ML20217P668
| ML20217P668 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/24/1998 |
| From: | Eric Simpson Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCR-H97-16, LR-N98022, NUDOCS 9805070013 | |
| Download: ML20217P668 (6) | |
Text
-
l Pubhc Serwce Ekstnc and Gas i
Company E. C. simpson Pubhc Service Electric ar!d Gas Company PO Box 236. Hancocks Bridge. NJ 08038 609 339-1700 knw v4.e N.4em - N4aw t og nee"og APR 241998 LR-N98022 LCR H97-16 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 SUPPLEMENTAL INFORMATION FOR A CHANGE TO TECHNICAL SPECIFICATIONS FRVS SURVEILLANCE TESTING REQUIREMENTS HOPE CREEK GENERATING STATION i
FACILITY OPERATING LICENSE NPF-57 i
DOCKET NO. 50-354 Gentlemen:
On August 26,1997, via letter LR-N97523, Public Service Electric & Gas (PSE&G)
Company transmitted License Change Request (LCR) H97-16 to the NRC to request a revision to the Technical Specifications (TS) for the Hope Creek Generating Station. In part, LCR H97-16 requested a revision to wording contained in the Filtration, Recirculation and Ventilation System (FRVS) surveillance requirements. Specifically, Hope Creek proposed changing TS 4.6.5.3.1.b and 4.6.5.3.2.b to state that the FRVS heaters should be " operable" instead of "on" when performing this 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> test.
The additional information contained in Attachment 1 of this letter is being provided to facilitate the review of LCR H97-16. The information contained in this transmittal does not alter any of the conclusions reached in the 10CFR50.92 No Significant Hazards Analysis contained in PSE&G's August 26,1997 submittal.
In accordance with 10CFR50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey. Should you have any questions regarding this request, we will be pleased to discuss them with you.
Sincerely, Affidavit
\\
Attachment (1) 9005070013 900424 a
DR ADOCK 050003 4
@=L
Document Control Desk APR 241998
'LR-N98022 C
Mr. H. Miller, Administrator - Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis, Licensing Project Managei - HC (ACTING)
U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Pindale (X24)
USNRC Senior Resident inspector - HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625
REF:
LR-N98022 LCR H97-16 STATE OF NEW JERSEY )
) SS.
COUNTY OF SALEM
)
i E. C. Simpson, being duly sworn according to law deposes and says:
I am Senior Vice President - Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief.
/
7 y'
Subscribed and Sworn to before me this A4 day of C l.
,1998 V
AwktL6.fdiL Notary P%Iic of Ne(d Jersby EUZABETH J.1000 My Commission expires on 30!ARY PU80C OF NEW JERSEY
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D: cum 2nt Control D:rk LR-N98022 Att: chm:nt 1 LCR H97-16 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS)
SUPPLEMENTAL INFORMATION FILTRATION. VENTILATION AND RECIRCULATION SYSTEM DESIGN BASIS AND OPERATION INFORMATION-As stated in Section 6.8 of the Hope Creek UFSAR, the Filtration, Recirculation and Ventilation System (FRVS) consists of two subsystems that are requir :d to perform post-accident, safety-related functions simultaneously. These subsystems are the recirculation system and the ventilation system. The recirculation subsystem reduces offsite doses significantly below 10CFR100 guidelines during a loss-of-coolant accident (LOCA), refueling accident or high radioactivity in the Reactor Building. The ventilation subsystem maintains the Reactor Building at a negative pressure with respect to the outside environment.
Upon Reactor Building isolation, the recirculation system is actuated and recirculates the Reactor Building air through filters and carbon adsorbers for cleanup. This subsystem is the initial cleanup system before discharge is made via the ventilation system to the outdoors. The ventietion system takes suction from the discharge duct of the recirculation system and discharges the air through filters and carbon adsorbers to the outdoors via a vent at the top of the Reactor Building. The FRVS filters the air in the Reactor Building following postulated high radioactivity accidents to reduce the concentration of radioactive halogens and particulates potentially present in the Reactor Building.
Each charcoal adsorber is assigned a decontamination efficiency of 95 percent removal efficiency for radioactive iodine as elemental iodine (12), and 95 percent removal efficiency for radioactive iodine as methyl iodide (CH3 ) when passing through the charcoal at 70 percent relative humidity and 30*C. Each operating equipment train contains the amount of charcoal required to adsorb the inventory of fission products calculated to be released from the primary containment during a LOCA, with adequate margin to prevent charcoal ignition.
Each permanent single unit (PSU) adsorber is gasketless and all welded stainless steel, filled with charcoal impregnated with potassium iodide and/or triethylenediamine.
