ML20217Q664

Application for Amend to License NPF-57,requesting Rev to TS to Clarify Plant Basis for Compliance W/Frvs TS Requirements

ML20217Q664
Person / Time
Site:	Hope Creek
Issue date:	08/26/1997
From:	Eric Simpson Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217Q667	List: ML20217Q664 ML20217Q673
References
LCR-H97-16, LR-N97523, NUDOCS 9709030305
Download: ML20217Q664 (11)

Text

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E. C. Simpoon P 009 339-1700 PutAc Servke Doctr6c and Gas Orgyg g g 230, Hancocks Drktge. NJ 00038

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LR' ?'9752 3 LCR H97-16 United States Nuclear-Regulatory Commission Document Control Desk-Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS-FRV8 SURVEILLANCE TESTING REQUIREMENTS HOPE CREEK LENERA11HG STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Gentlemen:

on March 31, 1947, via letter LR-N97158, Public Service Electric

& Gas (PSE60) Company transmitted License Change Request (LCR)

H97-Il to the NRC to request a revision to the Technical Specifications (TS) for the Hope Creek Generating Station. In part, LCR H97-11 requested a revision to wording contained in the Filtration, Recirculation and Ventilation System (FRVS) surveillance requirements. Specifically, Hope Creek. proposed changing TS 4.6.5.3.2.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.

Juatification for this TS requirement clarification relied upon the proposed change's consistency with requirements contained in USNRC Regulatory Guide 1.52, " Design < esting and Maintenance Criteria for Post Accident ESF Atmosphere Cleanup System Air Filtration and Adsorption Units," Revision 2.

'On July 9, 1997, the NRC issued Hope Creek TS-Amendment No. 99.

In the safety evaluation for that TS amendment, the NRC stated that the proposed surveillance changes contained in LCR H97-11 would not be approved since compliance with Regulatory Guide 1.52 requires that these heaters be continuously energized during the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance. As described in Hope Creek LER 97-016-00, all of the FRVS recirculation units were subsequently declared inoperable until-required revisions to-the Hope Creek UFSAR were Leompleted to justify exceptions to USNRC Regulatory Guide 1.52 requirements concerning heater operation for this surveillance

-test.

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In accordance with 10CFR50.90, PSE&G hereby requests a revision O to the TS to clarify Hope Creek's basis for compliance with these FRVS TS requirements. Justification for these proposed changes relies, in part, on the 10CFR50.59 safety evaluation performed for the-aforementioned UFSAR changes._ In accordance with g 9709030305 970826 I PM ADOCK 05 W 354 w ,._

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10CFR50. 91 (b) (1 ) , a copy of this submittal has been sent tc the State of New Jersey.

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l The proposed changes affect the following sections of the Hope  !

Creek TS: 1) Surveillance Requirement 4.6.5.3.1.b; 2)  !

Surveillance Requirement 4.6.5.3.2.b; and 3) the related TS  !

Bases. The proposed changes have been evaluated in accordance with 10CFR50. 91 (a) (1), using the criteria in 10CFR50.92(c), and a determination has been made that this request involves no significant hazards considerations.

The basis for the regaested change is provided in Attachment 1 to this letter. A 10CFR50.92 evaluation, with a determination of no significant hazards consideration, is provided in Attachment 2.

The marked up Technical Specification pages affected by the proposed changes are provided in Attachment 3.

Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities.

Should you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely, b M Affidavit Attachments (3) 95 4933

Dot itent Control Desk gyg gg jgg7 LR .197523 C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Jaffe, Licensing Project Manager - HC U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20052 Mr. S. Morris (X24)

USNRC Senior Resident Inspector - HC Mr. K. Tosch, Manager IV Dureau of Nuclear Engineering 33 Arctic Parkway i CN 415 Trenton, NJ 08625 l

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RWIIWeF til REFT LR-N97523 LCR H97-16 STATE-OF NEW JERSEY )

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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 rnd belief.

