ML20128M093
| ML20128M093 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/11/1993 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N93025, NUDOCS 9302220087 | |
| Download: ML20128M093 (7) | |
Text
..
5 y,
c y
,t.
r Pubfu: Servke.
Dectric and Gas
. 4 Cornparry
> Stanley LaBruna Pubhc SeMce Dectric and Gr: Company P O. Box 236. Mancocks Bridge. NJ 08030 609439-1200 FEB 11 1993-c w~+e e -
NLR-N93025 g
U.S. Nuclear Regulatory _ Commission
-Attention:
Document Control Desk Washington, DC 20555 d
Gentlemen:
- RESPONSE TO CO.MMENTS BY THE STATE OF NEW JERSEY.
DEPARTMENT OF ENVIRONMENTAL-PROTECTION AND ENERGY REGARDING REQUEST FOR AKE.dDMENT (LCR_91-02)
. HOPE CREEK GENERATING: STATION DOCKET'NO. 50-354 On November 25,'1991, Public Service Electric and Gas Company (PSE&G) submitted a revised request to-amend Appendix A:to'the:
Operating License-for our' Hope Creek Generating _ Station.
The amendment would increase in allowable Main Steam Isolation Valve (MSIV) leakage-and would result in elimination of the.MSTV Steam _
Sealing System.
On August. 17, 1992, the'New-Jersey Depa2.cment of Environmental Protection and Energy, Bureau of Nuclear lEngi'neering
-(BNE), under the ' provisions of 10 CFR _50.91(b), commented -on that - '
request.
'One of the reasons that the BNE stated for their concerns Is th'at
~
the amendment,lif approved, would permit-non-safety relatedt equipment to'be-relied on to function 51n place of safety related
. equipment-following a design basjs accident.
In r % 2= to this rmann, the Ctnclusicos m page 7-1 of the CE Report, NHX>-31858P, Rev.1, stata, ~"...it is clearly A safetyfimprovement to zglace a system that ims known limitatians.with the alternate inaln steam
~
- piping ard undreier; treatment pattuay dricti_has bem shownito have
=r=11 ant Inliability,# - The IMOG has detetCtined that Main SteMB p3phq[
and md==:her designs are extranaly IsJged and the ANSI /ASE-LOl.1 design:
requirsamts typically used for reclmr pwer plants (including Hope Creek)'
carttain a great deal of:nnrgin. Additicmally, the Sm0G reviewed limited /
eartlupake experienao data relative to the perfcanance of non-aniamir=11y :
1
. designed stsam piping and m&xwers. That study otsvWM that the =..
rmaihility of a failure whidt would cause'a IcFS Of E*aBGE'Or CordenGate in L
NR main stems piping or und=mers in the everst of a design basis -
i-earthquake is a...not cnly highly talikely, but also contrary to a large body of historical earthquake experience data, ard tisas urgum.ukubed.*:
4
?
/.
M 92022200s7:930a12-
-p0:
PDR ADDCK 05000354 P
ppg-
=a
Document Control Desk FEB 11.1993 NLR-N93025 Finally, a scismic ackigrey walk &wn ard evaluatico cxmformlJg to criteria 6 be stablished by the NRC in their Draft Safety Evaluation Report cn tM 1rqumted amandment, will be tuquired to to pericaned ard sutnitted to NRC prior to their apptwal and Isanrce of tM amandumt to our license.
A second statement in the BNE letter is that the requested change m il result in higher releases of radioactivity following a design basis accident.
Althxgh IDCA dcscs my be slightly higher for very lcw MHV leakage rates, tk prgreci treatent uthed can effectively treat Elv leakage cuer an eyded cperatiJg Innge. Additicmally, PSE&G rimmstrated, in our airusind rupest, that the incroaces in Inleased racilortivity runin well within Un NDC guidelines for off-cite ard control roan IDCA dcncs.
The final statement of concern in the 13NE letter is that, " Hope Creek is the lead plant... Approval of this amendment request will result in other Boiling Water Reactor licensees requesting the same increase in allowable MSIV leakage
',ncluding GPU Nuclear for the Oyster Creek plant which is also located in New Jersey."
As rif werad in the GE Report, NEDC-31353P, Iku.1, page 4-14, "EIV leakage rctes thct can be tolerated for any giwm site depend cn plant-specific piramators." Ttds unans that after the lead plant andment is approved, each plant must subnit its own mpest far an irkme in allcwahle EIV leakage which is based cn their plant-specific radiological calculaticm ard equiptent configuratians.
