ML20206R773

Summary of 981207 Meeting with Util in Rockville,Md to Discuss Status of Util License Change Request Re Heaters for Recirculation Subsystem of Filtration,Recirculation & Ventilation Sys for Plant

ML20206R773
Person / Time
Site:	Hope Creek
Issue date:	01/14/1999
From:	Richard Ennis NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9901200226
Download: ML20206R773 (21)

Text

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/ \ UNITED STATES h

s* j NUCLEAR RE5tULATORY COMMISSION WASHINGTON, D.C. 2066& 0001

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g g**.**,/g January 14, 1999 LICENSEE: Public Service Electric and Gas Company FACILITY: Hope Creek Generating Station

SUMMARY

OF DECEMBER 7,1998 MEETING REGARDING LICENSE CHANGE REQUEST RELATED TO THE HEATERS FOR THE FILTRATION, REClRCULATION, AND VENTILATION SYSTEM This summary refers to the meeting with Public Service Electric and Gas Company (PSE&G) conducted on December 7,1998, at the U.S. Nuclear Ragulatory Commission (NRC) office in Rockville, Maryland. The meeting was held to discuss the status of PSE&G's license change request related to the heaters for the recirculation subsystem of the Filtration, Recirculation, and Ventilation System (FRVS) for the Hope Creek Generating Station. The license change request would change the Technical Specifications to state that the heaters would be

" operating" (automatic heater modulation to maintala relative humidity) instead of "on" when performing the 10-hour monthly surveillance test. A list of the attendees at the meeting and a copy of the slides presented by the NRC are enclosed.

The NRC staff informed PSE&G on November 19,1998, that the staff had completed the review of PSE&G's application dated August 26,1997, as supplemented April 24,1998, and September 24,1998, and was prepared to deny the license change request. The NRC requested a teleconference to discuss the reasons for the denial. On November 20,1998, PSE&G requested that a meeting be held in lieu of the teleconference.

The NRC staff opened the meeting with a presentation that provided an overview of the pertinent issues associated with the FRVS license change request. The NRC presentation I closely followed the materialin the slides provided in Enclosure 2. The following major topics were discussed:

1) The chronology of significant interactions (e.g., conference calls, submittals, meetings) related to this license change request was discussed. The NRC staff emphasized that there were numerous interactions between the NRC and PSE&G on this issue and that adequate technical justification for the change had not yet been provided.

2) The applicable regulatory requirements related to engineered-safety feature (ESP) ,

atmospheric cleanup systems were reviewed. The key issue involved whether the heaters g l would sufficiently dry the charcoat in the FRVS recirculation unit filter trains during the 1 l monthly surveillance test if the heaters are allowed to modulate on and off while being controlled by a humidistat. Regulatory Guide 1.52, regulatory position C.4.d, requires that each ESF atmospheric cleanup train be operated for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the

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l heaters on (if so equipped), in order to reduce the buildup of moisture on the adsorbers and HEPA filters.

pQOb 9901200226 990114 PDR ADOCK 05000354 I ., -

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3) Discussion was held regarding heater operation during surveillance testing in atmospheric cleanup systems in other nuclear plants. PSE&Gs' position is that testing the FRVS recirculation units with the heaters " operable" (i.e., modulating via a humidistat), meets the intent of Regulatory Guide 1.52 with respect to keeping the charcoal dry. The NRC staff noted that other plants that use the word " operable" in their Technical Specifications have other design features (e.g., air purge, thermostats) that ensure that the charcoalis dried during the test.

4) The analysis of data to support PSE&Gs' application was discussed. Charcoal in each of the six FRVS recirculation unit filter trains is surveillance tested for moisture content every 18 months. Charcoal moisture data for some of the 18 month tests performed between 1989 and 1998 had been provided for NRC review. Before 1991, the FRVS recirculation unit heater monthly surveillance tests required the heaters to run for the full 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (heaters did not modulate on/off during the test). The surveillance test was changed in l 1991 to allow the heaters to modulate as part of the corrective actions associated with heater control panel fuse problems (fuses blew on high ambient temperature within the control panet). The NRC requested the charcoal moisture content data for before and after the 1991 modifications to compare the ability of the heaters to dry the charcoal with the heaters on versus modulating. The test data showed that the pre-modification average charcoal moisture content was approximately 6.7% versus approximately 6.34%

during post-modification testing. The NRC was unable to draw any firm conclusions from the data since the pre-modification data was sparse and the results seemed " counter-intuitive"(i.e., post-modification data with the heaters modulating should have shown a

! higher moisture content than the pre-modification data with the heaters on for the full 10-i hour test duration).

The NRC staff and PSE&G agreed that the fundamentalissue is whether the FRVS heater testing method complies with the plant's licensing basis. They also agreed that testing the FRVS recirculation units with the heaters modulating versus on is of low safety and risk significance. The originallicensing basis for the FRVS heater testing as stated in the Updated Final Safety Analysis Report (UFSAR) did not take exception to Regulatory Guide 1.52, regulatory position C.4.d. However, PSE&G revised the UFSAR in 1997 in accordance with 10 l CFR 50.59 to clarify that heaters " operable"is the equivalent to heaters "on."

