ML032340613

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Request for One Time Only Change to Technical Specifications Control Room Emergency Filtration System
ML032340613
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 08/14/2003
From: Garchow D
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR H03-05, LRN-03-0354
Download: ML032340613 (12)
v • d • e


Text

PSEC Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 AUG 142 3 PSEG LRN-03-0354 Nuclear LLC LCR H03-05 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 REQUEST FOR ONE TIME ONLY CHANGE TO TECHNICAL SPECIFICATIONS CONTROL ROOM EMERGENCY FILTRATION SYSTEM HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354

Reference:

Letter LRN-03-0217, Request For Change To Technical Specifications Control Room Emergency Filtration System, dated July 10, 2003 On July 10, 2003 PSEG requested a permanent change to TS 3.7.2, CONTROL ROOM EMERGENCY FILTRATION SYSTEM ACTION a. to allow one system to be inoperable for up to 30 days due to an inoperable chiller. This letter changes that request to a one time only change.

This proposed change revises TS 3.7.2, CONTROL ROOM EMERGENCY FILTRATION SYSTEM to allow the completion time required in ACTION a. to be extended up to 30 days, on a one time only basis to implement repairslupgrades to the control room emergency filtration (CREF) system chiller. This will expire at the end of cycle 12. This increase in the allowable outage time (AOT) will increase the overall reliability of the CREF system. The only change to the previous request is to add a footnote to page 3/4 7-6 that indicates this is a one time only request expiring at the end of cycle 12.

There has been no change to the No Significant Hazards Analysis or Environmental Assessment. The evaluation of the requested change, Attachment 1, was revised to reflect the one time only wording change. The marked up Technical Specification page provided in Attachment 2 also reflects this change.

In April 2003, PSEG identified the A Control Area Chiller (AK400) had begun to exhibit unacceptable fluctuations in oil reservoir level. At the present time, PSEG attributes the changes in reservoir level to compressor and motor labyrinth seal degradation.

Al1--,

95-2168 REV. 7/99

Document Control Desk 2

LRN-03-0354

'UG 1-4 200 LCR H03-05 The worn seals inhibit the process by which oil returns to the reservoir during the machine's freon cycle under decreased cooling load conditions and has recently resulted in rapid return of oil as cooling load increased. At this time the problem is manageable and the chiller is operable. Although the chiller is operable, these fluctuations represent an undesirable condition and PSEG has taken action to plan a maintenance window to overhaul the compressor, currently scheduled to commence on September 15, 2003. Execution of required repairs will require complete disassembly of the compressor as well as the removal of the outboard motor bearing assembly.

Although the overhaul may be completed in 7 days, PSEG desires to perform other required maintenance to the component during the maintenance outage. Approval of this proposed change is, therefore, being requested by September 10, 2003 to support planned maintenance of the A" Control Area Chiller scheduled for September 15, 2003.

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.

Sincerely, Executed on m0/ 41v3 D.F.Iacow Vice Presidrnt - Projects & Licensing Attachments (2)

Document Control Desk 3

LRN-03-0354 fAUGi4 2003 LCR H03-05 C:

Mr. H. Miller, Administrator-Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Richard Ennis, Project Manager - Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 08BI 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

HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REQUEST FOR ONE TIME ONLY CHANGE TO TECHNICAL SPECIFICATIONS CONTROL ROOM EMERGENCY FILTRATION SYSTEM

1. DESCRIPTION.................................

2

2. PROPOSED CHANGE.................................

2

3. BACKGROUND.................................

3

4. TECHNICAL ANALYSIS................................

3 4.1.Analysis................................

3

5. REGULATORY SAFETY ANALYSIS.................................

6

6. ENVIRONMENTAL IMPACT EVALUATION.................................

7

7. REFERENCES...........................................................................................................7

Document Control Desk LRN-03-0354 Attachment I LCR H03-05 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS CONTROL ROOM EMERGENCY FILTRATION SYSTEM

1. DESCRIPTION This letter is a request for a one time only change to Facility Operating License NPF-57 for the Hope Creek Generating Station (HCGS). The proposed change would revise Technical Specification (TS) 3.7.2 ACTION a. to allow the completion time required in ACTION a. to be extended up to 30 days, on a one time only basis to implement repairs/upgrades to the Control Room Emergency Filtration System until the end of cycle 12. Increasing the allowable outage time (AOT) will allow for extensive maintenance and increase the overall availability of the control room chillers. This provides additional assurance that a chiller will be operable on at least one train of the control room emergency filtration (CREF) system.
2. PROPOSED CHANGE The proposed changes to the TS are included in Attachment 2 of this submittal. In summary, it is requested that:

LImiting Condition for Operation 3.7.2 (PAGE 314 7.6) under ACTION a.

currently states:

"In OPERATIONAL CONDITION 1, 2 or 3 with one control room emergency filtration subsystem inoperable, restore the inoperable subsystem to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Is revised to read:

'In OPERATIONAL CONDITION 1, 2 or 3 with one control room emergency filtration subsystem inoperable, restore the inoperable subsystem to OPERABLE status within 7 days** or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Add footnote

    • The completion time required in ACTION a. may be extended up to 30 days, on a one time only basis to implement repairslupgrades to the Control Room Emergency Filtration System. This footnote expires at the end of cycle 12.

