ML032790206

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Summary of Public Meeting Between Rg&E and NRC Staff
ML032790206
Person / Time
Site: Ginna Constellation icon.png
Issue date: 09/30/2003
From: Mecredy R
Rochester Gas & Electric Corp
To: Clark R
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML032790206 (53)
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Text

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Always at Your Service Robert C. Mecredy Vice President Nuclear Operations September 30, 2003 Mr. Robert L. Clark Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

Subject:

Summary of Public Meeting Between RG&E and NRC Staff Held on August 19, 2003.

R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Clark:

On August 19, 2003 representatives of Rochester Gas and Electric Corporation (RG&E) met with members of the NRC Staff at your offices in White Flint. The purpose of the meeting was to brief the Staff and provide an overview of our Control Room Emergency Air Treatment System (CREATS) License Amendment Request (LAR) submitted on May 21, 2003. This letter is to summarize RG&E's impression of that meeting and should be docketed as a supplement to the above mentioned LAR.

The meeting was opened with introductions (Attachment 1), followed by a slide presentation outlining the modification and RG&E's plans for implementation (Attachment 2). During and subsequent to the presentation, RG&E responded to Staff questions. These questions and their response are listed in Attachment 3. The regulatory commitments made by RG&E are provided in Attachment 4.

I declare under penalty of perjury under the laws of the United States of America that I am authorized by Rochester Gas and Electric Corporation to submit this documentation and that the foregoing is true and correct.

If you have questions regarding the content of this meeting please contact Mr. Mike Ruby at 585.771.3572.

Executed on September 30, 2003 An equal opportunity employer Sincerely 4 4 t Robert C. Mecredy 89 East Avenue I Rochester, NY 14649 tel 585) 546-2700 www.rge.com jO0oo386 pr 0 E

E An Ergy Est Company

Attachments:

1.

List of Attendees

2.

Slide Presentation

3.

Staff Questions and Responses

4.

List of Commitments Cc:

Mr. Robert L. Clark (Mail Stop 0-8-C2)

Project Directorate I Division of Licensing Project Management Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector Mr. Peter R. Smith, Acting President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. Paul Eddy NYS Department of Public Service 3 Empire State Plaza, 10h Floor Albany, NY 12223

Attachment I List of Attendees RG&E:

Mark Flaherty Mike Ruby Dan Crowley Paul Swift Ken Rubin Licensing Manager Licensing Engineer Systems Engineer Electrical Engineer Consultant to RG&E (Dose Analysis)

NRC:

Jay Lee Naeem Iqbal Kris Parczewski Robert Dennig Brad Harvey Leta Brown Janak Raval Robert Giardina Pete Hearn Harold Walker Ronaldo Jenkins Paul Rebstock NRR/SPSB NRR/SPLB NRR/EMCB NRR/SPSB NRR/SPSB NRR/SPSB NRR/SPSB NRR/IROB NRR/IROB NRR/SPSB NRR/EEIB NRR/EEIB Presentation Slides

NRC S TAFF PRES ENTATION R. E. Ginna Station August 19, 2003 Control Room Emergency Air Treatment System (CREATS)

Modification and Alternate Source Term (AST) Tech Spec Submittal 1

PURPOSE Brief NRC Staff on submittal and implementation plans Receive feedback from the Staff 2

AGENDA

  • Upgrade of CREATS
  • Revised Technical Specifications
  • Schedule
  • Response to Initial NRC Staff Questions
  • Open Discussion 3

Upgrade of CREATS 4

Design Changes

  • Location - Relay Room Annex
  • Filtered Re-circulation design
  • Two Trains - Fans, Filters and Coolers
  • Safeguard Power
  • Retains old system for normal HVAC -

isolates on actuation of new system

  • Add actuation signal from Safety Injection 5

CREATS Design wil3

  • = CONTROL ROOM EMERGENCY ZONE BOUNDARY

(=

EXISTING CREATS & HEATING/COOLING i=

PROPOSED NEW SYSTEMS GINNA CONTROL ROOM HVAC

Benefit of New CREATS

  • Redundancy and Reliability
  • Reduce Control Room in-leakage potential
  • Robust system with flexibility for future modifications
  • Regulatory - Address issues associated with Generic Letter 2003-0 1
  • Provide a safe environment for operators to perform their safety function, thereby ensuring public health and safety 7

