LR-N02-0333, Supplement to License Change Request H02-03 Regarding Missed Surveillance Requirements & Adoption of TS Bases Control Program Using Clip
| ML023020332 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 10/21/2002 |
| From: | Garchow D Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LCR H02-03, LR-N02-0333 | |
| Download: ML023020332 (12) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bndge, New Jersey 08038-0236 OCT 2 1 2002 0 PSEG NuclearLLC LR-N02-0333 LCR H02-03 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 SUPPLEMENT TO LICENSE CHANGE REQUEST H02-03 REGARDING MISSED SURVEILLANCE REQUIREMENTS AND ADOPTION OF TS BASES CONTROL PROGRAM USING CLIIP HOPE CREEK GENERATING STATION DOCKET NO. 50-354 FACILITY OPERATING LICENSE NO. NPF-57
Reference:
Letter LR-N02-0037, Request For Change to Technical Specifications Regarding Missed Surveillance Requirements (T.S.
4.0.3) and Adoption of TS Bases ControlProgram (T.S. 6.5) Using CLIIP, dated July 25, 2002.
Gentlemen:
PSEG Nuclear, LLC (PSEG) hereby transmits a supplement to the referenced request for amendment of the Technical Specifications (TS) and supporting Bases for the Hope Creek Generating Station, pursuant to the requirements of 10CFR50.90.
License Change Request (LCR) H02-03 proposed an amendment to TS requirements for missed surveillance tests and adoption of a TS Bases Control Program using the Consolidated Line Item Improvement Process (CLIIP). Based upon discussion with the NRC Project Manager, further changes were identified since Hope Creek has not adopted the Standard Technical Specifications for General Electric BWR/4 Plants (STS), NUREG-1433.
This supplemental submittal revises Specification 4.0.1 and the corresponding Bases consistent with the requirements of STS, which will ensure that provisions currently located under TS 4.0.3 are retained. The markup of page 3/4 0-2 incorporates and supercedes the previously submitted changes to Specification 4.0.3 for clarity. The remaining TS and Bases changes from the original letter 95-2168 REV 7/99
Document Control Desk OCT 2 1 2002 LR-N02-0333 remain valid. In addition,, this supplement provides an updated No Significant Hazards Consideration for adoption of a Technical Specification Bases Control Program, which the CLIIP did not address.
Pursuant to 10CFR50.91(a)(1), PSEG Nuclear LLC has determined that this supplemental amendment involves no significant hazards considerations. The proposed supplement satisfies the criteria of 1 OCFR51.22 (c)(9) for categorical exclusion from the requirement for an environmental assessment.
Attachment I provides a description of the additional proposed changes and the supporting evaluations. Attachment 2 provides the marked up TS and Bases pages. This supplemental submittal contains no commitments.
The Station Operations Review Committee (SORC) and the Nuclear Review Board (NRB) have reviewed this proposed supplemental request for amendment.
Pursuant to the requirements of 10 CFR 50.91 (b)(1), a copy has been sent to the State of New Jersey.
Should you have any questions, please contact Carl Berger at (856) 339-1432.
I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, ExecLulted on David F. G rchow Vice President - Operations : Description and Assessment : Hope Creek Marked-up TS Pages : Proposed Changes to TS Bases Pages
Document Control Desk OCT 2 1 20 02 LR-N02-0333 C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. George Wunder, Project Manager - Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 08B2 Washington, DC 20555-0001 USNRC Resident Inspector Office (X24)
Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625
ATTACHMENT 1 LCR H02-03 LR-N02-0333 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 SUPPLEMENTAL INFORMATION REGARDING MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM DESCRIPTION License Change Request (LCR) H02-03 proposed an amendment to TS requirements for missed surveillance tests and adoption of a TS Bases Control Program using the Consolidated Line Item Improvement Process (CLIIP). This supplemental submittal proposes further changes to technical specification Surveillance Requirement 4.0.1 regarding performance of surveillances by relocating provisions from the existing TS 4.0.3 and incorporating the remaining requirements of STS.
PSEG is incorporating the STS language to replace Specification 4.0.1 and supporting Bases in their entirety. Only one new requirement will result from adoption of the STS, specifically that "failure to meet a Surveillance... shall be failure to meet the LCO." The other three requirements are already contained in the current Specification 4.0.1 or 4.0.3. There are no substantive differences in meaning or intent between the existing specifications and the corresponding STS requirements.
These additional changes are necessary since Hope Creek has not adopted the Standard Technical Specifications for General Electric BWRI4 Plants (STS),
NUREG-1433. The changes remain consistent with the Industry Technical Specification Task Force (TSTF) change on missed surveillances,TSTF-358, Revision 6, approved by the NRC on October 3, 2001.
