ML17300A417

Application for Amend to License NPF-41,changing Tech Specs to Lower Testing Requirements for HEPA Filter & Charcoal Adsorber Units in ESF Atmospheric Cleanup Sys to Allow Removal Efficiency of 99.0%.Fee Paid

ML17300A417
Person / Time
Site:	Palo Verde
Issue date:	08/21/1986
From:	Haynes J ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Knighton G Office of Nuclear Reactor Regulation
Shared Package
ML17300A418	List: ML17300A417 ML17300A421
References
ANPP-37825-JGH, GL-83-13, TAC-64071, TAC-64072, NUDOCS 8609030218
Download: ML17300A417 (12)

Text

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• CCESBION NBR: 8609030218 DOC. DATE: 86/08/21 NOTARIZED: NO DOCKET I FAClL: STN-50-528 Palo Verde Nuclear Stations Unit ii Arizona Publi 05000528 AUTH.- NANE AUTHOR AFFILIATION HAYNES'. Q. Ari zona Nuclear Pouer ProJect ( f ormerl9 Ari zona Public Serv REC IP. NANE RECIPIENT AFFILIATION NNIQHTON, G. N. PNR Prospect Directorate 7

SUBJECT:

Application for amend to License NPF-411 changing Tech Specs to lover testing requirements for HEPA filter 8c charcoal adsorber units in ESF atmospheric cleanup sos to al lou removal efficiency of 99. 0/.'. Fee Paid.

DISTRIBUTION CODE: AOOID COPIEB RECEIVED: LTR i ENCL( SIZE:

TITLE: OR Submittal: General Distribution NOTES: Standardized plant. N. Davis> NRR: iCg. 05000528 RECIPIENT COP I EB RECIPIENT COPIES ID CODE/NANE LTTR ENCL ID CODE/MANE LTTR ENCL PNR-8 EB 1 P WR-8 PE I CSB 2 2 PNR-8 FOB 1 1 PNR-8 PD7 L* 0 PNR-8 PD7 PD 01 5 5 LICITRAiE 1 PNR-8 PEICBB 1 PNR-8 RBB 1 1 INTERNAL: ACRB 09 6 6 ADN/LFNB 1 0 S3 0 NRR/OR*8 1 0 REQ Fl 04 RQN5 1.

EXTERNAL: EG8cQ BRUBNEi B 1 1 LPDR 03 1 1 NRC PDR 02 1 NSIC 05 1 NOTES:

TOTAL NUBBER OF COPIES REQUIRED: LTTR 29 ENCL 25

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Arizona Nuclear Power Project P.o. BOX S2034 4 PHOENIX, ARIZONA85072-2034 August 21, 1986 ANPP-37825-JGH/JRP/98.05'irector of Nuclear Reactor Regulation Attention: Mr. George W. Knighton, Project Director PWR Project Directorate 117 Division of Pressurized Water Reactor Licensing B U S

~ ~ Nuclear Regulatory Commission Washington' ~ C 20555

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Subject:

Palo. Verde Nuclear Generating Station (PVNGS)

Unit 1 Docket No. STN 50-528 (License NPF-41)

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Request for Technical Specification Change File: 86-F-005-419 F 05

Dear Mrs Knighton:

Attached please find an amendment proposal for a change to PVNGS Unit 1 Technical Specification Surveillance Requirements 4.6.4.3.f, 4.7.7.f, 4.7.8.f, and 4.9.12.f that is in accordance with the guidance provided by Generic Letter 83-13. Generic Letter 83-13 clarified the testing requirements for HEPA filter and charcoal adsorber units in ESF atmospheric cleanup systems as specified in the Standard Technical Specifications. If approved, this amendment will allow a removal effi-ciency of 99.0X for charcoal adsorbers.

The changes presented herewith were previously discussed with and agreed to by your staff during the PVNGS Unit 2 Technical Specification review process and have been incorporated into the PVNGS Unit 2 license.

An evaluation of this amendment proposal has determined that these changes would not involve a significant hazards consideration in accordance with 10 CFR 50.92.

Enclosed within this package are the following:

AD Description of Proposed Amendment.

B Justification for Proposed Amendment.

CD Basis for No Significant Hazards Determination.

D. Environmental Impact Consideration Determination.

ED Marked up Technical Specification change pages; By copy of this letter, we are notifying the Arizona Radiation Regulatory Agency of this request for a Technical Specification change.

