4 ASSESS AND EVALUATE LICENSING/DESIGN BASES AND OPERATOR DOSE ANALYSES Engineering Request ER 04-17574 includes sections detailing the assessment of the licensing and design bases. ENO reviewed the detailed engineering analyses of operator dose in the Control Room for the DBAs - Loss Of Coolant Accident (LOCA),

Control Rod Drop Accident (CRDA), Main Steam Line Break Accident (MSLBA), and Fuel Handling Accident (FHA) (References 5.6 and 5.7). These analyses assume that the operators will manually initiate Control Room Emergency Ventilation Air Supply System (CREVASS) 30 minutes after the accident for the DBA LOCA and CRDA. For the MSLBA, the analysis assumed manual isolation 12 minutes after the onset of the accident. This assumption provided a worst-case dose for the inhabitants of the Control Room.

The FHA analysis was performed using a limited application of the Alternate Source Term (AST) methodology and does not take credit for the CREVASS. As summarized in ER 04-17574, Control Room operators will be adequately protected against the effects of accidental release of toxic and radioactive gases, and the plant can be safely operated or shut down under design basis conditions.

2.5 CONFIRM THAT LIMITING DBA HAS BEEN USED To ASSURE ADEQUACY OF CRH DESIGN ER 04-17574 includes a review of the DBAs. ENO performed detailed Engineering analyses of operator dose in the CR for the DBA-LOCA, CRDA, MSLBA and FHA.

ENO has concluded that these accidents envelope all DBAs, and that they include the most limiting case.

Page 5 of 13

Attachment I to JAFP-04-0159.

Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 2.6 ASSESS AND EVALUATE POTENTIAL SOURCES OF HAZARDOUS CHEMICALS. UPDATE HAZARDOUS CHEMICALS SURVEYS AS NECESSARY ENO Calculation No. JAF-CALC-CRC-01953, Revision I 'Toxic Chemical Control Room Habitability Analysis (Reference 5.8) assesses and evaluates the potential hazardous chemicals that could impact Control Room Habitability. The original design of JAF did not incorporate specific features to protect Control Room operators from toxic gases entering the Control Room. The CREVASS provided pressurized filtered air to protect the Control Room from radioactive gases in the event of a design basis accident, but this system was not designed to provide protection from intrusion of toxic gases that could pass into the air intake as a result of a nearby industrial or transportation accident.

As part of the Three Mile Island (TMI) Action Plan, the NRC issued NUREG-0737 (Reference 5.5) containing item III.D.3.4, "Control Room Habitability" that required JAF to:

"...assure that control room operators will be adequately protected against the effects of accidental releases of toxic and radioactive gases and that the nuclear powerplant can be safely operated or shut down under design basis accident conditions."

In response to NUREG-0737, the plant surveyed governmental agencies with jurisdiction over hazardous material storage or transportation in nearby areas. The results of that survey determined that hazardous chemicals were stored and/or transported within five miles of JAF.

The plant re-performed the survey in late 1994 and updated the response to NUREG-0737 (Reference 5.9). Based on a detailed analysis, (Calculation No. JAF-CALC-CRC-01953 Revision 0), JAF concluded that Control Room operators were adequately protected from a postulated hazardous chemical accident.

Calculation JAF-CALC-CRC-01953 was recently revised (Revision 1) to re-assess and update the existing evaluation of various hazardous chemicals that may be stored or transported within five miles of JAF. This calculation was revised and updated pursuant to the guidance given in Section 3.2.3.2 of NEI 99-03, Revision 1, Hazardous Chemical Evaluation.

Page 6 of 13

Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant

-'> initial Summary Actions Repobt 2 Response to NRC Generic Letter 2003-01 Control Room Habitability 2.7 ASSESS AND EVALUATE CONTROL ROOM IN-LEAKAGE Control Room Envelope in-leakage testing was performed with sulfur hexafluoride tracer gas using procedures based on the methodology described in ASTM Standard E741-00 (Reference 5.14). The testing was performed during the period of June 24, 2004 to June 28, 2004 by NCS Corporation and Lagus Applied Technology. Samples were taken using syringes at various locations and were then subjected to gas chromatograph analysis to determine the presence of sulfur hexafluoride. As documented in ENO Report No. JAF-RPT-04-00423, 'Control Room Envelope Inleakage Testing at J.A. FitzPatrick Nuclear Plant " (Reference 5.11), the CRE tracer gas testing indicated that there was statistically no unfiltered in-leakage, which is less than the value assumed in the design basis radiological analyses (100 scfm).

2.8 ASSESS AND EVALUATE CONTROL RooM DURING SMOKE EVENTS NRC Generic Letter 2003-01 had asked licensees to confirm that reactor control capability is maintained from either the Control Room or the Alternate Shutdown Panels during a smoke event. JAF completed an evaluation of Control Room smoke events and documented the results in Interface Control Document No. JAF-ICD 00038, revision 0, "Control Room Habitability Smoke Evaluation" (Reference 5.12).

