LR-N14-0189, License Amendment Request to Revise Technical Specifications to Adopt TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month Using the Consolidated Line Item Improvement Process

License Amendment Request to Revise Technical Specifications to Adopt TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month Using the Consolidated Line Item Improvement Process

ML14329B244
Person / Time
Site:	Hope Creek
Issue date:	11/25/2014
From:	Davison P Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR H14-01, LR-N14-0189
Download: ML14329B244 (13)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 I>SL"("

.-. . 1..4 .I NOV* 2 5 2014 10 CFR 50.90 L R-N1 4-0189 LA R H1 4-01 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

License Amendment Request to Revise Technical Specifications to Adopt TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month" Using the Consolidated Line Item Improvement Process In accordance with the provisions of 1 0 CF R 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for an amendment to the Technical Specifications (TS) for Hope Creek Generating Station.

The proposed amendment would modify TS requirements to operate ventilation systems with charcoal filters for 1 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> each month in accordance with TSTF-522, Revision 0, " Revise Ventilation System Surveillance Requirements to Operate 1 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per Month." provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides existing TS Bases pages marked up to show the proposed changes. The Bases markup pages are being provided for information only.

PSEG requests approval of this LAR in accordance with standard N RC approval process and schedule. Once approved, the amendment will be implemented within 60 days from the date of issuance.

In accordance with 1 0 CF R 50.91 , a copy of this application, with attachments, is being provided to the designated State of New Jersey Official.

L R-N1 4-01 89 1 0 CF R 50.90 Page 2 If you have any questions or require additional information, please contact Ms. Tanya Timberman at 856-339-1426.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on __ \ \-1l'.-L_S_\'-\--I.( -'-

(Date)

Respectfully, Paul Davison Site Vice President - Hope Creek Generating Station Attachments:

1 . Description and Assessment

2. Mark-up of Proposed Technical Specification Pages

3. Mark-up of Proposed Technical Specification Bases Pages cc: Mr. D. Dorman, Administrator, Region I, N RC Ms. C. Sanders, Project Manager, N RC N RC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Manager IV, NJBNE PSEG Corporate Commitment Tracking Coordinator Hope Creek Commitment Tracking Coordinator

LR-N14-0189 Attachment #1 Attachment #1 Description and Assessment

LR-N1 4-01 89 LAR H1 4-01 Attachment #1 License Amendment Request to Revise Technical Specifications (TS) to Adopt TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 1 0 Hours per Month" Table of Contents

1.0 DESCRIPTION

... ..................................... . . .............. . ............. ................ .......................... 2 2.0 ASSESSMENT ................................................................................................................2 3.0 REGULATORY A NALYSIS ............... . . . . . . . . ................................. . . . . . . ......... . . . ....... ............ 3 3.1 No Significant Hazards Consideration Determination ............................................... 3 4.0 ENVIRO NMENTAL EVALUATIO N ...... . . .................................... . . ............... . . . . . . . . . . ...........4 1

LR-N14-0189 LAR H14-01 Attachment #1

1.0 DESCRIPTION

The proposed change revises the Surveillance Requirement (SR) which currently requires operating ventilation systems with the heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period at a frequency controlled in accordance with the Surveillance Frequency Control Program (SFCP).

The SR is revised to require operation of the system for 15 continuous minutes at a frequency controlled in accordance with the SFCP.

The proposed amendment is consistent with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 1 0 Hours per Month."

2.0 ASSESSMENT 2.1 Applicability of Pu blished Safety Evaluation PSEG has reviewed the model safety evaluation dated September 1 3, 201 2, as part of the Federal Register Notice of Availability (77 FR 58421). This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-522. PSEG has concluded that the justifications presented in the TSTF-522 proposal and the model safety evaluation prepared by the NRC staff are applicable to Hope Creek and justify this amendment for the incorporation of the changes to the Hope Creek TS.

