LR-N08-0150, Relief Request for Third Interval Inservice Inspection Program for Examinations and Tests of Snubbers and Associated License Amendment Request

Relief Request for Third Interval Inservice Inspection Program for Examinations and Tests of Snubbers and Associated License Amendment Request

ML082200316
Person / Time
Site:	Hope Creek
Issue date:	07/30/2008
From:	Barnes G Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N08-0150
Download: ML082200316 (40)

Text

PSEG Nuclear LLC PO. Box 236,, Hancocks Bridge, NJ 08038-0236 0 PSEG NuclearL.L. C.

10 CFR 50.55a 10 CFR 50.90 LR-N08-0150 JUL 3 0,,2008 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

Relief Request for Third Interval Inservice Inspection Program for Examinations and Tests of Snubbers and Associated License Amendment Request

Reference:

1) Letter from D. Garchow (PSEG Nuclear LLC) to USNRC, July 3, 2002

.(Accession No. ML021970412)

2) Letter from G. Salamon (PSEG Nuclear.LLC) to USNRC, December 18, 2002 (Accession No. ML023610335) 3 Letter from Jeffrie Keenan (PSEG Nuclear LLC) to USNRC, December 12, 2007 (Accession No. ML073531254)

In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(i), PSEG Nuclear LLC (PSEG), hereby requests NRC approval of the attached request associated with the third 10-year inservice inspection (ISI) interval for the Hope Creek Generating Station (HCGS). This relief request provides an alternative to the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation .and Maintenance of Nuclear Power Plants, 2001 Edition through the 2003 Addenda, Section ISTD-5200, "Inservice Operational Readiness Testing." The proposed alternative would permit HCGS to adopt ASME Code Case OMN-1 5 to extend test intervals for snubber operational readiness testing, based on acceptable test performance. The proposed alternative would provide an acceptable level of.quality and safety.

A

LR-N08-0150 JUL ý 0 2008 Page There are three elements to this request:

" Obtain authorization to use OMN-15 Code Case as an alternative to ISTD-5200 and. ISTD-5240.

• Relocate snubber surveillance requirements from Technical Specifications (TS) to the HCGS Technical Requirements -Manual (TRM).

• Incorporate new Limiting Condition for Operation (LCO) 3.0.8 into HCGS TS.

Snubber operational readiness testing is currently performed in accordance with the requirements of HCGS Technical Specification (TS) 3/4.7.5, "Snubbers," in lieu of the ASME Code, Section Xl requirements. However, after restart from HCGS refueling outage RF15 (Spring.2009), PSEG intends to adopt Subsection ISTD, "Inservice Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Power Plants,"

ASME OM Code, 2001 Edition through the .2003 Addenda, for examinations and tests of HCGS snubbers, as permitted in 10 CFR 50.55a(b)(3)(v), in place of the requirements for snubbers in Section Xl, ]WF-5200(a) and (b) and IWF-5300(a) and (b). The relief request in Attachment 1 would ýbe implemented in conjunction with adoption of subsection ISTD.

The-proposed alternative would permit use of the alternative test interval rules specified in ASME OM Code Case, OMN-15, published in the 2004 Edition of the ASME OM Code. Use of extended test intervals for snubber operational readiness testing is justified on the basis of the high demonstrated reliability of the Lisega hydraulic snubbers installed in HCGS.

PSEG originally proposed to extend the testing interval for HCGS snubbers, based upon exceptional snubber performance, in Reference 1. After discussion with the NRC staff, this request was subsequently withdrawn (Reference 2) since no industry initiative or consensus document had been published to validate such a request. Subsequent to the initial request, ASME Code Case OMN-15 has been published which describes a method to extend the testing interval for snubbers which demonstrate a high level of operability performance.

Pursuant to 10 CFR 50.90, PSEG also requests an amendment to Facility Operating License No. NPF-57 for. HCGS in order to implement the proposed alternative in . The proposed license amendment will modify TS .by relocating the current snubber TS requirements to the HCGS Technical Requirements Manual (TRM) and adding LCO 3.0.8 for inoperable snubbers to the TS. The associated TS Bases section would also be relocated. These changes are consistent with changes previously approved by the NRC for other reactor licensees and with Standard Technical Specifications, including Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-372 Revision 4. to this letter describes the proposed changes and provides justification for

-the changes. PSEG has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92. Attachment 3

LR-N08-0150 JUL 3 0,2008 Page 3 provides the marked up"Technical Specification pages. Attachment 4 provides the marked up Technical Specifications Bases pages. These Bases pages are being submitted for information only and -do not require issuance by the NRC..

-Tosupport planning.for the Fall 2010 HCGS refueling outage, PSEGrequestsapproval ,

of the proposed changes by August 31, 2009, with implementation -to be completed within 90 days. Upon implementation of the proposed changes, PSEG will no longer use Relief Request HC-13R-02, currently under NRC review (Reference 3), for snubber inservice examinations and tests. Upon implementation, PSEG will make appropriate changes to the TRM reflecting adoption of Subsection ISTD.

Regulatory commitments contained within this submittal are summarized in Attachment 5.

These proposed TS changes have been reviewed by the Plant Operations Review Committee, and the Nuclear Safety Review Board. We are notifying the State of New Jersey of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Mr. Paul Duke at 856-339-1466.