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Subscribed and Sworn-to before me this _Q (, day of Q _, 1997 v

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Notary P lic of kew J1rsey EUZABETH J. KIDD NOTARY PUBUC OF NEW JERSEY My Commission expires on- N "' "

I D:oument Centrol Dock' LR-N97523 AttOchment 1 LCR H97-16 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57

- DOCKET NO. 50-354 L REVISIDHS T' THE TECHNICAL SPECIFICATIONS (TS)

BASIS FOR REQUESTED CHANGE:

The changes proposed =in-this request clarify the-surveillance test requirements .for the Filtration, Recirculation and Ventilation-System ~(FRVS), and are being.made to provide a more clearly defined licensing basis for Hope Creek. ,Specifically, the proposed changes to the FRVS TS and associated TS Bases would more accurately reflect the manner in which the FRVS

--surveillances are performed at Hope Creek, REQUESTED CHANGE AND PURPOSEt-Currently, Surveillance Requirements 4.6.5.3.1.b and 4.6.5.3.2.b specify testing of the FRVS ventilation and recirculation units with their heaters "on" in order to reduce buildup'of moisture on the unit's carbon adsorbers and HEPA filters. As lndicated in Attachment 3 of this letter, these surveillance requirements are being revised to more precisely state that the FRVS ventilation and recirculation unit heaters must be " operating" during the 10

- hour test.- The-purpose of this change is to provide accurate-andL clearly defined criteria-for performing this surveillance-requirement within-the Hope Creek TS that_are consistent Hope Creek's = commitments to USNRC Regulatory Guide 1.52, " Design, Testing and Maintenance Criteria for Post Accident ESF Atmosphere Cleanup System Air Filtration and Adsorption Units," Revision 2.

BACKGROUND

- As stated in Section 6.8.1 of,the Hope Creek UFSAR, FRVS consists of two subsystems that are required to perform post-accident,-

safety-related: functions simultaneously. These subsystems are:

1)- the recirculation = system,-which reduces offsite doses significantly below 10CFR100 guidelines during a loss-of-coolant accident (LOCA), refueling accident, or occurrences of high

-radioactivity in the Reactor Building; and 2) the ventilation-system, which maintains the Reactor Building at a negative pressure with' respect to.the outdoors- The configuration of

=these subsystems is shown in UFSAR Figures' 9.4-4 and- 9.4-5. Upon

- Reuctor Building isolation,. the FRVS recirculation system is actuated and-recirculates:the Reactor Building air through

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Document Control Dock LR-N97523 AttOchment 1 LCR H97-16 filters for cleanup. This subsystem is the initial cleanup system before discharge is made via the FRVS ventilation subsystem, which discharges the air through filters to the outdoors via a vent at the top of the Reactor Building.

Each FRVS recirculation unit filter train is sized and specified for treating incoming air at 30,000 cfm at 140*F. The HEPA filter bank is considered to warrant a 99 percent removal efficiency for particulates in the accident dose evaluation when the filter bank is tested and meets the cr'.veria of Section C.S.c of Regulatory Guide 1.52-1978 using Section 10 of ANSI N510-1980.

Each charcoal adsorber is assigned a decontamination efficiency of 95 percent removal efficiency for radioactive iodine as elemental lodine (12), and 95 percent removal efficiency for radioactive iodine as methyl lodide (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.

The FRVS recirculation system consists of six 25 percent capacity recirculation fans and filter trains connected in parallel with the Reactor Building ventilation system. All six FRVS recirculation units include electric heating coils, high efficiency particulate air (HEPA) filters, charcoal filters, HEPA afterfilters, and water cooling coils. The FRVS ventilation system consists of two 100 percent capacity centrifugal fans and filter trains. Each FRVS ventilation unit takes the discharge from the FRVS recirculation system and processes the air through an electric heating coil, charcoal filter, and HEPA filter. Each charcoal adsorber is filled with charcoal impregnated with potassium iodide and/or triethylenediamine.