The original submittal proposed incorporation of a TS Bases Control Program, consistent with the program described in STS. Although use of the Consolidated Line Item Improvement Process (CLIIP) to modify the specification governing missed surveillances is predicated on concurrent adoption of a Bases control program, if not already incorporated in the TS, TSTF-358 does not provide complete justification for this aspect of the proposed change. As such, the Determination of No Significant Hazards Considerations is being modified to address the previously proposed addition of a Technical Specification Bases Control Program. In addition, the complete text of the original determination, which was incorporated into our original submittal by reference, is included directly in this supplement.
ATTACHMENT 1 LCR H02-03 LR-N02-0333 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 SUPPLEMENTAL INFORMATION REGARDING MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM Determination of No SignificantHazards Considerations The referenced No Significant Hazards Consideration determination published in the Federal Register as part of CLIIP, as updated in NRC-approved TSTF-358, Rev. 6, is included here. The determination also addresses the proposed additional modification to Technical Specification 4.0.1 and incorporation of a Technical Specification Bases Control Program in section 6.0. The updated and supplemented Determination of No Significant Hazards Considerations, as presented herein, satisfies the requirements of 10CFR50.91 (a).
In accordance with the criteria set forth in 10 CFR 50.92, PSEG has evaluated these proposed Improved Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Specification 4.0.3 The proposed change relaxes the time allowed to perform a missed Surveillance.
The time between Surveillances is not an initiator to any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be OPERABLE and capable of performing the accident mitigation functions assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly affected.
Specification 4.0.1 The proposed additional requirement equating failure to meet a surveillance with failure to meet the LCO is consistent with current interpretation of the technical specifications. This change, along with relocation and rewording of existing requirements from Specification 4.0.3, are administrative in nature and do not adversely affect accident initiators, design functions, facility configuration or the manner of operation or control. The ability of structures, systems and components to perform their intended function remains unaffected.
Bases Control Program The proposed change to adopt a Technical Specification Bases Control Program is also administrative in nature and does not adversely affect accident initiators, design functions, facility configuration or the manner of operation or control. The ability of structures, systems or components to perform their intended function
ATTACHMENT 1 LCR H02-03 LR-N02-0333 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 SUPPLEMENTAL INFORMATION REGARDING MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM remains unaffected. Future changes to the TS Bases will continue to be administratively controlled in accordance with the requirements of 10CFR50.59.
Therefore, these three changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
None of the three proposed changes involves a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Thus, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in a margin of safety?
Specification 4.0.3 The relaxed time allowed to perform a missed Surveillance does not result in a significant reduction in the margin of safety. As supported by the historical data, the likely outcome of any Surveillance is verification that the LCO is met. Failure to perform a Surveillance within the prescribed Frequency does not cause equipment to become inoperable. The only effect of the additional time allowed to perform a missed Surveillance on the margin of safety is the extension of the time until inoperable equipment is discovered to be inoperable by the missed Surveillance. However, given the rare occurrence of inoperable equipment, and the rare occurrence of a missed Surveillance, a missed Surveillance on inoperable equipment would be very unlikely. This must be balanced against the real risk of manipulating the plant equipment or condition to perform the missed Surveillance. In addition, parallel trains and alternate equipment are typically available to perform the safety function of the equipment not tested.
Specification 4.0.1 The proposed changes to TS 4.0.1, including relocation and rewording of existing requirements from Specification 4.0.3, are administrative in nature and do not reduce the level of programmatic or procedural controls associated with the Surveillance Requirements. There are no substantive differences in meaning or intent between the existing specifications and the corresponding STS requirements. Further, these changes have no impact on equipment design, configuration, analytical basis, setpoints or operation.
ATTACHMENT I LCR H02-03 LR-N02-0333 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 SUPPLEMENTAL INFORMATION REGARDING MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM Bases ControlProgram The proposed change to adopt a Technical Specification Bases Control Program is also administrative in nature and does not reduce the level of programmatic or procedural controls associated with the Bases. There is no impact on equipment design, configuration, analytical basis, setpoints or operation.
Thus, there is confidence that the equipment can perform its assumed safety function. Therefore, this change does not involve a significant reduction in a margin of safety.
ATTACHMENT 2 LCR H02-03 LR-N02-0333 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following additional Technical Specifications for Hope Creek, Facility Operating License NPF-57, are affected by this supplemental request.
The markup of page 3/4 0-2 incorporates and supercedes the previously submitted changes to Specification 4.0.3 for clarity, including additional text labeled "Insert 'A"'. Text being added is shown in bold italics on the markup pages.
The markup of Bases page B 3/4 0-4 replaces the previous submittal, although the additional text labeled "Insert 'C'" is retained.
Technical Specification Page 4.0.1 3/4 0-2 Bases 4.0.1 B 3/4 0-4
APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions specified for in theApplicabilityfor individual Limiting Conditions for Operation, unless otherwise stated in an individual the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performancesof the Surveillance, shall be failure to meet the Limiting Condition for Operation.
