ML18107A406

Provides Supplemental Info to Proposed License Amend, Modifying TS 3/4 7.7, Auxiliary Bldg Exhaust Air Filtration Sys. Info Re Acceptance Criterion Discussed

ML18107A406
Person / Time
Site:	Salem
Issue date:	06/21/1999
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LR-N990273, TAC-M99875, TAC-M99876, NUDOCS 9907010123
Download: ML18107A406 (8)

Text

Louis F. Storz Public Service Electric and Gas Company Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President

-Nuclear Operations LR-N990273 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

SUPPLEMENTAL INFORMATION FOR REQUEST FOR LICENSE AMENDMENT AUXILIARY BUILDING VENTILATION SALEM GENERA TING STATION UNITS 1.AND 2 JUN21199a*

FACILITY OPERA TING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 By letter dated February 17, 1999, Public Service Electric and Gas Company (PSE&G) provided the Nuclear Regulatory Commission (NRC) with the additional information relative to the PSE&G propos_ed amendment to modify Technical

• Specification 3/4 7.7 "Auxiliary Building Exhaust Air Filtration System." (TAC Nos. M99875 and M99876). During PSE&G's review of the proposed changes relative fo procedural changes, PSE&G noted a discrepancy in the submittal relative to testing requirements.

Specifically, PSE&G agreed to test the charcoal adsorber to a removal efficiency of;;:: 90% of methyl iodine at 30 6 C and 95% R.H. This acceptance criterion is based on ASTM 03803 Revision 1989, for a standard charcoal bed of 2 inches in depth. The Salem station Auxiliary Building Exhaust Air Filtration System charcoal train is a one-inch depth bed. Consequently, an acceptance criterion of;;:: 90% of methyl .1 iodine at 30 °C and 95% R.H is not appropriate.

Subsequently, to this finding, PSE&G notified the Salem NRC Project Manager that a new acceptance criterion had to be determined for the Salem configuration.

PSE&G determined that an acceptance criterion of;;:: 80% for methyl iodine is appropriate for a 1-inch charcoal bed. This acceptance criterion allows for a (\ 0 0 \ reasonable degradation due to use and is consistent with the acceptance criterion

\, of ASTM 03803. The Salem off-site and control room dose calculation was revised using the 80% value for methyl iodine and has been shown to yield acceptable results. @, Printed on Recycled Paper -i

<' Document Control Desk LR-N990273 The TACT5 computer code in the HABIT computer code package was used to determine off-site doses rather than using Stone and Webster Engineering Corporation's proprietary PERC2 computer code. Additionally, the CONHAB computer code in the HABIT computer code package and the MicroShield Version 4.21 computer code were used to determine control room doses rather than using Stone and Webster Engineering Corporation's proprietary PERC2 computer code and the QAD-P5A computer program. The re-analysis incorporates a number of parameter value changes. These are: a) Ninety-one percent of all radioactive iodine released is assumed to be in the form of elemental iodine, 5 percent in the form of particulate iodine, and 4 percent in the form of organic iodides. In our previous analysis, the radioactive iodine released before containment isolation and the radioactive iodine released as a result of Engineering Safety Feature (ESF) leakage outside containment was assumed to be entirely in the form of elemental iodine. This change was made to simplify the analysis and use more appropriate fractions for the ESF leakage contribution.

b) The ESF leakage rate outside containment was assumed to be 7600 cc/hr rather than 7680 cc/hr to be more consistent with design basis documentation and station leakage control procedures.

c) The Auxiliary Building exhaust air filtration system HEPA filter particulate removal efficiency was assumed to be 95 percent to be consistent with the radioactive iodine species assumed. Previously the Auxiliary Building exhaust air filtration system HEPA filters were not credited in the analysis because the radioactive iodine released as a result of ESF leakage outside containment was assumed to be entirely in the form of elemental iodine. d) It was assumed that all ESF leakage outside containment that becomes airborne passes through HEPA filters. e) The Auxiliary Building exhaust air filtration system charcoal bank organic iodide removal efficiency was assumed to be 80 percent after charcoal bank alignment to be consistent with the radioactive iodine species assumed. Previously the Auxiliary Building exhaust air filtration system organic iodide removal was not credited in the analysis because the radioactive iodine released as a result of ESF leakage outside containment was assumed to be entirely in the form of elemental iodine. 95-4933 JUN211999 Document Control Desk LR-N990273 f) The control room envelope was assumed to be fully pressurized within one minute rather than 48 seconds in order to simplify the analysis model. Attachment I contains the revised limiting condition for operation submitted in our February 17, 1999 letter (Ref: LR-N990085).

Additionally, the word "efficiency" is also added following the word "removal" to clarify the sentence, and the word ASTM replaces the word ANSI. PSE&G has reviewed the no safety hazards evaluation submitted in support of our original submittal (LR-N97488), and determined that it remains valid. Should there be any additional questions or comments on this transmittal, please do not hesitate to contact us. Attachment (1) Affidavit Sincerely, C Mr. H.J. Miller, Administrator

-Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager -Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockviile Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris USNRC Senior Resident Inspector (X24) Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933 STATE OF NEW JERSEY) ) SS. COUNTY OF SALEM ) REF: LR-N990273 LCR S95-44 L. F. Storz, being duly sworn according to law deposes and says: I am Senior Vice President

-Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Salem Generating Station, Units 1 and 2, are true to the best of my knowledge, information and belief. Subscribed and Sworn to before me day of lh;..;e,, , 1999 .Nota1yPublic of New Jersey "'** -' . DELORIS 0. HADDEN Notary Public of New Jerlar My Commission Expires . M C . . . 03-29-2000 y omm1ss1on expires on _____________

_ I I !