Alternate Source Term 8

Why Change To Alternate Source Term

  • Opportunity to standardize old analysis
  • Widely accepted methodology
  • Existing regulatory basis and guidance -

1 OCFR50.67 and Regulatory Guide 1. 1 83 9

AST vs Old (TID) Method

  • More realistic timing, magnitude and chemical form of the release
  • Iodine release is predominately particulate
  • HEPA filters are credited to remove the particulate
  • Iodine removal from spray is mechanical, reducing importance of NaOH 10

Analysis Summary Accident LOCA FHA-CNMT FHA - AUX MSLB (a)

MSLB (b)

SGTR (a)

SGTR (b)

Lkd Rotor Rod Ejection SFP TMA GDT Rupture a Accident Initiated Spike b Pre-Accident Spike EAB 5.92 (25.0) 1.10 (6.3) 0.31 (6.3) 1.05 (2.5) 0.15 (25.0) 0.22 (2.5) 0.71 (25.0) 2.75 (2.5) 1.47 (6.3) 0.07 (6.3) 0.28 (0.5)

LPZ 1.06 (25.0) 0.07 (6.3) 0.02 (6.3) 0.15 (2.5) 0.03 (25.0) 0.02 (2.5) 0.05 (25.0) 0.55 (2.5) 0.24 (6.3)

N/A 0.02 (0.5)

Cont 3.03 (5.0) 1.20 (5.0) 0.09 (5.0) 0.64 (5.0) 0.18 (5.0) 0.14 (5.0) 0.88 (5.0) 3.72 (5.0) 1.04 (5.0)

Rm 0.06 0.10 (5.0)

(5.0) 11

Locked Rotor Dose Analysis

  • Artificially High Due to Conservative Fuel Failure Assumptions
  • Exceeds Reg Guide and SRP guidance of 2.5 rem TEDE, but well below regulatory limit of 25 rem
  • Locked Rotor not currently in Ginna' s licensing basis 12

Proposed Changes to Ginna Technical Specifications 13

New Considerations

  • RG&E will review/resubmit applicable sections of this submittal based on approved TSTF-448 14

Section 1.1

- Definitions

  • Change Dose Equivalent I-131 to reflect ICRP-30 standards 15

Section 3.3.6 - CREATS Instrumentati on

  • Add new CREATS initiation signal from SI
  • Remove note allowing 1/24 hour unisolation of Control Room - Not needed, new system has redundant trains.
  • Remove Core Alteration Applicability consistent with Standard Tech Specs 16

Section 3.4.16 - RCS Specific Activity

  • Remove Figure 3.4.16-1, 1-131 vs Power
  • Replace curve with single limit
  • Changes consistent with new analysis methodology and assumptions 17

Section 3.6.6 - CNMT Systems

  • Remove CNMT Post Accident Charcoal Filters
  • Change NaOH Tank volume requirement consistent with analysis
  • Move upper NaOH Tank concentration limit from TRM to Tech Specs 18

Section 3.7.9 - CREATS

  • Complete rewrite to reflect new system configuration based on WOG Standard Tech Specs (will revise to approved TSTF-448).

19

Section 5.5.10 - VFTP

  • Delete CNMT Post Accident Charcoal System
  • New surveillance criteria for CREATS DP -

format consistent with STS 20

Section 5.5.15

  • Add requirement for a Control Room Integrity Program 21

Section 5

. 7

  • Add reporting requirement for control room boundary inoperability 22

Summary of Proposed Changes

  • Modify/Replace the CREATS
  • Update Control Room and Off-Site Dose Analysis for Accidents using AST Methodology per Reg Guide 1.183
  • Revise Ginna Technical Specifications to reflect changes and realize benefits of AST 23

Tentative Schedule

  • Issue detailed design - January 2004
  • Complete construction and implement Tech Spec - June 2004
  • Complete initial Tracer Gas inleakage testing - September 2004 24

Responses to Initial Staff Questions 25

Appendix R

  • Is the modification modifying any Appendix R fire areas?

