ML20137N651
| ML20137N651 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/29/1985 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8512040182 | |
| Download: ML20137N651 (13) | |
Text
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e Public Service Electric and Gas Cornpany Corbin A. McNelli, Jr.
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge NJ 08038 609 339-4800 Vict President
- NucIrar November 29, 1985
' Director-of Nuclear-Reactor Regulation United States Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Attention:
Ms. Elinor Adensam, Director Project Directorate 3 Division of BWR Licensing
Dear Ms. Adensam:
. COMPLETION OF ACTIVITIES SUPPORTING FUEL LOAD AND LOW POWER / POWER ASCENSION TESTING HOPE CREEK GENERATING STATION DOCKET NO. 50-354
'Public Service Electric and Gas Company (PSE&G) has just completed a detailed assessment of the status of the work activities necessary to support fuel loading and low power /
power ascension testing at Hope Creek Generating Station (HCGS).
The results of this effort indicate the design, construction, and testing required to support issuance of a low-power license-(5%) at HCGS will be completed
-during the month of February 1986.
In conjunction with this effort, it has become apparent that construction, preoperational testing, and post-test reviews of certain portions of a small number of systems may not be complete prior to fuel load.
The delays in
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completing this work are due to a variety of design, delivery, and installation issues.
The draft listing of the affected systems is included as Attachment I.
PSE&G's present evaluation of the deferred work concludes that these systems would not affect the ability of HCGS to safely operate during fuel loading and low power / power ascension testing as summarized in Attachment I.
This determination is made on the basis of an evaluation of Technical Specifi-cation requirements and/or the absence of fission products and decay heat loads up to criticality and the small inventory through low power (0-5%) testing.
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Director of-Nuclear 2.-
11-29-85 Reactor Regulation A finalized list of systems which will not be completed by fuel load wil1~be furnished to the NRC at least 30 days prior to the anticipated fuel load date.
Each item to be deferred will undergo a safety evaluation to ensure that the. proposed deferred work poses no undue risk to the health and safety of the public.
Both the Stati9n Operation Review Committee (SORC) and the Offsite Sarety i
Review Group (OSR) will review each safety evaluation prior to submittal.
The results of these safety evaluations will be submitted in the aforementioned letter.
In order to control and manage the deferred activities during low power testing, a multi-discipline Work Coordin-ation Team.will be established.
The purtose of this team will be to interface between the Operatic.as staff ar;d
. Construction and Testing personnel.
Details of the organ-ization, responsibilities, and interface mechanism of this team will be forwarded in separate correspondence.
All work for-which deferral is being requested has been
' reviewed to determine if any exemptions from 10 CFR Part 50;are required.
No such exemptions have been found to be necessary.
With regard to readiness for fuel loading,
,/
completion of corrective actions for 10CFR50.55(e) report-
.able ' deficiencies and,inspectiN. repprt open items are being resolved directly with Region.I.
Please advise PSE&G if any additional information is required to' allow the NRC to plan its resources to support timely issuance of a low power license for the Hope Creek Generating Station.
m.
Sincerely, Corbin A.
McNeill, Jr.
Vice President - Nuclear Attachment-C D.H. Wagner USNRC Licensing Project Manager R. W.
Borchardt USNRC' Senior Resident Inspector t
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. ATTACHMENT I DEFERRALS AT PUBL LOAD
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A.
Radwaste HVAC Systems.
B.
. Reactor Building Filtration Recirculation
-and Ventilation System (FRVS)
-C.
-Liquid Radwaste System
. D.
Solid Radwaste' System E.
Radiation Monitoring System, Area / Process
.F.
Transverse.In-Core Probe Monitoring G.
Main' Turbine Control (EHC)-System H.
Radwaste Building and Turbine Building:. Fire Protection Water Systems (Automatic Suppression Systems) and Early Warning Smoke Detection Systems
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I.
Gaseous Radwaste J.-
Containment Pre-purge Clean-up System (CPCS)
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- A.-
Radwaste_HVAC Systems-The Ra'dwaste HVAC Systems.are non-safety-related and
. provide _the following functions:
1.-
Maintain area temperatures within design limits.
2.
Maintain' direction of air flow from areas of lower potential contamination toward areas of increasing potential contamination.
3..
Provide exhaust.from radioactive _ contaminated tanks and sumps: maintaining them at slightly negative
-pressure.
One of'the two Radwaste Tank' Vent" Filtration units, one of the two-Radwaste' Supply and two of the three
'Radwaste Exhaust units will be operational prior to fuel' load in order to provide direct' ventilation
'and filtration from:the collection tanks and. sumps
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-which are operational prior to fuel load.
Installation of'the required filters in these trains will be completed prior to initial criticality.
Final pre-op testing of the operating system identified:
above will be completed prior to exceeding 5% power.
. Installation of-all filters and associated monitoring
. instrumentation will be completed and operational prior to exceeding 5% power.
Deferment of completion of the Radwaste HVAC Systems ~
. pre-op; testing until prior to exceeding 5% power' in the-Power Ascension Program does not-affect any safety related systems or the safe operation of the plant.