The plant has remote alternate shutdown panels that would be used in the cases where extensive smoke makes the Control Room uninhabitable. Reactor control can be accomplished from either the Control Room or the alternate shutdown panels to safely shutdown the plant.

JAF has seven independent smoke removal/ventilation systems, including one for the Control Room and one for the Relay Room. Additionally, the Reactor Building ventilation system and the Emergency Diesel Generator Building ventilation system service each alternate shutdown panel location such that smoke from a design basis fire would not adversely affect either location. These smoke removal system's normal functions are to support manual fire fighting activities at the plant by removing the products of combustion in affected areas to ensure area habitability. Smoke removal capability is not relied upon during accidents because the postulated fire is not analyzed concurrent with a design basis accident. Although smoke removal capability is on standby, these components may be available in the event of fire during accident scenarios.

An extreme failure of a fire barrier (wall/ceiling/floor) between the independent smoke removal/ventilation systems during a fire was the only possible scenario where both Control Room and alternate shutdown panels could be unusable, however, this is not considered to be a credible event. ENO takes the position that a barrier failure is beyond the intended scope of Generic Letter 2003-01 and NEI 99-03, Revision 1, especially since smoke alone will not cause a barrier failure.

Page 7 of 13

-  ; . g' F i~ ' t Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant

^ initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability The current plant design meets NFPA 204, 'Guide for Smoke and Heat Venting" (Reference 5.15) for smoke removal.

No known credible smoke event exists that could affect CRH while simultaneously blocking the normal egress path to the alternate shutdown panels or reactor controls.

Sufficient procedural guidance exists to mitigate credible smoke events. All active Control Room operators are qualified in the use of self-contained breathing apparatus (SCBAs).

2.9 ASSESS AND EVALUATE THE ADEQUACY OF EXISTING CONTROL RooM EMERGENCY VENTILATION TECHNICAL SPECIFICATIONS The current Technical Specifications surveillance requirement is a positive 1/8" water gauge differential pressure test to demonstrate CRE integrity.

The tracer gas testing, summarized in Section 2.7 above, determined that statistically the plant has no unfiltered in-leakage (zero scfm excluding the 10 scfm for ingress/egress). The CRE boundary does have some leakage, however, the leakage is out of the Control Room as designed.

The most likely source of future in-leakage of unfiltered air is from the higher pressure Relay Room ductwork and components that reside in the CRE. Normal system monitoring by the system engineer will identify and correct any significant degradation in the condition of this ductwork and associated components. However, ENO will commit to creating a preventive maintenance (PM) surveillance procedure to annually inspect the Relay Room duct work and components located inside the CRE to ensure that the CRE unfiltered inleakage vulnerability is rigorously maintained as leak tight as possible.

ENO concludes that the current surveillance testing supplemented by the system engineer's system monitoring and the new annual PM inspection provides adequate assurance that the integrity of the CRE is ensured and the dose to the operators will stay within GDC-19 limits. Therefore, no changes to the plant's Technical Specifications are merited.

Page 8 of 13

Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant in ihitial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 3.0 RESPONSE TO GENERIC LETTER 2003-001 ITEMS 1(a),1(b),1(c), 2, & 3 3.1 RESPONSE To ITEM 1 NEI 99-03, Revision 1, uControl Room Habitability Guidance," identifies a process to assemble and review the current licensing and design bases for Control Room Habitability. Using this guidance, ENO assembled and reviewed the plant's current licensing bases, design bases, operating and surveillance procedures, and relevant analyses (See Section 2 above).

Based on this review, and the results of the completed Control Room in-leakage test discussed in the response to paragraph 1(a) below, ENO confirms that the plant CRE and CRH systems currently meet the applicable habitability regulations and are designed, constructed, configured, operated, and maintained in accordance with the plant design and current licensing bases described in the Updated Final Safety Analysis Report (UFSAR).

Item 1(a)

The radiological analyses assume various scenarios and timing during the accidents with unfiltered inleakages of 100 scfm, 300 scfm, 2,100 scfm and/or 15,000 scfm. The radiological analyses most limiting unfiltered in-leakage case assumed 100 scfm with no single failures associated with a Main Steam Line Break Accident with high Reactor Coolant System (RCS) radiological activity. Testing was performed with sulfur hexafluoride tracer gas using procedures based on the methodology described in ASTM Standard E741-00. The testing was performed from June 24, thru June 28, 2004 by NCS Corporation and Lagus Applied Technology. The samples were taken using syringes at various locations and were then subjected to gas chromatograph analysis to determine the presence of sulfur hexafluoride. The CRE tracer gas testing indicated that there was statistically no unfiltered in-leakage, which is less than the value assumed in the design basis radiological analysis (100 scfm)

Item 1(b)

The current toxic gas analysis (hazardous chemical assessment) was originally performed in 1994 and updated for NRC Generic Letter 2003-01 in 2004. The toxic gas analysis uses 15,000 scfm of unfiltered inleakage, which is conservatively above the maximum forced flow capability (13,250 scfm) of the Control Room air handling unit.