4he allowahle MSIV leakage can vary greatly, 'Ibe limit of 200 SCm por.
stema line allchable leakage in the Ikpe Croek request was Imhyxl ly EIV mnufacturr_d statenants that leahqe rats up to 200 SCHI aru rch indicative of substantial dafects tMt would challenge the EIV isolaticn capabilitics - as well as its being a leekage value that results in acceptable ircrease in off-site ard u. shul roca dosw for IIcpe Crock.
11 ape Cccek plant-specific IDCA ckna calculations parformed by General Electric ompany strw mIV leakage rates as high as 500 SCW per stmm line would ret Insult in mrmiing regulatory guidelines omtairnt in 10 cm 100 and 10 Cm 50, 4pundix A.
Otber plants that decide to apply for this amerdent (includity Oyster Creek) would rupest Elv allt.wable Icekage rates that a'so have bocn calculated, based upon their cun plant-spccific parameters, to rumain within the rugulatory gulMines.
We believe that the above discussions address the reasons that the BNE has given for the comments which were attached to their August 17, 1992 letter.
However, we have also responded, in of this letter, to those BNE comments.
~
Document' Control Desk -
FE811 1993.
NLR-N93025-We further believe that our attached responses to those comments demonstrate that our November 25, 1991 submittal, which-included Gen 3ral Electric Company document, NEDC 31858P, Rev.
1, provided adequata information to justify the granting of our amendment and-exemption requests (contingent on an NRC's review of our seismic adequacy walkdown and evaluation).
Should you have any-questions regarding this matter,-we wil1 be
~
pleased to discuss there with you.
Sincerely, Attachmeat C
Mr.
T. T. Martin, Administrator - Region I.
U.
S.
Nuclear Regulatory Commission 475 Allendale Rosd King of Prussia, PA 19406 Mrs.
A.-K.
Pelletier, Project Engineer U.
S. Nuclear Regulatory Commission One White Flint North MS 14 E 11555 Rockville Pike Rockville, MD-20852 Mr.
S.
Dembek, Licensing-Project Manager U.
S.
Nuclear Regulatory Commission One White Flint North-MS,14 E-21 11555 Rockville Pike Rockville, MD 20852-Mr. T.
P. Johnson (SO9)
USNRC Senior Resident Inspector Mr. K. Tasch, Chief NJ'Depertment of' Environmental Protection & Energy Division of Environmental Quality Bureau of Nuclear E!gineering CN 415
. Trenton, NJ 08625 l
A4TACID(ENT 1
]
RESPONSBS TO COMMENTS DY THE 1
(
HEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION AND ENERGY I
DIVISION OF ENVIRONMENTAL-QUAL 1TY-130 PEAU OF NUCLEAR MRIERIRQ
]
Concerns exprer; sed by the NJ Bureau of Nuclear Engineering are reproduced below.
Each is follevad by PSE&G's response.
1.
%pa CreeA is one of only two SGs in the U.S. kMrs a positive pressure is used to ocntml leakage throtyh the HSIVs. '1his is acormplishM by pressurizing the sot.ians of main stam pipirg betunen the iriami aid j
outboard MSIVs a:d between the c ttboani 131Vs ard the Main Stem Stop i
Valves to a presmite abcne that of tM mactor vmel. Since ucst IERs-operate a leakage centrol sists (ILS) at a nerp.tive pimure, noch of tb justification ocntained in the GE Geport, NTtDC-31858P, _is taw.l on a -
rxgative pressuru Irs. Wo in11evo that the operatiny ard wintenarco experience with positive preemre cystes should be provicad. 'nn possibility of inpxuving the perforwarca and reliwility of a positive pmssure Its mst be thoreghly ecosidettd before aliatinatiry the system "
ibmpango
'nmre am innerant alvar.tagos in rcplacirs the cristing penitive prmmzra IDS with an eccentially peaalve, stapler syatan that Ma prtuan ru11 ability. Valvts in the eclected drain line am the c.ily activu comparvmts in the alternate patNay, ard tira pard-wru t gerating pracrum is exdy a m
fw Irdes of water grmtcr tun the ambient atarsThrric precaxte. Wo are-confiamt that this licerre cMrge will facillc'ato sirptificant mintanarce crmt savirrp as wall as canum retrticau.