LR-N990273 ATTACHMENT I SUPPLEMENTAL INFORMATION FOR REQUEST FOR LICENSE AMENDMENT AUXILIARY BUILDING VENTILATION SALEM GENERATING STATION UNITS 1AND2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 The Insert material from Request for License Amendment originally submitted in our February 17, 1999 letter (Ref: N990085) is shown below with currently proposed changes. The proposed changes are shown in Bold for emphasis.

Insert A (LCO UNIT 1) Three Auxiliary Building exhaust air HEPA filter trains, one carbon adsorber bank, two supply fans, and three exhaust fans, shall be OPERABLE L}. Insert 8 (ACTION) a. With one HEPA filter train inoperable, restore the inoperable HEPA filter train to OPERABLE status within 7 days or be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. b. With no HEPA train associated with the one Carbon Adsorber operable, restore at least one associated HEPA train to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in HOT STAND-BY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. c. With the carbon adsorber inoperable, restore the carbon adsorber to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. d. With one supply fan or one exhaust fan inoperable, restore the fan to OPERABLE status within 14 days or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. e. With less than two exhaust fans operable restore one exhaust fan to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. f. With no supply fans operable, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. (*)One of the Supply Fans may be considered OPERABLE with its start circuit administratively controlled (removed from service) to prevent more than one supply -

LR-N990273 ATTACHMENT I SUPPLEMENTAL INFORMATION FOR REQUEST FOR LICENSE AMENDMENT AUXILIARY BUILDING VENTILATION SALEM GENERATING STATION UNITS 1AND2 FACILITY OPERA TING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 fan from operating at any time. (SURVEILLANCE REQUIREMENTS)

Insert C (UNIT 1 TS 4.7.7.1) The Auxiliary Building Exhaust air filtration system shall be demonstrated OPERABLE:

a. At least once each 31 days by aligning to the ECCS flow path and initiating flow for at least 15 minutes (for each train) through: 1. filter train 11 and carbon adsorber train 14, then 2. filter train 12 and carbon adsorber train 14 b. At least once each 18 months, or (1) following painting, fire or chemical release in any ventilation zone communicating with the system, or (2) any partial or complete replacement of the HEPA or carbon filters, by: 1. Verifying that, with the ECCS duct flow path and HEPA train 11 aligned to carbon adsorber train 14 and operating at a flow rate of 21,400 CFM +/-10%, the total bypass flow is less than or equal to 1 % when tested by injecting halogenated hydrocarbon refrigerant.

2. Verifying that, with the ECCS duct flow path and HEPA train 12 aligned to carbon adsorber train 14 and operating at a flow rate of 21,400 CFM +/-10%, the total bypass flow is less than or equal to 1 % when tested by injecting halogenated hydrocarbon refrigerant.

3. Verifying that, in-place leak testing of the carbon adsorber train 14 removes 2::99% of a halogenated hydrocarbon refrigerant test gas when tested at 21,400 CFM +/-10% in accordance with Regulatory Guide 1.52 Rev 2, 1978, Section C.5.d. 4. Verifying that, in-place leak testing of HEPA filter banks in LR-N990273 ATTACHMENT I SUPPLEMENTAL INFORMATION FOR REQUEST FOR LICENSE AMENDMENT AUXILIARY BUILDING VENTILATION SALEM GENERATING STATION UNITS 1AND2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 trains 11, 12, 13 will remove 99% of DOP when tested at their rated design flow capacity +/-10% for each housing in

• accordance with Regulatory Guide 1.52 Rev 2, 1978, Section C.5.c. 5. Verifying within 31 days after removal that laboratory analysis of a representative carbon sample demonstrates a removal efficiency of methyl iodine when tested at 30 degree C and 95% RH in accordance with ASTM 03803 Revision 1989. 6. Verifying that flow rate through the carbon adsorber does not exceed 21,400 CFM +/- 10% when either HEPA+ carbon adsorber combination is aligned to the ECCS areas. 7.a. Verifying the total pressure drop across HEPA train 11 and carbon adsorber train 14 is Water Gauge when tested at 21,400 CFM +/-10%. 7.b. Verifying the total pressure drop across HEPA train 12 and carbon adsorber train 14 is Water Gauge when tested at 21,400 CFM +/-10%. .

' ' LR-N990273 ATTACHMENT I SUPPLEMENTAL INFORMATION FOR REQUEST FOR LICENSE AMENDMENT AUXILIARY BUILDING VENTILATION SALEM GENERATING STATION UNITS 1AND2 FACILITY OPERA TING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Insert D (UNIT 1 4.7.7.1) c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation verify that within 31 days after removal that laboratory analysis of a representative carbon sample demonstrates a removal efficiency of methyl iodine when tested at 30 degree C and 95 % RITTn accordance with ASTM 03803 Revision 1989. d. After maintenance affecting the flow distribution, verify that the airflow distribution of the system is acceptable when tested in accordance with Regulatory Guide 1.52, Revision 2, 1978 Section C.5.b. e. After any structural maintenance on the HEPA or carbon adsorber unit mounting frames or housing, perform tests as required by surveillance 4.7.7.1.b.1 through 4.7.7.1.b.4.

f. After operation of Auxiliary Building normal flow path through the carbon adsorber, prior to mode 4 entry, verify the carbon adsorber will remove of a halogenated hydrocarbon refrigerant test gas when in-place leak tested at a flow rate of 21,400 CFM +/-10%. g. After operation of containment purge exhaust flow path through the carbon adsorber, prior to mode 4 entry, verify the carbon adsorbers will remove of a halogenated hydrocarbon refrigerant test gas when in-place leak tested at a flow rate of 21,400 CFM +/-10%. The same changes described above are applicable to the Salem 2 Technical Specifications.

Insert J ( UNIT 1 & 2 BASES) No changes are required from the original insert.