Page 9 of 13

Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant

'KilnitialSummary Actions Reporti Response to NRC Generic Letter 2003-01 Control Room Habitability.

Reactor control capability is available from either the Control Room or various local control stations in the plant, in the event of smoke. In addition, the Control Room has a purge mode that can be used at the Shift Manager's discretion to remove smoke by dilution. The purge mode was specifically designed to provide the capability to remove smoke and other contaminants from the Control Room and introduce fresh air to ensure Control Room habitability. Additionally, breathing apparatus is available for Control Room operators, if needed.. Plant procedures provide for operator actions in the event of fire/smoke in the Control Room or fire external to the Control Room that affects instrumentation or control functions.

The procedures provide instructions for performing plant condition monitoring and equipment operation, including reactor control functions, at the local control stations if the Control Room becomes uninhabitable. Operability and surveillance requirements are identified in the Technical Specifications Section 3.3.3.2, Remote Shutdown System, for those local control stations needed to place and maintain the plant in a safe shutdown condition.

A credible smoke event does not exist that could affect Control Room habitability while simultaneously blocking the normal egress path to the alternate shutdown panels or controls.

Item 1(c) (Refer to item 2.9)

The current Technical Specifications surveillance requirement is a positive 1/8" water gauge differential pressure test to demonstrate CRE integrity.

The tracer gas testing, summarized in Section 2.7 above, determined that statistically, the plant has no unfiltered in-leakage (zero scfm excluding the 10 scfm for ingress/egress). The CRE boundary does have some leakage, however, the leakage is out of the Control Room as designed.

The most likely source of future in-leakage of unfiltered air is from the higher pressure Relay Room ductwork and components that reside in the CRE. Normal system monitoring by the system engineer will identify and correct any significant degradation in the condition of this ductwork and associated components. However, ENO will commit to creating a preventive maintenance surveillance procedure to annually inspect the Relay Room duct work and components located inside the CRE to ensure that the CRE unfiltered inleakage vulnerability is rigorously maintained as leak tight as possible.

ENO concludes that the current surveillance testing supplemented by the system engineer's system monitoring and the new annual PM inspection provides adequate assurance that the integrity of the CRE is ensured and the dose to the operators will stay within GDC-19 limits.

Page IOofl3

Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 3.2 RESPONSE To ITEM 2 ENO does not currently use compensatory measures at the plant. The results of the CRE tracer gas test were acceptably within the radiological and toxic gas calculation assumptions.

3.3 RESPONSE To ITEM 3 ENO will comply with the NRC Generic Letter 2003-01 regarding CRH. No further documentation is required for this question.

Page 1Iofl3

Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report; Response to NRC Generic Letter 2003-01 Control Room Habitability 4.0

SUMMARY

OF PLANS AND SCHEDULES Based on the satisfactory results of the CRE tracer gas testing, there are no further plans or schedules required for the James A. FitzPatrick Nuclear Power Plant. .

Page 12 of 13

Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant

., ;iInitial Summary Actions Report:*

Response to NRC Generic Letter 2003-01 Control Room Habitability

5.0 REFERENCES

5.1 NRC Generic Letter 2003-01, "Control Room Habitability", dated June 12, 2000 5.2 ENO Letter to USNRC, JPN-03-019, "NRC Generic Letter 2003-01, "Control Room Habitability," 60-day response", dated August 6, 2003.

5.3 NEI 99-03, 'Control Room Habitability Guidance", Revision 1, dated March 2003.

5.4 Engineering Request No. [[::JAF-04-17574|JAF-04-17574]], 'Support NRC Generic Letter 2003-01 on Control Room Habitability Through Action Plan JENG-APL-03-012 and the Corresponding Project Plan", Revision 0, dated September 15, 2004.

5.5 NUREG-0737, "Clarification of TMI Action Plan Requirements", Item III.D.3.4 'Control Room Habitability", dated October 1980.

5.6 Calculation No. JAF-CALC-RAD-00042, "Control Room Radiological Habitability Under Power Uprate Conditions and CREVASS Reconfiguration",

Revision 3D, dated June 9, 2004.

5.7 Calculation No. JAF-CALC-RAD-04410, 'Fuel Handling Accident- AST Analysis for Relaxation of Secondary Containment Operability", Revision 1, dated September 12, 2002.

5.8 Calculation No. JAF-CALC-CRC-01953, 'Toxic Chemical Control Room Habitability Analysis", Revision 1, dated April 7, 2004.

5.9 New York Power Authority Letter to USNRC (JPN-95-01 0), Regarding "Response to NUREG-0737, Item III.D.3.4 Control Room Habitability", dated March 2, 1995.

5.10 USNRC Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release",

Revision 1, dated December 2001.

5.11 Report No. JAF-RPT-04-00423, "Control Room Envelope Inleakage Testing at J.A. FitzPatrick Nuclear Plant", dated August 18, 2004.

5.12 Interface Control Document No. JAF-ICD-04-00038, "Control Room Habitability Smoke Evaluation", Revision 0, dated March 2, 2004.