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

Executed on 7/K 6 /c (date)

Sincerely, George P. Barnes Site Vice President Hope Creek Generatingr Station Attachments (5)

1. Relief Request HC-13R-04

2. Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

3. Markup of Technical Specification pages

4. Markup of Technical Specification Bases pages

5. List of Commitments

LR-N08-0150 July 30, 2008 Page 4 cc: S. Collins, Regional Administrator - NRC Region I R. Ennis, Project Manager - USNRC NRC Senior Resident Inspector - Hope Creek P. Mulligan, Manager IV, NJBNE

ATTACHMENT 1 Relief Request HC-13R-04

-Hope Creek Generating Station NRC Docket No. 50-354

ISI ProgramPlan Hope Creek GeneratingStation, Third Interval 10 CFR 50.55a RELIEF REQUEST: HC-13R-04 Revision 0 (Page 1 of 5)

Request for Relief for Alternate Testing and Examination Requirements for Snubbers In Accordance with 10 CFR 50.55a(a)(3)(i) 1.0 ASME CODE COMPONENTS AFFECTED:

Snubbers within the scope described in OM Code Subsection ISTA- 1100.

2.0 APPLICABLE CODE EDITION AND ADDENDA:

The InserviceInspection program for examination and testing of snubbers will be based on the American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code, Section ISTD, 2001 Edition through the 2003 Addenda.

3.0 APPLICABLE CODE REQUIREMENT:

The regulation in 10 CFR 50.55a (b)(3)(v) permits the use of Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," ASME OM Code, 1995 Edition through the 2001 edition with 2003 addenda, in place of the requirements for snubbers in ASME Section XI, IWF-5200(a), IWF-5200(b), IWF-5300(a) and IWF-5300(b), by making appropriate changes to their technical specifications or licensee controlled documents.

ISTD-5200 specifies that snubbers shallbe tested for operational readiness during each fuel cycle.

ISTD-5240 specifies that tests of snubbers from the facility shall be performed every fuel cycle.

4.0 REASON FOR REQUEST:

ISTD-5200 and ISTD-5240 require snubber operational readiness testing during each fuel cycle. Pursuant to 10 CFR 50.55a (a)(3)(i), relief is requested from Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," ASME OM Code, 2001 edition with 2003 addenda, on the basis that the proposed alternative of utilizing the initial sample size and extended test intervals specified in ASME OM Code Case OMN-15, provides an acceptable level of quality and safety. OM Code Case, OMN- 15, 2004 Edition through 2006 Addenda, has not yet been addressed by the NRC.

Use of the extended test intervals would result in significant reductions in maintenance costs and radiologicaPexposure to plant personnel, while maintaining the same or better

ISI ProgramPlan Hope Creek GeneratingStation, Third Interval 10 CFR 50.55a RELIEF REQUEST: HC-13R-04 Revision 0 (Page 2 of 5) confidence level in snubber operational readiness as that provided by following ASME OM Code, ISTD requirements.

5.0 Proposed Alternative And Basis For Use:

Proposed Alternative As an alternative to performing operational readiness testing during each fuel cycle, PSEG Nuclear LLC (PSEG) requests relief to use the alternative test interval rules specified in ASME OM Code Case, OMN-15, published in the. 2004 Edition of the ASME OM Code and revised in the 2006 Addenda.

Snubber preservice and inservice visual examinations will be conducted using the VT-3 visual examination method described in IWA-2213 of ASME B&PV Code,Section XI.

Integral and non-integral attachments for snubbers, including lugs, bolting, pins and clamps, shall be visually examined in accordance with ASME Section XI, Subsection IWF.

Repair/replacement activities performed on snubbers shall be in accordance with Article IWA-4000 of the ASME B&PV Code,Section XI.

Basis for Use ASME OMN- 15 Code Case describes a method to extend the testing interval for snubbers. Code Case OMN-15 has not yet been addressed by the NRC under RG 1.192, or RG 1.193. However, based on the demonstrated reliability of the HCGS snubbers, the requirements in Code Case OMTN-1 5 provide the same confidence level or better than those resulting from the use of ISTD-5200 and ISTD-5240.

HCGS recognized snubber performance as an area for improvement in 1987. Improved performance would result in fewer tests, thereby reducing maintenance costs and radiological exposure to plant personnel. After substantial research, the Lisega snubber was chosen to replace all of the PSA mechanical snubbers as well as E-Systems hydraulic snubbers installed at the HCGS. Snubber replacements were completed in 1997. After four subsequent operating cycles without a test failure, it was determined to pursue an extended test interval based upon improved snubber performance. As a result of initial discussions with NRC staff, PSEG supported the development of an ASME Code Case that would provide an industry consensus document and a method to accomplish this.

Since the installation of the improved snubbers at HCGS, after seven operating cycles there have been only 2 test failures in 345 tests, compared to the seven previous operating

ISI ProgramPlan Hope Creek GeneratingStation, Third Interval 10 CFR 50.55a.RELIEF REQUEST: HC-13R-04 Revision 0 (Page 3 of 5) cycles in which there were 103 test failures including 38 test failures in RF0 1. This demonstrates the significant improvement in snubber performance at HCGS.

With regard to the implementation of the OMN- 15 Code Case, HCGS snubber population includes more than 370 snubbers, therefore the test plan specified in ONIN-15 for this size population is Test Plan 1. Under the OMN-15 Code Case, Test Plan 1, the initial test sample for the HCGS population will be 52 rather than the 37 sample under the previous plan. Testing an initial sample of 52 snubbers meets the statistical basis for the OMN-15 Code Case which demonstrates a higher minimum operational readiness level than the existing ISTD Code. With the HCGS test population of 630 snubbers, there would have to be an uncharacteristically large number of snubber test failures to fall below the 95/90 confidence level presently required by the 37 plan specified in Subsection ISTD. Based upon site specific testing experience at HCGS since the installation of the replacement snubbers, this is highly unlikely to occur, and would be a significant departure from the HCGS experience over the past seven operating cycles where there have been only 2 failures in 345 tests.

