ML18102B304
| ML18102B304 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/14/1997 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18102B305 | List: |
| References | |
| LCR-S97-12, LR-N97288, NUDOCS 9705210167 | |
| Download: ML18102B304 (10) | |
Text
Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 MAY 141997 LR-N97288
. LCR S97-12 REQUEST FOR EXIGENT CHANGE TO TECHNICAL SPECIFICATIONS CONTROL ROOiv.I EMERGENCY AIR CONDITIONING SYSTEM (CREACS)
SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND 75 DOCKET NOS. 50-272 AND 50-311 Gentlemen:
In accordance with IOCFR50.90, Public Service Electric & Gas (PSE&G) Company hereby requests a revision to the Technical Specifications (TS) for the Salem Generating Station Unit
. Nos. I and 2. In accordance with IOCFR50.9l(b)(I), a copy of this submittal has been sent to the State ofNew Jersey.
The proposed Technical Specification changes contained herein revise Surveillance Requirement (SR) 4.7.6.1.d.l, to: I) indicate that the specified acceptable filter differential pressure (DP) is to be measured across the filter housing, and 2) reflect a filter DP acceptance value of~ 2. 70" Water Gauge (WG). These changes expand the Surveillance Test boundary to include the Roughing filter, which is also located in the filter housing. and is a contributor to an increase in DP during the extended post-accident operational period. The change in the filter DP acceptance limit is made to reallocate design margin associated with filter performance to CREACS fan performance in the control room pressurization mode.
The CREACS flow requirements, control room pressurization requirement,. filter removal efficiencies, and control room dose acceptance criteria are unaffected by thi~ change.
PSE&G requests that the proposed changes be processed on an exigent basis. The proposed changes support completion of CREACS design basis acceptance testing without further impact to the Salem Unit No. 2 restart schedule. Approval of the proposed changes is required toM~)
support entry to Mode 4, which is scheduled to occur on June 8, 1997.
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DQcument Control Desk LR-N97288 MAY 141997 The proposed changes have been evaluated in accordance with 10CRF50.91(a)(l), using the criteria in 10CFR50.92(c), and PSE&G has concluded that this request does not involve a significant hazards consideration. The basis for the requested change is provided in Attachment 1.
A 10CFRS0.92 evaluation supporting a No Significant Hazards determination is provided in. The marked up Technical Specification pages affected by the proposed changes are provided in Attachment 3. Upon NRC approval of the proposed changes, PSE&G requests that the amendment be made immediately effective on the date of issuance, with a 60 day implementation period.
Should you have any questions regarding this request, we will be pleased to discuss them with you.
Sincerely,
~~/
95-4933
Document Control Desk LR-N97288 Affidavit Attachments (3)
- C Mr. H. Miller, Administrator - Region U.S. Nuclear Regulatory Commission 4 7 5 Allendale Road King of Prussia, PA 19406 Mr. L. Olshan, Licensing Project Manager - Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall (X24)
USNRC Senior Resident Inspector - Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic parkway CN415 Trenton, NJ 08625 MAY 141997 95-4933
REF: LR-N97288 LCR S97-12 STATE OF NEW JERSEY )
)
SS.
COUNTY OF SALEM
)
L. F. Storz, being duly sworn according to law deposes and says:
I am Senior Vice President - Nuclear Operations of Public Service Electric and Gas Company -
and as such, I find the matters set forth in the above referenced letter, concerning Salem Generating Station, Units 1 and 2, is true to the best of my knc;>wledge, information and belief.
Subscribei and Sworn to before me this L..!J!}_ day ofLfl]~, 1997 Notary Public ofNew Jersey/
...