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4 3-After the completion of the NRC presentation, PSE&G stated that it would be easier to comply with the NRC's interpretation of Regulatory Guide 1.52 rather than pursuing this change any further. PSE&G committed to withdrawing the license change request and to submitting a Licensee Event Report (LER). The LER will state that the testing method in the future will require that the monthly surveillance tests be run with the heaters on. PSE&G also committed

-to revising the UFSAR accordingly..

original signed by:  ;

Richard B. Ennis, Project Manager Project Directorate 1-2 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-354 -

Enclosures:

1. Attendance Ust

2. NRC Slides cc w/encis: See next page DISTRIBUTION:

_ Hard Cooy ,

• Docket File PUBLIC PDI-2 Reading OGC ACRS REnr/,

E-Mag SCol.m#tZimmerman DO'Neal BBogei JRaval JZwolinski BMcCabe WDean GMeyer, RGN-l MO'Brien TMartin LMarsh JSegala BThomas HWalker JLinville, RGN-l DOrr, Hope Creek RI n *Previously Concurred OFFICE PDI-2/PM Nf J /, SPLB/BC* PDl-2/D n NAME REnnis:r b LMarsh 'WDean M DATE I /13/99 ./ h/99 01/06/99 1 /l 99

. OFFICIAL RECORD COPY DOCUMENT NAME: HC12-7.MTS

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i 3-After the completion of the NRC presentation, PSE&G stated that it would be easier to comply with the NRC's interpretation of Regulatory Guide 1.52 rather than pursuing this change any further. PSE&G committed to withdrawing the license change request and to submitting a Licensee Event Report (LER). The LER will state that the testing method in the future will require that the monthly surveillance tests be run with the heaters on. PSE&G also committed to revising the UFSAR accordingly.

1

, Richard B. Ennis, Project Manager Project Directorate 1-2 Divisic.a. of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosures:

1. Attendance List

2. NRC Slides cc w/encls: See next page

Public Service Electric & Gas Hope Creek Generating Station

. Company cc:

Jeffrie J. Keenan, Esquire . Manager- Joint Generation Nuclear Business Unit- N21 Atlantic Energy P.O. Box 236 6801 Black Horse Pike Hancocks Bridge, NJ 08038 Egg HarborTwp., NJ 08234-4130 Hope Crsek Resident inspector Richard Hartung U.S. Nuclear Regulatory Commission Electric Service Evaluation Drawer 0509 Board of Regulatory Commissioners Hancocks Bridge, NJ 08038 2 Gateway Center, Tenth Floor

) Newark, NJ 07102 Mr. Louis Storz Sr. Vice President - Nuclear Operations Lower Alloways Creek Township

~

Nuclear Department c/o Mary O. Henderson, Clerk P.O. Box 236 Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 General Manager- Hope Creek Operations Mr. Elbert Simpson Hope Creek Generating Station Senior Vice President-P.O. Box 236 Nuclear Engineering Hancocks Bridge, NJ 08038 Nuclear Department P.O. Box 236 Director- Licensing Regulation & Fuels Hancocks Bridge, NJ 08038 Nuclear Business Unit- N21 P.O. Box 236 Mr. Harold W. Keiser Hancocks Bridge, NJ 08038 Chief Nuclear Officer & President Nuclear Business Unit Regional Administrator, Region l Public Service Electric and Gas U.S. Nuclear Regulatory Commission Company 475 Allendale Road Post Office Box 236 King of Prussia, PA 19406 Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director

• Radiation Protection Programs NJ Department of Environmental Protection and Energy CN 415 Trenton, NJ 08625-0415

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.. 1 MEETING ATTENDANCE LIST Licensee: Public Service Electric and Gas Comoany Plant (s): Hope Creek

Subject:

Filtration. Recirculation. and Ventilation System License Chanae Reauest Date: December 7.1998 Time: 10:00 a.m.

Location: NRC Offices. OWFN Room 1-F-5 NRC STAFF TITLE ORGANIZATION J. Zwolinski Acting Director NRR/DRPE R. Capra Project Director NRR/DRPE/PDI-2 R. Ennis Project Manager NRR/DRPE/PDI 2

. T. Marsh Branch Chief NRR/DSSA/SPLB J.Segala Reactor Systems Engineer NRR/DSSA/SPLB H. Walkar Sr. Reactor Systems Engineer NRR/DSSA/SPLB B. Thomas Acting Section Chief NRR/DSSA/SPLB J. Linville Branch Chief RGN-l/DRP/RPB3 D. Orr Resident inspector RGN-l/DRP/RPB3 D. O'Neal Reliabilty & Risk Analyst NRR/DSSA/SPSB J. Raval Systems Engineer NRR/DSSA/SPLB -

PSE&G D. Garchow Director, Design Engineering D. Powell Director, Licensing and Fuels

, G. Salamon Manager, Hope Creek Licensing P. Roberts Manager, Hope Creek System Engineering R. DeNight Supervisor, Analysis / Specialty Engineering '

