ML20236Y421

Application for Amend to License NPF-57,revising Tech Specs 3/4.6.5.3 Re Filtration,Ventilation & Recirculation Sys & 3/4.7.2 Re Control Room Emergency Filtration Sys.Fee Paid

ML20236Y421
Person / Time
Site:	Hope Creek
Issue date:	11/25/1987
From:	Corbin McNeil Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20236Y423	List: ML20236Y421 ML20236Y427 ML20244B622
References
NLR-N87223, NUDOCS 8712110311
Download: ML20236Y421 (7)

Text

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4 Public Service Electric and Gas Company Corbin A. McNeill, Jr. Public Service Electric and Gas Company P.O. Box 236. Hancocks Bridge, NJ 08038 609 339-4800 Senor Vice President -

November 25, 1987 NLR-N87223 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen: l REQUEST FOR AMENDMENT PACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 In accordance with the requirements of 10CPR50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits a request for amendment of Facility Operating License NPF-57 for Hope Creek Generating Station (HCGS). In accordance with the requirements of 10CFR50.91(b)(1), a copy of this request has been sent to the State of New Jersey as indicated below. In accordance with the requirements of 10CFR170.21, a check in the amount of $150.00 is enclosed.

This amendment request revises Technical Specification 3/4.6.5.3, Filtration, Ventilation and Recirculation System (FRVS) and 3/4.7.2, Control Room Emergency Filtration System (CREFS).

Specifically, the chances shown in Attachment 2 separate subsystems within the FRVS Technical Specification, clarify surveillance requirements in order to extend PRVS service life and permit the interposition of a detailed evaluation of the potential impact of specific maintenance activities on the FRVS and CREFS efficiencies as predecisional to the presently required surveillance testing.

Attachments 1, 3 and 4 contain further discussion and justification for these proposed revisions. In order to effectively implement these revisions when issued, please issue the license amendment, following the necessary review and approval, with an implementation date within sixty (60) days after issuance.

8712110311 871125 \ yi d II I44l PDR ADOCK 05000354 A gD\

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Document Control Desk 2 11-25-87 This submittal includes one (1) signed original, including affidavit, and thirty-sevea (37) copies pursuant to 10CFR50.4(b)(2)(ii).

Should you have any questions on the subject transmittal, please do not hesitate to contact us.

Sincerely, l

Enclosure (check)

Affidavit Attachments (4) l C Mr. G. W. Rivenbark USNRC Licensing Project Manager Mr. R. W. Borchardt USNRC Senior Resident Inspector Mr. W. T. Russell, Administrator USNRC Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628

Ref: LCR 87-17 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

Corbin A. McNeill, Jr., being duly sworn according to lau deposes and says:

7 am Senior Vice President of'Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated November 25, 1987 , concerning Facility Operating License NPF-57 for Hope Creek Generating Station, are true to the best of my knowledge, information and belief.

w SubscribeJ this 15 and day Sworn of to

/Abefore A ,me 1987

/ nt n fft

/ NotaryjPublic of New Jersey g p E9 Y) B ersey My Commission Expires May In 1993 My Commission expires on

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[TTACHMENT__1 PROPOSED CHANGE TO Ref. LCR 87-17 TECHNICAL SPECIFICATIONS HOPE CREEK GENERATING STATION DESCRIPTION OF CHANGE Within Technical Specification Section 3/4.6.5.3, Filtration, Ventilation and Recirculation System (FRVS) create separate sections.. 3/4.6.5.3.1, FRVS Ventilation and Piltration and 3/4.6.5.3.2,_PRVS Recirculation and Filtration ...and reword certain surveillance requirements and add _a footnote per the marked-up pages in Attachment 1 for those sections.

Additionally, for Section 3/4.7.2, Control Room Emeroency Filtration System (CREFS), reword surveillance requirement 4.7.2.c and add the same footnote as above per the attached-marked-up pages for that section.

REASON FOR CHANGE There are similer needs for clarification in both the FRVS end CREFS Technical Specifications. The Hope Creek Reactor Building Filtration, Recirculation and Ventilation System consists of two separate subsystems as indicated by the proposed separation. Separation of the two FRVS subsystems in the specifications and incorporation'of the proposed wording in the surveillance requirements of both the FRVS and CREFS subsystems will: 1) clarify the surveillance requirements for both FRVS and CREFS; 2) relax presently over-conservative surveillance commitments which will, in turn, significantly extend the service life of the FRVS Recirculation and Filtration subsystem charcoal without affecting the systems' capabilities or effectiveness as stated in the FSAR; and, 3) permit maintenance activities, such as welding and painting, in the reactor building or control room areas without dogmatically requiring a lenothy (roughly 4 weeks) surveillance test of the FRVS or CREFS without regard for the actual impact of those maintenance activities on ventilation system efficiency.

SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS 1st criterion This change does not involve a significant increase in the probability or consequences of any previously evaluated

Ref. LCR 87-17 l

l l SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS (Cont'd) accident or malfunction of equipment important to safety.