The NTC stattd, in WREG 1169, that EIV Imlurp Centml Sytcsm1 are rrt rtgiard to assure plant safety ard cornnatal that they could be eliminated.
It is ~Jso of interust to rote that older IMs (such an Oyster CrwA) are not-ruquired to havu MIV lealaxp control systan, ard that 12u Mvanotd IMt (AIM)-
(km rot have a leakage ocotrul systan in its design.
2.
- The cha.ge regaest pzrproca use of the whi stem lim, drain lirns ard.
the conkrrar as a leakage collrrtion systm. W have the folhuijg concerrs wtth this approachu These ron-safety relatal ocanporents have been in sc vice for 5 years.
a.
Tne effects of age-related degradation such as corrteica and ermion on tuse carptnents at be investigated."
Ib ayya Eresian asyl corzunicn exnstitute a well inrnwn potential prchlen in feMwater heater drain linrs becaune of their httft candonaate flow ratm..
Since there is rurmally rn (or very leu) f1cw thru,xft the mlected main stmm drain line patNay, eracdcri ard corrrmim am of rn n3rpiricant cen:2.!rn..
'Itw altertaba pa'Juay will be uw3 to process MSIV 1mkage at near atamphoric-prum:ure. 'This entityneet tas designed in 'mmtmco with ANSI /ASME-B31.1 rtglirtrrnts which prcuida adcqAtte a dgra mrgin for operaticri at carmidensbly higher pnemurea (up t's 1000 psig). ?titerial thickrescos would esily sutport the pressurm that On altermte patNuy would sea significarkly havtrri that point whem corrocico or cronim wtuld adversely 13 pact rorral plant operation.
- - ~ ~ -
AITAONINT 1,_ (Cbnt'd) _
b.
- Iheso acr:ponents are wwvi ftincticml in tM safety analyr.is -
prrposed by PSE&G. Thornfore, appropriate atrveillances and limitirq canditions for creration nist be addcd to the technical specifications to assure nontinucd cporability of those cmponents."
Runya 1ho cnly functional Irquituudu are that the pattury unt runain -
intact an1 that the mlocted drain line valven zust be capable of boirn opanad folicwirn IIXA ovents. Th3 tuntlts of 12 Intermticm1's ocismic event data-base averleroe sttdy (4pandix D of IEIX}-31858P, Bevision 1) omfina that.
I integrity is assurrd follcwirq soismic events and, sinoa the selected drain
{
valvm will be provided with safety-rulated powr, operation upon loss of -
02f-sito power is assurud.
c.
"The change recpest states that the pr:: posed leakage collection metrod is crrsistent with the shilccx5 y of pmtection by n11tiple leak-tight h
barriers. Ik: raver, to leak inspection or inservice inspection program of the stear line, drain line, drain line valves, or ccadensers is proposed."
Emmcum Dwin3 inanal cocraticm, the main candcwcr ard annociatal drain linco axemte at a prtsauru of appruxiantely 27 to 29 incfwis of )hturty vacuum.
Air in-loakage is a mnjor omoern ard is closely urnitonx1 to ensure efficient cynraticn. Any significant brnv31 of ttxso compcnonts during plant operation is unlikniy and would, in any case, be idcutified and repalmd in a tisely mmner, the atin atoam lire iniegrity is astmul by rarnal plant operator rcAnds ard arm radiatirm untitors; themfare, altiticnal ingxction is rot considertd te be tw xssary.
6.
"Inakage fzun fittings ord valvo sten packing will beoxe a pathway for an umnnitorral relc*2se of radicactivity. Thin Taist be cu s idered 'in the dose calculations."
Eawag Pucki/g 1mkago frun rmall 1000 psig valvec sould be irragnificant ccraiderixJ that tha differential pressut, is cnly a few irdxs of water.. As this is a kelded systs, there is little opportunity for In*ge thcagh ficthgs. Because of the low post-IDCA operatirg precsure, lontaga.ttua throard fitthys (taperature probas, etc.) sould also be irnnscqoctrtial.
c.
"The remtits of the verification of the seismic. adequacy of Mmse ccupenerats should be prvvi'.ed for review as part of of the 10 CFR 100 exmption requat. A fielo walkdcun to assess the fall-dmn potential of otdier carynnents onto the talA steam lim, drain line, valves ard condenmr should be perforned ard documnted. An analysis of the consc<pences of any relevant fall-down shculd be providcd."