2.2 Optional Changes and Variations PSEG is not proposing any variations or deviations from the TS changes described in the TSTF-522, Revision 0, or the applicable parts of the N RC staff's model safety evaluation dated September 13, 201 2.

Hope Creek TS utilize a different numbering system than the Standard Technical Specifications (STS) NUREG-1 433 on which TSTF-522 was based. Specifically, the "Control Room Emergency Filtration System" S R in the Hope Creek TS are numbered 4. 7.2.1.1 rather than 3.7.4.1 (Main Control Room Environmental Control System). These differences are administrative and do not affect the applicability of TSTF-522 to Hope Creek.

The model safety evaluation states that the effects of moisture on the charcoal adsorbers are accounted for in the Ventilation Filter Testing Program by performing testing at a relative humidity of 95 percent. Hope Creek does not have a specific Ventilation Filter Testing Program.

All ventilation filter testing requirements are specified in the S R. Charcoal adsorber testing is performed at a relative humidity of 70 percent. The effects of moisture on the charcoal adsorbers are accounted for. S R 4. 7.2.1. 1.e.4 verifies the heaters are able to maintain humidity less than or equal to 70 percent. In conclusion, the relative humidity is not applica ble to this TSTF.

The Bases markup pages are being provided for information only.

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LR-N1 4-01 89 LAR H1 4-01 Attachment #1

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Hope Creek requests adoption of an approved change to the standard technical specifications (TS), to revise the TS 3.7.2, "Control Room Emergency Filtration System (CREF)" S R to operate each CREF subsystem with the electric heaters on for a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period at a frequency controlled in accordance with the SFCP. The S R is revised to require operation of the system for 15 continuous minutes at a frequency controlled in accordance with the SFCP.

As required by 1 0 CFR 50.9 1(a), an analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change replaces an existing S R to operate each Control Room Emergency Filtration (CREF) subsystem equipped with electric heaters on for a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period at a frequency controlled in accordance with the SFCP with a requirement to operate each subsystem for 1 5 continuous minutes with heaters on.

This system is not an accident initiator and therefore, these changes do not involve a significant i ncrease in the probability of an accident. The proposed system and filter testing change is consistent with current regulatory guidance for these systems and will continue to assure that these systems perform their design function which may include mitigating accidents. Thus the change does not involve a significant increase in the consequences of an accident.

Therefore, it is concluded that this change does not involve a significant increase in the proba bility or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change replaces an existing SR to operate each CREF subsystem with electric heaters on for a 1 0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> period at a frequency controlled in accordance with the SFCP with a requirement to operate each subsystem for 15 continuous minutes with heaters on.

The change proposed for this ventilation system does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Condition for Operation is met and the system compo nents are capable of performing their intended safety functions. The change does not create new failure modes or mechanisms and no new accident precursors are generated.

3

LR-N1 4-01 89 LAR H1 4-01 Attachment #1 Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed change replaces an existing S R to operate each CREF subsystem with electric heaters on for a 1 0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> period at a frequency controlled in accordance with the SFCP with a requirement to operate each subsystem for 1 5 continuous minutes with heaters on.

The design basis for the CREF systems' heaters is to heat the incoming air which reduces the relative humidity. The heater testing change proposed will continue to demonstrate that the heaters are capable of heating the air and will perform their design function. The proposed change is consistent with regulatory guidance.

Therefore, it is concluded that the proposed changes do not involve a significant reduction in a margin of safety.

Based upon the above, PSEG concludes that the proposed change presents no significant hazards consideration under the standards set forth in 1 0 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 1 0 CF R 20, or would change an inspection or SR. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 1 0 CFR 51 .22(c)(9). Therefore, pursuant to 1 0 CFR 51 .22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

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LR-N1 4-01 89 Attachment #2 Attachment #2 Mark-up of Proposed Technical Specification Pages

LR-N14-0189 Attachment #2 Mark-up of Proposed Technical Specification Pages The following Technical Specifications pages for Renewed Facility Operating License NPF-57 are affected by this change request:

Technical Specification 3.7.2, Control Room Emergency Filtrations System 3/4 7-6a

PLANT SYSTEMS CONTROL ROOM EMERGENCY FILTRATION SYSTEM LIMITING CONDITION FOR OPE RATION (continued)

2. With both control room emergency filtration subsystems inoperable for reasons other than Condition b.3, suspend handling of recently irradiated fuel in the secondary containment and operations with a potential for draining the reactor vessel.