With regard to implementation of other approved Code cases relating to snubbers, PSEG will not apply the OMN-13 visual examination extended interval Code Case. It is recognized that the combined examination, testing and service life monitoring requirements defined in ISTD result in a comprehensive approach toward maintaining snubber health and operational readiness. Visual examinations will be performed in accordance with the requirements of Table ISTD-4252-1 of Subsection ISTD.

The Lisega hydraulic snubbers installed in HCGS are designed to operate with reduced degradation that can cause snubbers to fail. Design features that contribute to their demonstrated high reliability include a sealed and pressurized design to prevent moisture intrusion; the use of corrosion resistant materials; non-metallic guide rings to isolate metal to metal sliding surfaces; and the use of hydraulic fluids qualified for long service life. To date, there have been two Lisega functional test failures in a total 345 tests during the previous seven test campaigns since 1997. This reveals a test failure rate of below 1% over this entire period.

Snubber visual inspections will continue to be performed in accordance with the requirements of the OM ISTD Code to provide assurance of snubber operational readiness. The interval for visual inspection depends on the number of unacceptable snubbers found in proportion to the size of the population or category for each type of snubber included in the previous inspection. The manufacturer's guidance for service life monitoring, (Reference 5), states that the majority of information concerning a Lisega hydraulic snubber's condition and application environment can be obtained by visual examination.

ISI ProgramPlan Hope Creek GeneratingStation, Third Interval 10 CFR 50.55a RELIEF REQUEST: HC-13R-04 Revision 0 (Page 4 of 5)

The service life of snubbers will be monitored to ensure that the service life is not

• exceeded between surveillance inspections. The service life of a snubber is evaluated via manufacturer input and information through consideration of the snubber service conditions and associated installation and maintenance records. The maximum expected service life of critical snubber components is extended or shortened based on monitored test results and failure history. Critical parts are required to be replaced so that the

• maximum service life will not be exceeded during a period when snubber operational readiness is required. Based on guidance from the manufacturer (Reference 5), PSEG has determined the service life of Lisega hydraulic snubbers installed in HCGS to be 21 years.

Functionally testing a representative sample of these snubbers once per 18 months requires a significant -expenditure of resources and subjects plant personnel to radiological exposure while providing a negligible benefit. Extending the interval for functional testing as allowed in Code Case OMN- 15 will reduce maintenance costs and occupational radiological exposure while maintaining the required assurance of functional reliability for the hydraulic snubbers.

8.0 DURATION OF PROPOSED ALTERNATIVE:

Relief is requested for the remainder of the Third Ten-Year Inspection Interval for Hope Creek Generating Station.

9.0 PRECEDENTS

Extended surveillance intervals have been granted for snubbers based upon reliable performance.

0 GL 90-09: Alternative Requirements for Snubber visual examination intervals

• OMN-13 Code Case: Requirements for extending snubber inservice visual examination interval.

10.0 REFERENCES

1. D. Garchow (PSEG) letter to USNRC dated July 3, 2002, Document LR-N02-0229 requesting increased snubber test interval

2. White Paper - Mathematical Basis for ASME OMN-15 Code Case Prepared for Electric Power Research Institute.

3. ASME OM Code, 2001 Edition with 2003 Addenda

ISI ProgramPlan Hope Creek GeneratingStation, Third Interval 10 CFR 50.55a RELIEF REQUEST: HC-13R-04 Revision 0 (Page 5 of 5)

4. ASME Code Case OMN-15, 2004 Edition through 2006 Addenda

5. Lisega Inc. letter to Lisega Users Group member plants, dated March 29, 2001, "Service Life, of Lisega Hydraulic Snubbers"

ATTACHMENT 2 License Amendment Request Hope Creek Generating ,Station NRC Docket No. 50-354 Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

Subject:

Relocation of Technical Specification 3/4.7.5 and Addition of LCO 3.0.8 Regarding Snubbers

5.0 REGULATORY ANALYSIS

5.1 No-Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria

7.0 REFERENCES

LR-N08-0150 LAR H08-03 Page 1 of 8 DESCRIPTION OF PROPOSED CHANGES, TECHNICAL ANALYSIS, AND REGULATORY ANALYSIS

1.0 DESCRIPTION

In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) requests the following amendment to Appendix A, Technical Specifications (TS), of Facility Operating License NPF-57 for Hope Creek Generating Station (HCGS). The proposed change would revise the Operating License by relocating Technical Specification (TS) requirements for snubbers to the HCGS Technical Requirements Manual (TRM) and adding a new Limiting Condition for Operation (LCO) 3.0.8 to the TS.

Relocating the snubber TS requirements to the TRM would allow PSEG to revise snubber testing requirements in accordance with 10 CFR 50.59. This change is consistent with NUREG-1433, Rev. 3.0, "Standard Technical Specifications, General Electric Plants, BWR/4."

LCO 3.0.8 would provide a delay time for entering a supported system TS when the inoperability is due solely to an inoperable snubber, if risk is assessed and managed.