Brranse
'Ibe ble has statcd their intertion to require docimrntation ard the3r review /arrrrual of cur crimic walh3mn verification prior to issuanco of the regmted licanse charge.
AITAC21MDfI' 1, (CaLTt'd)
~3-f.
"Althatgh th.tisolated cenknser unthod of leak cmtrol is described as a passive Inethod, catrol it:m cperator acticn is required to open the ctrain line valves. 'Itese valves ard their notor operators nust be demnstrated to be capable of cperatirn in a pcot-aocident ernizunnent."
Drgny3 With the plarn:d additim of refety ralated pwer, these valvm can be easily as:nnanstruted to be operable in tM post-notddmt cruisn ut siim tim turbin's 1:uildirg post-accident crivimramt in significantly Ims ha.rnh than duriin autel plarrt operation.
g.
"'Ihe notor-oparai.cd valves (IWs) needed to oparate in tbn drain lines nust be added to the IM Program required by Generic Ictter-89-10.
ihmocmg Sinoa the prnmv1 m1V 1mkage altermte trntent patluny in rot l
safety-related, ASHC Sectirn XI dom rot a@y Inr dom CL 89-10.. PSE&G will, howver, utm innlmer.tation of the ruvacstod ariuduud-, incorporate the i
subject NNs into mr irMicrvice tostng (IST) pwp.mu for ASE Section XI valvm.
3.
FurtMr information en the assuqtions ircluded in tM off-site doce calculations is needed.
Is it assumed that all ruterial is held-up for 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> and then released instantanecnaly? Or, is it assumi that the material is released at a constant rate? Or, is sme reterial held-up and some released at a Twtant rate? Table 1 of the ICR rhus the calculated doses resultiry frca a naxin2m M3IV leak rate of 200 scfh. Is this a 200 scfh leak per steam line?
Eggponse
.cpecifics of the nxilological dose Inlease isodel are docurxntal in Appenlix C of NELF33858P, Devisirm 1.
A multi-compenant rulcam nochi calculates the rnlease as a fLrctial of tim. The ficw rate is assumod-comtarit at the umh== allowable MIV leakrge rate (requestai in tim license.
chirge) of 800 scfh total.- All of the asemptions and un$al dmcripticn are rkv=w?.ed in the ateve-referrnood Appenlix C.
4.
'*Ihe need for upgraded or acklitional radiation nonitors in the Turbi x axildirg or elsewheze nust be addresscd."
Bgggm@
IEE&G has no information that would stggest that our current radiatlan monitors are rnt ahpata to monitor this release pathway fmo the birnine buildirg. 'Iho resultirq release remairs wl1 below 100R100 limits.
4
ATfAC1MEM' 1, - (Ctxit'd),
5.
"The charge vill result in an increased dose to traintenarce personnel' virkhg on the rain steam system or candonar. ' Ibis shoald be quantified.
Ihusrc
'Ilm Fuqual charge would txt zumit in any. irr.rtam in expomIru l
durirq or follcwiry rorml cperation. Any incrmscd dano would oxur artly after a severe accickmt that involves a Ice of all ECCS for soveral hoaru.-
It is rot sqw+M that statico namgtsant would be carmtral with performity mirAnnrure en tte cxxxkumr or anin staan system for a cxmsiderable period of tian follcwirq the type of nevere accitkut asawn1 here. 'Dn very Icw.
probability of the postulated occurmcu, cau;21ed with air amecamud. wttich clisacunts ony road for minterance perstmal to be in the turbino billaisy l
fo11cuire that occurum, ckos not wirrant qJantificatim of the inczmsad &me l
to plant persamal sucyp?stod by the INE.
I l
6.
"If this charge is inplcrented, sorte plant areas will have higher post-accident radiation levels. Ibst-accident accesa nquimtents into these amis mst be assessed. Equipnent that tir3t tunain furctical in these higher radiation arms must te evaluated."
Ihmgang
'Iharu is to o?tir=vit (otter than the alternato MIIV leakage pathway) in the effccted arms of the turbire billairg that is safety related or requimi to ruoain ibncticnal folicwirq a IOCA and, as stated in cur responso to (5) alxwe, there is no change in radiatico levelri auring rarmi l
plant operation arel ro apparent tearon for plant persanrel to enter these atoas -
follcubg the pastulated Iccn.
I l
1 t
<