ML17290A857

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Requests Addl Info Needed Prior to Completion of Review of Submittal Re Amend to TS 3/4.6.5.3, Standby Gas Treatment & 3/4.7.2, Control Room Emergency Filtration Sys
ML17290A857
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 12/29/1993
From: Clifford J
Office of Nuclear Reactor Regulation
To: Parrish J
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
TAC-M84138, NUDOCS 9401050104
Download: ML17290A857 (9)


Text

Docket No. 50-397 December 29, i99 Hr. J.

V. Parrish (Hail Drop 1023)

Assistant Managing Director, Operations Washington Public Power Supply System P.O.

Box 968

Richland, Washington 99352-0968

Dear Hr. Parrish:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION WITH REGARD TO PROPOSED AMENDMENT TO TECHNICAL SPECIFICATION 3/4.6.5.3, "STANDBY GAS TREATMENT," AND 3/4.7.2, "CONTROL ROOM EMERGENCY FILTRATION SYSTEMS,"

FOR WASHINGTON NUCLEAR PLANT, UNIT NO.

2 (TAC NO. H84138)

By letter dated July 13,

1992, Washington Public Power Supply System requested an amendment to technical "specifications (TS) 3/4.6.5.3, "Standby Gas Treatment,"

and 3/4.7.2, "Control Room Emergency Filtration Systems."

The proposed amendment contains changes to incorporate improvements in charcoal testing standards and minor clarifications and changes to upgrade the two TS so that they accurately reflect the design and capability of the systems, remove potential ambiguities in the required surveillance testing, and editorially correct the Table of Contents.

After review of the submittal, the staff determined the need for additional information.

Enclosed is a request for additional information (RAI) that is needed prior to completion of the review of your submittal.

We request that you respond to the RAI within 60 days of your receipt of this letter.

This request for information affects fewer than 10 respondents.

Therefore, it is not subject to Office of Management and Budget review under Pub.

L.96-511.

Please contact us should you have any questions regarding this request.

9401050104 931229 PDR ADOCK 05000397 P

PDR

Enclosure:

As stated cc w/enclosure:

See next page Sincerely, Original signed by:

Sheri R. Peterson for James Clifford, Senior Project Manager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation NRC E Local PDRs EAdensam

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IIIEII:HE M'if~MV DATE 12/22 93 12 27 93 93 OFFICIAL RECORD COPY 039 9',l 7j DOCUHENT NAME:

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20M&4001 December 29, 1993 Docket No. 50-397 Hr. J.

V. Parrish (Hail Drop 1023)

Assistant Managing Director, Operations Washington Public Power Supply System P.O.

Box 968

Richland, Washington 99352-0968 II g.,'

Dear Hr. Parrish:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION WITH REGARD TO PROPOSED AMENDMENT TO TECHNICAL SPECIFICATION 3/4.6.5.3, "STANDBY GAS TREATMENT," AND 3/4.7.2, "CONTROL ROOM EMERGENCY FILTRATION SYSTEMS,"

FOR WASHINGTON NUCLEAR PLANT, UNIT NO.

2 (TAC NO. H84138)

By letter dated July 13,

1992, Washington Public Power Supply System requested an amendment to technical specifications (TS) 3/4.6.5.3, "Standby Gas Treatment,"

and 3/4.7.2, "Control Room Emergency Filtration Systems."

The proposed amendment contains changes to incorporate improvements in charcoal testing standards and minor clarifications and changes to upgrade the two TS so that they accurately reflect the design and capability of the systems, remove potential ambiguities in the required surveillance testing, and editorially correct the Table of Contents.

After review of the submittal, the staff determined the need for additional information.

Enclosed is a request for additional information (RAI) that is needed prior to 'completion of the review of your submittal.

We request that you respond to the RAI within 60 days of your receipt of this letter.

This request for information affects fewer than 10 respondents.

Therefore, it is not subject to Office of Management and Budget review under Pub.

L.96-511.

Please contact us should you have any questions regarding this request.

Enclosure:

As stated cc w/enclosure:

See next page Sincerely,

~N~- R..

~

~

~

James Clifford, Senior Project Manager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

n 1,

RE VEST FOR ADDITIONAL INFORMATION Enclosure TECHNICAL SPECI IC ON CHANG S FILTER TESTING FOR S ANDBY GAS TREATHEN SG SYSTEM AND CONTROL ROOM EMERGENCY FILTRATION CREF SYSTEM WASHINGTON NUCLEAR POWER PLAN UNIT 2 The following questions relate to the request by Washington Public Power Supply System (Supply System) to amend Technical Specifications (TS) 3/4.6.5.3, "Standby Gas Treatment,"

and 3/4.7.2, "Control Room Emergency Filtration Systems."

The proposed amendment contains changes to incorporate improvements in charcoal testing standards and minor clarifications and changes to upgrade the two TS so that they accurately reflect the design and capability of the systems, remove potential ambiguities in the required surveillance testing, and editorially correct the Table of Contents for Washington Nuclear Plant, Unit 2.

la.