The proposed addition of LCO 3.0.8 is consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-372 Revision 4. The availability of this TS improvement was published in the Federal Register on May 4, 2005 as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 PROPOSED CHANGE

TS 3/4.7.5, "Snubbers," would be removed from the TS and relocated to-the HCGS TRM. In addition, TS 6.10.3.1 which refers to Technical Specification 4.7.5, would be removed from the TS and relocated to the TRM.

The proposed change would add a new LCO 3.0.8 to-the TS. This new LCO states:

When one or more required snubbers are unable to perform their associated

-support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one-train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or

b. the snubbers not able to perform -their associated support function(s) are associated with more than one train or subsystem of a multiple train or

Attachment 2 LR-N08,0150 LAR H08-03 Page 2 of 8 subsystem supported- system and are able to perform their associated.

support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) .

shall be declared not met.

• Marked up TS pages are provided in Attachment 3. Marked up TS Bases pages are provided in Attachment 4. These Bases pages are being submitted for information only and do not require issuance by the NRC. PSEG will implement the TS Bases changes in .accordance with the TS Bases Control Program.

3.0 BACKGROUND

Snubbers -are devices that provide restraint to a -component or system during the sudden application of forces, but allow essentially free motion during thermal movement. Snubbers function to ensure that the structural integrity of the reactor coolant system and other safety related systems is maintained during and following a seismic or other event initiating dynamic loads.

Snubbers are chosen in lieu of rigid supports in areas where restricting thermal growth during normal operation would induce excessive stresses in the piping nozzles or other equipment. Although they are classified as component standard supports, they are not designed to provide any transmission of force during normal plant operations. However, in the presence of dynamic transient loadings, which are induced by seismic events as well as by plant accidents and transients, a snubber functions as a rigid support. The location and size of the snubbers are determined by stress analysis based on different combinations of load conditions, depending on the design classification of the particular piping.

TS 3/4.7.5 currently contains requirements for snubber operability-and surveillance testing. With one or more snubbers inoperable, the required TS Action is to replace or restore the inoperable snubber(s) to operable status and perform an engineering

-evaluation of the supported component within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Otherwise, the supported system is required to be declared inoperable.

As discussed below, requirements for snubber operability and surveillance testing are not required by 10 CFR 50.36(d)(2)(ii) to be included in the TS. Relocating TS 3/4.7.5 to the TRM would permit snubber requirements to be revised in accordance with 10 CFR 50.59 without requiring a license amendment. The TRM is controlled as a

.procedure described in the Updated Final Safety Analysis Report (UFSAR). Changes to the TRM are subject to review in accordance with 10 CFR 50.59.

The NRC has taken the position that relocating snubber requirements to a licensee-controlled document effectively eliminates the'72-hour delay to enter the TS actions for

Attachment .2 LR-N08-0-150 LAR H08-03 Page 3 of 8 supported equipment when snubbers.are unable to perform their required support function. TSTF-372 Revision 4 resolves this discrepancy by adding LCO 3.0.8. The availability of this TS improvement was published in the Federal Register on May 4, 2005 as part of the consolidated line item improvement process (CLIIP).

4.0 TECHNICAL ANALYSIS

Relocation of TS 3/4.7.5 to the TRM The proposed change would remove TS 3/4.7.5, "Snubbers," from the TS and relocate it to the HCGS TRM. As discussed below, the snubber TS requirements do not meet any of the four criteria in 10 CFR 50.36(d)(2)(ii) for inclusion in the TS.

1. Snubbers are not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Therefore, the HCGS snubbers do not satisfy Criterion 1.

2. Snubbers are design features used to prevent unrestrained pipe motion under dynamic loads as might occur during an earthquake or severe transient. However, the snubbers are not explicitly considered in the accident analysis and are not considered a required initial condition for a design basis accident or transient to maintain the integrity of a fission product barrier. The effects of an inoperable snubber will be controlled by theTechnical Specification requirements of the supported system. The availability of the snubbers is assured based -on the performance of periodic inspections and testing. Therefore, the HCGS snubbers do not satisfy Criterion 2.

3. Safety-related snubbers are design-features that function during accidents or severe transients to prevent the propagation of an event to systems that are part of the primary success path for accident mitigation. However, snubbers are not explicitly considered in the accident analysis, but are a structural design feature whose operation is -assured by an inspection program. The snubbers are not part of the primary success path for accident mitigation; therefore the HCGS snubbers do not satisfy Criterion 3.

4. Operational experience or probabilistic safety assessment have not shown

.snubber performance to be significant to the public health and safety.

Therefore, the HCGS snubbers do not satisfy Criterion 4.

Removal of TS 3/4.7.5, "Snubbers," from the TS and relocation to the HCGS TRM is consistent with NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4." Changes to the TRM are subject to review in accordance with LR-N08-0150 LAR H08-03 Page 4 of 8 10 CFR 50.59. Therefore, the functionality and testing of snubbers will continue to be adequately assured.

TS 6.10.3.1, which specifies that retention requirements for "records of the snubber service life monitoring pursuant to Technical Specification 4.7.5," would -also-be --..........

relocated to the TRM. Record retention requirements are also located in 10 CFR 50, Appendix B, and in 10 CFR 50.71. It is not necessary to include redundant or additional requirements in the TS administrative controls. Removal of record retention requirements from the TS and relocation to the HCGS TRM is consistent with NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4."

Addition ofTS LCO 3.0.8 - Applicability of Published Safety Evaluation PSEG has reviewed the safety evaluation dated May.4, 2005 as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-372. PSEG has concluded that the justifications presented in the TSTF:proposal and the safety evaluation prepared by the NRC staff are applicable to HCGS and justify this amendment for the incorporation of the changes to the HCGS TS.