- The Ginna modification process requires a thorough Appendix R review.

However, no change to current licensing basis is anticipated

  • How is smoke handled by the modification?

Smoke will be addressed in accordance with Reg Guide 1. 196 and NEI 99-03 26

TURBINE BUILDING AL INTERMEATE BUILDING CONTAJNMENTA w

Y TRANSFORMER YARD CONTROL BUILDIN(

CONTROL ROOM EXIT TO URBINE DECK CONTROL ROOM i

-.CONTRT ROOM11 ALTERNPATE EXIT ilA tA N_

AUXIUARY BUILDING SECTION A-A A STAIRWELL CONNECTS THE CONTROL & RELAY ROOMS.

EXIT FROM CONTROL ROOM CAN BE TO:

1) TURBINE DECK (NORMAL ENTRANCE/EXIT)
2) TURBINE BLOG. MIDDLE LEVEL, VIA THE RELAY ROOM (ALTERNATE)
3) OUTSIDE.

VIA THE RELAY ROOM (ALTERNATE)

GINNA CONTROL BUILDING ARRANGEMENT 27

Electrical 28

Will a design modification package be provided to allow the staff to determine if electrical design requirements for an ESF ventilation system are met ?

  • Yes, a design package will be submitted addressing all aspects of IEEE-603 29

Question - In Attachment 5 to the submittal, you committed to perform a tracer gas in-leakage test of the control room envelope after completion of the planned installation of new Control Room Emergency Air Filtration System. Discuss in detail how you intend to meet the guidelines provided in new Regulatory Guide 1. 197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," in performing such planned test.

30

RG&E Plans-Reg Guide 1.197

  • Ginna is isolation/re-circulation design
  • CRE boundary will be evaluated/inspected
  • Initial inleakage testing per ASTM E741

Question - In your submittal, you re-analyzed the radiological dose and toxic gas consequences of the modified CREATS to the control room operators. Discuss in detail how you met the guidelines provided in new Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors."

32

RG&E Plans-Reg Guide 1.196

  • Licensing basis redefined per new Tech Specs
  • System designed to meet licensing basis
  • Chemicals verified for assumed inleakage
  • CR remains habitable for dose/chemical

Reg Guide 1.196 Continued

  • Maintenance and monitoring per Tech Spec prescribed program
  • Configuration control and training -

prescribed program, training established by modification process

  • Degraded or non-conforming conditions -

compensatory measures will be defined in plant procedures 34

Question - In your submittal, you proposed to revise, among other things, Ginna Technical Specification Sections 5.7.9, 5.5.16, and 5.6.7 as prescribed in proposed traveler TSTF-448 proposed by the Owner's Group. The staff has not accepted the proposed TSTF-448. The NRC response to the proposed TSTF-448 is provided in an NRC letter to NEI dated July 1, 2003. Discuss in detail how you intend to meet the guidelines provided in Appendix B to RG 1.196, "Acceptable Technical Specification and Bases Revision for Westinghouse Plants."

35

Response

  • RG&E will review/resubmit applicable sections of this submittal based on approved TSTF-448 36

Question - In Section 3.0, "Background" of the submittal, you briefly discussed the procedures for installing the new CREATS during plant operation. Discuss it in more detail with appropriate supporting drawings and figures how you intend to maintain the control room integrity during installation of the new CREATS.

37

Overview On-Line Construction Plans 38

CREATS Design Awb

  • =

CONTROL ROOM EMERGENCY ZONE BOUNDARY

  • = EXISTING CREATS & HEATING/COOLING

= PROPOSED NEW SYSTEMS GINNA CONTROL ROOM HVAC

Control Room Penetration Flange 4

East wall armor plate I.