Each adsorber in the recirculation system holds a total of approximately 5260 pounds of charcoal that has a minimum ignition temperature of 330*C and each adsorber in the Page 1 of 3
g Docum:nt Control Drk LR-N98022 Att: chm:nt 1 LCR H97-16 ventilation system holds a total of approximately 2160 pounds of charcoal also having a minimum ignition temperature of 330 C. The charcoal adsorber is bulk filled and bulk evacuated at its installed location by supplementary equipment.
There are eight removable test canisters installed in each of the charcoal adsorber housings for sampling. The canisters are mounted so that a parallel flow path is created between each canister and the adsorber. A !aboratory test is performed on the carbon adsorbent initially (before loading), every 18 months thereafter, after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, and, upon evaluation, following painting, fire, or chemical release in any ventilation zone communicating with the system. As required by Hope Creek's Technical Specifications, testing conforms to Regulatory Guide 1.52-1978 using ASTM l
D3803 Method A.
I An electric heater (100 kW for the recirculation system and 32 kW for the ventilation system) is provided for each unit, which maintains the process flow at a relative humidity below 70% for charcoal adsorber efficiency by imparting a temperature rise to the flow. Each heater is controlled by a safety-related humidistat (high moisture switch). The function of the safety-related humidity control instrumentation is to activate the heaters (which will occur when FRVS airflow relative humidity is greater than 55%). This setpoint was established by PSE&G in conjunction with a high humidity alarm (annuciated in the Hope Creek control room at 60% relative humidity) to i
ensure that the process flow through the carbon adsorber units remains below the design basis limit of 70% relative humidity.
The periodic testing of the FRVS recirculation and ventilation sub-systems (required by TS 4.6.5.3.1.b and 4.6.5.3.2.b) is controlled by procedure HC.OP-ST.GU-0001, "FRVS Operability Test - Monthly." This procedure requires that the safety-related humidistats be set at 55% relative humidity during the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> TS required monthly test and during normal standby service. USNRC Regulatory Guide 1.52, " Design, Testing and Maintenance Criteria for Post Accident ESF Atmosphere Cleanup System Air Filtration and Adsorption Units," Revision 2, position C.4.d, states that 10 hcur duration of this test is necessary to reduce the buildup of moisture on the adsorbers and HEPA filters in the FRVS recirculation and ventilation units.
PSE&G has concluded that the humidistat setpoint of 55% relative humidity (during the required surveillance testing and standby conditions) adequately maintains the FRVS carbon adsorber units in a condition which ensures the fulfillment of its safety function to reduce the concentration of radioactive halogens and particulates potentially present during worst case design basis conditions. During standby conditions, the FRVS carbon adsorbers and HEPA filters are enclosed and isolated in a confined space, unaffected by Reactor Building humidity levels. During FRVS normal operations Page 2 of 3
/
Docum:nt Control D:ak LR-N98022 Attichm:nt i LCR H97-16 (including accident operations under conservative design basis conditions of FRVS air intake at 100% relative humidity) the heaters would maintain process airflow below 70% relative humidity required for proper carbon adsorber efficiency removal capability.
For the conservative design condition of 100% intake relative humidity, both the testing method described in USNRC Regulatory Guide 1.52 Position C.4.d and the FRVS testing method utilized at Hope Creek with the heaters modulating are essentially equivalent in the end results since the heaters are energized in both cases. In fact, from the conservative design condition of 100% relative humidity down to 55% relative humidity (the FRVS heater actuation set point), the effect on the adsorber and the HEPA filters is identical. Below 55% relative humidity, energization of the heaters would only further shorten the dehumidification period although the run duration will continue to be 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. In either case, the adsorber and HEPA filters will asymptotically approach (as illustrated in Figure A1.1 of ASTM D 3803-89, " Standard Test Method for Nuclear-Grade Activated Carbon") the percent humidity of the drying air in the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period and both will dry the adsorbers and HEPA filters below the 70% relative humidity level required to meet the FRVS design capability. The laboratory tests performed for activated carbon decontamination efficiency since the monthly surveillance was performed with the heaters modulating (1991) has produced consistent efficiency results greater than 99 4%, while the limits specified by USNRC Regulatory Guide 1.52, position C.6, assigns a decontamination efficiency of 95% for activated carbon, while maintaining 99% for the vent subsystem and 92.5% for the recirculation subsystem tested for a methyl iodide penetration at 30*C and 70% relative humidity.
In summary, PSE&G has concluded that carbon adsorbers and HEPA filters in the recirculation and ventilation systems of FRVS will remain capable of performing their design basis safety functions at anytime during their monthly surveillance interval. This conclusion was based upon: 1) the standby condition of the carbon adsorber units (isolated from the Reactor Building atmosphere); 2) the safety-related heaters and the 55% relative humidity setpoint will ensure that the process airflow remains below the required 70% relative humidity for proper carbon adsorber efficiency removal capability; and 3) over six years of surveillance test data has demonstrated high levels of activated carbon decontamination efficiency with the carbon adsorbers maintained in accordance with the monthly surveillance by Hope Creek procedure HC.OP-ST.GU-0001, "FRVS Operability Test - Monthly."