Addition of TS LCO 3.0.8 - Optional Changes and Variations PSEG is not proposing any variations or deviations from the TS changes described in TSTF-372, Revision 4 or the NRC staffs model safety evaluation dated May 4, 2005.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration PSEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed change to relocateTS 3/47.5 to theTRM is administrative in nature and does not involve the modification of any plant equipment or affect basic plant operation. Snubber operability and surveillance requirements will be contained in the TRM to ensure design assumptions for accident mitigation are maintained.

The proposed change to add LCO 3.0.8 allows a delay time for entering a supported system technical specification (TS) when the inoperability is due.solely to an inoperable snubber if risk is assessed and managed. Entrance into TS actions .or delaying entrance into actions is not an initiator of any accident LR-N08-0150 LAR H08-03 Page 5 of 8 previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The consequences of an accident while relying on allowance provided by proposed LCO 3.0.8 are no different than the consequences of an accident while relying on the current TS required actions in effect without the allowance provided by proposed LCO 3.0.8.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No. ....

The proposed change to relocate TS 3/4.7.5 to the TRM is administrative and does not involve any physical alteration of plant equipment. The proposed change does not change the method by which any safety-related system performs its function. As such, no new or different types of equipment will be installed, and the basic operation of installed equipment is unchanged. The methods governing plant operation and testing remain consistent with current safety analysis assumptions. Therefore, -the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change to add LCO 3.0.8 does not involve a physical alteration of the plant (no new or different type of equipment will be installed). Allowing delay times for entering supported system TS when inoperability is due solely to inoperable snubbers, if risk is assessed and managed, will not introduce new failure modes or effects.

Therefore, the proposed change does not create the possibility of a new or different-kind of accident from any previously evaluated.

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

Response: No.

The proposed change to relocate TS 3/4.7.5 to the TRM is administrative in nature, does not negate any existing requirement, and does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or safety system settings-that would adversely affect plant safety as.a result of the proposed change. Margins of LR-N08-0150 LAR H08-03 Page 6 of 8 safety are unaffected by requirements that are retained, but relocated from the TS to the TRM.

The proposed change to add LCO 3.0.8 toTS allows a delay time before

- declaring -supported TS systems. inoperable when the associated snubber(s) .....

cannot perform the required safety function. The proposed change retains an allowance in the current HCGSTS while upgrading it to be more conservative for snubbers supporting multiple trains or sub-systems of an associated system.

The updated TS will continue to provide an adequate margin of safety for plant operation upon incorporation of LCO 3.0.8. The station design and safety analysis assumptions provide margin in the form of redundancy to account for periods of time when system capability is reduced.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

.Based on the above, PSEG concludes that the proposed amendment presents 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 10 CFR 50.36 requires that the TSs include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls and states also that the Commission may include additional TSs as it finds to be appropriate. However, the regulation does not specify the particular TSs to be included in a plant's license.

The regulation sets forth four criteria to be used in determining whether a limiting condition for operation (LCO) is required to be included in the TS, as follows:

(1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition .of a design basis accident or transient analysis that either

-assumes the failure of or presents a challenge to the integrity of a fission product barrier;

• (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes thefailure of or presents a challenge to the integrity of a-fission product barrier; or

ýLR-N08-0150 LAR H08-03 Page 7 of 8 (4) a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Existing LCOs and related surveillances included as TS requirements which fall within or satisfy any of the criteria must be retained in the TSs, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.

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, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.3 Addition of TS LCO 3.0.8 - Verification and Commitments As discussed in the notice of availability published in the Federal Register on May 4, 2005 for this TS improvement, plant-specific verifications were performed as follows:

The licensee will establish TS Bases for LCO 3.0.8 which provide guidance and details on how to implement the new requirements. LCO 3.0.8 requires that risk be managed and assessed. The Bases will also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one

-or more snubbers are not able to perform their associated support function. Finally, HCGS has a -Bases Control Program consistent with Section 5.5 of the STS.

6.0 ENVIRONMENTAL CONSIDERATION

PSEG has reviewed the environmental~evaluation included in the model safety evaluation dated May 4,'2005 as part ofthe CLIIP. PSEG has concluded that the staff's findings presented in that evaluation are applicable to HCGS and the evaluation is hereby incorporated by reference for this application.

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in thetypes or significant increase in the LR-N08-0150 LAR H08-03 Page 8 of 8 amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection -with the proposed amendment.

7.0 REFERENCES

1.. NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4."

2. Federal Register Notice, -"Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding the Addition of Limiting Condition-for Operation 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process," published May 4, 2005 (70 FR 23252).

3. TSTF-372, Revision 4, "Addition of LCO 3.0.8, Inoperability of Snubbers," April 23, 2004.

4. Vermont Yankee Nuclear Power Station - Issuance of Amendment Re: Adoption of Technical Specification Task Force (TSTF) Change TSTF-372, "The Addition of Limiting Condition for Operation (LCO) 3.0.8 on the Inoperability of Snubbers" (TAC No. MD1664) Accession No. ML070530159

ATTACHMENT 3 Hope Creek Generating Station Facility OperatingLicense No. NPF-57 NRC Docket No. 354.

