ML20245B469
| ML20245B469 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/17/1989 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20245B470 | List: |
| References | |
| NLR-N89078, NUDOCS 8904260121 | |
| Download: ML20245B469 (9) | |
Text
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e Public Service l,
Electric and Gas l
Company St;ven E. Mittenberger Public Service Electric and Gas Company P.O. Box 236. Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Cruef Nucis Offcer April 17, 1989 NLR-N89078
Reference:
LCR 87-17 U.S.
Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 Gentlemen:
SUPPLEMENTAL REQUEST FOR AMENDMENT FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 In a letter dated November 25, 1987, Public Service Electric and Gas Company (PSE&G) requested an amendment to Facility Operating License No. NPF-57, Technical Specifications Sections 3/4.6.5.3,
" Filtration, Recirculation and Ventilation System" (FRVS) and 3/4.7.2, " Control Room Emergency Filtration System" (CREFS).
In a subsequent telephone discussion with NRC staff reviewers, a minor revision to the wording of our proposed insert to the specifications was suggested by NRC.
We have made the suggested modification to our request and additionally, made a small, non-technical clarification of the wording regarding the FRVS Recirculation portion of the system...as marginally highlighted in the marked-up TS pages in Attachment 3.
Finally, the reviewers requested that PSE&G provide an argument jg3' describing why our proposed amendment to the Hope Creek Nnz Generating Station FRVS Technical Specifications (TS) should be Go' reviewed as a plant specific rather than as a generic issue.
This discussion, as well as our rationale for any decision on mo whether or not to obtain and analyze charcoal samples based on wg the evaluation provision proposed in our amendment request, are 38 provided in Attachments 1 and 2, respectively.
oo Since the modifications shown in Attachment 3 do not involve any gg further technical issues, adding only clarification to our
&c previous request, the supporting information and analyses for the change, and the basis for a no significant hazards consideration determination previously provided remain applicable.
PSE&G, therefore, believes that this proposed addition to our previously submitted amendment request does not add any new consideration 1
that should require additional review or public notice.
00\\
Document Control Desk
-2~
April 17, 1989 NLR-N89078 Pursuant: to 10CFR50. 4 (b) (2) (ii), this submittal includes one (1) signed original and thirty-seven (37) copies and, in accordance i
with 10CFR50.91(b) (1), PSE&G has provided a copy to'the State of New Jersey.
Should you'have any questions regarding this request, weLwill be pleased to discuss them.with you.
Sincerely, W
G l
Attachments C
Mr. W. T.
Russell, Administrator USNRC Region I Mr. C. Y.
Shiraki-USNRC Licensing Project Manager Mr. G. W. Meyer USNRC Senior Resident Inspector Mr.
K. Tosch, Chief, Bureau of Nuclear Engineering New Jersey Department of Environmental Protection c____________
NLR-N89078 ATTACHMENT 1 JUSTIFICATION FOR PLANT-SPECIFIC REVIEW As described in our November 25, 1987 Amendment Request, the Hope Creek Generating Station (HCGS) Reactor Building engineered safety feature ventilation syctem, the Filtration, Recirculation and Ventilation System (FRVS), consists of six (6) recirculation units and two ventilation ~ units.
On an ESF actuation of the FRVS, all six recirculation units and both ventilation units are available to start.
However, normal operation of the system has only four of the six recirculation units and one of the ventilation units in service.
Each recirculation and ventilation unit contains carbon adsorbent for filtering methyl iodide.
The recirculation system has two functions: 1) normal building cleanup, and 2) act as a " guard" filtration system to the FRVS ventilation system.
Operating flows are 30,000 cfm per recirculation unit (as discussed above, a normal total flow of 120,000 cfm) and 9,000 cfm per vent unit.
For a typical 1150 MWe reactor plant, per page 63 of the Nuclear Air Cleaning Handbook (ERDA 76-21), 3795 lbs of carbon adsorbent are required to provide adequate protection against desorption and ignition under accident conditions.
Each of our FRVS recirculation units has 5200 lbs of carbon adsorbent...or 110% of that amount required for a 1150 MWe reactor.
Therefore, just the recirculation portion of the FRVS system design at HCGS contains 660%, and in normal operation, 440% of the required volumetric capacity required for iodine removal.
The FRVS recirculation units, then, provide a significant level of " guard-bed" protection for the adsorbent in the ventilation portion of the system.
The recirculation units, even at the efficiency of 80%
proposed in our amendment request, coupled with a vent unit i
efficiency of 95% still yield an overall system efficiency of J
99%.
i Other than the Limerick Generating Station which has a similar, j
but considerably smaller-scaled ventilation scheme, we believe HCGS to be unique with regard to system design.
Based on the above information and the unique nature of our reactor building I
ventilation operation, PSE&G feels that our requested amendment is not generically applicable and can be reviewed as plant I
specific.
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s ATTACHMENT 2
,g-GUIDELINES FOR DETERMINATION OF FRVS DEGRADATION The.following outline is'being provided to support the FRVS Technical Specification change LCR 87-17 in reference to. Tech Spec 3/4.6.5.3.
Background:
Presently, a list of sample chemicals / solvents is being assembled in order to prioritiz'e the substances most commonly used in the Reactor Bldg.
From this list,' samples will be sent-to.NUCON for analysis of carbon degradation with, respect to the type of carbon adsorbent installed in the FRVS.
system at Hope Creek Nuclear Generating Station. No' samples i
have been analyzed to date. Particular emphasis will be placed on the evaporation rate of these samples, effects of %
weight by volume, and dissipation or cure times.
