LR-N05-0031, Request for Change to Technical Specifications Removal of Performance Restrictions from Surveillance Requirements

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Request for Change to Technical Specifications Removal of Performance Restrictions from Surveillance Requirements
ML052920468
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 10/11/2005
From: Barnes G
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR H05-06, LR-N05-0031
Download: ML052920468 (18)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236. Hancocks Bridge, New Jersey 08038-0236 OCT IZIDS 0 PSE LR-N05-0031 ANuclear MLC LCR H05-06 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS REMOVAL OF PERFORMANCE RESTRICTIONS FROM SURVEILLANCE REQUIREMENTS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) hereby transmits a request for amendment of the Technical Specifications (TS) for Hope Creek Generating Station. In accordance with 10 CFR 50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey.

The proposed amendment revises certain eighteen-month TS surveillance requirements (SR) by eliminating the condition that testing be conducted "during shutdown' oruduring COLD SHUTDOWN or REFUELING' (i.e., shutdown conditions). The restriction to perform certain surveillance tests only during shutdown conditions is intended to ensure the surveillances are performed consistent with safe plant operation. However, many components affected by this restriction are designed such that they may be safely tested at power.

The proposed amendment will result in a reduction in the number of components that must be tested during shutdown conditions. This reduction in shutdown testing will improve the availability of systems while the plant is in a shutdown condition. Tests that cannot be performed safely at power will continue to be performed during shutdown conditions; however, performing component testing during shutdown conditions that duplicates testing performed at power is an unnecessary distraction for Operations and Maintenance personnel. Plant safety is not adversely affected and shutdown risk can be reduced by allowing credit to be taken for testing accomplished while at power, which reduces burden to plant personnel by eliminating duplicate testing.

Atoo 95-2168 REV. 7/99

Document Control Desk LR-N05-0031 100T 112005 The proposed amendment is consistent with wording in similar TS SR of NUREG-1433, 'Standard Technical Specifications General Electric Plants, BWR/4," and previous generic guidance regarding specific conditions for performing TS SR. In Generic Letter (GL) 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-month Fuel Cycle," the Nuclear Regulatory Commission (NRC) specifically recommends the elimination of the shutdown condition from TS SR. The intent of the restriction to perform surveillances uduring shutdown" is to ensure the surveillance is performed consistent with safe plant operation. In GL 91-04, the NRC recognized that the consideration of safe plant operation is valid for other surveillances that are performed during operational modes other than shutdown, but is not addressed by restricting the conduct of these surveillances. provides a description of the proposed changes. Attachment 2 provides the existing TS pages marked-up to show the proposed changes.

PSEG requests implementation within 60 days of receipt of the approved amendment. Approval of this change is requested by April 3, 2006 to support Hope Creek Generating Station refueling outage RF 13.

Should you have any questions regarding this request, please contact Mr. Paul Duke at (856) 339-1466.

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

Executed on 0// I/04: Sincerely, (Date)

George P. Barnes Site Vice President Hope Creek Generating Station Attachments (2)

Document Control Desk OCT 11205 LR-N05-0031 C Mr. S. Collins, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission Mr. S. Bailey, Project Manager - Hope Creek Mail Stop 08B1 Washington, DC 20555-0001 USNRC Senior Resident Inspector - Hope Creek (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P.O. Box 415 Trenton, NJ 08625 LCR H05-06 LR-N05-0031 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 CHANGE TO TECHNICAL SPECIFICATIONS REMOVAL OF PERFORMANCE RESTRICTIONS FROM SURVEILLANCE REQUIREMENTS Table of Contents

1. DESCRIPTION ....................................... .1
2. PROPOSED CHANGE ........................................ 1
3. BACKGROUND............................................................1
4. TECHNICAL ANALYSIS ........................................ 2
5. REGULATORY SAFETY ANALYSIS ...................................... 3 5.1 No Significant Hazards Consideration ........................................ 3 5.2 Applicable Regulatory Requirements/Criteria ........................................ 5
6. ENVIRONMENTAL CONSIDERATION ....................................... 6
7. REFERENCES ........................................ 6

ATTACHMENT 1 LCR H05-06 LR-N05-0031 CHANGES TO TECHNICAL SPECIFICATIONS

1. DESCRIPTION The proposed amendment revises certain eighteen-month Technical Specifications (TS) surveillance requirements (SR) by eliminating the condition that testing be conducted "during shutdown" or "during COLD SHUTDOWN or REFUELING' (i.e.,

shutdown conditions). The restriction to perform certain surveillance tests only during shutdown conditions is intended to ensure the surveillances are performed consistent with safe plant operation. However, many components affected by this restriction are designed such that they may be safely tested at power.