Relocation of Technical Specification 3/417.5 and Addition of LCO 3.0.8 Regarding Snubbers Markup of Proposed Technical Specification Page Changes TS Pages xiii xx 3/4 0-1 3/4 7-13 3/4-7-14 3/4 7-15 3/47-16 3/4 7-17 3/4 7-17a 3/4 7-17b 3/4 7-18 6-22 LR-N08-0150 LAR H08-03 Page 2 of 2 3.0.6 Not used.

3.0.7 Not used.

3.0.8 Inoperability of Snubbers When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

.At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

a INDEX REQUIREMENT LIMITING CONDITIONS FOR OPERATION AM SURVEILLANCE SECTION PAGE 3/4.7.3 FLOOD PROTECTION ...................................... 3/4 7-9 Table 3.7.3-i Perimeter Flood Doors ................. 1/4 7-1D 3/4.7.4 REACTOR CORE ISOLATION COOLING SYSTEM ....... ........ 7-11 1'~. igure 4.7..;-l Sa a

.3/4."7.6 SEALED SOURCE CONTAMINATION ............................ ...3/4 7.19 3/4.7.7 MAIN TURBIE BYPASS SYSTEM ............................... 3/4 7-21 3/4.8 ELECTRICAL POWER SYSTEMS

.3/4.8.1 -A.C. SOURCES A.C. Sources-Operating ................................... 3/4 8-i

.Table 4.8.1.1.2-3 Diesel Generator Test Schedule... 3/4 8-10 A.C. Sources-Shutdown .................................. 3/4 8-11 3/4.8.2 D.C. SOURCES "D.C. Sources-Operating ................................. 3/4-8-12 Table 4.8.2.1-1 'attery Surveillance Requirements.. 3/4 8-15 D.C. Sources-Shutdown. ................................. 3/4 8-1-7 3/4 8.3 ONSITE VOWER DISTRIBUTION SYSTEMS Distribution- Operating ................................ 3/4 8-18 Distribution - Shutdown... I ............................ .3/4 8-21 3/4.8.4 ELECTRICAL EQUIPMENT TIROTECTIVE DEVICES Primary Coatainment Penetration Conductdr OvercurrePft Protective Devices .................................... .. :-.4 Table 3.8.4.1-1 Primary Containment penetr&aion Conductor Overcurrent Protective Devices..... 3/4 8-26 Motor operated Valve Thermal Overload Protection (Bypassed) .............................................. 3/4 8-30 123 HOPE-CREEK xiii Amendment No. I

INDEX SECTIO 3/4.7 PLANTr SYSTM 3/4.7.1 SERV- Z WATER S STEMS .B 3/4 7-1 3/4.7.2 CO ROL ROOM S-E-RGEITCY FILTFý.TION SYSTE--M ........ B 3!4 7-1 i!'/4.7.3 OOD PRO'TECTION . " B 314 7-1 3/4.7,4 REACTOR CORE ISOLATION COOLING SYSTEM ........... B 3,/4 7-la 3/4.,7.5 - 2 3/4.7.6 SEALED SOURCE CONTAMINATION ........................ B 3/4 7-4 3/4.7.7 MAIN TURBINE BYPASS SYSTEM ...................... 'B 3/4 7-4 3/4.8 "LECTRICAL POWER SY M 3/-4.8.1. 3/4.8.2 and 3/4.8.3 'A.C. SOURCES, -D.C. SOURCES and O07SITE POWER DISTRIBUTION SYSTEMS ............................ B 3/4 8-1 314.8.4 .ELECTRICAL EQUIPMENT PROTECTIVE, DEVICES .......... B 3/4 9-3 3/4.9 REFUELING OPERATIONS 3/4.9.1 REACTOR MODE SWITCH .............................. B 3i4 9--

3/4 .9.2 INSTRUMENTATIZN ................................... 3/4 3/4.9.3 CONTROL ROD POSITION ............................. B 3/4 9-1 3/4.9.4 :DELETED........................................... B 3,4 9-1 3 14.9.5 DELETED. .......................................... B 3,4 9-1

.B 3/4.9.6 DELETED .......................................... 3/4 9-2 B

3/4.9.7 DELETED ........................................... 3/4 9-2 B

.3/.4.9.8 and3/4.9.9 WATER LEVEL - REACTOR VESSEL '

and WATER .LEVEL SPENT FUEL STORAGE POOL........ 3/4 9-2 B

33/4. 9:TO CONTRUL ROD P-MOVAL. . ..................... 3/4.9-:2

• B 3/4.9.11 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION,*.. 3/4 9-2

-HOPE CREwEK xx Amendment No. 137

3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with -the Limiting Conditions for Operation contained in the-succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiti~na C . - - ----- 4-- a be 3.0.2 Noncomp anc t specification s all exist when therequirement of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting condition for Operation is restored prior to expiration of the specified time intervals, completion of the Action requirements is not required.

3.0.3 When aLimiting Condition -for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in an OPERATIONAL CONDITION in which the specification does not apply by placing it, .as applicable, in-

.1. At least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

2. At least HOT SHUTDOWN within-the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least .COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time

.limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these zequirements are stated in the individual

.Specifications.

This Specification is not applicable in OPERATIONAL CONDITIONS 4 or 5.

3.0.4 Entry into -an OPERATIONAL CONDITION or other specified condition shall*

not be made when the conditions -for -the Limiting Condition for Operation are not met and -the associated ACTZON requires a shutdown if they are not met within a :specified time interval. Entry into an OPERATIONAL CONDITION or other specified condition may be -made in -accordance with the ACTION requirements when copformance to-them permits continued operation of the facility for an unlimited period of 'time. -This provision -shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION

-requirements. Exceptions to these requirements are stated in the individual Specifications. ..

