RBG-46669, License Amendment Request, Application for Technical Specification (TS) Change Regarding Ventilation Filter Testing Program (Vftp), TS 5.5.7, Control Room Fresh Air System (Crfas) Heater Wattage
| ML070930338 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/28/2007 |
| From: | Venable J Entergy Operations |
| To: | Document Control Desk, NRC/NRR/ADRO |
| References | |
| RBG-46669 | |
| Download: ML070930338 (9) | |
Text
Enteigy Entergy Operations, Inc.
River Bend Station 5485 US Highway 61 St. Francisville, LA 70775 Tel 225 381 4374 Fax 225 381 4872 jvenabl@entergy.com Joseph E. Venable Vice President, Operations River Bend Station RBG-46669 March 28, 2007 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
License Amendment Request Application for Technical Specification (TS) Change Regarding Ventilation Filter Testing Program (VFTP), TS 5.5.7, Control Room Fresh Air System (CRFAS) Heater Wattage River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47
Dear Sir or Madam:
Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests the following amendment for River Bend Station, Unit 1 (RBS). Entergy requests modification of the River Bend Technical Specifications (TS) to revise the Control Room Fresh Air System (CRFAS) heater wattage (kW) requirement shown in Technical Specification 5.5.7 Ventilation Filter Testing Program, subsection TS 5.5.7.e.
The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The bases for these determinations are included in the attached submittal.
The proposed change does not include any new commitments.
Although this request is neither exigent nor emergency, your prompt review is requested.
Once approved, the amendment shall be implemented within 60 days.
4001
RBG-46669 Page 2 of 2 If you have any questions or require additional information, please contact Bill Brice at 601-437-5076.
I declare under penalty of perjury that the foregoing is true and correct. Executed on March 28, 2007.
Sincerely, Joseph E. Venable Vice President, Operations River Bend Station, Unit 1 JEV/WBB Attachments:
- 1. Analysis of Proposed Technical Specification Change
- 2. Proposed Technical Specification Changes (mark-up) cc:
Dr. Bruce S. Mallett U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 U.S. Nuclear Regulatory Commission Attn: Mr. Bhalchandra K. Vaidya MS O-7D1 Washington, DC 20555-0001 Louisiana Department of Environmental Quality Office of Environmental Compliance Attn: Mr. Jeff Meyers Surveillance Division P. 0. Box 4312 Baton Rouge, LA 70821-4312 RBG-4669 Analysis of Proposed Technical Specification Change to RBG-46669 Page 1 of 4
1.0 DESCRIPTION
This letter is a request to amend Operating License NPF-47 for River Bend Station, Unit 1 (RBS).
The proposed change will revise the Operating License to revise the Control Room Fresh Air System (CRFAS) heater wattage (kW) testing requirement shown in Technical Specification 5.5.7 Ventilation Filter Testing Program, subsection TS 5.5.7.e.
2.0 PROPOSED CHANGE
Technical Specification 5.5.7.e., Ventilation Filter Testing Program, specifies the required power (in kW) for the Control Room ventilation electric heaters (HVC*FLT3AH/3BH) to decrease relative humidity of the air to less than 70 percent as required for proper operation of the charcoal absorber components when tested in accordance with ANSI N510-1989 "Testing of Nuclear Air Treatment Systems". Entergy proposes to revise the CRFAS heater wattage testing requirement from 23 +/- 2.3 kW, to a new value of - 15 kW.
There are no associated Technical Specification Bases changes.
3.0 BACKGROUND
Removal of radioiodines from the main Control Room ventilation outside air supply during a Design Bases Accident (DBA) is accomplished through use of charcoal filter trains. To comply with the Control Room radiation protection requirements of 10 CFR 50.67, "Accident Source Term" two 100-percent capacity redundant charcoal filter trains are provided. The main Control Room charcoal filter trains are designed in accordance with requirements of Regulatory Guide 1.52 "Design, Inspection and Testing Criteria for Air Filtration and Adsorption Units of post-Accident Engineered-Safety-Feature Atmospheric Cleanup Systems in Light-Water-Cooled Nuclear Power Plants" (with the exceptions noted in Updated Safety Analysis Report (USAR) Table 6.5-1). Both filter trains and associated air handling equipment are designed to Seismic Category I and are located within the main Control Room pressure boundary.
Each Control Room charcoal filter train includes an electric heating coil powered from a standby bus to limit the relative humidity of the incoming air to 70 percent at design flow during post-LOCA conditions. The charcoal filter train air heater is automatically energized if neither the high filter air temperature cutout nor the low filter air flow cutout have been activated.
Control Room Charcoal Filter Heaters (HVC*FLT3AH/3BH) are powered from Division I and II standby Engineered safety System (ESF) buses respectively. USAR Tables 8.3-2a and 8.3-2b show that these heaters each have a nameplate rating of 23 kW.