3. With one or more control room emergency filtration subsystems inoperable due to an inoperable C RE boundary , immediately suspend handling of recently irradiated fuel and operations with a potential for draining the vessel.

c. The provisions of Specification 3.0.3 are not applicable in OPERATIONAL CO NDITION*.

SU RVEILLANCE REQUIREMENTS 4.7.2. 1 .1 Each control room emergency filtration subsystem shall be demonstrated OPERABLE:

a. DELETED

b. In accordance with the Surveillance Frequency Control Program by verifying that the subsystem operates for at least with the heaters on.

15 continuous minutes

• When recently irradiated fuel is being handled in the secondary containment and during operations with a potential for draining the reactor vessel.

The main control room envelope (CRE) boundary may be opened intermittently under administrative control.

HOPE CREEK 3/4 7-6a Amendment No. 191

LR-N14-0189 Attachment #3 Attachment #3 Mark-up of Proposed Technical Specification Bases Pages

LR-N1 4-01 89 Attachment #3 Mark-up of Proposed Technical Specification Bases Pages The following Technical Specifications Bases pages for Renewed Facility Operating License NPF-57 are affected by this change request Technical Specification Bases B 3/4.7.2.1, Control Room Emergency Filtration System B 3/4 7-1

Operation with the heaters on for;::: 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action.

3/4.7 PLANT SYSTEMS BASES 3/4.7.1 SERVICE WATER SYSTEMS The OPERABILITY of the station sErvice water and the safety auxiliaries cooling systems ensures that sufficiert cooling capacity is available for continued operation of the SACS and its associated safety-related equipment during normal and accident conditions. The redundant cooling capacity of these systems, assuming a single failure, i consistent with the assumptions used in the accident conditions within acceptc:ble limits.

3/4.7.2 CONTROL ROOM SYSTEMS 3/4.7.2.1 CONTROL ROOM EMERGENCY FILTJATION SYSTEM The OPERABILITY of the control rcom emergency filtration system ensures that the control room will remain habitabl;for occupants during and following all design basis accident conditions. peration of the system with the heaters and humidity oontrol instruments OPBRZ\BLE for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> during eaoh :n day period is suffioient to reduce the buildup of moisture on the adsorbers and REP filters. The OPERABILITY of this system in conjunction with control room design provisio is based on limiting the radiation exposure to personnel occupying the control r om to 5 rem or less total effective dose equivalent (TEDE) . This limitation is consistent with the requirements of 10 CFR Part 50.67, "Accident Source Ter ."

INSERT: The Surveillance Frequency handling of fuel only requires OPERABILITY of CREF when ntly irradiated, i.e., fuel that has occupied part of is controlled under the Surveillance within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Each CREF subsystem is Frequency Control Program. he individual components necessary to limit Control

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Roo--mEn v ____ _ c

_ _u_p_a_ntexposure are OPERABLE. A subsystem is considered OPERABLE when its associated:

a. Fans are OPERABLE (i.e., one CREF fan, one control room supply fan and one control room return air fan) ;

b. HEPA filter and charcoal adsorbers are not excessively restricting flow and are capable of performing their filtration functions, and

c. Heater, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

The Control Room Envelope (CRE) is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room, and other non-critical areas including adjacent support offices, toilet and utility rooms. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, ceiling, ducting, valves, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

In order for the CREFAS subsystems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

HOPE CREEK B 3/4 7-1 Amendment No. 191 (PSEG Issued)