. ]B.
Reactor Building Filtration, Recirculation and Ventilation System (FRVS)
The1FRVS comprise the ESF containment atmospheric cleanup
. systems for.the HCGS.
The completion of pre-op testing for FRVS operation is not required until initial criticality
-is achieved.
The FRVS recirculation' system recirculates and filters air in the' reactor building to reduce the concentration of potential ra'dioactive halogens and particulates.
The
- FRVS ventilation system maintains the reactor building at a negative-pressure with reference to outside atmosphere and further filters the building atmosphere to limit offsite dose.
The FRVS is initiated from either one or a combination of the following events:
- 1) Reactor vessel level low,
- 2) Drywell pressure high, 3) Refueling floor high radiation, and 4)' Reactor building high radiation.
The radioactive fission and activation products of concern for-radiation dose consequences will-not be present prior to initial criticality.
Deferment of completion of the FRVS until prior to achieving initial. criticality does not affect'any safety related
' systems or safe operation of the plant..
C.
Liquid Radwaste System.
The Liquid Radwaste System is designed to collect, store, process and dispose of or recycle all radioactive or potentially
' radioactive liquid wastes generated during plant operation.
The HCGS Technical Specification 3.11.1 requires that the concentration of radioactive material released in liquid-effluents to unrestricted areas be limited to the concentrations specified in 10CFR Part.20,-Appendix B, Table II, Column-2 for radionuclides other than dissolved or entrained noble
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_ gases at all times.
During low power testing, radioactive
' fission and activation products will not be' generated in the reactor at any appreciable level.
Collection tanks
-in the radwaste system can contain a volume'of fluids beyond the quantities to be. produced up to 5% power.
The following
. list: details the storage capacity of the~ liquid radwaste system which_will be available at fuel load.
Capacity Each Components Quantity (gal.)
Tanks Waste collector 2
32,000 Floor drain collector tanks 2
17,000 Waste surge tank
-1 67,500 Waste neutralizer tanks 2
27,500 Concentrated-waste tanks 2
12,000 Detergent drain tank 1
2,000 Decontamination solution 1
700 concentrated waste tank Chemical waste tank 2
4,500 Waste sample tanks-2 17,000 Floor drain sample tanks 2
17,000 Deferment of completion of preoperational testing of the Liquid Radwaste System until prior to exceeding 5% rated thermal power does not affect any safety related system (nr the safe operation of Hope Creek.
D.
Solid Radwaste System Th'e Solid'Radwaste System is scheduled to be completed and available to support power ascension testing above 5% rated thermal power.. Prior to this time (i.e.
fuel 11oad through 5% power) low power testing will be supported by utilizing the services of a contracted radwaste vendor to process and package-radwaste on
- site, if required.
The services of the contracted vendor will be retained beyond 5% power if the per-manent plant equipment is not ready.
PSE&G will obtain the services of a vendor with an NRC approved Process Control Program (PCP) consistent with the requirement of Technical Specification 3.11.3.
.An. engineering review of<the subject.PCP will be performed to assure vendor. operational requirements are compatible
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with Hope Creek system operations responsibility.
All vendor procedures will.be reviewed by-Engineering and approved by SORC-in accordance with Hope Creek procedure SA.AP.ZZ-001(Q).
The solid radwaste compactor.will be operational at fuel load.
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E. _ Radiation Monitoring System, Area / Process A letter-from R. L. Mittl (PSE&G) to W.
Butler (NRC) dated September-10, 1985, identified those portions of the Hope Creek Radiation Monitoring System (RMS) that would not be functional by the December 1985 fuel load date.
PSE&G is evaluating the impact of the revised fuel load
-date on the schedule contained in the September 10, 1985 RMS: submittal..
Separate correspondence will. address the results of this evaluation, and also respond to the NRC's letter of November 21, 1985, on this topic.
-Q -
n F.
-Traversing In-Core Probe Neutron Monitoring The. Traversing In-Core Probe (TIP) System is used to recalibrate the Local Power Range Monitors (LPRMs).
This can be done over a range of 5 to 100 percent of rated reactor power.
Hope Creek's Technical Specification requires this to
'be done at least_once per 1000 effective full power hours.
TIP also'can be used to provide an X-Y mapping of gamma
' flux throughout the reactor core and to verify a particular LPRM reading.
Each of the five TIP detectors consists of a detector, probe drive train and power supply, logic, instrumentation and control circuits.
Acceptance criteria for the preoperational testing of this~ system includes verification of the following:
1.
Acceptability of the insulation resistance of each TIP detector, 2.
Acceptability of.the mechanical installation arrangement, TIP probe driving torque, purge rate and pressure, ball valve operability and squib explosive valve continuous monitoring and firing current, 3..
Appropriate core bottom and top limits which are input into program cards and, 4..
Acceptability of all operating modes, interlocks, logic and. indications.
Preoperational testing of the TIP system will be completed prior to' initial criticality.
This is acceptable for the following reasons.
TIP cannot be used to calibrate LPRMs below 5% rated reactor power.
Deferment of the completion of'the preoperational testing until prior to initial criticality will not affect any safety-related system or the safe operation of the plant.