3.0.5 -Equipment removed from service or declared inoperable to comply with ACTIONS may -be returned to service under -administrative control solely to perform testing required to demonstrate its OPERABILITY or the. OPERABILITY of other equipment. -"This is an exception to LOS 3..0.2 for the system returned to TI&i" servioe .under administrative -control-- to perform the testing required to demonstrate OPERABILITY.

HOPE CREE 3/4 o0-1 Amendment No.63

7 4. *5 4.SNUBBERS 3/

LITING.CONDITION FOR OPERATION -

3..7.5 11 snubbers shall be OPERABLE.

APPLICABI Y: OPERATIONAL CONDITIONS 1,2, and 3. OPERATIONAL COND -ONS 4 an or sn bars located on systems required OPERABLE in those OP0 TIONAL ACODTIONS. or restore the within 72 'hours re~ace evaluation snu~b rs-inperable, a engineering .attached With one .o* more t \OPERABLE status perform and declare the system.

.inoperable snubber(s) component statement for that ca onti 4.7, g gn the attached

.5. ACTI pe rpecifi appropriate th and follo system inoperabl~e **

TREMENTS SURVE ILLANCE RE U t s of nme t ec t pro g r a mdan e-threq ui re n sp n t e d i n ser v ic e i F

• fo lwltongi au gme.4.0. 5.

Speci~fication .

• Types /

Insoection snubbers

a. type .oT snubber shill mean capaci ty.

in this ~cifi s cation, i r sec tiveof reactor Asused iuanufacturer, ille "during e ofstabl shuedi same criteria~~~~~~~~

d es and bythOPRABLE rstents ind salbbseupntepviuisecon peffctbfor ac .ss ine 1 a io5 ae meendnerneaut

.inop the inaccessible or as Insp tions ategorized ib..Visual are c

" Snubber *,nd accessible)rthis lb f t es a eories (inaccess sci edul e ode using ter milned t o n.E ac ac or in to he de ermaine "t of ypce Soper i d p nd nl iins pion interval fo each interval ma e i sp ce .5 1 htefirsti u l ecin

\. .

• Table 4.74sn7:5-and Wtable SURVEILACE-RE QUIEMNT nube sal

.4..5Eah b dmos t PRALEbypefomaceofth

- t 50 Amendment No.

7-3/4 13 sOse CrEEK

LAN S STS SU LLANCEE ~EOUIREMEN'TS (Continuedl REOUIREMENTS (Continued)

C. Isual Inspection Acceptance Criteria Vis I inspections shall verify (1)that there are no sible indicat ons of damage or impaired OPERABILITY, (2) a .achments to the foun tion or supporting structure are secure, rnd (3) fasteners for attach .t of the snubber to the component d to the snubber

.anchorage are ecure. Snubbers which appear ' operable as a result of visual inspe ions shall be classified a unacceptable and may be reclassified'ac table for the purpos of establishing the next visual inspecti period, providin that: (1) the cause of the rejection is clearly es lished .and edied for that particular

.snubber and for ther snu ers irre ctive of type on that system that may be generically sus ti eor (2) the affected snubber is functionally tested in the as und condition and determined OPERABLE per Specifications .4.7A4. f r leaw and evaluation shall be per-formed and documenntedto j t inued operation with an unaccept-able snubber. If"contin o eration annot be justified, the snubber shall be declared nop able andthe AC N requirements shall be met.

-d. 'Transient Event I ection

ýAn inspection all be performed of all snubbers tached to sections of systm a have-experienced.unexpected, potent ly damaging transient , as determined -from -areviow of operational ata .or a

-visual Ispection of the -systems, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for incd sible sys and 6 months for inaccessible systems following thh eter-mii on. 'In 'addition to satisfying the visual inspection ac tance iteria, freedom-of-motion of. mechanical snubbers shall be ver' 'ed using at least one of the following: (-1) manually induced snubber mov~iment, or (2) evaluation of 'in-place snubber -piston setting.

~M Aer~dc 11L1w.I 7lA

LANT SYSTEMS ENTS (Continued) ok S VEILLANCE REqUIREM vi 'Functional 'Tests During the first refueling shutdown and at least once per 1 months thereafter during shutdown, a representative sample of sn bers shall e tested using one of the following sample plans for ea type of ubber. The sample plan shall be selected prior to th test period an cannot be changed during the test period. The NR Regional Admin-ist tor shall be notified in writing of the sample an selected prior to the test period or the sample plan used i/the prior test period hall be implemented:

I) At ast 110% of the total of each type of ubber shall be funct nally tested either in-place or i a bench test. For each snubber of a type that does not meet -th functional test acceptance criteria f Specification 4.7.5.f., an additional 10% of that type of snubber shall be functionally tes d until no more failures are found or un il all snubbers of that type have been functionally tested. 'Tes tng equipment failur during functional testing may invalidate tha day'Is testing an allow that day's .testing to.

resume anew .at later time, pr viding all .snubbers tested with the failed equip nt during-t day of equipment failure are re-tested; or

2) A representative sa e of each type of snubber shall be functionally tested in ordance with Figure 4.7.-5-1. "C" is the total number of snu rs of a type found not meeting the-acceptance requiremen .o Specification 4.7.5..f. The cumulative number of snubbers o a ty tested is denoted by "N". At the end of testing 'N" nubbers, the results shall be plotted on-Figure 4*7.5-1. atany ti' -the point plotted falls on.o r, abovethe "ReJe line -alI sn bers of that type shall be func-tionally teste If at any time the point plotted falls on or elow the Ac testing snubbers-of that typma he terminatd he hepit plotte lies in the "Continue Test-ing" regio , additional snubbers of' at type shall be tested

.Until the oint falls in the "Accept" egion or -the "Reject" region, r all the snubbers of that t havebeen nyp tested.