1 Page 3 of 3
6 Pueic servce Electv and Gas Cor9 par'y E. n. simpson Pubhc Serv ce E'ecmc and Gas Comca"y Po Box 236 Hancocas B' age NJ 08038 609 339M00
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APR 241998 LR-N98022 LCR H97-16 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 SUPPLEMENTAL INFORMATION FOR A CHANGE TO TECHNICAL SPECIFICATIONS FRVS SURVEILLANCE TESTING REQUIREMENTS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Gentlemen:
On August 26,1997, via letter LR-N97523, Public Service Electric & Gas (PSE&G)
Company transmitted License Change Request (LCR) H97-16 to the NRC to request a revision to the Technical Specifications (TS) for the Hope Creek Generating Station. In part, LCR H97-16 requested a revision to wording contained in the Filtration, Recirculation and Ventilation System (FRVS) surveillance requirements. Specifically, Hope Creek proposed changing TS 4.6.5.3.1.b and 4.6.5.3.2.b to state that the FRVS heaters should be " operable" instead of "on" when performing this 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> test.
The additional information contained in Attachment 1 of this letter is being provided to facilitate the review of LCR H97-16. The information contained in this transmittal does not alter any of the conclusions reached in the 10CFR50.92 No Significant Hazards Analysis contained in PSE&G's August 26,1997 submittal.
In accordance with 10CFR50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey. Should you have any questions regarding this request, we will be pleased to discuss them with you.
Sincerely, Affidavit Attachment (1)
I p G =* 4 g o, w
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o Document Control Desk. APR 241998 LR-N98022 C
Mr. H. Miller, Administrator - Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis, Licensing Project Manager - HC (ACTING)
U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Pindale (X24)
USNRC Senior Resident inspector - HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625 I
REF:
LR-N98022 LCR H97-16 STATE OF NEW JERSEY )
) SS.
COUNTY OF SALEM
)
E. C. Simpson, being duly sworn according to law deposes and says:
I am Senior Vice President - Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief.
L 7
(j Subscribed and Sworn to before me this a4 day of C l.
,1998 i
V ML C. b i
Notary P%lic of Nek Jersby i
EUZMIETH J. KIDD My Commission expires on 30[W PU8UC OF NEW JERSEY m
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D$ cum:nt C:;ntrol Dnk LR N98022 Attachment i LCR H97-16 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50 354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS)
SUPPLEMENTAL INFORMATION FILTRATION, VENTILATION AND REClRCULATION SYSTEM DESIGN BASIS AND OPERATION INFORM ATION:
As stated in Section 6.8 of the Hope Creek UFSAR, the Filtration, Recirculation and Ventilation System (FRVS) consists of two subsystems that are required to perform post-accident, safety-related functions sirnultaneou.ly. These subsystems are the recirculation system and the ventilation system. T ie recirculation subsystem reduces offsite doses significantly below 10CFR100 guid slines during a loss-of-coolant accident (LOCA), refueling accident or high radioactivity in the Reactor Building. The ventilation subsystem maintains the Reactor Building at a negative pressure with respect to the outside environment.
Upon Reactor Building isoladon, the recirculation system is actuated and recirculates the Reactor Building air through filters and carbon adsorbers for cleanup. This subsystem is the initial cleanup system before discharge is made via the ventilation system to the outdoors. The ventilation system takes suction from the discharge duct of the recirculation system and discharges the air through filters and carbon adsorbers to the outdoors via a vent at the top of the Reactor Building. The FRVS filters the air in l
l the Reactor Building following postulated high radioactivity accidents to reduce the concentration of radioactive halogens and particulates potentially present in the Reactor Building.
Each charcoal adsorber is assigned a decontamination efficiency of 95 percent removal efficiency for radioactive iodine as elemental iodine (12), and 95 percent removal efficiency for radioactive iodine as methyl iodide (CH31) when passing through the charcoal at 70 percent relative humidity and 30*C. Each operating equipment train contains the amount of charcoal required to adsorb the inventory of fission products calculated to be released from the primary containment during a LOCA, with adequate margin to prevent charcoal ignition.
Each permanent single unit (PSU) adsorber is gasketless and all welded stainless steel, filled with charcoal impregnated with potassium iodide and/or triethylenediamine.
Each adsorber in the recirculation system holds a total of approximately 5260 pounds of charcoal that has a minimum ignition temperature of 330'C and each adsorber in the i
i Page 1 of 3 l
Documsnt Control Duk LR-N98022 l
Att:chmtnt 1 LCR H97-16 ventilation system holds a total of approximately 2160 pounds of charcoal also having a minimum ignition temperature of 330*C. The charcoal adsorber is bulk filled and bulk evacuated at its installed location by supplementary equipment.