2. PROPOSED CHANGE The proposed changes will revise TS SR 4.1.5.d, footnote (a) to Table 4.3.2.1-1, footnote (a) to Table 4.3.5.1-1, TS SR 4.7.1.1.b, and TS SR 4.7.1.2.b to delete the words "during shutdown" from the text of the TS SR and table footnotes. In addition, proposed changes will revise TS SR 4.6.3.2 and TS SR 4.6.5.2.b to delete the words "during COLD SHUTDOWN or REFUELING" from the text of the TS SR. An editorial change to TS SR 4.6.5.2.b is needed following the deletion of the words 'During COLD SHUTDOWN or REFUELING" to begin the TS SR by capitalizing the first letter in "at".
3. BACKGROUND The Hope Creek Generating Station TS establish requirements for the operability of equipment necessary to safely operate the plant. Each TS Limiting Condition for Operation requires surveillance activities that establish the operability of the key systems or components necessary to accomplish the TS function. Each TS SR specifies the tests to be performed, the acceptance criteria, and the testing frequency. Some Hope Creek Generating Station TS have additional restrictions requiring the performance of certain TS SR during shutdown conditions.

The proposed amendment is consistent with wording in similar TS SR of NUREG-1433, "Standard Technical Specifications General Electric Plants, BWR/4," and previous generic guidance regarding specific conditions for performing TS SR. In Generic Letter (GL) 91-04, 'Changes in Technical Specification Surveillance Intervals to Accommodate a 24-month Fuel Cycle," the Nuclear Regulatory Commission (NRC) specifically recommends the elimination of the shutdown condition from TS SR. The intent of the restriction to perform surveillances "during shutdown" is to ensure the surveillance is performed consistent with safe plant operation. In GL 91-04, the NRC recognized that the consideration of safe plant operation is valid for other surveillances that are performed during operational modes other than shutdown, but is not addressed by restricting the conduct of these surveillances.

1

ATTACHMENT 1 LCR H05-06 LR-N05-0031 GL 91-04 states:

The staff concludes that the TS need not restrict surveillances as only being performed during shutdown. Nevertheless, safety dictates that when refueling interval surveillances are performed during power operation, licensees give proper regard for their effect on the safe operation of the plant. If the performance of a refueling interval surveillance during plant operation would adversely affect safety, the licensee should postpone the surveillance until the unit is shut down for refueling or is in a condition or mode that is consistent with the safe conduct of that surveillance.

The proposed amendment will allow certain eighteen-month TS SR previously performed while shutdown to be performed during power operation, and thereby, simplify and shorten the scheduling of testing and surveillance windows during a refueling outage. Risk is assessed and managed in accordance with 10 CFR 50.65(a)(4) prior to performing maintenance and surveillance activities both online and offline. Activities are scheduled to minimize outage times for TS required equipment. At certain thresholds of risk, contingency plans are required to maximize the reliability of the equipment relied upon for nuclear safety or power operation, and to safely recover from credible events that may further degrade the online risk level. Unacceptable levels of risk require deferral of the activity to an acceptable time in the schedule.

4. TECHNICAL ANALYSIS The proposed changes eliminate the current requirements to perform the identified surveillance testing only 'during shutdown" or 'during COLD SHUTDOWN or REFUELING" from certain TS. The restriction to perform certain surveillance tests only during shutdown conditions is intended to ensure the surveillances are performed consistent with safe plant operation. However, many components affected by this restriction are designed such that they may be safely tested at power. Many of the affected components are required by TS SR to be tested quarterly and are routinely tested at power. However, the existing TS SR with the restriction to be performed during shutdown conditions force additional redundant testing to be performed on a substantial number of components solely to meet the TS SR condition of "during shutdown" or 'during COLD SHUTDOWN or REFUELING". The TS SR testing frequency of at least once per eighteen months may have been already met by previous component testing performed at power, but all components must be tested during shutdown conditions to meet the current TS SR. Thus, the proposed change would allow credit to be taken for testing accomplished while at power to meet the eighteen-month TS SR and eliminate redundant testing.