J. Priest Licensing Engineer J. Cichello System Engineer New Jersey Department of Environmental Protection A. Kapsalopoulou Research Scientist, Bureau of Nuclear Engineering Enclosure 1 l

[

Hope Creek FRVS TS Amendment (TAC 'M99477)

U.S. Nuclear Regulatory Commission e

December 7,1998 0

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(,5),, Overview

+....

e Chrono ogy

.i 9 Regulatory Framework 9 Industry Practice anc Regulatory Insights e Analysis of Data O Summary O Options

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(,,M) Chronology G 6/86 - TS Amenc ment "O 3 era ale" to "On" G 6/9' - 3 LERs on Hea:er Fuse Pro 3lem 9 8/9' - Licensee's Corrective Actions 9 3/97 - TIA " rom Region l 9 3/97 - TS Amenc ment "On" to "O 3 era ale"

9 6/97 - PM Resaoncs to TIA 9 6/97 - Conference Call O 7/97 - NRC Jenies TS Amencment 9 7/97 - Licensee Declares FRVS Ino3erble O 7/97 - Conference Call

f Chronology

[\g/fMGqi(Continued)

O 7/97 - Conference Call with Projects 9 8/97 - TS Amenc ment "On" to "O 3erable" 9 9/97 - Region l Inspection Re3 ort O 11/97 - Conference Ca I 9 3/98 - PDI-2 Meeting witi SPLB 9 8 - ic see Su its More Information 9 6/98 - Mee':ing Licensee anc NRC 9 7/98 - Licensee Provices Some Data 9 7/98 - Conference Call

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4 70 Chronology (g/

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(Continued)

O 9/98 - Licensee Submits Supalement G 9/98 - PM asks Licensee for A.ll Data O 10/98 - Licensee Faxes 6 New Data Points e 10/98 - Conference Call e 1' /98 - Licensee Faxes 9 New Data Points

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TfD NEGO Regulatory Framework

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O Part 100 anc GDC ' 9 Dose Limits e SRP 6.5.' , ES = Atm. C eanu a Systems O RG ' .52, Regulatory Position C.4.c "Eac1 ESF atmosaheric c eanu a train shoulc be 03erated at east 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> aer month, with t7e heaters on (i so ec uia 3ec), in orc er to rec uce the Juilc u 3 o moisture on the acsor3er anc HEPA ilters."

,- s, Regulatory Framework (g/

(Continued)

O Plant Licensing Basis

. Originally Committec to Regu atory Position C.4.c of RG 1.52

2. 6/86 TS Change "O 3erable" to "On"

3. Current TS

... verifying that the subsystem operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters on in order to recuce the builcup of moisture on the carbon acsorbers and HEPA filters."

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Regulatory Framework t

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's (Continued) e Proposec Charcoal Filter Testing Generic Letter I

. Identifies proalems with stancarcs other than ASTM D3803-1989 '

2. TS Amencments O Revisec' Source Term (NUREG-1465)

Plant saecific

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[hj Industry Practice and

% s# Regulatory insights (Cont.)

O All ESF Filtration Systems in t1e STS exceat SGTS specify that systems with heaters must be 03eratec for 10 continuous hours with the heaters on.

e SGTS in the STS specify 1: hat systems

, must be operated for 10 continuous hours with the heaters on (automatic heater

cycling to maintain temperature).

Thermostats maintain temperature Humicistats maintain relative humidity

(

[e~gg; Industry Practice and N. . ./ Regulatory insights 9 NRC not aware of any alant who got a 33roval for similar TS amendment O Tyoical Inc ustry Practice is to have the heaters "on" for 10 continuous hours aer month O Other Plants with "O3eraale" in TS

1. Limerick -

Dry Instrument Air Purge

2. LaSalle -

Heaters "On" with fan j

2. Farley -

Thermostat

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(,M), Analysis of Data i

9 Heater Control Panel Tem aerature Data

- Demonstrated heater ran for 10 hrs at least once after 1991 mocifications  ;

O Charcoal Moisture Data More moisture 3 resent with heaters on?

2. Pre-modification cata saarse

3. Acceptance criteria not defined I

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Summary m(W),l e Amendment uncer active review for 14 i months '

- Unable to reach resolution O Basic neec for Amencment not clear and has c7angec over time 9 Not clear why test can not be run monthly with heaters on .

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Summary (g!/

3.f,; (Continued)

O Technica lustification that moisture content o"tle charcoa wii not 3e i significantly affectec ay 3er'orming the test wit 7out the heaters on has not 3een cemonstratec O Have not 3resentec technica justification for change

e p m arco (hih,)

Options O No regulatory requiremen~: ~:0 lave leaters

-But must test clarcoal a: 95%RH & SF=7 ,

O PSE&G may withdraw amendment rec uest 9 Staf~ alans to ceny amencment 9 Unless charcoal is tested at 95% RH, test must 3e run with heaters "ON" as stated in TS

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• Options ~

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(Continued) e UFSAR anc TS 3ases should 3e revisec to clarify that "ON" anc

" OPERABLE" are not ec uivalent i

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