5.13 Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors", dated May 2003.

5.14 ASTM Standard E741-00, Standard Test Method for Determining Air Charge in a Single Zone by Means of a Tracer Gas Dilution.

5.15 National Fire Code NFPA 204, "Guide for Smoke and Heat Venting", 1998 Edition.

Page 13 of 13

Attachment 2 to JAFP-04-0159 Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Summary of Commitments Page 1 of 2

!.! r - " : -';.: , - " I - ' -

Attachment 2 to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

List of Regulatory Commitments TYPE SCHEDULED (Ch one)

Ak COMPLETION ONE-TIME CONTINUING DATE (If Required)

COMMITMENT ACTION COMPLIANCE This letter contains One (1) new commitments.

ENO commits to creating a preventive X 12/31/2004 maintenance surveillance procedure to annually inspect the Relay Room and components located inside the CRE to ensure CRE unfiltered inleakage vulnerability is maintained as leak tight as possible.

Page 2 of 2

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP Entergy P.O. Box 11 0 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 T.A. Sullivan September 27, 2004 Site Vice President - JAF JAFP-04-0159 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

Subject:

Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 NRC Generic Letter 2003-01 Control Room Habitability, Initial Summary Actions Report

References:

1. NRC Generic Letter 2003-01, "Control Room Habitability," dated June 12, 2003.
2. Entergy Nuclear Operations Inc., Letter to USNRC (JPN-03-019) dated August 6, 2003, Regarding NRC Generic Letter 2003-01 "Control Room Habitability", 60-Day Response.
3. Nuclear Energy Institute, NEI 99-03, Revision 1, "Control Room Habitability Guidance," March 2003.

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. (ENO), as operator of the James A. FitzPatrick Nuclear Power Plant (JAF), hereby submits its second response to NRC Generic Letter 2003-01 (Reference 1).

ENO committed to submit this report in its 60-day response to Generic Letter 2003-01 (Reference 2). summarizes the results of initial 'one-time" actions outlined in Section 3 of NEI 99-03, Revision 1 (Reference 3). These initial actions provide the technical and licensing basis for additional actions, such as modifications, tests, technical specification changes, license amendments, or further analyses. Attachment I also addresses the information requested, including subparts 1(a),1 (b) and 1(c), by Generic Letter 2003-01, and summarizes the plans and schedules for the resolution of any significant discrepancies or conditions adverse to quality identified during these initial actions.

summarizes ENO's commitment contained in Attachment 1.

Should you have any questions concerning this letter, please contact Mr. Richard A. Plasse, Regulatory Compliance Manager, at (315) 349-6793.

Respectfully, Iv n Site Vice President Attachments:

1. Initial Summary Actions Report - NRC Generic Letter 2003-01, 'Control Room Habitability"
2. Summary of Commitments cc:

Mr. Samuel J. Collins Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Patrick Milano, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop MS-8-C21 Washington, DC 20555-0001 Office of Resident Inspector James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission P. 0. Box 136 Lycoming, New York 13093 State Contact Office of Nuclear Facility Safety - NY State Department of Nuclear Safety

IAttachment 1 to JAFP-04-0159 Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability Page 1 of 13

"<Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability TABLE OF CONTENTS

1.0 INTRODUCTION

2.0

SUMMARY

OF INITIAL ACTIONS 2.1 ASSEMBLE CONTROL ROOM HABITABILITY (CRH) LICENSING AND DESIGN BASES 2.2 ASSEMBLING THE CRH ANALYSES 2.3 DOCUMENT CRH LICENSING AND DESIGN BASES AND ANALYSES 2.4 ASSESS AND EVALUATE LICENSING/DESIGN BASES AND OPERATOR DOSE ANALYSES 2.5 CONFIRM THAT LIMITING DBA HAS BEEN USED To ASSURE ADEQUACY OF CRH DESIGN 2.6 ASSESS AND EVALUATE POTENTIAL SOURCES OF HAZARDOUS CHEMICALS. UPDATE HAZARDOUS CHEMICALS SURVEYS AS NECESSARY 2.7 ASSESS AND EVALUATE CONTROL ROOM IN-LEAKAGE 2.8 ASSESS AND EVALUATE CONTROL ROOM DURING SMOKE EVENTS 2.9 ASSESS AND EVALUATE THE ADEQUACY OF EXISTING CONTROL ROOM EMERGENCY VENTILATION TECHNICAL SPECIFICATIONS 3.0 RESPONSE TO GENERIC LETTER 2003-001 ITEMS 1, 2 AND 3 3.1 RESPONSE To ITEMS 1(a), 1(b), AND 1(C) 3.2 RESPONSE To ITEM 2 3.3 RESPONSE To ITEM 3 4.0

SUMMARY

OF PLANS AND SCHEDULES

5.0 REFERENCES

Page 2 of 13

Attachment I to JAFP-04-0159i Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability

1.0 INTRODUCTION

ENO has followed a systematic approach to assess and evaluate Control Room Habitability (CRH) at the James A. FitzPatrick Nuclear Power Plant (JAF). ENO used Section 3 of NEI 99-03, 'Control Room Habitability Guidance", Revision 1 (Reference 5.3) and Regulatory Guide 1.196, 'Control Room Habitability at Light-Water Nuclear Power Reactors" (Reference 5.13) as guidance. The following initial, "one-time actions" were part of these assessments, as necessary and appropriate:

  • Assemble CRH licensing and design bases (3.1.1);
  • Assembling the CRH analyses (3.1.2);
  • Document CRH licensing and design bases and analyses (3.1.3);
  • Assess and evaluate licensing/design bases and operator dose analyses (3.2.1);
  • Confirm that limiting Design Bases Accident (DBA) has been used to assure adequacy of CRH design (3.2.2);
  • Assess and evaluate potential sources of hazardous chemicals. Update hazardous chemicals surveys as necessary (3.2.3);
  • Assess and evaluate control room in leakage (3.2.4);
  • Assess and evaluate control room during smoke events (3.2.5); and

(NOTE: The corresponding Section of NEI 99-03, Revision. 1 is shown in parenthesis.)

These initial actions provide the technical and licensing basis for additional actions such as modifications, tests, Technical Specifications changes, license amendments, or further analyses.

This report summarizes the results of these initial actions. It also addresses Section 1, including subparts 1(a), 1(b), and 1(c), of Generic Letter 2003-01 (Reference 5.1).

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Attachment 1 to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 2.0

SUMMARY

OF INITIAL ACTIONS 2.1 ASSEMBLE CRH LICENSING AND DESIGN BASES ENO utilized NEI 99-03, Revision 1 as the guideline for completing the evaluation of Engineering Request (ER) No. 04-17574, "Support NRC Generic Letter 2003-001 On Control Room Habitability Through Action Plan JENG-APL-03-012 And The Corresponding Project Plan", (Reference 5.4). This ER summarizes the analyses and reviews completed to respond to NRC Generic Letter 2003-01.

The regulatory commitment to NUREG-0737, Item III.D.3.4, "Control Room Habitability" (Reference 5.5), requires JAF to "assure that control room operators will be adequately protected against the effects of accidental releases of toxic and radioactive gases and that the nuclear power plant can be safely operated or shut down under design basis accident conditions." This definition, expanding on the radiological requirements in General Design Criterion (GDC) 19 of Appendix A to 10 CFR Part 50, "Control Room", establishes the requirements for CRH. Engineering Request No. ER 04-17574 summarizes the licensing and design basis issues associated with CRH.

NEI 99-03, Revision I presents a structured process for the assessment of CRH at individual facilities. The process generally consists of the following steps:

  • Assemble licensing and design bases;
  • Assemble available CRH analyses;
  • Compare as-built plant conditions to the licensing and design bases;
  • Compare operating and maintenance practices and procedures to the licensing and design bases;
  • Evaluate applicability of industry issues;
  • Selection of limiting DBA for radiological analysis of CRH;
  • Toxic gas infiltration to the CRE;
  • Perform baseline testing to determine unfiltered in-leakage for radiological and toxic gas events;
  • Demonstrate conformance of baseline testing results with licensing and design bases; and
  • Implement a plant specific program to manage CRH.

Engineering Request No. ER 04-17574 follows the NEI suggested steps to address Control Room Habitability issues identified by industry and the NRC based on experiences with operating plants.

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B I to JAFP-04-0159*

  • .'Attachment Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 2.2 ASSEMBLING CRH ANALYSES The assembly of CRH analyses was performed during the preparation of ER 04-17574. The analyses are identified in the ER references and are retrievable for review.

2.3 DOCUMENT CRH LICENSING AND DESIGN BASES AND ANALYSES Engineering Request ER 04-17574 includes a summarization of these analyses. ER 04-17574 is a comprehensive summary prepared using NEI 99-03, Revision 1 guidance to ensure that all CRH related information is recorded and retrievable.

2.4 ASSESS AND EVALUATE LICENSING/DESIGN BASES AND OPERATOR DOSE ANALYSES Engineering Request ER 04-17574 includes sections detailing the assessment of the licensing and design bases. ENO reviewed the detailed engineering analyses of operator dose in the Control Room for the DBAs - Loss Of Coolant Accident (LOCA),

Control Rod Drop Accident (CRDA), Main Steam Line Break Accident (MSLBA), and Fuel Handling Accident (FHA) (References 5.6 and 5.7). These analyses assume that the operators will manually initiate Control Room Emergency Ventilation Air Supply System (CREVASS) 30 minutes after the accident for the DBA LOCA and CRDA. For the MSLBA, the analysis assumed manual isolation 12 minutes after the onset of the accident. This assumption provided a worst-case dose for the inhabitants of the Control Room.

The FHA analysis was performed using a limited application of the Alternate Source Term (AST) methodology and does not take credit for the CREVASS. As summarized in ER 04-17574, Control Room operators will be adequately protected against the effects of accidental release of toxic and radioactive gases, and the plant can be safely operated or shut down under design basis conditions.