The eighteen-month TS SR associated with this proposed amendment also involve testing of components (e.g., relays) that are coupled with safety related systems and components which interface with core cooling systems used during shutdown 2

ATTACHMENT 1 LCR H05-06 LR-N05-0031 conditions. Performance of this testing during shutdown conditions increases the shutdown risk (e.g., by adding challenges to core cooling systems and extending the time other safety systems are out of service). The proposed changes will result in a reduction of components that must be tested during shutdown conditions. This reduction in shutdown testing will improve the availability of systems while the plant is in a safe shutdown condition. Additionally, the redundant component testing performed during shutdown conditions is an unnecessary distraction for operation and maintenance personnel. Shutdown risk can be reduced by allowing credit to be taken for testing accomplished while at power.

The proposed amendment does not change the current type or frequency of TS SR. The proposed amendment deletes only the requirement to perform certain testing during shutdown conditions. Certain components can be tested only during plant shutdown in order to avoid a plant transient during power operation. Allowing testing to be performed either at shutdown or crediting testing performed at power maintains plant safety and reduces shutdown activities to be planned and performed, which will reduce the shutdown risk.

Removal of the shutdown condition from the requested TS will have no detrimental effect on the surveillance program because the obligation to determine the plant conditions required to safely and prudently perform the required surveillance tests on all affected components remains a PSEG Nuclear LLC responsibility. Some of the TS SR affected by this proposed change will continue to be performed in whole or in part during periods of plant shutdown. However, the testing conditions will be based on an evaluation of specific plant conditions with respect to the individual components, Hope Creek Generating Station plant design, and the requirements of the specific test.

The proposed editorial change has no impact on plant safety.

5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration PSEG Nuclear LLC (PSEG) has evaluated whether or not a significant hazards consideration is involved with the proposed changes to Technical Specification (TS) Surveillance Requirement (SR) 4.1.5.d, footnote (a)to Table 4.3.2.1-1, footnote (a) to Table 4.3.5.1-1, TS SR 4.6.3.2, TS SR 4.6.5.2.b, TS SR 4.7.1.1.b, and TS SR 4.7.1.2.b by focusing on the three standards set forth in 10 CFR 50.92, 'Issuance of amendment" as discussed below:
1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

3

ATTACHMENT I LCR H05-06 LR-N05-0031 The proposed changes permit PSEG to evaluate the conditions required to safely perform a TS SR. These surveillance tests verify that equipment will perform its intended safety function of mitigating an accident. No analyzed accident scenario is being revised. The initiating conditions and assumptions for accidents described in the Hope Creek Generating Station Updated Final Safety Analysis Report (UFSAR) remain as previously analyzed.

The proposed changes do not reduce the ability of the mitigating equipment to perform its safety function. The TS will continue to require the surveillance tests to be performed on an eighteen-month periodicity to verify operability. As a result, the ability of the mitigating equipment to perform its safety function is unaffected by the proposed change.

The capitalization change is proposed to improve readability and does not alter any requirement.

Based upon the above, the proposed changes will not involve a significant increase in the probability or consequences of an accident previously analyzed.

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 changes do not create the possibility of a new or different kind of accident from any accident previously evaluated in the UFSAR. No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed changes. Specifically, no new hardware is being added to the plant as part of the proposed change, no existing equipment is being modified, and no significant changes in operations are being introduced.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed changes will not alter any assumptions, initial conditions, or results of any accident analyses. The proposed changes to remove the requirement to perform certain testing during shutdown conditions allows 4

ATTACHMENT 1 LCR H05-06 LR-N05-0031 PSEG to evaluate the conditions needed to safely perform the required testing. There is no change to the frequency of testing or in the testing that is required. There is no change in the responsibility of PSEG to perform tests in a safe and responsible manner. Any changes to procedures will have to be individually evaluated to ensure that they do not reduce the margin of safety. The changes do not affect the ability of systems, structures or components to perform their safety related functions. In addition, the proposed changes do not affect the ability of the safety systems to ensure that the facility can be maintained in a shutdown or refueling condition for extended periods of time.

