ML20195E214

Advises That Util Planning to Modify Filtration Sys to Replace Downstream HEPA Filters W/High Efficiency Filter.Mod Expected to Be Completed During First Refueling Outage Scheduled to Begin in Mar 1989

ML20195E214
Person / Time
Site:	Beaver Valley
Issue date:	11/01/1988
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8811070297
Download: ML20195E214 (9)

Text

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er Poaw Stat <>n Shengport. PA 150774004 C.,i".L., c,o

<pum November 1, 1988 U. S. Nuclear Regulatory Commission Attn:

Document Control Desk Washingtors, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 2 Docket No. 50-413, License No. NPF-73 SLCRS Downstream HEPA Filter Replacement Gentlemen:

Our Unit 2

Supplementary Leak Collection and Release System (S LCRS) as described in FSAR section 6.5.3.2 consists of two redundant filter trains.

Each train consists of a

moisture separator, prefilter and electric heater followed by two parallei HEPA filters, charcoal filters and a second HEPA filter.

This design configuration in in accordance with the requirements of Regulatory

(

Guide 1.52.

We are planning to modify this filtration system to replace the downstream HEPA filters with a high efficiency type filter (non-HEPA design).

The downstream HEPA filter is designed to remove charcoal fines collected from the upstream charcoal filter and to provide additional protection against particulate releases in the case of failure of the upstream HEPA filter bank.

The new replacement filters will satisfy the same function by removing charcoal fines at a

filter efficiency of 90% or greater.

The SLCRS prefilters along with the downstream high efficiency filter provides a high degree of protection in the event of failure of the upstream HEPA filter.

In

addition, radiation monitors downstream of the filter assemblies would alert operators of a

failed system such that the redundant train could be placed in service.

The upstream HEPA filter will continue to be tested in accordance with Regulatory Guide 1.52 and our Technical Specifications surveillance requirement 4.7.8.1.b.2 to verify an officiency of 2 99.95%.

As provided in 10CFR50.59, changes to tha plant may be made without prior NRC approval provided these changes do not involve an unreview>d safety question and do not require a change to the plant Technical Specifications.

A safety evaluation has been performed for this change and we have concluded that no unreviewed safety question exists.

We have also reviewed the plant Technical Specifications for any required changes as a

result of this modification.

Technical g

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B cvsr Valley Powar Station, Unit No. 2 Docket No. 50-412, License No. NPF-73 Page 2 Specification 3.7.8.1 requires two SLCRS filter trains to be operable and Surveillance Requirement 4.*/.8.1.b.2 requires DOP testing of the HEPA filters.

There is no distinction between upstream and i

downstrsam HEPA filters in the Technical Specifications.

We have therefore concluded that no change to the c.d. sting Technical Specification wording is required.

However, since surveillance requirements for DOP leakage testing on the new downstream filter will no longer apply, we are providing notice to the NRC staff as we i

proceed with this change.

A copy of the design concept and 10CFR50.59 evaluation is provided as information.

This modification is expected to be completed during the upcoming Unit No. 2 first refueling outage scheduled to begin in March of 1989.

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Required changes to the UFSAR will be included in a future UFSAR i

revision.

Should you have any questions on this matter, please contact me or members of my staff.

Ve y truly yours,

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J.

D. S e er l

Vice President Nuclear Group

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cct Mr. J.

Beall, Sr. Recident Inspector

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l Mr. W. T. Russell, NRC Region I Administrator Mr.

P. Tam, Project Menager

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Director, Safety Evaluation & Control (VEPCO)

Mr. T. M. Gerusky, Director BRP/ DER i

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Design Concept DCP-1964 Revision 9 Page 3 of 5 SUPPLEMENTAL LEAK COLLECTION AND RELEASE SYSTEM (SLCRS)

DOWNSTREAM HEPA FILTER REPLACEMENT

1. # 2E31Q1 Ql.fECTIVE 1.1 Replace the downstreae HEPA (high efficiency particulate air) filters with high efficiency non-(HEPA) typ? filters to reduce the complexity of the testing requirements associated with MEPA's installed down stream.

The testing of both upstress and downstreen HEPA's require the use of a special test apparatus and entry into the filter bank housing's to test the NEPA filters.

The additinnel testing considerations of HEPA versus non HKPA are as follove:

1. Increased Testina Itat - This is due to the installation of special test apparatus into the filterbank housings which also affects systee operability (Technical Specification 3/4.7.8) and presents radiation exposure (ALARA) concerne.

2. Doerational Concerns - The installation of the test apparatus requires multiple starts / stops of SLCRS system which introduce 4

l coordination efforts between the various groups. (Operations, Testing etc.)

3. Additional. Costa - This would occur due to the increased operatione scheduling and testing efforts.

Also HEPA filter replacement costs are higher than high efficiency filter replacement costs.