- MyCommi~sionexpires~ ~~ ~
KIMBERL V JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission Expires April 21, 1998
Document Control Desk LR-N97288 DWD/
BC Senior Vice President - Nuclear Engineering (N19)
General Manager - Salem Operations (SOS)
Director - QA/NSR (XO 1)
Manager - Business Planning & Co-Owners Affairs (N18)
Manager - Salem Operations (SOI)
Manager - System Engineering - Salem (S02)
Manager - Licensing & Regulation (X09)
Principal Engineer [Salem] Operational Licensing (X09)
Onsite Safety Review Engineer - Salem (Xl 5)
J. Keenan, Esq.
Records Management (N21)
Microfilm Copy Files Nos. 1.2.1 (Salem, 2.3 (LCR 897-12)
MAY 141997
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- CHANGE TO TECHNICAL SPECIFICATIONS (TS)
CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM (CREACS)
FILTER DIFFERENTIAL PRESSURE ACCEPTANCE CRITERIA BASIS FOR REQUESTED CHANGE REQUESTED CHANGE AND PURPOSE Revise SR 4.7.6.1.d.1 to read as follows;
- 1.
Verifying that the pressure drop across the combined filter housing is ::;; 2. 70 inches Water Gauge while operating the ventilation system at a flow rate of 8000 cfin +/-
10%.
The proposed change expands the Surveillance Test boundary to include the roughing filter and documents a basis for the CREACS filter differential pressure (DP) acceptance value. A new acceptance value is also proposed. The new filter DP acceptance limit, together with planned modifications to reduce control room boundary leakage, will ensure that CREACS design basis acceptance testing is satisfactorily completed without further impact to the Salem Unit 2 restart schedule. The proposed changes maintain a conservative operability basis for the CREACS filter train.
BACKGROUND The CREACS is a subsystem of the Control Area Ventilation System (CAYS) and is designed to maintain a positive pressure in the control room in order to limit the dose to control room personnel following a design basis accident to less than the limits specified by 1 OCFR50, Appendix A, General Design Criteria (GDC) for Nuclear Power Plants, Criterion 19. This is accomplished by recirculating the control room air volume through a Roughing filter, HEP A filter, and Charcoal Adsorber bank arranged in series within a common filter housing. A portion of outside air is introduced in order to maintain C02 at an acceptable level and provide a source of air to pressurize the boundary. This minimizes the infiltration of contaminants that may impact the habitability of the control room.
The CA VS has recently been modified to enhance its performance and reliability. This modification established a new operating mode for the CREACS called the "Single Train Operation." This operating mode can be characterized essentially as the "Accident Pressurized" mode with one train inoperable.
Operation of CREACS in the "Single Train Operation" mode is limiting with respect to maintaining the control room pressure boundary at a positive pressure. Acceptance testing for this operational mode consists of; 1) balancing the system, 2) verifying fan flow capability at the simulated maximum filter DP, and 3) verifying the ability of the system to pressurize the control room boundary to 0.125" Water Gauge (WG) with respect to adjacent rooms at the maximum allowed filter DP. The current Technical Specification value for this filter DP is~ 3.5" WG for the combined HEP A and Charcoal Adsorber sections with no consideration given to the contribution of the Roughing filters to the overall pressure drop. To date, the system has been balanced and the ability of the supply fans to develop the design volumetric flow with the present Technical Page 1 of 3
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CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM (CREACS)
FILTER DIFFERENTIAL PRESSURE ACCEPTANCE CRITERIA Specification allowable DP value has been confirmed by a combination of testing and analysis.
However, when the system was aligned for control room pressurization, the required control room DP could not be maintained due to the presence of previously unidentified leakage paths in the control room boundary. In the course of developing modifications to address this latter test deficiency, a change in the filter DP acceptance limit was identified as one potential source of margin recovery for the control room pressurization test.
The proposed changes expand the Surveillance Test boundary and provide a conservatively defined CREACS filter DP acceptance limit.
A new acceptance limit for filter DP (i.e.,
cleanliness) is also proposed. The change to the filter DP acceptance limit reallocates design margin associated with filter performance to CREACS fan performance in the control room pressurization mode. This change, in conjunction with planned modifications to reduce control room boundary leakage, will ensure that CREACS design basis acceptance testing is satisfactorily completed without further impact to the Salem Unit No. 2 restart schedule.