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

Based on the above, PSEG concludes that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of 'no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria The following regulatory requirements are applicable:

10 CFR 50.65(a)(4) - Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.

The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety.

The intent of the current restrictions to perform certain eighteen-month TS SR during shutdown conditions is to ensure that the TS SR is performed consistent with safe plant operation. Removal of the shutdown restriction will have no detrimental effect since the obligation to determine the plant conditions required to safely and prudently perform the required TS SR remains a PSEG requirement.

The performance of certain eighteen-month TS SR during power operation will be in accordance with 10 CFR 50.65.

In conclusion, based on the considerations discussed above:

1) There is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, 5

ATTACHMENT 1 LCR H05-06 LR-N05-0031

2) Such activities will be conducted in compliance with the Commission's regulations; and
3) Issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
6. ENVIRONMENTAL CONSIDERATION PSEG has determined the proposed amendment relates to changes in a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or relates to changes in an inspection or a surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase inthe amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed change is not required.
7. REFERENCES
1. The NRC has approved a similar license amendment for the Shearon Harris Nuclear Power Plant when it issued Amendment No. 77 on April 14,1998 (TAC No. M98271)
2. The NRC has approved a similar license amendment for the Beaver Valley Power Station Unit 2 when it issued Amendment No. 118 on October 13,2000 (TAC No. MA9865)
3. The NRC has approved a similar license amendment for Donald C.

Cook Nuclear Plant Unit 1 and Unit 2 when it issued Amendments 275 and 257 on April 22, 2003 (TAC Nos. MB5695 and MB5696) 6

ATTACHMENT 2 LCR H05-06 LR-N05-0031 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Hope Creek Generating Station Facility Operating License NPF-57 are affected by this change request:

Technical Specification Paae 4.1.5.d 3/4 1-20 Table 4.3.2.1-1 Footnote (a) 3/4 3-31 Table 4.3.5.1-1 Footnote (a) 3/4 3-55 4.6.3.2 3/4 6-18 4.6.5.2.b 3/4 6-49 4.7.1.1 .b 3/4 7-2 4.7.1.2.b 3/4 7-4

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

b. At least once per 31 days by:
l. Verifying the continuity of the explosive charge.
2. Determining that the available weight of sodium pentaborate is greater than or equal to 5,776 lbs and the concentration of boron in solution is within the limits of Figure 3.1.5-1 by chemical analysis.*
3. Verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.
c. Demonstrating that, when tested pursuant to Specification 4.0.5, the minimum flow requirement of 41.2 gpm, per pump, at a pressure of greater than or equal to 1255 psig is met.
d. At least once per 18 months doing oh
1. Initiating one of the standby liquid control system subsystem, including an explosive valve, and verifying that a flow path from the pumps to the reactor pressure vessel is available by pumping demineralized water into the reactor vessel and verifying that the relief valve does not actuate.

The replacement charge for the explosive valve shall be from the same manufactured batch as the one fired or from another batch which has been certified by having one of that batch successfully fired. Both injection subsystems shall be tested in 36 months.

2. **Demonstrating that all heat traced piping between the storage tank and the injection pumps is unblocked and then draining and flushing the piping with demineralized water.
3. Demonstrating that the storage tank heaters are OPERABLE by verifying the expected temperature rise of the sodium pentaborate solution in the storage tank after the heaters are qenergized.
  • This test shall also be performed anytime water or boron is added to the solution or when the solution temperature drops below 70'F.
    • This test shall also be performed whenever both heat tracing circuits have been found to be inoperable and may be performed by any series of sequential, overlapping or total flow path steps such that the entire flow path is included.