Regarding the replacement of the reference to Regulatory Guide (RG)l'.52 with ASTH D 3803-1989:

The subject

standard, ASTH D 3803-1989, deals with only laboratory testing of carbon samples.

Explain the new standards applicability and adequacy for tests other than laboratory tests of carbon samples.

Both references should be retained in the subject surveillance requirement (SR), which could be revised to state that the tests will be performed in accordance with RG 1.52, Rev.

2 and ASHE N510-1989 or RG 1.52, Rev.

2 and ASTH D3803-1989, whichever is applicable.

This is consistent with the words used in Section 5.7.2. 13 of NUREG-1433 (Improved STS for BWR/4) so far as references to RG 1.52, ASHE N510-1989 and ASTH D3803-1989 are concerned.

lb.

Regarding the change of acceptance criteria for lab testing at 30'C and relative humidity 95N by showing a methyl iodide penetration of less than 20X for the SGT and used control room carbon and 3X for replaced new carbon:

The staff notes that the control room and offsite dose analyses assume 95 and 99 percent efficiencies for removal of organic and elemental forms of iodine by the control room and SGT carbon absorbers, respectively.

The Supply System needs to demonstrate the 95X and 99M

'fficiencies for the removal of organic and elemental forms of iodine by the control room and SGT absorbers.

To support the above assumption, the acceptance criteria should be no more than 1X and 0.2Ã methyl iodide penetration for the control room and SGT absorbers.

These percentages resulted from the use of a safety factor of 5 in determining the acceptance criteria for lack of operating data that supports a lower safety factor for the findings of the test performed in accordance with ASTH D3803-1989.

2.

Regarding the SGT 31-day operability test in SR 4.6.5.3.a from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 1 hour:

The Supply System uses the argument that the SGT units have thermostatically controlled strip heaters that elevate the charcoal inlet plenum temperature to 90 F, which assures that the relative humidity of the charcoal remains below 70X.

Please provide justification for ensuring the operability of these thermostatically controlled strip heaters.

The staff questions the reliability of the heaters to elevate the plenum temperature to 90'; therefore, the staff believes that the current 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of operation of the main heaters should be retained.

The proposed INSERT E to the Bases Page B 3/4.6-5 should be deleted.

3.

Regarding the Supply System proposed the deletion of flow rate test criteria specified in ANSI N510-1980, Section 8.3.1, Items 6 and 7:

The Supply System stated in their request that these two criteria are concerned with verifying flowrate under degraded filter conditions, but the filter elements have differential pressure alarms to alert the operators of degraded filter conditions and TS requirements maintain the pressure drop across HEPA and charcoal banks below specified limits.

Therefore, the degraded conditions are not experienced and the tests are superfluous.

These test requirements are not as much a test under degraded filter conditions as a test on the fan capability.

Therefore, the Supply System needs to verify whether the fan as furnished is capable of achieving the design air flow under actual field conditions at maximum and minimum filter pressures.

In this context, the staff notes that ASHE N510-1989 (which the staff has suggested as a replacement for ANSI N510-1980),

Section 8.5. 1.4 simplifies the test Criterion 8.3. 1, Item 6 and deletes the test Criterion 8.3.1, Item 7 of ANSI N510-1980.

Specifically, the 1989 standards does not call for air flow test under a

pressure drop of 1.25 times the design dirty filter pressure drop for the system, but under maximum housing component pressure drop for the system (as specified in the test program or project specifications).

Therefore, in lieu of the 1980 standards Section 8.3. 1, Items 6 and 7, the flow rate test should be conducted'in accordance with 1989 standards, Section 8.5. 1.4.

Hr. J.

V. Parrish Washington Public Power Supply System WPPSS Nuclear Project No.

2 (WNP-2)

CC:

Hr. J.

H. Swailes WNP-2 Plant Hanager Washington Public Power Supply System P. 0.

Box 968

Richland, Washington 99352-0968 G.

E.

C. Doupe, Esq.

(Hail Drop 396)

Washington Public Power Supply System 3000 George Washington Way P. 0.

Box 968

Richland, Washington 99352-0968 Hr. Warren Bishop, Chairman Energy Facility Site Evaluation Counci P. 0.

Box 43172 Olympia, Washington 98504-3172 Mr. Alan G. Hosier (Mail Drop PE20)

WNP-2 Licensing Manager Washington Public Power Supply System P. 0.

Box 968

Richland, Washington 99352-0968 Mr. D. Coleman (Mail Drop PE20)

Acting Regulatory Programs Manager Washington Public Power Supply System P. 0.

Box 968

Richland, Washington 99352-0968 Regional Administrator, Region V

U.S.

Nuclear Regulatory Commission 1450 Haria Lane, Suite 210 Walnut Creek, California 94596 Chairman Benton County Board of Commissioners P. 0.

Box 190

Prosser, Washington 99350-0190 Hr. R. C. Barr U. S. Nuclear Regulatory Commission P. 0.

Box 69 1

Richland, Washington 99352-0968 H. H. Philips, Jr.,

Esq.

Winston

& Strawn 1400 L Street, N.W.

Washington, D.C.

20005-3502

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