4.0.2 Each Surveillance Requirement shall be performed within itsexceed specified extension not to surveillance interval with a maximum allowable "
interval.
25 percent of the specified surveillance 4.0.3 Failure to perform a Surveillance Requirement within the specified frequency allewed sur-veillance interval, defined by Specification t.0.2,shallt b enstitute a failure to meet the OPERAhBILITY requirements for a Limiting
- Condition_ for operation, except as provided in Specification4.0.3. 41hc timne limits ef t- ............. qu i-ee ramret - Jepp l . at..
. .e t m it....... . .......... that a ur.ve4.4.a ee-R-equ...em.nt has net .been.per-f .. d. The AGTION rf- i4m-n-s -may he delayed for 2p24hours t-e-permit the eemplet.i.n .fthe ui-oil ."1ane.
when the alle-able tage time limits of the AG.N .. ru-emen-ts are less-t-hefi 24 heurs, if it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirementto declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater.This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greaterthan 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shallbe managed.
If the Surveillance is not performed within the delay period,the Limiting Conditionfor Operation must immediately be declarednot met and the applicableActions must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declarednot met and the applicableAcin must be enteredrS-urvyeillances rcuiremcnt do not have to be performed on (inopera-ble equipment or variables outside specified limits.
4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements.
4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, & 3 components shall be applicable as follows:
- a. Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50 Sections 50.55a(f) and 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(f) (6) (i) or Section 50.55a(g) (6) (i).
- b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and HOPE CREEK 3/4 0-2 Amendment No. 4-&-
ATTACHMENT 3 LCR H02-03 LR-N02-0333 PROPOSED CHANGE TO TS BASES PAGES Insert D (Modifies Bases for TS 4.0.1)
Failure to meet a Surveillance within the specified Frequency, in accordance with Specification 4.0.2, constitutes a failure to meet an LCO.
Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when either:
- a. The systems or components are known to be inoperable, although still meeting the Surveillance Requirements, or
- b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.
Insert E (Modifies Bases for TS 4.0.1)
Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given Surveillance. In this case, the unplanned event may be credited as fulfilling the performance of the Surveillance Requirement. This allowance includes those Surveillances whose performance is normally precluded in a given OPERATIONAL CONDITION or other specified condition.
Surveillances, including Surveillances invoked by ACTIONS, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with Specification 4.0.2 prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with Specification 4.0.2. Post maintenance testing may not be possible in the current OPERATIONAL CONDITION or other specified conditions in the Applicability due to the necessary unit parameters not having been established.
In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function.
This will allow operation to proceed to an OPERATIONAL CONDITION or other specified condition where other necessary post maintenance tests can be completed.
ATTACHMENT 3 LCR H02-03 LR-N02-0333 Some examples of this process are:
- a. Control Rod Drive maintenance during refueling that requires scram testing at > 950 psig. However, if other appropriate testing is satisfactorily completed and the scram time testing of TS 4.1.3.2 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach 950 psig to perform other necessary testing.
- b. High Pressure Coolant Injection (HPCI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
3/4.0 APPLICABILITY BASES (Con't)
Specifications 4.0.1 through 4.0.5 establish the general requirements appli cable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, 10 CFR 50.36(c)(3):
"Surveillance requirements are requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is t1, maintained, that facility operation will be withi..s*. limits, andt t the f1-"0 limiting coiditions of operation will be met."
Specificat on 4.0.1 establishes the requirement th'umSurveillan eAmust beAxv&t p a during the OPERATIONAL CONDITIONS or other*conditionshfor which the sp - ;ýf-requirements of the Limiting Conditions for Operation apply unless§therwise le As*taed in an individual Surveillance Requirement. )&-po::.e*-_PI[s VAnio, OPEPAGIWL/T*^gper-ti.ona! is to nsure specifications:t-o',rof thatandsurveillances systems are that components and performed to verifythe peraetI6kre wihin "
specified limits jt -:.
- r . a-Taperatle : thY W14611t)
.-W_-
- t. 1p - _-. is.*
S1) do not have to be performed when the facilitl is in an OPERATIONAL CONDITIONAOro*ir4 specfe4
"" for which the requirements of the associated Limiting Condition for Operation 4-;vin (AIJACdo not applyp unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.
, pecification 4.0.2 establishes the limit for which the specified time
-*. -er* interval for Surveillance Requirements may be extended. It permits an
' . allowable extension of the normal surveillance interval to facilitate J surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result-of any particular surveillancf being performed is the verification of conformance with the Surveillance Requirements. This provision Is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.
Spe cation 4.0.2, hat constitut allure to meet the provision this specification, sys and componen as to be OPE when Surveillance Requi nts have been satisfac ormed he pecfie in tie vl. oweernoting hi5provision *to APR 3 1990 "i1