HOPE CREEK 3/4 1-20 Amendment No. 11

TABLE 4.3.2.1-1 (Continued)

ISOLATION ACTUATION INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL OPERATIONAL CHANNEL FUNCTIONAL CHANNEL CONDITIONS FOR WHICH TRIP FUNCTION CHECK TEST CALIBRATION SURVEILLANCE REQUIRED HIGH PRESSURE COOLANT INJECTION SYSTEM ISOLATION (Continued)

h. HPCI Torus Compartment Temperature - High NA Q R 1, 2, 3
i. Drywell Pressure - High NA Q R 1, 2, 3
j. Manual Initiation NA R NA 1, 2, 3
7. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION
a. Reactor Vessel Water Level -

Low, Level 3 S Q R 1, 2, 3

b. Reactor Vessel (RHR Cut-in Permissive) Pressure - High NA Q R 1, 2, 3
c. Manual Initiation NA Q(a) NA 1, 2, 3
    • When any turbine stop valve is greater than 90% open and/or when the key-locked bypass switch is in the Norm position.
  1. Refer to Specification 3.1.5 for applicability. 9 (a) Manual initiation switches shall be tested at least once per 18 months e All other circuitry associated with manual initiation shall receive a CHANNEL FUNCTIONAL TEST at least once per 92 days as part of circuitry required to be tested for automatic system isolation.

(b) Each train or logic channel shall be tested at least every other 92 days.

HOPE CREEK 3/4 3-31 Amendment No. 146

TABLE 4.3.5.1-1 REACTOR CORE ISOLATION COOLING SYSTEM ACTUATION INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CHANNEL FUNCTIONAL CHANNEL FUNCTIONAL UNITS CHECK TEST CALIBRATION

a. Reactor Vessel Water Level -

Low Low, Level 2 S Q R

b. Reactor Vessel Water Level - High, Level 8 S Q R
c. Condensate Storage Tank Level - Low NA Q R
d. Manual Initiation NA Q(a) NA (a) Manual initiation switches shall be tested at least once per 18 months Z g.ele w 1KAll other circuitry associated with manual initiation shall receive a CHANNEL FUNCTIONAL TEST at least once per 92 days as part of circuitry required to be tested for automatic system actuation.

HOPE CREEK 3/4 3-55 Amendment No. 62

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS 4.6.3.1 Each primary containment isolation valve shown in Table 3.6.3-1 shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by cycling the valve through at least one complete cycle of full travel and verifying the specified isolation time.

4.6.3.2 Each primary containment automatic isolation valve shown in Table 3.6.3-1 shall be demonstrated OPERABLE Jeein~j COLD SIIUTDOWNA nor=JLIu2Qat least once per 18 months by verifying that on a containment isolation test signal each automatic isolation valve actuates to its isolation position.

4.6.3.3 The isolation time of each primary containment power operated or automatic valve shown in Table 3.6.3-1 shall be determined to be within its limit when tested pursuant to Specification 4.0.5.

4.6.3.4 At least once per 18 months, verify that a representative sample of reactor instrumentation line excess flow check valves shown in Table 3.6.3-1 actuates to the isolation position on a simulated instrument line break signal.

4.6.3.5 Each traversing in-core probe system explosive isolation valve shall be demonstrated OPERABLE*:

a. At least once per 31 days by verifying the continuity of the explosive charge.
b. At least once per 18 months by removing the explosive squib from at least one explosive valve such that each explosive squib in each explosive valve will be tested at least once per 90 months, and initiating the explosive squib. The replacement charge for the exploded squib shall be from the same manufactured batch as the one fired or from another batch which has been certified by having at least one of that batch successfully fired. No squib shall remain in use beyond the expiration of its shelf-life or operating life, as applicable.

HOPE CREEK 3/4 6-18 Amendment No. 132

CONTAINMENT SYSTEMS SECONDARY CONTAINMENT AUTOMATIC ISOLATION DAMPERS LIMITING CONDITION FOR OPERATION 3.6.5.2 The secondary containment ventilation system (RBVS) automatic isolation dampers shown in Table 3.6.5.2-1 shall be OPERABLE with isolation times less than or equal to the times shown in Table 3.6.5.2-1.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3 and *.