This revision will provide extended service life of FRVS charcoal and facilitate maintenance activities in the reactor building and control room areas while still meeting the efficiencies st 'ed in the FSAR and ensuring continued compliance with the requirements of Regulatory Guide 1.52.

The values proposed are consistent with the charcoal l

testing criteria clarification provided by William Gammil, Chief of the Effluent Treatment Systems Branch, in his letter dated September 24, 1981 (see Attachment 3). In this clarification, Mr. Gammill states that acceptance criteria should be based on the accident analysis.

l The proposed change incorporates an 80% value into the FRVS Recirculation laboratory testing criteria by allowing a 7.5% penetration (by interpolation of the clarification in Mr. Gamill's letter). For the overall FRVS, Sections 6.8 of the Hope Creek FSAR and 6.5.1.2 of t hi SER assign a 99%

system decontamination efficiency for accident iodines (elemental and organic). For the FRVS Ventilation and Filtration subsystem, Regulatory Guide 1.52 assigns a 95%

removal efficiency, based on a two inch bed. Therefore, to l achieve the PSAR/SER-assigned overall system efficiency I value of 99%, the FRVS Recirculation and Filtration subsystem, which functions as the initial cleanup system prior to, and as a guard bed for, the FRVS Ventilation and Filtration subsystem, needs only to have an 80% efficiency.

Most Standby Gas Treatment Systems (which is the equivalent system designation to the Hope Creek FRVS Recirculation subsystem) are rated at 4,000 cfm at 95% efficiency. The Hope Creek FRVS Recirculation units are each rated at 30,000 cfm such that even at 80% lab test efficiency, each of the six units provides 110% protection against any iodiac releans.

Addition of the proposed footnote and wording changes to Sections 4.6.5.3.c and 4.7.2.c provide latitude for evaluation of the need for testing following any work or event involving potential communication of the FRVS or CREFS subsystems with the resulting off-products of painting, welding, fire or chemical releases. The present Technical Specification, interpreted literally, makes no allowances for the type, quantity, length of exposure, known impact, or previous accumulation history of contaminants which could reduce the FRVS or CREFS subsystem efficiency below the minimums required in the Technical Specifications.

E ,

Ref. LCR 87-17

~

SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS (Cont'd)

The. proposed footnote will require a thorough evaluation of all' potential contamination events, taking into account the previously mentioned elements which are pertinent to any determination of the degree of impact on system efficiency.

In the event that any of these proposed evaluations determines that contamination which could reduce system efficiency to below that required by the current Technical Specification may have occurred, or if there is any arbiguity in the results any of the proposed evaluations, the appropriate testing will be performed.

The CREFS filter trains, described in FSAR Sections 6.4 and 6.5.1, are normally isolated from control room atmosphere.

Therefore, the addition of the words, ' filter train', to Section 4.7.2.c more clearly defines that portion of each CREFS subsystem that can be affected by any potential contamination...instead of considering communication with the control room supply units or return air fans as having any effect on subsystem efficiency.

2nd Criterion This proposed change does not create the possibility of a new or-different-kind of accident from any previously evaluated because, other than allowing an 80% efficiency for the FRVS Recirculation units which as previously stated will still meet all FSAR and SER overall system efficiency requirements, there is no change to existing plant equipment, procedures, or operating parameters.

3rd Criterion A)though this change would permit reduced efficiency of the FRVS Recirculation and Filtration subsystem from the existing (overly conservative) Technical Specification requirements, there is no significant reduction in any associated margin of safety. The efficiency values determined in the laboratory tests involve testing of a carbon sample two inches in diameter and two inches deep.

No consideration is given to the actual volume or frontal surface area of the carbon adsorbent in the as-built configuration. In each of the six FRVS Recirculation and Filtration units at the Hope Creek Station, there are roughly 5200 lbs. of carbon adsorbent. At the proposed efficiency of 80%, each unit would be capable of providing 110% protection against the projected accident iodine release for a 1150 MW(e) reactor...for a total of 660%

volumetric capacity for iodine removal for the FRVS subsystem. The formula for the volume of carbon adsorbent 3-

Ref. LCR 87-17 SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS (Cont'd) required for a particular reactor size was extracted from page 63 of the Nuclear Air Cleaning Handbook (ERDA 76-21),

the reference book used by Regulatory Guide 1.52 and the Standard Review Plan Section 6.5.1 (see Attachment 4).

Based on the above, we have determined that this proposed change does not involve a Significant Hazards Consideration. Additionally, we suggest that this change conforms to example (vi) of the guidance provided by the Commission, in 48FR14870 of the Federal Register, for Amendments Not Likely To Involve A Significant Hazards Consideration, in that, although the change may reduce, in some way, a margin of safety, plant operation with the proposed change in place would remain within all acceptable criteria, with respect to the CREFS AND FRVS subsystems, as specified in Standard Review Plan Sections 6.4, 6.5.1 and 6.5.3.

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