2.5 CONFIRM THAT LIMITING DBA HAS BEEN USED To ASSURE ADEQUACY OF CRH DESIGN ER 04-17574 includes a review of the DBAs. ENO performed detailed Engineering analyses of operator dose in the CR for the DBA-LOCA, CRDA, MSLBA and FHA.

ENO has concluded that these accidents envelope all DBAs, and that they include the most limiting case.

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Attachment I to JAFP-04-0159.

Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 2.6 ASSESS AND EVALUATE POTENTIAL SOURCES OF HAZARDOUS CHEMICALS. UPDATE HAZARDOUS CHEMICALS SURVEYS AS NECESSARY ENO Calculation No. JAF-CALC-CRC-01953, Revision I 'Toxic Chemical Control Room Habitability Analysis (Reference 5.8) assesses and evaluates the potential hazardous chemicals that could impact Control Room Habitability. The original design of JAF did not incorporate specific features to protect Control Room operators from toxic gases entering the Control Room. The CREVASS provided pressurized filtered air to protect the Control Room from radioactive gases in the event of a design basis accident, but this system was not designed to provide protection from intrusion of toxic gases that could pass into the air intake as a result of a nearby industrial or transportation accident.

As part of the Three Mile Island (TMI) Action Plan, the NRC issued NUREG-0737 (Reference 5.5) containing item III.D.3.4, "Control Room Habitability" that required JAF to:

"...assure that control room operators will be adequately protected against the effects of accidental releases of toxic and radioactive gases and that the nuclear powerplant can be safely operated or shut down under design basis accident conditions."

In response to NUREG-0737, the plant surveyed governmental agencies with jurisdiction over hazardous material storage or transportation in nearby areas. The results of that survey determined that hazardous chemicals were stored and/or transported within five miles of JAF.

The plant re-performed the survey in late 1994 and updated the response to NUREG-0737 (Reference 5.9). Based on a detailed analysis, (Calculation No. JAF-CALC-CRC-01953 Revision 0), JAF concluded that Control Room operators were adequately protected from a postulated hazardous chemical accident.

Calculation JAF-CALC-CRC-01953 was recently revised (Revision 1) to re-assess and update the existing evaluation of various hazardous chemicals that may be stored or transported within five miles of JAF. This calculation was revised and updated pursuant to the guidance given in Section 3.2.3.2 of NEI 99-03, Revision 1, Hazardous Chemical Evaluation.

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Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant

-'> initial Summary Actions Repobt 2 Response to NRC Generic Letter 2003-01 Control Room Habitability 2.7 ASSESS AND EVALUATE CONTROL ROOM IN-LEAKAGE Control Room Envelope in-leakage testing was performed with sulfur hexafluoride tracer gas using procedures based on the methodology described in ASTM Standard E741-00 (Reference 5.14). The testing was performed during the period of June 24, 2004 to June 28, 2004 by NCS Corporation and Lagus Applied Technology. Samples were taken using syringes at various locations and were then subjected to gas chromatograph analysis to determine the presence of sulfur hexafluoride. As documented in ENO Report No. JAF-RPT-04-00423, 'Control Room Envelope Inleakage Testing at J.A. FitzPatrick Nuclear Plant " (Reference 5.11), the CRE tracer gas testing indicated that there was statistically no unfiltered in-leakage, which is less than the value assumed in the design basis radiological analyses (100 scfm).

2.8 ASSESS AND EVALUATE CONTROL RooM DURING SMOKE EVENTS NRC Generic Letter 2003-01 had asked licensees to confirm that reactor control capability is maintained from either the Control Room or the Alternate Shutdown Panels during a smoke event. JAF completed an evaluation of Control Room smoke events and documented the results in Interface Control Document No. JAF-ICD 00038, revision 0, "Control Room Habitability Smoke Evaluation" (Reference 5.12).

The plant has remote alternate shutdown panels that would be used in the cases where extensive smoke makes the Control Room uninhabitable. Reactor control can be accomplished from either the Control Room or the alternate shutdown panels to safely shutdown the plant.

JAF has seven independent smoke removal/ventilation systems, including one for the Control Room and one for the Relay Room. Additionally, the Reactor Building ventilation system and the Emergency Diesel Generator Building ventilation system service each alternate shutdown panel location such that smoke from a design basis fire would not adversely affect either location. These smoke removal system's normal functions are to support manual fire fighting activities at the plant by removing the products of combustion in affected areas to ensure area habitability. Smoke removal capability is not relied upon during accidents because the postulated fire is not analyzed concurrent with a design basis accident. Although smoke removal capability is on standby, these components may be available in the event of fire during accident scenarios.

An extreme failure of a fire barrier (wall/ceiling/floor) between the independent smoke removal/ventilation systems during a fire was the only possible scenario where both Control Room and alternate shutdown panels could be unusable, however, this is not considered to be a credible event. ENO takes the position that a barrier failure is beyond the intended scope of Generic Letter 2003-01 and NEI 99-03, Revision 1, especially since smoke alone will not cause a barrier failure.