The current TS is based on the name plate data and not the design requirement. This change provides a calculated value for the heater to perform its design function rather than the nameplate value. This new acceptance criterion is more representative and will provide improved operational reliability and flexibility.
to RBG-46669 Page 2 of 4
4.0 TECHNICAL ANALYSIS
River Bend Station has calculated the required Control Room charcoal filter unit heater capacity to be 15 kW utilizing worst case conditions for moisture loading. This heater capacity is based on main Control Room ambient temperature of 75°F. For LOCA conditions the heater capacity is required to be 12 kW at Control Room ambient temperature of 80°F.
The calculation for required heater capacity was performed as follows:
Determination of input conditions:
Outside Air Flow:
2000 cfm +/- 10%
Temperature:
95 0F Relative Humidity:
100%
Control Room Recirculation Air:
Flow:
2000 cfm +/- 10%
Temperature:
75 0F Relative Humidity:
70%
QH = CFM (Vsp)-1 (ho - hi)
Where:
QH = Required Heater Dissipation (Btu/hr)
CFM = Flow rate of air in cubic feet per minute (cfm)
VsP = Specific Volume of air in cubic feet per pound (ft3/Ib) hi= Inlet air enthalpy (Btu/Ib) ho= Outlet air enthalpy at 70% relative humidity sensible heating (Btu/Ib)
The electric heater provides sensible heating of the air stream at constant moisture conditions (no latent heat provided, no humidification added).
The inlet air to the charcoal filter unit is an even mixture of outside air and recirculated Control Room air (50% outside air, 50% recirculated air). Therefore, the air properties are evaluated based on this mixture. Psychrometric Chart provided results as follows:
Mixture Air Temperature = 85°F Mixture Air Specific Volume V = 14.28 ft3/Ib hi (Inlet air enthalpy) = 47.6 Btu/Ib of air ho (Outlet air enthalpy at 70% relative humidity sensible heating) = 50.2 Btu/Ib of air The total airflow to the heater CFM = 2200 + 2200 = 4400 cfm (tolerance used for maximum loading) to RBG-46669 Page 3 of 4 QH = 4400. (60 minutes/hr) (14.28)l -(50.2 - 47.6) = 48067 Btu/hr QH = 48067 Btu/hr- (0.2931 watts per btu/hr) = 14088 watts, or 14.088 kW Therefore, the minimum heater size was conservatively approximated as 15 kW.
5.0 REGULATORY ANALYSIS
5.1 Applicable Requlatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.
Entergy has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any General Design Criterion (GDC) differently than described in the Updated Final Safety Analysis Report (UFSAR.) Adequate radiation protection of the Control Room under accident conditions continues to be provided in accordance with GDC 19 with a lower heater wattage requirement.
Neither Regulatory Guide 1.52 nor ASME N510-1989 specify heater acceptance criteria.
5.2 No Siqnificant Hazards Consideration Entergy Operations, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
This change specifies the required power (in kW) for the Control Room ventilation electric heaters to decrease relative humidity of the air to less than 70% relative humidity as required for proper operation of the charcoal absorber components based on calculated requirements. The heater will continue to perform its intended design function as designed. The heater is not an accident precursor.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
to RBG-46669 Page 4 of 4 The heater will continue to perform its function as designed. The heater provides humidity control for the Control Room filter unit during a design basis accident.
Changing the test acceptance criteria to a calculated value has no influence on, nor does it contribute in any way to, the possibility of a new or different kind of accident or malfunction from those previously analyzed. No change has been made to the design, function or method of performing testing. No safety-related equipment or safety functions are altered as a result of this change.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3.
Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
No margin of safety is changed as a result of this change. The heater will continue to perform its design function. Testing methodology has not changed. The function of the heater is unchanged. The acceptance criterion has been changed to a calculated value rather than the name plate rating to make testing more realistic. The heater will continue to operate to perform its intended design function.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Entergy concludes that the proposed amendment present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
5.3 Environmental Considerations 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.
7.0 REFERENCES
- 1. Regulatory Guide 1.52 "Design, Inspection and Testing Criteria for Air Filtration and Adsorption Units of post-Accident Engineered-Safety-Feature Atmospheric Cleanup Systems in Light-Water-Cooled Nuclear Power Plants"
- 2. ANSI N510-1989 "Testing of Nuclear Air Treatment Systems" RBG-4669 Proposed Technical Specification Changes (mark-up) to RBG-4669 Page 1 of 1 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)
- e.
Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N510-1989:
ESF Ventilation System Wattage SGTS
>61 kW FBVS
>49 kW CRFAS 25 -L 2.5 kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.
5.5.8 Explosive Gas and Storage Tank Radioactivity Monitorinq Proqram This program provides controls for potentially explosive gas mixtures contained in the main condenser offgas treatment system and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.
The program shall include:
- a.
The limits for concentrations of hydrogen in the main condenser offgas treatment system and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion); and
- b.
A surveillance program to ensure that the quantity of radioactive material contained in any unprotected outdoor tank is limited to -*- 10 curies, excluding tritium and dissolved or entrained noble gases.
The provisions of SR 3.0,2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies, 5.5.9 Diesel Fuel Oil Testing Proqram A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The (continued)
RIVER BEND 5.0-13 Amendment No.