ML112990142

Draft Request for Additional Information

ML112990142
Person / Time
Site:	Hope Creek
Issue date:	10/25/2011
From:	Richard Ennis Plant Licensing Branch 1
To:	Chernoff H Plant Licensing Branch 1
Ennis R, NRR/DORL, 415-1420
References
TAC ME5748
Download: ML112990142 (4)

Text

October 25, 2011 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager /ra/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

HOPE CREEK GENERATING STATION, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NO. ME5748)

The attached draft request for additional information (RAI) was transmitted on October 25, 2011, to Mr. Paul Duke of PSEG Nuclear LLC (the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensee=s amendment request for Hope Creek Generating Station (HCGS) dated February 28, 2011, as supplemented on August 29, 2011. The proposed amendment would modify the HCGS Technical Specifications (TSs) to revise the existing TS for the Control Room Emergency Filtration (CREF) system and to add a new TS for the Control Room Air Conditioning (AC) system. The proposed amendment is based, in part, on Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Standard TS (STS) Change Traveler TSTF-477, Revision 3, Adding an Action Statement for Two Inoperable Control Room Air Conditioning Subsystems. Plant-specific deviations from TSTF-477 are proposed to accommodate differences between the HCGS TSs and the STSs originally used to develop TSTF-477.

This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensees request.

Docket No. 50-354

Attachment:

Draft RAI

October 25, 2011 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager /ra/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

HOPE CREEK GENERATING STATION, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NO. ME5748)

The attached draft request for additional information (RAI) was transmitted on October 25, 2011, to Mr. Paul Duke of PSEG Nuclear LLC (the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensee=s amendment request for Hope Creek Generating Station (HCGS) dated February 28, 2011, as supplemented on August 29, 2011. The proposed amendment would modify the HCGS Technical Specifications (TSs) to revise the existing TS for the Control Room Emergency Filtration (CREF) system and to add a new TS for the Control Room Air Conditioning (AC) system. The proposed amendment is based, in part, on Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Standard TS (STS) Change Traveler TSTF-477, Revision 3, Adding an Action Statement for Two Inoperable Control Room Air Conditioning Subsystems. Plant-specific deviations from TSTF-477 are proposed to accommodate differences between the HCGS TSs and the STSs originally used to develop TSTF-477.

This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensee's request.

Docket No. 50-354

Attachment:

Draft RAI DISTRIBUTION PUBLIC HWalker, NRR/DSS/SCVB LPL1-2 R/F MHamm, NRR/DIRS/ITSB RidsNrrDorlLpl1-2 Resource RidsNrrDorlDpr Resource RidsNrrPMREnnis Resource ACCESSION NO.: ML112990142 OFFICE LPL1-2/PM NAME REnnis DATE 10/25/11 OFFICIAL RECORD COPY

DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT ADD ACTION FOR TWO INOPERABLE CONTROL ROOM AIR CONDITIONING SUBSYSTEMS HOPE CREEK GENERATING STATION DOCKET NO. 50-354 By application dated February 28, 2011, as supplemented on August 29, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML110590636 and ML112420124, respectively), PSEG Nuclear LLC (PSEG, the licensee) submitted a license amendment request for the Hope Creek Generating Station (HCGS). The proposed amendment would modify the HCGS Technical Specifications (TSs) to revise the existing TS for the Control Room Emergency Filtration (CREF) system and to add a new TS for the Control Room Air Conditioning (AC) system. The proposed amendment is based, in part, on Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Standard TS (STS)

Change Traveler TSTF-477, Revision 3, Adding an Action Statement for Two Inoperable Control Room Air Conditioning Subsystems. Plant-specific deviations from TSTF-477 are proposed to accommodate differences between the HCGS TSs and the STSs originally used to develop TSTF-477.

The NRC staff has reviewed the information the licensee provided that supports the proposed amendment and would like to discuss the following issues to clarify the submittal.

1. PSEGs response to request for additional information (RAI) question 3 in the supplement dated August 29, 2011, stated, in part, that:

HVAC system inoperability may result in CREF inoperability. In the event of a A(B)-P-400 chilled water pump trip, the A(B)-K-400 chiller will trip, which will trip the A(B)-VH403 and the CREF system. Due to these interlocks, if the Control Room AC subcomponents trip, then CREF will also be inoperable.

However, the CREF function is to maintain habitability within the Control Room Envelope via filtration. The CREF trains are independent of the Control Room AC system and would be functional for conditions that do not result in a trip of the Control Room AC system, for example reduced chiller heat removal capability.

The use of the word independent in the above statement is not clear. If the CREF trains are independent of the Control Room AC system, why does a trip of the Control Room AC result in an inoperable CREF?

Attachment

2. Please confirm if the following statements are correct (if not, please clarify):

(a) Air exhausting from each CREF filter train (A(B)-VH400) goes to the respective Control Room Supply (CRS) unit (A(B)VH403) and then to the control room.

(b) Each CRS unit has a low efficiency filter, a high efficiency filter, a fan, a cooling coil (cooled by chilled water system), a heating coil and a humidifier. The cooling coil supports the control room AC function.

(c) In order for CREF to perform its design basis function, the fan portion of the CRS needs to be operating. CREF system functionality is not dependent on the control room AC temperature control function.

(d) Due to the electrical interlocks in the current plant design, if a control room AC subcomponent trips, the associated CRS unit will trip thus also making the associated CREF train inoperable (i.e., solely because the CRS fan is inoperable).

(e) If the proposed amendment is approved, the licensee may make a subsequent plant modification to remove the interlocks discussed in (d). This would enable control room AC to be inoperable without automatically tripping the CRS unit including its fan. As such, the associated CREF train would no longer need to be declared inoperable solely due to control room AC system inoperability.

(f) If the proposed amendment is approved and the licensee does not perform the plant modification discussed in (e) (i.e., interlocks are still in place), if a control room AC subcomponent trips, the associated CRS unit will trip thus also making the associated CREF train inoperable (i.e., solely because the CRS fan is inoperable).

(g) If the proposed amendment is approved (and before the plant modification is done), if both trains of the control room AC system were inoperable, then both trains of CREF would need to be declared inoperable and the plant would enter TS 3.0.3 per the CREF TS. This is no different than the current TS requirements.

(h) The proposed amendment does not change any of the assumptions in the HCGS licensing basis analyses of design basis accident consequences.

3. With an inoperable control room AC system and an inoperable CRS unit, will the control room return air (CRRA) fan and corresponding flow element be inoperable? Is the CRRA fan required to be operable in order for the CREF to be operable?