~oo Sb090302 1 8 Sb082 1 ADOLF, 05000528 I

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Mr. George W. Knighton Request for Technical Specification Change ANPP 37825 Page 2 In accordance with 10 CFR 170.12(c), the license amendment application fee of

$ 150.00 is also enclosed.

Very truly yours, o/@by~

J. G. Haynes Vice President Nuclear Production JGH/JRP/rw Attachment cc: 0. M. De Michele E. E. Van Brunt, Jr.

E. A. Licitra R. P. Zimmerman A. C. Gehr C. F. Tedford, ARRA Director

i' A.

tDescri tion of Pro osed Amendment t

Within the PVNGS Unit 1 Technical Specifications are Section 4.6.4.3, 4.7.7, 4.7.8, and 4.9.12 which address the surveillance requirements for the containment hydrogen purge system, the control room essential filtration system, the ESF pump room air exhaust cleanup system, and the fuel building essential ventilation system, respectively. Subsections 4.6.4.3.f, 4.7.7.f, 4.7.8.f and 4.9.12.f delineate what constitutes a "demonstration of operability" for charcoal adsorbers within these filtration systems. Each of these requirements currently specify a charcoal adsorber removal efficiency "greater than or equal to 99.95X of a halogenated hydrocarbon refrigerant test gas when they are tested in place". This proposed amendment will change the 99.95K removal efficiency to 99.0X or conversely will allow charcoal adsorber bypass leakage of 1/.

\

B. Justification of Pro osed Amendment On March 2, 1983, the Nuclear Regulatory Commission issued Generic Letter No.

83-13, Clarification of Surveillance Requirements For HEPA Filters and Charcoal Adsorber Units In Standard Technical Specifications On ESF Cleanup Systems. The generic letter was issued to clarify HEPA filter and charcoal adsorber testing requirements as specified in Regulatory Guide 1.52, Rev. 2, and ANSI N510-1975 because the current revision of the Standard Technical Specifications (STS) did not clearly reflect the guidance provided in these documents.

As a result of Generic Letter No. 83-13, corrective changes were incorporated in a revision to the STS. PVNGS Unit 2 Technical Specifications were modified

-to reflect this correction before issuance. The PVNGS Unit 1 Technical Specifica-tions, which were drafted prior to the STS revision, require a change to incor-porate this guidance and to maintain consistency in Technical Specifications be-tween PVNGS Unit 1 and PVNGS Unit 2. The PVNGS Unit 1 Surveillance Requirements for testing of Charcoal Adsorbers currently requires a 99.95X removal efficiency.

This Technical Specification amendment proposes a removal efficiency of 99.0X for charcoal adsorbers which is consistent with the allowable ESF filtration system efficency of 95%%u for radioiodine as assigned in NUREG-0857 (PVNGS Safety Evalua-tion Report).

C. Basis for No Si nificant Hazards Determination The Commission has provided certain examples (48FR14864) of action likely to in-volve no significant hazards consideration. This proposed amendment matches the example of a change that "may reduce in some way a safety margin, but where the results of the change are clearly within all acceptable criteria with respect to the system". Operation of PVNGS Unit 1 in accordance with this amendment would not:

(1) Increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as evaluated in the FSAR because the ESF filtration system efficiency, as evaluated in Sec-tion 15B of the PVNGS FSAR, is not changed.

g r Page 2.

(2) Create the possibility for a accident or malfunction of a different type than previously evaluated in the FSAR because the assigned effi-ciency of ESF filter units remains at 95% as evaluated in PVNGS FSAR Chapter 6/Chapter 15 .accident analyses.

(3) Reduce the margin of safety as defined in the basis for any Technical Specification. The efficiency of charcoal adsorbers, which is components within the ESF filtration systems, are slightly reduced but the effi-ciency of the systems and operability of the systems remain the same.

Therefore, the results are clearly within all acceptable criteria and the margin of safety for the systems is not reduced.

(1 D. Environmental Zm act Consideration Determination The proposed change request does not involve an unreviewed environmental question because operation of PVNGS Units 1 and 2, in accordance with this change, would not: '

tw (1) Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as mod-ified by the staff's testimony to the Atomic Safety and Licensing Board, Supplements to the FES, Environmental Impact appraisals, or in any deci-sions of the Atomic Safety and Licensing Board; or (2) Result in a significant change in effluents or power levels; or (3) Result in matters not previously reviewed in the licensing basis for PVNGS which may have a significant environmental impact.

E. Marked U Technical S ecification Chan e Pa es