2

Document Control Desk LRN-03-0354 Attachment I LCR H03-05

3. BACKGROUND The AK400 Control Area Chiller has begun to exhibit unacceptable fluctuations in oil reservoir level. Changes in reservoir level are attributable to compressor and motor labyrinth seals. The degraded seals inhibit the process by which oil returns to the reservoir during the machine's freon cycle under decreased cooling load conditions and, has recently resulted in rapid return of oil as cooling load increased. The condition has been evaluated and concluded that the problem is manageable and the chiller is operable.

PSEG has also determined that these fluctuations represent an undesirable condition and have taken action to plan a maintenance window to overhaul the compressor just prior to the onset of winter, at which time fluctuations will most assuredly increase in frequency. Execution of required repairs will require complete disassembly of the compressor as well as the removal of the outboard motor bearing assembly.

With one control room AC subsystem inoperable, the inoperable control room AC subsystem must be restored to OPERABLE status within 30 days. With the unit in this condition, the remaining OPERABLE control room AC subsystem is adequate to perform the control room air conditioning function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of the control room air conditioning function. The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining subsystem can provide the required protection, and the availability of alternate safety and non-safety cooling methods.

4. TECHNICAL ANALYSIS 4.1. Analysis Control Room Emergencv Filtration The control room emergency filtration (CREF) system is designed to maintain control room habitability by providing filtration of fresh air and recirculated air during any accident that may release high radioactivity.

The CREF system is safety-related and is designed to accomplish the following objectives:

Monitor radiation levels at the outside air intakes and automatically filter any contaminated fresh air through the emergency charcoal filters upon detection of high radiation, in accordance with the mode switch position.

3

Document Control Desk LRN-03-0354 Attachment I LCR H03-05 Maintain pressure above that of the adjacent areas to inhibit air in-leakage into the main control room, except when the system is selected for the 100 percent recirculation mode.

  • Operate during and after an accident condition without loss of function.

Provide redundancy for active and passive components to meet the single failure criteria.

  • Operate the redundant active components from separate Class I E power sources.

Provide tornado protection for fresh air intake ducts.

Provide missile protection for the equipment, ducts, and accessories.

Meet Seismic Category I requirements.

Provide capability in the 100 percent recirculation mode to permit ten people to inhabit the main control room for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> without exceeding the maximum allowable concentration of 1 percent of CO2 by volume.

Under normal plant conditions, the CREF system is not in operation: however, when high radiation is detected at the outside air intake, the main control room outside air supply is automatically diverted through the CREF system.

When the CREF system is in operation, the volume of air flowing through it is continuously indicated on a local panel. Low flow or loss of airflow in the CREF automatically trips and isolates the operating CREF train and alarms in the main control room.

The control room supply (CRS) system maintains design conditions in the main control room and associated adjacent rooms. It is comprised of two 100 percent air handling units, each supplied by a separate Class IE power source. Each unit is equipped with outside air intake, outside radiation monitors, outside air smoke detectors, motorized isolation dampers, pre-filters, after-filters, humidifiers, chilled water coil, electric heating coil, and supply fan. A fixed amount of outside air is provided to satisfy ventilation, exhaust, and pressurization requirements. Each unit is connected to a common Seismic Category I supply and return duct system. Air is delivered to the CRS unit via the control room return air (CRRA) fan. Excess ventilation air is exhausted to the outdoors by the control air exhaust (CAE) system.

The chilled water for the cooling coils in each unit are supplied by a Seismic Category 1, independent chilled water system. The chilled water system pump (AP400) is interlocked with the supply air fan so that the A Control Area chiller (AK400) cannot operate without the CRS fan (AVH403) being energized.

Control Area Chilled Water System The Control Area Chilled Water System consists of two subsystems: The Control Room Chilled Water System and the Safety-Related Panel Room Chilled Water System. The 4

Document Control Desk LRN-03-0354 Attachment I LCR H03-05 chilled water systems provide chilled water to maintain satisfactory ambient air temperatures for different portions of the Auxiliary Building. Each of the two subsystems has two independent, 100 percent capacity chilled water loops. Each water chiller includes a motor driven centrifugal compressor, water-cooled condenser, evaporator, pump out unit, oil pump, oil heater, refrigerant piping, controls, and instrumentation.

The Control Room Chilled Water System (CWS) serves the following areas:

Main control room Auxiliary equipment rooms, including the computer room and battery rooms Emergency switchgear rooms Safety Auxiliaries Cooling System (SACS) pump rooms (Reactor Building)

The design bases for the control area CWS are as follows:

The control area CWS is safety-related and is designed to Seismic Category I and redundancy requirements to remain functional following a loss of collant accident (LOCA) or design basis accident (DBA).