Verification that the primary containment valves (i.e. squib and ball valves) operate acceptably will be performed prior to entering a condition at which Hope Creek's Technical Specification-requires Primary Containment integrity be maintained.
Based on the above, deferment of the completion of this testing does not affect any safety-related system or the safe operation of the plant.
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. Main Turbine Control (EHC) System The Turbine-Generator Control System is a GE electrohydraulic control (EHC) system.
It is' designed to control turbine inlet pressure during normal operation, and provide pressure control during reactor heatup.
During plant transients,
.the EHC operates'the turbine bypass valves in order to
. reduce the magnitude of reactor. pressure transients.
The EHC system is not safehy related.,
Prior to opening of the MSIVs, the EHC system which controls
-the Main Stop Valves,1the Control Valves, Bypass Valves,
-and the Combined Intermediate' Valves, is_not required for operation. 'Hence, the EHC. system preoperational testing will be completed prior to-opening of the MSIVs.
Deferment of completion of preoperational testing of the Main Turbine Control System until prior to opening of the MSIVs does not affect any safety related system or the safe operation of'the plant.
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H.
Radwaste Building and Turbine Building:- Fire Protection Water Systems (Automatic Suppression Systems) and Early Warning Smoke Detection Systems Preoperational testing of.the Radwaste and Turbine Building Fire Protection Water Systems (Automated Suppression) and Early Warning Smoke Detection Systems will be completed prior to achieving initial' criticality during low power
. testing.
-Fire-Protection Water Systems OWS3, OWE 5, OWS6, OWS7, OWS8, OWS13, OWS16, OWS17, OPS 2, OD3, OD4 and IPS6 serve certain areas of-the Radwaste Building.
Early warning smoke detection systems are also provided in various areas of the Radwaste Building.
These areas will have operable mitigating fire fighting provisions.such as portable fire extinguishers and fire hoses.
Out of the aforementioned 12 auto'matic
-suppression (water) systems, lPS6 and OWS6 protect areas with safe shutdown cables and will be operable by fuel load.- Also, the detection systems in the radwaste wing areas' cover areas with safe shutdown cables and will be operable at fuel load.
The other Radwaste Building areas where safe shutdown cables exist (the remote shutdown panel
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room and in rooms 3442, 3444, 3414, 3605 and 3606) will have operable smoke detection systems to alert fire brigade and control' room personnel of..a possible fire.
These detection systems will be operable prior to fuel load.
j; Administrative controls including a roving fire watch and controlled access will be imposed to-prevent fire in the other areas of the Radwaste' Building.
In addition, the fire protection status panel in the main control room will be operable for the systems in service.
' Fire Protection Water Supr.ression Systems in the Turbine Building are not essential for safe shutdown of Hope Creek.
Also, the detecti<n systems in the Turbine Building do not protect any safety-related areas.
Portable fire extinguishers and fire hoses are provided as mitigating fire protection throughout the Turbine Building for manual fire fighting.
In the absence of an operating smoke detection system, administrative controls including a roving firewatch and controlled access will be imposed to prevent fire.
Deferment of completion of preoperational testing of the identified Radwaste Building and Turbine Building Fire Protection Systems and Early Warning Smoke Detection Systems until prior to initial criticality does not affect any safety related system or the safe operation of Hope Creek.
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Gaseous Radwaste
- The Gaseous Radwaste System is~ designed to collect' and delay release of noncondensible radwaste gases removed from the main condenser by the air ejectors:
during plant operation.
The HCGS Technical Specification 3.11.2 requires that the done rate due to radioactive materials released in gaseous effluents from the site.to areas at and beyond.the site boundary b'e limited to specified values for gases and particulates at all times.
During the low power testing period prior.to opening the MSIVs, radioactive r.oble. gases and particulates will not be produced in the reactor to any appreciable level and only' air will be collected in the main condenser with the MSIVs closed.
When the MSIVs are opened, steam and.noncondensible gases will pass to the main condenser and the' steam jet air ejectors will-then begin processing the noncondensibles through the Gaseous Radwaste System.
Por this reason, preoperational testing and turnover will lx2 completed prior to opening the MSIVs to ensure that Te chnical Specification requirements are met.
Deferment of completion of preoperational testing of the Gaseous Radwaste-System until prior to opening of-the MSIVs does not affect any safety related system for the safe ~ operation of the plant, since no radioactive noncondensible gases can collect in the main condenser until the MSIVs have been opened during initial heatup.
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' Containment Pre-purge Clean-up System (CPCS)
Deferral of the completion'of the Cont'ainment Pre purge 4 Clean-up System.until prior to reaching initial criticality in the Power Ascension Program is proposed.
-The CPCS'does'not normally operate and is required only to reduce radioactive fission products prior to drywell
~and; torus purging by the'RBVS system.
Prior to initial criticality,-:the_CPCS is not required to operate since radioactive 1 fission and activation products will not be present.
Deferment of the CPCS until prior to initial criticality
.does not affect any safety related system or.the safe operation of-Hope. Creek since there will be n'o fission products generated until initial criticality.
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