JUSTIFICATION OF REQUESTED CHANGE The Roughing filters and HEP A filters are installed to remove particulate matter, which may be radioactive. Roughing filters remove the larger particles to prevent excessive loading on the HEP A filters. The HEP A filters remove the finer particulate matter and pass the air stream to the Charcoal Adsorber section where the gaseous iodine (Methyl and Elemental) is removed. As the roughing filter accumulates dust and airborne contaminates, the DP across this filter element increases. As the DP increases, a reduction in CREACS flow rate can occur, potentially resulting in the inability to maintain the required control room positive pressure. It is for this reason that the roughing filter DP should be included in the Surveillance Test boundary.
Filter DPs observed during recent filter and post-modification testing, have been reviewed to establish an appropriate acceptance value for the combined filter train acceptance test.
The maximum observed values are summarized in the Table below. For comparison, the vendor's estimated "clean filter" and recommended "dirty filter change out" values have also been provided.
Test Data Vendor Data Filter Bank Max. DP In. WG Filter Bank Vendor Clean DP In. WG Roughing filters 0.15 Roughirig filters 0.125 (Chg. out 1.5)
HEP A Filters 0.92 HEP A Filters 1.0 (Chg. out 2.0)
Charcoal Filters 1.07 Charcoal Ads.
1.0 Total 2.14 Total 2.15 Page 2 of 3
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- CHANGE TO TECHNICAL SPECIFICATIONS (TS)
CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM (CREACS)
FILTER DIFFERENTIAL PRESSURE ACCEPTANCE CRITERIA The above "Test Data" values for the HEPA filter are representative of filter conditions present after approximately nine years of installation. The Charcoal Adsorb er data reflects approximately one month of operation that accumulated during post-modification testing (Feb. 4, 1997-March 7, 1997). These values were recorded when the system was operating within 200 cfin of its design flow rate of 8000 cfin. When the instrument accuracy of+/- 3% (i.e., this is the accuracy of the actual Shortridge instrument used in this testing) is applied to this value, the result is 2.204" WG.
This value was then adjusted to compensate for flow rates up to the design value of 8000 cfin +/-
10%, resulting in a Surveillance Test maximum allowable filter differential pressure of ~2. 70" WG. It should be noted that minor differences might be observed in any of the banks due to manufacturing tolerances from lot to lot and variations in packing densities of the Type II Charcoal Adsorber trays utilized in this system.
The allowance for the post-accident period of operation to be included in the CREACS design basis acceptance test plan is 0.30" WG (i.e., simulated filter differential pressure of 3.0" WG).
This value is judged to be conservative on the basis of experience accumulated during post modification testing of the system. As previously stated, this testing resulted in approximately one month of operation on the current filter train, after which; measured filter DPs were determined to be approximately the same as those associated with clean filter conditions. The significance of this duration is that it approaches that of the post-accident operational period as well as the value established in Regulatory Guide 1.52 (i.e., 720 hrs.) as a threshold point at which Charcoal efficiency testing must take place.
The efficiencies of the HEP A and Charcoal Adsorber elements are monitored separately and are not affected by this change. The removal efficiencies are a function of filter residence time which is dependent on the flow rate through the filter element (e.g., the higher the flow rate, the lower the removal efficiency). Testing to demonstrate these efficiencies is conservatively based on the maximum allowed CREACS flow rate. Similarly, control room dose calculations are based on the minimum allowable HEP A and Charcoal Adsorber efficiencies with no credit taken for improved efficiencies which might result at lower flow rates.
The requirement for control room pressurization is unchanged by this proposal. As such, infiltration rates assumed in the dose calculations are unaffected by these changes. For these reasons, the licensing basis control room dose calculations remain conservative.
The environmental control function of the CREACS (i.e., cooling coils, fans, distribution ductwork and associated dampers, and filtration capability) is not affected by the proposed changes.