The use of the special test apparatus may inadvertently cause desage to other filter housing oceponents when installed or removed which could cause the total maintenance costs to increase.

Long tore maintenance costs for this systee with downstrees HEPA filters installed will increase.

1. 2 The proposed solution is to replace the dovnairene HEPA filte?Q Ad the Supplemental Leak Collection and Release 3ystem (SLCRS) with high efficiency type filters with an efficiency of greator than or equal to 90X.

T>is proposed solution is based on the following considerations:

1. Reduce fastinn I133,- This is due to the ability to periore all of the required SLCRS tests without entry into the filter bank housing.

Injection and sample ports can be placed upstress and downstrees of the filter / absorber assemblieo to conduct tests.

Personnel need not enter the housings thereby avoiding potential handling damage to filters and exposure to potentially radioactive components.

2. Operational Concerns - Cycling of the SLCC systen to periore tests would be substantially reduced fr',3 that Tath the currently installed downstreme HEPA configurat1On.

Design Concept DCP-1968 Revision 8 i

Page 4 of 3

1. 3 The downstreas HEPA filter function is to remove particulate and carbon fines, the high efficiency filters (greater than or equal to 901 efficiency) vill perform this function as well as reduce the testing and maintenance requirements.

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2. 0 ROURDARIES QE CHAMGE 2.1 The boundaries of this change are the downstreen HEPA filter banks in the SLCRS filter housings in the Auxiliary Builditg elevetion 773.

Listed belov l

are the identification number, description and location of the affected items:

Ites Component Description Location 1.

2HVSeFLTA296A Train A-Downstresa HEP'.

Aux. Bldg.

Filter-F11terhouse Elev. 773 Assembly No. 1 2.

2HVC9FLTA299A Train A-Downstream HEPA Aux. Bldg.

Filter-Filterhouse Elev. 773 Amoesbly No. 2 3.

2HVSeFLTA206B Train B-Downstress HLPA Aux. Bidg.

Filter-Filterhouse Elev. 773 Assembly No. 3 4.

2HVSeFLTA2998 Train 3-Downstream HEPA Aux. Bldg.

j Filter-Filterhouse Elev. 773 j

Aeoesbly No. 4

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2. 2 This design change requires hardware changes only in the area of the plant listei above.

3. 0 UAE PROTECTIDM COMSIDERATIONS 3.1

!.~ accordance with UAP 2.15, ' Fire Protection Progren', this design change I

will not tapact compliance to regulatory fire protection requirements.

3. 2 This design change vill not require a chcnge to the Fire Protection Evaluation Report, FSAR Section 9.5.1 and Appendix 9.5A.

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Design Concept DCP-1964 Revision S Page 5 of 5 4.0 &jARA REVIEW CONSIDERATICMS 4.1 In accordance with SAP Chapter 23, OCCUPAfIDMAL RADIATION EXPOSURE SEDUCTION Section VI.F, 'ALARA Review on Modificatione'l this design change does involve en actual or a potentially radioective systes and component.

4. 2 The SLCRS filter bank housings are located in the radiologically controlled area.

All work performed in this radiologically controlled area shall be done in accordance with DLC Radiological Contrel Group and operation's reconsendations.

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5. 0 ERYIRONMENTAL QUA1,IFICATIQ( CONSIDERATIONS 5.1 In accordance with UAP 2.18, ' Equipment Qualification of Class IE Equ 4 Mct,t', no QA Category I, Class IE equipment will be effected by this d w.ra enange.

Therefore, equipment qualification is not applicable.

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6. 0 IRPACT Q1 1 E ISI/IST PROGRAM 6.1 This design change does not impact the ISI/IST Programs.

7. 8 liMHAR ELCTQRs EmoIMEERIuG CONSIDFRAIJQgg 7.1 This design change does not affect the Control Room workspace, instrumentation and/or controls in accordance with NUREG-9780, 'GuideHnes for Control Roon Design Review'.

8. 8 EFFECTS Q1 EQ'JIPREMT UEEE II&It JURISDICTION 8.1 This design change vill not affect equipment knder state Jurisdiction.

9. 0 ATTACHMEMYS t

9.1 Preliminary Design Input List f

9.2 Preliminary List of Design Outputs f

l 43 Cost Evaluation

9. 4 Safety Evaluation I

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9. 5 (Sketches, Figures, Marked-Up Drawings, etc.)

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ATTA CH MENT

9. e DUQUESNE LIGHT COMPANY I

Nuclear Group Nuclear Engineering Department Engineering 10CFR50.59 Safety Evaluation i

STATION:

Beaver Valley unit No. 2 DCP NO.

1060 SYSTEM:

Supplemental Leak Collection and Release System EQUIPHENT:

Dovnstream HEPA Filter Banks MARit NOS.:

2HVS*FLTA206A, 2HVS*FLTA209A 2HVS*FLTA2068, 2HVS*FLTA209B DESIGN CONCEPT NO.