Plans are also being formulated to analyze welding smoke generated by the particular types-of weld rod used at Hope Creek.
OUTLINE The following determinations are to be followed prior to use of any chemicals / solvents in the Reactor Bldg.
- 1. The cognizant department to be contacted prior to entering the Reactor' Bldg with any chemical / solvent.
- 2. The cognizant department will evaluate the chemical / solvent for its effects on the FRVS carbon adsorbent.
a) Has the chemical / solvent been analyzed by NUCON ?
1.
If yes, then
}
a) What is the maximum quantity allowed in the l
Reactor Bldg at any one time.(based on NUCON test results) b) What precautions should be taken in the event of a FRVS initiation during usage.
2.
If no, then tenting and temporary filtration is required.
- 3. The cognizant department will track all chemicals / solvents taken into the Reactor Building and its usage. The log will contain specific location (s) of use.
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- 4. The responsible supervisor or his/her designee will report to the cognizant department the amount of the chemical / solvent used.
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..y NOTE If'there is a FRVS initiation while usinq or shortly after appli,ation, of a chemical / solvent in the Reactor Buildinc.
- 5. The cognizant department will determine the amount and type of chemicals / solvents in the Reactor Building, a) Determine by NUCON testing results the expected percentage of degradation, if any, as a result of the communication of the carbon-adsorber with the release.
Air flow, room size, and time will be calculated into this analysis. Both_the Recirc system and Vent units must be analyzed separately.
b) Record the calculated values for comparison with the next 18 month carbon sample results-required by Tech Spec 3/4.6.5.3.
The following'is a hypothetical example of a typical analysis the cognizant department would make if the FRVS had communicated with a known chemical / solvent tested by NUCON.
Scenario: 50 gallons'of epoxy paint were applied in the Reactor Building when the PRVS started. 4 out of_6 Recirc units and 1 vent unit were in operation for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The epoxy paint was analyzed by NUCON to have 2% volatiles with a evaporation rate per the graph below. The Recirc and vent unit carbon was tested as 99.9% efficient previously.
i VEAWILATEb AWh l
1 n
. _. %, _ m 1
j
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- a *.
1 i
o M %(wd i d
80 b
j FRVS Recirc units The paint had fully cured during a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period.
Assume that 100% of the volatiles had entered the FRVS system (a conservative approach since only the shaded area under the curve communicates with the FRVS system 1 2
L.
'h.
Based on'the above conditions'-
50 gals of. epoxy paint @ 10.7;1bs/ gal = 535:1bs paint L
.02.xf535 = 10.7 lbs of' volatiles l
Based on the fact that the 4 Recirc units are 99.9% efficient, then
-10.7 lbs.of volatiles / 22080 lbs of carbon =.00048 Through NUCON test results'for this particular epoxy paint tested with the carbon adsorbent used at Hope Creek,.it has been shown that a 5% volatile weight per carbon adsorbent weight will degrade the carbon to 95% efficiency.
The 50. gallons of epoxy paint represents a.05%
weight / weight ratio.
A degradation of 1.5% based on NUCON testing result for this substance.
Therefore it can be analyzed that-the efficiency of the 4 FRVS Recirc units have-degraded to 98.4%
efficiency, well above our Tech Spec limit of 80%.
This new efficiency (98.4%) will be the value used for-the next analysis, if one is needed before the next 18 month carbon adsorbent sample test. Again, this new.
number is conservative since only 4 of 6 units were operating.
FRVS Vent units Taking the new revised efficiency for the recirc units.
'(conservative in approach) then 1.5% of the Reactor Building air would pass unfiltered through the Recirc units.
Of this 1.6% unfiltered air, 7.5% would communicate with the vent units.(based on 4 x 30000 cfm flow / Recirc unit and 9000 cfm / vent unit)
.016 x.075 =.0012 =.12% weight of volatiles
.01284 lbs of volatiles
.0012 x 10.7
=
If there is 2160 lbs of carbon in the vent unit, then
.01284 / 2160 =.00000594 Per NUCON test results, 5% volatiles weight per adsorbent weight will degrade the carbon to 95%
efficiency.
The above results in a.000594% weight / weight ratio A degradation of.05% based on NUCON testing results for this substance.
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l Therefore it can be analyzed that the efficiency of I
the FRVS Vent unit has degraded to 99.85% efficiency, I
well above our Tech Spec limit of 95%.
This new efficiency (99.85%) will be the value used for the next analysis, if one is needed before the next 18 month carbon adsorbent sample test. Again, this new number is conservative since only 1 of the 2 units were operating.
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ATTACHMENT 3 INSERTS AND MARKED-UP PAGES
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I The inserts on.the following'page'are modified.from our i
original submittal:asLidentified by~ marginal markings:
)
-i Changes-that were suggested by NRC. reviewers are
- )
identified by a single bar.
An additional ~ change, identified by' double marginal i
bars, will! clarify TS 3.6.5.3.2, ACTION b.,
This i
specification presently requires that "With three FRVS' J
recirculation units inoperable...ete".
This wording l
is confusing with regard to whether it means three of the total of six FRVS units (which is what was meant) or three of the above required five units'(which is less conservative than the first interpretation).
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Stating this_ requirement -.in the sameLway as ACTION a, will eliminate any confusion.
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a e