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-  ; . g' F i~ ' t Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant

^ initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability The current plant design meets NFPA 204, 'Guide for Smoke and Heat Venting" (Reference 5.15) for smoke removal.

No known credible smoke event exists that could affect CRH while simultaneously blocking the normal egress path to the alternate shutdown panels or reactor controls.

Sufficient procedural guidance exists to mitigate credible smoke events. All active Control Room operators are qualified in the use of self-contained breathing apparatus (SCBAs).

2.9 ASSESS AND EVALUATE THE ADEQUACY OF EXISTING CONTROL RooM EMERGENCY VENTILATION TECHNICAL SPECIFICATIONS The current Technical Specifications surveillance requirement is a positive 1/8" water gauge differential pressure test to demonstrate CRE integrity.

The tracer gas testing, summarized in Section 2.7 above, determined that statistically the plant has no unfiltered in-leakage (zero scfm excluding the 10 scfm for ingress/egress). The CRE boundary does have some leakage, however, the leakage is out of the Control Room as designed.

The most likely source of future in-leakage of unfiltered air is from the higher pressure Relay Room ductwork and components that reside in the CRE. Normal system monitoring by the system engineer will identify and correct any significant degradation in the condition of this ductwork and associated components. However, ENO will commit to creating a preventive maintenance (PM) surveillance procedure to annually inspect the Relay Room duct work and components located inside the CRE to ensure that the CRE unfiltered inleakage vulnerability is rigorously maintained as leak tight as possible.

ENO concludes that the current surveillance testing supplemented by the system engineer's system monitoring and the new annual PM inspection provides adequate assurance that the integrity of the CRE is ensured and the dose to the operators will stay within GDC-19 limits. Therefore, no changes to the plant's Technical Specifications are merited.

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Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant in ihitial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 3.0 RESPONSE TO GENERIC LETTER 2003-001 ITEMS 1(a),1(b),1(c), 2, & 3 3.1 RESPONSE To ITEM 1 NEI 99-03, Revision 1, uControl Room Habitability Guidance," identifies a process to assemble and review the current licensing and design bases for Control Room Habitability. Using this guidance, ENO assembled and reviewed the plant's current licensing bases, design bases, operating and surveillance procedures, and relevant analyses (See Section 2 above).

Based on this review, and the results of the completed Control Room in-leakage test discussed in the response to paragraph 1(a) below, ENO confirms that the plant CRE and CRH systems currently meet the applicable habitability regulations and are designed, constructed, configured, operated, and maintained in accordance with the plant design and current licensing bases described in the Updated Final Safety Analysis Report (UFSAR).

Item 1(a)

The radiological analyses assume various scenarios and timing during the accidents with unfiltered inleakages of 100 scfm, 300 scfm, 2,100 scfm and/or 15,000 scfm. The radiological analyses most limiting unfiltered in-leakage case assumed 100 scfm with no single failures associated with a Main Steam Line Break Accident with high Reactor Coolant System (RCS) radiological activity. Testing was performed with sulfur hexafluoride tracer gas using procedures based on the methodology described in ASTM Standard E741-00. The testing was performed from June 24, thru June 28, 2004 by NCS Corporation and Lagus Applied Technology. The samples were taken using syringes at various locations and were then subjected to gas chromatograph analysis to determine the presence of sulfur hexafluoride. The CRE tracer gas testing indicated that there was statistically no unfiltered in-leakage, which is less than the value assumed in the design basis radiological analysis (100 scfm)

Item 1(b)

The current toxic gas analysis (hazardous chemical assessment) was originally performed in 1994 and updated for NRC Generic Letter 2003-01 in 2004. The toxic gas analysis uses 15,000 scfm of unfiltered inleakage, which is conservatively above the maximum forced flow capability (13,250 scfm) of the Control Room air handling unit.

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Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant

'KilnitialSummary Actions Reporti Response to NRC Generic Letter 2003-01 Control Room Habitability.

Reactor control capability is available from either the Control Room or various local control stations in the plant, in the event of smoke. In addition, the Control Room has a purge mode that can be used at the Shift Manager's discretion to remove smoke by dilution. The purge mode was specifically designed to provide the capability to remove smoke and other contaminants from the Control Room and introduce fresh air to ensure Control Room habitability. Additionally, breathing apparatus is available for Control Room operators, if needed.. Plant procedures provide for operator actions in the event of fire/smoke in the Control Room or fire external to the Control Room that affects instrumentation or control functions.

The procedures provide instructions for performing plant condition monitoring and equipment operation, including reactor control functions, at the local control stations if the Control Room becomes uninhabitable. Operability and surveillance requirements are identified in the Technical Specifications Section 3.3.3.2, Remote Shutdown System, for those local control stations needed to place and maintain the plant in a safe shutdown condition.

A credible smoke event does not exist that could affect Control Room habitability while simultaneously blocking the normal egress path to the alternate shutdown panels or controls.