There are eight removable test canisters installed in each of the charcoal adsorber housings for sampling. The canisters are mounted so that a parallel flow path is created between each canister and the adsorber. A laboratory test is performed on the I
carbon adsorbent initially (before loading), every 18 months thereafter, after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, and, upon evaluation, following painting, fire, or chemical release in any ventilation zone communicating with the system. As required by Hope Creek's l
Technical Specifications, testing conforms to Regulatory Guide 1.52-1978 using ASTM i
D3803 Method A.
An electric heater (100 kW for the recirculation system and 32 kW for the ventilation system) is provided for each unit, which maintains the process flow at a relative humidity below 70% for charcoal adsorber efficiency by imparting a temperature rise to the flow. Each heate-is controlled by a safety-related humidistat (high moisture switch). The function of the safety-related humidity control instrumentation is to activate the heaters (which will occur when FRVS airflow relative humidity is greater than 55%). This setpoint was established by PSE&G in conjunction with a high humidity alarm (annuciated in the Hope Creek control room at 60% relative humidity) to ensure that the process flow through the carbon adsorber units remains below the design basis limit of 70% relative humidity.
The periodic testing of the FRVS recirculation and ventilation sub-systems (required by TS 4.6.5.3.1.b and 4.6.5.3.2.b) is controlled by procedure HC.OP-ST.GU-0001, "FRVS Op erability Test - Monthly." This procedure requires that the safety-related 1
humidistats be set at 55% relative humidity during the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> TS required monthly test and during normal standby service. USNRC Regulatory Guide 152, " Design, Testing and Maintenance Criteria for Post Accident ESF Atmosphere Cleanup System Air Filtration and Adsorption Units," Revision 2, position C.4.d, states that 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> duration of this test is necessary to reduce the buildup of moisture on the adsorbers and HEPA filters in the FRVS recirculation and ventilation units.
PSE&G has concluded that the humidistat setpoint of 55% relative humidity (during the required surveillance testing and standby conditions) adequately maintains the FRVS carbon adsorber units in a condition which ensures the fulfillment of its safety function to reduce the concentration of radioactive halogens and particulates potentially present l
during worst case design basis conditions. During standby conditions, the FRVS carbon adsorbers and HEPA filters are enclosed and isolated in a confined space, unaffected by Reactor Building humidity levels. During FRVS normal operations Page 2 of 3 1
\\
D6 cum:nt Contrcl Dnk LR-N98022 l
' Attichm:nt i LCR H97-16 i
(including accident operations under conservative design basis conditions of FRVS air intake at 100% relative humidity) the heaters would maintain process airflow below i
70% relative humidity required for proper carbon adsorber efficiency removal capability.
For the conservative design condition of 100% intake relative humidity, both the testing method described in USNRC Regulatory Guide 1.52 Position C.4.d and the FRVS testing method utilized at Hope Creek with the heaters modulating are essentially equivalent in the end results since the heaters are energized in both cases. In fact,
{
from the conservative design condition of 100% relative humidity down to 55% relative humidity (the FRVS heater actuation sei point), the effect on the adsorber and the HEPA filters is identical. Below 55% relative humidity, energization of the heaters i
would only further shorten the dehumidification period although the run duration will continue to be 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. In either case, the adsorber and HEPA filters will asymptotically approach (as illustrated in Figure A1.1 of ASTM D 3803-89, " Standard Test Method for Nuclear-Grade Activated Carbon") the percent humidity of the drying air in the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period and both will dry the adsorbers and HEPA filters below the 70% relative humidity level required to meet the FRVS design capability. The laboratory tests performed f9r activated carbon decontamination efficiency since the monthly surveillance was performed with the heaters modulating (1991) has produced consistent efficiency results greater than 99.4%, while the limits specified by USNRC Regulatory Guide 1.52, position C.6, assigns a decontamination efficiency of 95% for activated carbon, while maintaining 99% for the vent subsystem and 92.5% for the recirculation subsystem tested for a methyl iodide penetration at 30 C and 70% relative humidity.
In summary, PSE&G has concluded that carbon adsorbers and HEPA filters in the recirculation and ventilation systems of FRVS will remain capable of performing their design basis safety functions at anytime during their monthly surveillance interval. This conclusion was based upon: 1) the standby condition of the carbon adsorber units (isolated from the Reactor Building atmosphere); 2) the safety-related heaters and the 55% relative humidity setpoint will ensure that the process airflow remains below the required 70% relative humidity for proper carbon adsorber efficiency removal capability; and 3) over six years of surveillance test data has demonstrated high levels of activated carbon decontamination efficiency with the carbon adsorbers maintained in accordance with the monthly surveillance by Hope Creek procedure HC.OP-ST.GU-0001, "FRVS Operability Test - Monthly."
Page 3 of 3