As such control room temperature, humidity and air distribution and cleanliness requirements will continue to be maintained within acceptance limits.
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CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM (CREACS)
SIGNIFICANT HAZARDS EVALUATION 10CFRS0.92 EVALUATION Public Setvice Electric & Gas (PSE&G) has concluded that the proposed changes to the Salem Generating Station Unit Nos. 1 and 2 Technical Specifications (TS) do not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three standards set forth in 10CFRS0.92 is provided below.
REQUESTED CHANGE Revise SR 4. 7.6.1.d.1 to read as follows; BASIS
- 1.
Verifying that the pressure drop across the combined filter housing is ~ 2. 70 inches water gauge while operating the ventilation system at a flow rate of 8000 cfm +/-
10%.
- 1.
The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The CREACS filter train is provided for post-accident atmospheric cleanup of the control room air volume in order to limit doses to control room personnel to less than the limits prescribed by 10CFR50, Appendix A, Criterion 19.
The CREACS does not communicate with the Reactor Coolant System (RCS) and does not penetrate the Containment. The environmental controls portion of the system (i.e., cooling coil, fans, ductwork and associated dampers, and filtration capability) are not affected by the proposed changes. Therefore, control room temperature, humidity, air distribution and cleanliness requirements will continue to be maintained within acceptance limits. As such, the probability of an accident previously evaluated is unchanged.
The change to the Sutveillance Test boundary requires that the pressure drop across all elements in the filter train be evaluated, thereby ensuring that the CREACS filter is maintained in a condition which would not restrict post-accident CREACS flow below acceptable levels. The change to the filter DP acceptance limit reallocates design margin associated with filter performance to CREACS fan performance in the control room pressurization mode. As such, infiltration of potentially contaminated air is limited to that presently assumed in the dose analysis.
The Technical Specification maximum allowable CREACS flow rate, minimum allowable HEPA and Charcoal Adsorber removal efficiencies, and post-accident control room pressurization Page 1 of 2
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CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM (CREACS)
SIGNIFICANT HAZARDS EVALUATION requirements are not affected by this change. As such, the consequences of previously evaluated accidents are unchanged.
- 2.
The proposed change does not create the possibillty of a new or different kind of accident from any accident previously evaluated The CREACS does not communicate with the Reactor Coolant System (RCS) and does not penetrate the Containment. The proposed changes do not require any modification to the CREACS or its support systems. The design basis safety function of the CREACS is unaffected by the proposed changes. The environmental controls portion of the CREACS (i.e., cooling coil, fans, ductwork and associated dampers, and filtration capability) are not affected by the proposed changes. As such control room temperature, humidity and air distribution requirements will continue to be maintained within acceptance limits. The maximum allowable_ CREACS flow rate and control room DP requirements imposed by the Technical Specifications are not changed by this proposal. For these reasons, the possibility of a new or different kind of accident is not created.
- 3.
The proposed change does not involve a significant reduction in a margin of safety.
A new acceptance limit for filter DP (i.e., cleanliness) has been proposed. The change to the filter DP acceptance limit reallocates design margin associated with filter performance to CREACS fan performance in the control room pressurization mode. Planned modifications to reduce control room leakage paths, together with the proposed changes to the CREACS filter DP Surveillance Test acceptance limit, ensure that control room pressurization requirements and CREACS filter functionality are maintained during post-accident operation.
The environmental controls portion of the system (i.e., cooling coil, fans, ductwork and associated dampers, and filtration capability) are not affected by the proposed changes.
Therefore, control room temperature, humidity, air distribution and cleanliness requirements will continue to be maintained within acceptance limits. The proposed changes to the Surveillance Test boundary and acceptance limits maintain a conservative Operability standard for the CREACS filter train.
Acceptance limits and test methods specified for the HEP A filter and Charcoal Adsorber efficiencies are not affected by this proposal.
Based on the above discussion, it is concluded that the margin of safety has not been reduced.
CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.
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