An electric heater in the FRVS ventilation units maintains the process flow at a relative humidity below 70 percent to maintain charcoal adsorber efficiency by imparting a temperature rise to >

the flow. An analysis of heater capabilities for various entering saturated air conditions up to 107*F yields a peak heating requirement of 109,000 Btu /h at the maximum 9000 cfm airflow. A 32-kilowatt heater is provided for each unit and controlled by a high moisture switch.

An electric heater in the FRVS recirculation units maintains the process flow at a relative humidity below 70 percent for charcoal adsorber efficiency by imparting a temperature rise to the flow.

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l'E Document Ccntrol D:sk LR-N97523 Attochment 1 LCR H97-16

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An analysis of heater capabilities for various entering saturated air conditions up to 140'F yields a peak heating requirement of 342,000 Btu /h, at 30.000 cfm airflow. A 100-kilowatt heater is provided for each filter unit and controlled by a humidistat.

On July 17, 1997, Hope Creek performed a 10CFR50.59 safety evaluation (H97-044) for a UFSAR change (H97-038) to Hope Creek's commitment to USNRC Regulatory Guide 1.52 requirements.

Specifically, this UFSAR change took exception to the USNRC Regulatory Guide 1.52 requirement to have the FRVS heater units energized and dissipating heat during thin 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance test and justified a test method where the heaters would modulate (i.e., " operable" or " operating") to reduce the buildup of moisture on the carbon adsorbers and HEPA filters. This 10CFR50.59 safety evaluation updated Hope Creek's licensing basis (by revising the UFSAR commitments to USNRC Regulatory Guide 1.52 and superseding Hope Creek's letter (NLR-N86066) dated, June 13, 1986, concerning FRVS testing methods) to support the testing nethod currently utilized for the FRVS recirculation and ventilation units.

PSE(.G has concluded that a TS change should be processed to preclude any further questions concerning the basis for performing this surveillance test. Approval of the proposed changes contained in this submittal, based upon the justification provided in the following section, would clearly define the licensing basis for satisfying this surveillance requirement consistent with Hope Creek's current UFSAR commitments to USNRC Regulatory Guide 1.52.

JUSTIFICATION OF REQUESTED CHANGES:

The following justification for the proposed TS changes was derived, in part, from the 10CFR50.59 safety evaluation performed for the UFSAR changes in commitment to USNRC Regulatory Guide 1.52 requirements. The propUsed changes result in FRVS surveillance requirements that clearly states that the FRVS heaters must be operating (modulating on and off as required to reduce the buildup c' moisture on the carbon adsorbers and HEPA filters) when the monthly surveillances required by TS 4.6.5.3.1.b and 4.6.5.3.2.b are conducted.

In evaluating USNRC Regulatory Guide 1.52, position C.4.d, which states that, "Each ESF atmosphere cleanup train should be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the heaters on (if so equipped), in order to reduce the buildup of moisture on the Page 3 of 5

Document Centrol Dock LR-N97523 Att chment 1 LCR H97-16 adsorbers and HEPA filters," PSE&G has concluded that the intent of this requirement is to reduce the buildup of moisture on the absorber and HEPA filters so that they will perform their function 4.f called upon. In the unlikely event that the adsorber and HEPA filters, that are enclosed and isoleted in a confined space should reach an equilibrium at the maximum design operating humidity level, the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> run with heaters energized would reduce the humidity to acceptable levels. The duration of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> required by the Regulatory Guide 1.52 is provided to assure that sufficient time is allowed to permit drying of the absorbers and HEPA filters at the maximum design relative humidity (100%)

of the intake air.

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 identical 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. Since the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> running duration is sufficient to remove any adsorbed moisture from the adsorber and HEPA filters, any lower humidity intake air would only reach this desired state sooner.

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 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.

Operation of the FRVS recirculation and ventilation system heaters during the monthly 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> maintenance surveillance test, energized with the instrumentation controls in automatic modulation to maintain the relative humidity within the design requirenents, has been shown (in/ approximately six years of charcoal surveillance and analyses required by TS 4.6.5.3.1.c and 4.6.5.3.2.c) to meet the intent of the USNRC Regulatory Guide 1.52, position C.4.d, in reducing adsorber and HEPA filter moisture levels. 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, Page 4 of 5

Document Control Desk LR-N97523 Attachmont 1 LCR H97-16 require only a 95't efficiency for the FRVS ventilation and recirculation units.