ACTION:

With one or more of the secondary containment ventilation system automatic isolation dampers shown in Table 3.6.5.2-1 inoperable, maintain at least one isolation damper OPERABLE in each affected penetration that is open and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> either:

a. Restore the inoperable dampers to OPERABLE status, or
b. Isolate each affected penetration by use of at least one deactivated damper secured in the isolation position, or
c. Isolate each affected penetration by use of at least one closed manual valve or blind flange.

Otherwise, in OPERATIONAL CONDITION 1, 2 or 3, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Otherwise, in Operational Condition *, suspend handling of recently irradiated fuel in the secondary contaihment and operations with a potential for draining the reactor vessel. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.6.5.2 Each secondary containment ventilation system automatic isolation damper shown in Table 3.6.5.2-1 shall be demonstrated OPERABLE:

a. Prior to returning the damper to service after maintenance, repair or replacement work is performed on the damper or its associated actuator, control or power circuit by cycling the damper through at least one complete cycle of full travel and verifying the specified isolation time.
b. Peeing COLD CIHUTDO':T 7 or lErUDLIUI/ At least once per 18 months by verifying that on a containment isolation test signal each isolation damper actuates to its isolation position.
c. By verifying the isolation time to be within its limit at least once per 92 days.

HOPE CREEK 3/4 6-49 Amendment No. 146

PLANT SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

C. In OPERATIONAL CONDITION 4 or 5 with the SACS subsystem, which is associated with safety related equipment required OPERABLE by Specification 3.5.2, having two SACS pumps or one heat exchanger inoperable, declare the associated safety related equipment inoperable and take the ACTION required by Specification 3.5.2.

d. In OPERATIONAL CONDITION 5 with the SACS subsystem, which is associated with an RHR loop required OPERABLE by Specification 3.9.11.1 or 3.9.11.2, having two SACS pumps or one heat exchanger inoperable, declare the associated RHR system inoperable and take the ACTION required by Specification 3.9.11.1 or 3.9.11.2, as applicable.
e. In OPERATIONAL CONDITION 4, 5, or **, with one SACS subsystem, which is associated with safety related equipment required OPERABLE by Specification 3.8.1.2, inoperable, realign the associated diesel generators within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to the OPERABLE SACS subsystem, or declare the associated diesel generators inoperable and take the ACTION required by Specification 3.8.1.2. The provisions of Specification 3.0.3 are not applicable.
f. In OPERATIONAL CONDITION 4, 5, or **, with only one SACS pump and heat exchanger and its associated flowpath OPERABLE, restore at least two pumps and two heat exchangers and associated flowpaths to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or, declare the associated safety related equipment inoperable and take the associated ACTION requirements.

SURVEILLANCE REQUIREMENTS 4.7.1.1 At least the above required safety auxiliaries cooling system subsystems shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve in the flow path that is not locked, sealed or otherwise secured in position, is in its correct position.
b. At least once per 18 months id . egwwby verifying that: 1)

Each automatic valve servicing safety-related equipment actuates to its correct position on the appropriate test signal(s), and 2)

Each pump starts automatically when its associated diesel generator automatically starts.

HOPE CREEK 3/4 7-2 Amendment No. 75 1

PLANT SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

b. In OPERATIONAL CONDITION 4 or 5:

With only one station service water pump and its associated flowpath OPERABLE, restore at least two pumps with at least one flow path to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or declare the associated SACS subsystem inoperable and take the ACTION required by Specification 3.7.1.1.

c. In OPERATIONAL CONDITION *:

With only one station service water pump and its associated flowpath OPERABLE, restore at least two pumps with at least one flow path to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or declare the associated SACS subsystem inoperable and take the ACTION required by Specification 3.7.1.1. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.7.1.2 At least the above required station service water system loops shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power operated or automatic), servicing safety related equipment that is not locked, sealed or otherwise secured in position, is in its correct position.
b. At least once per 18 months 4rit1 RhuI% $ by verifying that:
1. Each automatic valve servicing non-safety related equipment actuates to its isolation position on an isolation test signal.
2. Each pump starts automatically when its associated diesel generator automatically starts.

HOPE CREEK 3/4 7-4 Amendment No. 75 l

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