3 3

Inside Outside 40

Perform integrity evaluation of CRE Connect short pipe with blind flange to inner walls Cut hole from outside around inner radius of the short pipe

'I Iq Complete construction of new system and connect to opening Pressure test new system to verify integrity Remove inner flange and connect new duct work - new system available Continued 41

4 Credit stairwell as extended boundary Enter TS 3.7.9 Condition A and place CREATS dampers in mode F PI Secure fans (old System) 41 Open duct work inside stairwell and install 4 new dampers m

V Complete construction and perform system testing Implement new Tech Spec (enter LCO for no tracer gas test)

Perform Tracer gas testing 42

Question - Explain the basis or derivation of 300 CFM unfiltered air inleakage rate used in your control room radiological consequence analysis.

  • Reasonable number based on industry feedback and relatively small volume of the Ginna Control Room Emergency Zone 43

Staff Feedback and Questions Open Discussion 44 RG&E Response to Staff Questions The following are questions asked by NRC staff during the public meeting on August 19, 2003 and RG&E's response.

1.

What is the maximum letdown rate?

Response

60 GPM (see UFSAR Table 9.3-6).

2.

Is the ECCS leakage value of 4 GPH double the operability value?

Response

Yes.

3.

Does Ginna have a design criteria for installation of charcoal filters within containment (e.g., pre-GDC)?

Response

Ginna Station was designed to Atomic Energy Forum (AIF) General Design Criteria (GDC) issued by the AEC for public comment on July 10, 1967. A search of the Ginna UFSAR indicated no design requirements for installation of charcoal filters within these GDC.

4.

Please review the basis for the proposed 14 dP limit for the new filters. This seems too high. Need to look at N510, Section 8.3.1 for more guidance.

Response

Based on the referenced standard, RG&E will provide a revised number after initial startup testing of the new system.

5.

NRC would prefer that RG&E use 2% versus 1% iodine partitioning for beyond 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> of ECCS leakage.

Response

Agree. RG&E will revise the appropriate dose calculations.

6.

Is re-circulation assumed to occur at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />?

Response

Yes.

7.

What is the technical basis for lowering the NAOH tank levels?

Response

RG&E agreed to provide the basis/analysis in a future submittal.

8.

Table 5.2 of Attachment 1 of the LAR submittal (page 38) shows that RG&E assumed certain efficiencies of the CNMT post accident charcoal filters, when RG&E is planning to rrhove these filters.

Response

This is incorrect and will be revised.

9.

NRC believes that going beyond the Standard Review Plan (SRP) limit for locked rotor would not set a good precedent, even if the locked rotor accident is not within our current licensing basis. The NRC suggested that we evaluate ways of reducing excessive conservatism from this analysis.

Response

Agreed. RG&E will review the dose analysis and revise if appropriate.

10. The NRC needs the calculation for spray removal coefficient for particulate as described on page 46/47 of Attachment 1 to the LAR.

Response

RG&E will provide the calculation.

11. Can the NRC obtain copies of the HABIT code files (input/output)?

Response

These were provided on CD-ROM at the meeting.

12. The NRC would like detailed design descriptions of the new system (electricafmechanical, P&lDs).

Response

RG&E agreed to provide design details.

13. What are the timing assumptions used for isolation of the control room?

Response

Sixty (60) seconds was used in all cases except Steam Generator Tube Rupture (SGTR), which assumes 6 minutes. This is bounding, especially since a SI signal has been added to the CREATS actuation circuitry.

14. For Fuel Handling Accidents (FHAs), is this a uniform release over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />?

Response

Yes. RG&E assumed 99.9% of the activity was released over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> using a constant flow rate.

15. Ginna assumed a 30-day Control Room dose for LOCAs. For other accidents, radioactivity will be retained within the control room. These should also reflect 30 days even though the calculated dose will not be changed.