Chilled water from the control room chillers is supplied (at 50 degrees F) by the control area CWS to maintain the design ambient air temperatures in the areas served.

Single failure of any active or passive component, coincident with a loss of offsite power (LOP), will not result in the loss of chilled water supply.

Control Room Chilled Water System The Control Room Chilled Water (CRCW) System provides a means of cooling the air supply to parts of the Auxiliary Building Control Area to maintain satisfactory ambient air temperature. The CRCW system has two full capacity, separate closed loops. Each loop consists of one packaged, electrically driven, centrifugal water chiller (A(B)K400),

one head tank (A(B)T410), one recirculation pump (A(B)P400), and one chemical feed tank (A)(B)T401). It is a redundant system having two independent and separate 100 percent chilled water loops, either of which is capable of performing the system safety function necessary for achieving safe shutdown following a design basis accident given a single active failure or passive failure. The CRCW electrically operated components are environmentally qualified. SACS provides cooling water for the chiller condensers.

The SACS pumps are supplied with Class 1 E power.

The CRCW System supplies chilled water to the air-handling units in the Auxiliary Building and Reactor Building. The units served by the CRCW A and B loops include:

Control Room Supply System (CRS) Unit A/BVH403 5

Document Control Desk LRN-03-0354 Attachment I LCR H03-05 Control Equipnent Room Supply System (CERS) Unit AIBVH407 Switchgear Room Cooling (SRC) Units A-D401 coils AB SACS Room Cooling Units A-DVH214 One loop is normally operating and the other is in standby. The operating chiller is powered from the same Class I E power bus as the chilled water pump, control room air supply (CRS), control room emergency filter (CREF), and control equipment room supply (CERS) fans. The same is true for the standby chiller. Control actuation, indications, and alarms for the chillers are located in the main control room and also in the local panels, one panel per chiller. The B loops of the systems are capable of being controlled from the remote shutdown panel (RSP). On LOP or LOCA, the operating chilled water system is tripped and sequenced on to the emergency diesel generators after a time delay by the LOCA sequencer-the chiller auto starting at 60 seconds and the pump at 65 seconds. The loop that was in service remains in service. Single failure of any active or passive component, coincident with a LOP, will not result in the loss of the chilled water supply. On detection of low chilled water flow in the operating loop, a control room alarm sounds and the system automatically re-aligns to the standby units.

On a high or low chilled water supply temperature, a control room alarm sounds and the system automatically shuts off the operating units and changes to the standby units.

The CRCW system is safety-related and must meet the following safety-function requirements:

Supply chilled water at 50 degrees F from the chillers to each cooling coil at the required flow rate to maintain the design area temperatures in the areas served Operate during normal, shutdown, and accident conditions without loss of function

5. REGULATORY SAFETY ANALYSIS The proposed change would revise Technical Specification (TS) 3.7.2 ACTION a. to allow the completion time to be extended up to 30 days, on a one time only basis to implement repairs/upgrades to the Control Room Emergency Filtration System In conclusion, based on the above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6

Document Control Desk LRN-03-0354 Attachment I LCR H03-05

6. ENVIRONMENTAL IMPACT EVALUATION PSEG has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7. REFERENCES 7.1. 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 7

Document Control Desk LRN-03-0354 LCR H03-05 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (S)

TECHNICAL SPECIFICATION PAGE WITH PROPOSED CHANGE The following Technical Speciffication for Facility Operating License NPF-57 are affected by this change request:

Technical Specification Page 314.7.2 314 76

PLANT SYSTEMS 3/4.7.2 CONTROL ROOM EMERGENCY FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.2 Two independent control room emergency filtration system subsystems shall be OPERABLE with each subsystem consisting of:

a)

One control room supply unit, b)

One filter train, and c)

One control room return air fan.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3, 4 and *.

ACTION:

a.

In OPERATIONAL CONDITION 1, 2 or 3,with one control room emergency filtration subsystem inoperable, restore the inoperable subsystem to OPERABLE status within 7 days** or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b.

In OPERATIONAL CONDITION 4 or *:

1.

With one control room emergency filtration subsystem inoperable, restore the inoperable subsystem to OPERABLE status within 7 days or initiate and maintain operation of the OPERABLE subsystem in the pressurization/recirculation mode of operation.

2.

With both control room emergency filtration subsystems inoperable, suspend handling of recently irradiated fuel in the secondary containment and operations with a potential for draining the reactor vessel.

c.

The provisions of Specification 3.0.3 are not applicable in Operational Condition *.

SURVEILLANCE REQUIREMENTS 4.7.2 Each control room emergency filtration subsystem shall be demonstrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is less than or equal to 850F*.

b.

At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, the control area chilled water pump, flow

This footnote expires at the end of cycle 12.

{This does not require starting the non-running control emergency filtration subsystem.

HOPE CREEK 3/4 7-6 Amendment No.

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