1060, Dated 4/29/88, Revision _0, Description & Purpose of Hodification At the present time, the testing of both upstream and dovnstream HEPA (high efficiency particulate air) filters require the use of a special test apparatus and entry into the filter bank housings to test the HEPA filters.

l Operations Testing and Plant Performance requested Engineering to replace the dovnstream HEPA fi'ters in the Supplemental Leak Collection and Release System (SLCRS) vith high efficiency type filters (vith an efficiency of greater than or equal to 90%)

to eliminate the need for extensive testing.

This modification can reduce testing ilme and maintenance regnirements, j

Safety Evaluation This design char.se is safe in that the replacement of the dovnstream l

HEPA filter in SLCRS vill not affe:t any equipment important to safety, as t

previously analyzed, or create any new malfunctions or accidents.

The i

Technical Specifications in Section 3/4.7.8 are not affected, and there are i

only some editorial changes to figures, tables and text to indicate HEPA replacement vius high ef ficiency type filter in UFSAR Sections 6.5.1, 6.5.3.

6.5.4, and Tchle 6.5-7.

After this replacement, the system still consists of sufficient sequential components (i.e.,

upstream HEPA filter. charcoal filtet and downstream fi~ter) to remove the fine discrete parti:ulate matter and pass the air stream through the charcoal absorber to mee-e design requirements and criteria of Reg. Guide 1.52.

The fun: tion of the new dovnstream filter of

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collecting carbon fines is consistent with the original requirement for a dovnstream HEPA filter. The function and operation of the SLCRS remains the i

same. The design change does not have an impact on the filter's function of removing airborne radioactivity from exhaust air before release to the outside atmosphere.

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ATTA CH M EN T %P i

i Unreviewed Safety Question Determination 1.

Is the probability of an occurrence or the cor. sequence of an accident or malfunction of equipment important to safety as previously evaluated in the Updated Final Safety Analysis Report (FSAE) increased?

J Reason:

The proposed modification does not increan the possibility of an occurrence or the consequence of an accident or malfunction of equipment impc' tant to safety referenced in the Updated Final Safety Analysin Report in Chapter 15.

It does not have the impact on the function of the Supplementary Leak Collection and Release System. This modification can reduce testing time and maintenance requirements.

2.

Is the possibility for an c.ccident or malfunction of a different type than previously evaluated in the Updated Final Safety Analysis Report created?

i Reason:

This modification to replace dovnstream HEPA filter in SLCRS

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vill not create an accident or malfunction of a different type than previously evaluated in the Updated Final Safety Analysis Report.

It does not have an impact on the filter's function of removing airborne radioactivity from exhaust air before release to the outside atmosphere.

The failure of this filter has no effect on the safe shutdown of the plants therefore, a

different type than previously evaluated in the UFSAR vill not be created.

)

3.

Is the margin of safety as defined in the basis for any Technical Specification reduced?

g Reason:

This modification has no effeet on the margin of safety in the i

Technical Specification. Section 3/4.7.8.

This replacement does not change the filter's capability to remove the fine f

diccrete particulate matter and pass the air stream through the charcoal absorber to meet the design requirements and criteria 3

of Reg. Guide 1.52.

The filter efficiency for particulatt and iodine removal vill remain the same therefore, the offsite do'e consequences of design basis accidents remain the same.

Technical Specification vill be maintained with the same safety asrgin as it is nov vith no change.

4.

Based on ihe above, is an unrevieved Jafety qJestion involved?

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Is a change to the Updated FSAR required?

YES i

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Reason:

Editerial change to figures, tables and text to fndicate HEPA l

replacement with high efficiency type filter in Section 6.5-2, l

6.5-3, 6.5 4, Table 6.5-7, Fig. 6.5-2 and Fig. 6.5-4

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6.

Is a change to the Technical Specifications required?

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L A TT A C H M E N T

f. y 0.A. CATEGORY REVIEV 1.

Q. A. Program Aprendices A, B, and C Appendix At This modification falls under the definition of QA Category I.

Appendix 5:

The modifications to be incorporated under this design change are QA Category I.

Appendix C N/A 2.

Unit 1 Updated FSAR, Appendix 8:

The supplementary leak collection and release system is listed as requiring seismic loading design.

Unit 2 Updated FSAR, Table 3.2-1:

The supplementaty leak collection and release system is listed as QA Category I and Seismic Category I.

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Haster Equipment List (H.E.L.):

Equipment GA Category 2HVS*FLTA206A I

2HVS*FLTA209A I

2HVS*FLTA2065 I

2HVS*FLTA2098 I

0.A. CATEGORY CONCLUSION Based on the above OA review, this modification is OA Category I, seismic.

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