Based upon the above, PSE6G believes that: 1) the exception taken by Hope Creek to USNRC Regulatory Guide 1.52, position C.4.d, does not change the post accident performance characteristics of the FRVS adsorbers or HEPA filters below the design requirements; and 2) the TS changes proposed in this submittal are justified.

CONCLUSIONSt The changes proposed in this request are being made to resolve compliance related issues involving Hope Creek's licensing basis.

PSE&G concludes that these proposed changes are adequately justified and result in No Significant Hazards Considerations as described in Attachment 2 of this letter.

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D3cument C ntrol D0ck LR-N97523 Att chment 2 LCR H97-16

= HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS) 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Hope Creek Generating Station Technical Specifications do not involve a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below.

REQUESTED CRANGE The proposed changes affect the following sections of the Hope Creek TS: 1) Surveillance Requirement 4.6.5.3.1.b; 2)

Surveillance Requirement 4.6.5.3.2.b; and 3) associated Bases 3/4.6.5 Specifically, these changes are_being made to clarify the manner-in which Filtration, Recirculation and Ventilation System (FRVS) recirculation unit and ventilation unit testing is performed.

BASIS

1. The proposed changes do not involve a significant increase in the probability or consequences _ of an accident previously-evaluated.

The proposed TS revisions involve no hardware changes and no changes to existing structures, systems or components.

Conducting TS Surveillance Requirements 4.6.5.3.1.b and A.6.5.3.2.b with the FRVS recirculation unit and ventilation unit heaters in automatic modulation to maintain the relative humidity within the design requirements, meets the intent of the USNRC Regulatory Guide 1.52, position C.4.d, in reducing adsorber and HEPA filter moisture levels. In the unlikely event that the adsorber and.HEPA filters, that are enclosed and isolated in-a confined space should reach an equilibrium.at the maximum design operating humidity-level,-the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> run with heaters energized-would reduce the humidity to acceptable levels.~ Therefore, the proposed changes do not change the post-accident. performance characteristics aof .the FRVS adsorber or- HEPA filters below the-design. requirements and does not increase the consequences of accidents previously identified. Since there are no changes to the-operation of FRVS in. normal.or post-accident operating Page'1-of 2

l Document C:ntrol D:sk LR-N97523 l* Attachment 2 LCR H97-16 I

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conditions, there is no increase in the probability of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of accident fron, any accident previously eval ua t ed.

The proposed changes contained in this submittal will not adversely impact the operation of any safety related component or equipment. PSE&G has concluded that method of performing the monthly FRVS recirculation unit and ventilation unit surveillances with the heaters modulating adequately maintains and demonstrates operability of FRVS. Since the proposed changes involve: 1) no hardware changes; 2) no changes to FRVS operation in normal operating or post-accident conditions; and 3) no changes to existing structures, systems or components, there can be no impact on the potential occurrence of any accident.

Furthermore, there is no change in plant testing proposed in this change request which could initiate an event. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety.

The revisions to TS Surveillance Requirements 4.6.5.3.1.b and 4.6.b.3.2.b provide a more accurately defined basis for performing this surveillance test. The proposed changes reflect PSE&G's position on satisfying USNRC Regulatory Guide 1.52, position C.4.d. Since PSE&G has concluded that performing TS Surveillance Requirements 4.6.5.3.1.b and 4.6.5.3.2.b with the FRVS recirculation unit and ventilation unit heaters in automatic moduation to maintain the relative humidity within the design requirements, adequately reduces adsorber and HEPA filter moisture levels, the proposed changes do not significantly reduce a mergin of safety in FRVS, Since the FRVS recirculation units and ventilation units will continue to be tested with the heaters: 1) operable; and 2) set at the demand necessary to

" reduce the buildup of moisture," PSE&G believes that the proposed changes to clarify the TS are justified.

CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

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