Response

RG&E initially agreed at the meeting that the analysis should be revised. However, further evaluation indicates that this is unnecessary. GDC-1 9 and 1 OCFR50.67 require the cumulative dose to remain less than the stated limit for the "duration of the accident,"

which from a release perspective is defined by RG 1.183. The flow rates for the new system, assuming only one train operation, will turn over the volume of the Control Room approximately once every six minutes, quickly reducing the Control Room Iodine concentrations to minimal values after release termination.

Subsequent to the release, the Control Room could also be purged to reduce the exposure, if necessary. For the Ginna analysis, the intervals were extended beyond the required release duration to provide the maximum integrated dose. Therefore, RG&E believes that there is no benefit to revising the dose calculations to include a 30 day evaluation. RG&E requests that the Staff notify us as soon as possible if they do not agree with this position so that the issue can be resolved in a timely manner.

16. For Main Steam Line Break (MSLB), is the 1 GPM leakage consistent with Technical Specification (TS) leakage?

Response

No, the actual limit is 0.1 GPM, making the assumption conservative. The 1 GPM value is consistent with expected future Steam Generator (SG) leakage TS.

17. For MSLB and locked rotor accidents, what is the steam release assumed for the intact SG at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (Tables 7.1 and 9.1 of LAR Attachment 1)?

Response

RG&E agreed to provide the requested information.

18. Is the 150 GPD SG leakage consistent with TS?

Response

Yes, since the current TS limits per LCO 3.4.13 is 0.1 GPM per SG as averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

19.

Please clarify LAR Attachment 1, Table 8.2 and what the mass flows actually mean, including the partitioning factors for Steam Generator Tube Ruptures (SGTR)

Response

RG&E will clarify the information in a future submittal.

20. Does LAR Attachment 1, Section 9.0 (locked rotor), first bullet, assume that the only leak path is via the SG?

Response

Yes.

21. In LAR Attachment 1, Table 10.1, what is the basis for the natural deposition coefficient value?

Response

RG&E agreed to provide this information in a future submittal.

22. On LAR Attachment 1 page 77, the second paragraph under 12.2, what is meant by "Section 7.1.6".

Response

This is apparently a typographical error which RG&E agreed to correct, and provide the necessary information in a future submittal.

23. Why did RG&E assume a 2-hour dispersion for Gas Decay Tank (GDT) rupture, especially since the previous analysis done for Ginna, related to TS Amendment 78, assumed a puff release?

Response

RG&E agreed to revise the analysis and do a puff release with no CR isolation, consistent with the analysis performed for Amendment 78.

24. LAR Attachment 1 page 80, bottom of page has typo (renumbers).

Response

RG&E agreed and will correct the typo.

25. Is the entire new ventilation system covered under 1 OCFR 50, Appendix B?

Response

Yes.

26. Are there any TS setpoint changes? If so, need to send all associated calculations.

Response

There are no TS setpoint changes.

27. When will Ginna resubmit the TS to reflect the final approved TSTF-448?

Response

The Staff and RG&E agreed to wait until later this year to review the status of the TSTF, and then decide on a submittal date.

List of Regulatory Commitments The following table identifies those actions committed to by RG&E in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENT DUE DATE Revise the original CREATS LAR to reflect Attachment 3, December 1, 2003 hems 8,10,17, 19, 21, 22 and 24.

Revise dose calculations and LAR to reflect Attachment 3, December 1, 2003 items 5 and 23.

Evaluate ways of reducing excessive conservatism from the Locked Rotor January 31, 2004 analysis and revise as necessary.

Revise the proposed 14"dP limit for the new CREATS filters after startup testing, After Startup testing of new system as necessary.

(anticipated May 2004)

Provide the NRC with the technical basis for lowering the required NaOH tank December 1, 2003 levels.

Provide NRC with detailed design January 31, 2004 descriptions of the new CREATS system (electrical/mechanical and P&lDs)

Resubmit appropriate Tech Spec sections Upon approval of TSTF-448. If not issued based on resolution of TSTF-448 by December 15, 2003, RG&E will hold further discussions with the NRC Staff.

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