LR-N03-0085, Information Regarding Relaxation of Containment Operability Requirements
| ML030630623 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/25/2003 |
| From: | Garchow D Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LCR H02-001, LR-N03-0085 | |
| Download: ML030630623 (6) | |
Text
PSEG Nuclear LLC P 0 Box 236, Hancocks Bridge, New Jersey 08038-0236 LR-N03-0085 LCR H02-001 FEB 2 5 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 o PSEG Nuclear LLC Gentlemen:
HOPE CREEK GENERATING STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING RELAXATION OF CONTAINMENT OPERABILITY REQUIREMENTS (TAC NO. MB5548)
FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354
Reference:
Letter LR-N02-0002, Request for Change to Technical Specifications Relaxation of Secondary Containment Operability Requirements and Elimination of FRVS Recirculation Charcoal Filters, dated June 28, 2002 On June 28, 2002, PSEG Nuclear LLC (PSEG) submitted the referenced request for a revision to the Technical Specifications (TS) to relax secondary containment operability requirements and eliminate the FRVS charcoal filters for the Hope Creek Generating Station.
In a letter dated February 14, 2003, PSEG received a request from the NRC staff for additional information regarding the subject request. This request for additional information was discussed with Mr. George Wunder, NRC Hope Creek Project Manager and other members of the NRC staff on February 14, 2003. Attachment 1 contains PSEG's responses.
Commitments made in this response are outlined in Attachment 2.
If you have any questions or require additional information, please contact Mr. Michael Mosier at (856) 339-5434.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on 5ý2/2/
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I Sincer y, D. F. G rchow Vice President-Projects and Licensing Attachments (2) 95-2168 REV 7/99
Document Control Desk FEB 2 5 2003 LR-N03-0085 LCR H02-001 C:
Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. George Wunder, Project Manager - Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 08B3 Washington, DC 20555-0001 USNRC Senior Resident Inspector-Hope Creek (X24)
Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625 2
Document Control Desk Attachment I LR-N03-0085 LCR H02-001 HOPE CREEK GENERATING STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING RELAXATION OF CONTAINMENT OPERABILITY REQUIREMENTS (TAC NO. MB5548)
NRC Question 1:
In your January 18, 2003, submittal you provided the Control Room, Exclusion Area Boundary, and Low Population Zone post-LOCA calculated doses via the containment leakage path. Please explain the effect of the elimination of credit for the Filtration, Recirculation, and Ventilation System recirculation charcoal filters on these calculated doses.
Response
Tables 1 and 2 below provide the information requested for the containment leakage pathway. However, based upon further discussion with the NRC Technical staff, additional information regarding the other pathways was required and is also included in Tables 1 and 2.
Table I Proposed License Amendment Without FRVS Recirculation Charcoal Filters or FRVS Heaters Post-LOCA Post-LOCA Dose (Rem TEDE)
Activity Release Receptor Location Path Control Room EAB LPZ Containment Leakage 1.01 (See Note) 0.44 0.17 ESF Leakage 1.17 0.18 0.09 MSIV Leakage 1.96 2.45 0.43 Total 4.14 3.07 0.69 Note: In our submittals of June 28, 2002 and January 18, 2003, the control room dose due to containment leakage was stated to be 1.00, however it should be 1.01.
This error was due to incorrect roundoff.
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Document Control Desk Attachment I Table 2 Proposed License Amendment Crediting FRVS Recirculation Charcoal Filters and FRVS Heaters LR-N03-0085 LCR H02-001 Post-LOCA Post-LOCA Dose (Rem TEDE)
Activity Release Receptor Location Path Control Room EAB LPZ Containment Leakage 0.44 0.38 0.12 ESF Leakage 0.03 0.00 0.00 MSIV Leakage 1.96 2.45 0.43 Total 2.43 2.83 0.55 COMPARISON Total Change 1.71 0.24 0.14 Change as Percentage Of 41%
8%
20%
Total Submittal Value Allowable TEDE Limit 5.00 25.00 25.00 NRC Question 2:
In your application you state that the reduction in ESF leakage from 10 gpm to 1 gpm is based on operating experience. Please explain why you are confident that this number is, and will remain, accurate.
Response
The HCGS Tech Specs, Section 6, Administrative Controls, Subsection 6.8, Procedures and Programs, Subsection 6.8.4.a, states: "A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels" shall be established, implemented and maintained. The UFSAR Section 1.10, TMI Related Requirements for New Operating Licenses and Section 5.2.5, Detection of Leakage through the Reactor Coolant Pressure Boundary and from the Emergency Core Cooling System, relate to such a program.
This program for primary coolant sources outside containment is implemented by the HCGS Procedure HC.RA-AP.ZZ-0051 (Q), Leakage Reduction Program. This program includes the portions of the following systems that are located outside of the primary containment:
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Document Control Desk RCIC RHR Core Spray HPCI LR-N03-0085 LCR H02-001 Hydrogen/Oxygen Analyzer System Post-Accident Sampling Containment Hydrogen Recombination Control Rod Drive Hydraulic System (SCRAM discharge portion)
This program is implemented by maintaining an ongoing summation of all known leaks on the above systems. The leaks are documented, quantified, and added to the total ESF leakage value tracked by HC.RA-AP.ZZ-0051 (Q). Any leaks found will be evaluated and corrective action initiated when required. When the leaks are corrected the total leakage is updated to reduce the total leakage to the newly determined value.
The total measured leakage is tracked and maintained less than 10 gpm. After the license amendment is approved, this will be changed to 1 gpm.
A leakage limit of 10 gpm is a relatively large number compared to limits used at other BWRs (e.g. Duane Arnold). Because plant history has been that leakage is less than 1 gpm, LCR H02-01 reduced this number to 1 gpm and the dose analysis was changed to use this new value (the ESF leakage is doubled in the analysis per Reg. Guide 1.183 and 2.0 gpm is used).
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Document Control Desk LR-N03-0085 LCR H02-001 Commitments being made in this response As part of the response to the request for additional information PSEG commits to the following:
Upon implementation of the license amendment PSEG will reduce the ESF leakage from 10 gpm to 1 gpm. This will reside in HCGS-Procedure HC.RA-AP.ZZ-0051 (Q),
Leakage Reduction Program.
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