Item 1(c) (Refer to item 2.9)

The current Technical Specifications surveillance requirement is a positive 1/8" water gauge differential pressure test to demonstrate CRE integrity.

The tracer gas testing, summarized in Section 2.7 above, determined that statistically, the plant has no unfiltered in-leakage (zero scfm excluding the 10 scfm for ingress/egress). The CRE boundary does have some leakage, however, the leakage is out of the Control Room as designed.

The most likely source of future in-leakage of unfiltered air is from the higher pressure Relay Room ductwork and components that reside in the CRE. Normal system monitoring by the system engineer will identify and correct any significant degradation in the condition of this ductwork and associated components. However, ENO will commit to creating a preventive maintenance surveillance procedure to annually inspect the Relay Room duct work and components located inside the CRE to ensure that the CRE unfiltered inleakage vulnerability is rigorously maintained as leak tight as possible.

ENO concludes that the current surveillance testing supplemented by the system engineer's system monitoring and the new annual PM inspection provides adequate assurance that the integrity of the CRE is ensured and the dose to the operators will stay within GDC-19 limits.

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Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability 3.2 RESPONSE To ITEM 2 ENO does not currently use compensatory measures at the plant. The results of the CRE tracer gas test were acceptably within the radiological and toxic gas calculation assumptions.

3.3 RESPONSE To ITEM 3 ENO will comply with the NRC Generic Letter 2003-01 regarding CRH. No further documentation is required for this question.

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Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report; Response to NRC Generic Letter 2003-01 Control Room Habitability 4.0

SUMMARY

OF PLANS AND SCHEDULES Based on the satisfactory results of the CRE tracer gas testing, there are no further plans or schedules required for the James A. FitzPatrick Nuclear Power Plant. .

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Attachment I to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant

., ;iInitial Summary Actions Report:*

Response to NRC Generic Letter 2003-01 Control Room Habitability

5.0 REFERENCES

5.1 NRC Generic Letter 2003-01, "Control Room Habitability", dated June 12, 2000 5.2 ENO Letter to USNRC, JPN-03-019, "NRC Generic Letter 2003-01, "Control Room Habitability," 60-day response", dated August 6, 2003.

5.3 NEI 99-03, 'Control Room Habitability Guidance", Revision 1, dated March 2003.

5.4 Engineering Request No. [[::JAF-04-17574|JAF-04-17574]], 'Support NRC Generic Letter 2003-01 on Control Room Habitability Through Action Plan JENG-APL-03-012 and the Corresponding Project Plan", Revision 0, dated September 15, 2004.

5.5 NUREG-0737, "Clarification of TMI Action Plan Requirements", Item III.D.3.4 'Control Room Habitability", dated October 1980.

5.6 Calculation No. JAF-CALC-RAD-00042, "Control Room Radiological Habitability Under Power Uprate Conditions and CREVASS Reconfiguration",

Revision 3D, dated June 9, 2004.

5.7 Calculation No. JAF-CALC-RAD-04410, 'Fuel Handling Accident- AST Analysis for Relaxation of Secondary Containment Operability", Revision 1, dated September 12, 2002.

5.8 Calculation No. JAF-CALC-CRC-01953, 'Toxic Chemical Control Room Habitability Analysis", Revision 1, dated April 7, 2004.

5.9 New York Power Authority Letter to USNRC (JPN-95-01 0), Regarding "Response to NUREG-0737, Item III.D.3.4 Control Room Habitability", dated March 2, 1995.

5.10 USNRC Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release",

Revision 1, dated December 2001.

5.11 Report No. JAF-RPT-04-00423, "Control Room Envelope Inleakage Testing at J.A. FitzPatrick Nuclear Plant", dated August 18, 2004.

5.12 Interface Control Document No. JAF-ICD-04-00038, "Control Room Habitability Smoke Evaluation", Revision 0, dated March 2, 2004.

5.13 Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors", dated May 2003.

5.14 ASTM Standard E741-00, Standard Test Method for Determining Air Charge in a Single Zone by Means of a Tracer Gas Dilution.

5.15 National Fire Code NFPA 204, "Guide for Smoke and Heat Venting", 1998 Edition.

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Attachment 2 to JAFP-04-0159 Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Summary of Commitments Page 1 of 2

!.! r - " : -';.: , - " I - ' -

Attachment 2 to JAFP-04-0159 Entergy Nuclear Operations, Inc. - James A. FitzPatrick Nuclear Power Plant Initial Summary Actions Report Response to NRC Generic Letter 2003-01 Control Room Habitability The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

List of Regulatory Commitments TYPE SCHEDULED (Ch one)

Ak COMPLETION ONE-TIME CONTINUING DATE (If Required)

COMMITMENT ACTION COMPLIANCE This letter contains One (1) new commitments.

ENO commits to creating a preventive X 12/31/2004 maintenance surveillance procedure to annually inspect the Relay Room and components located inside the CRE to ensure CRE unfiltered inleakage vulnerability is maintained as leak tight as possible.

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