Testin

.b 0 'subeequipment t! t failure ietype during e-c funcytio 1 testing w~ mayos"o invali-maytbe

.date hat day's testing and allow that di 'stesting to resume ane~ edatte, a laterhentime, thepl providing all snubber tested sipoltpi

.with the

/~ faI equipment during the -day of equipment ailIure are rtested; or

'3) An initial representative sample of 55 snubber~s feach-type shall be functionally tested. 'For each snubber type wh h does -not meet

-the functional.test acceptance criteriaanother sa ple of at'least one-half -.the size of the initial 'sample -shall be tes ed until-the

'total number tested is equal to the initial 'sample simultiplied by-bythe-factor,"'-1-'+/2 'where `'C` -is-the -number-of "nbers -found-

-which do- not 'meet the 'functional test acceptance -criter 'The results 'from this sample plan shall be plotted using an "cept" line which follows the equation N-= 55(1-+ C/2). Eac h sub er point shoul~d be 'plotted when "IN"snubbers have been tested. f the

'HOPE CREEK 3/4"'125

LANT SYSTEMS SU EILLANCE REOUIREMENTS Continued point plotted falls on or below the "Accept" line, testing 1' that type of snubber may.be terminated. If the point plotted flls ave the "Accept" line, testing must continue until the oint Us on or below the "Accept" line or all the snubbers f that tehave been tested. 'Testing equipment failure duri g func-tio I testing may invalidate that day's testing and llow that day's testing to resume anew at a later time, provi ng all snubbe tested with the failed equipment during t e day of equipme failure are retested.

The 'repres tative sample selected for the ini ial function test sample plans- hall be randomly .selected from he -snubbers of each type and revi.ed before beginning the test' g The review shall ensure as far a practical that they are resentative of the var-ious configurati s, operating- environmer s, range of size, and capacity .of snubbe s of each type. Snu ers placed in the same locations .as snubbe which failed the revious functional test shall be retested at the ti e of the next f/nctional test but shall not be included in the sample -an, and fai ure of this functional -test

%shallnot be the .sole c se -for in asing the sample size under the sample -plan. If during t func onal testing, additional sampling is -required due to failure: f o y -one type Of snubber, the func-tional-testing results shllb b reviewed at the-time to determine if additional samples should be imited to the type of snubber which has failed -the 'functional testi

f. Functional Test Acceptanc 'Criterra The snubber functional st shall v ify that:

.1) Activation (rest range in both ttsion compres .achieved iningandaction) n;" within the specified

2) Snubber bleed or release rate where required, is present in both tension and compression, within - *e specified range (hydraulic_..

snubbers o y);

,3) For mach ical snubbers, the 'force requi d to initiate or main-tain .mo on of the snubber is within-the cified range in both directons of travel; and

-4) For nubbers -specifically required not to disp ace under co inuous load, the ability of the snubber to 'thstand load

w. hout displacement.

Testj g methods may -be used to -measure parameters indire tly or pameters other thanthose .specifidif tho'se reSlits ca be corre-1 . d to thespecified parameters through established meth s..

g. )*unctional Test Failure Analysis .

An engineorihg evaluation shall be made of each failure to mee the i

functional test acceptance criteria to determine the cause .of th failure. The results of this evaluation shall be used, if applic *e, inOselecting snubbers 'to be tested in an effort to determine the PE/ 'REEK

N LANTSYSSTEMS g VýTLLhNCE-REOUIREMEKTS (Continued' EILLANCEE RREENUIRREMMEENNTS (Continued)

OPERABILITY .of other snubbers irrespective of type which may be subject to the same -failure mode.

,For the snubbers found inoperable, an engineering evaluaton shall

%Ue performed on the components to which the inoperable soubbers are a ached. The purpose of this engineering evaluation 'hall be to det rmine if the components to which the inoperable sjubbers are attn ed were adversely affected by the inoperabill~t.of the snubbers in ordr to ensure that the component remains capaple of meeting the designe service. /

/

If any snub r selected for functional testiS either fails to lock up or fails tmove, i.e., frozen-in-place, he cause will I be ievaluated and if caused -manufacturer or design de ciency all .snubbers of the same type s ect to the same defect . a&l be functionally tested.

This testing requ ent shall be indep dent of the requirements stated in Specific ion 4.7.5.s. for s bbers not meeting the

h. Functional Testine of Repaired and enlaced Snubbers

-Snubbers which fail the v ual J spection or the functional test 9 acceptance criteria shall b snubbers and snubbers which aired or replaced. Replacement *.

ve repairs which-might affect the

-functional test result .shal b tested to meet the functional test criteria before Installati in he unit. Mechanical -snubbers shall have -met the acceptance c iteria ubsequent to their most recent service, and the free of-motion test must have been performed within 2 months befo being insta ed in the unit.

-i. Snubber Service Life Replacement P-rn r

'The service life, all snubbers shAll be- nitored to ensure that the service life, is not exceeded between s veillance inspections.

The maximum ex cted service life for varlo seals, springs, and other critica parts shall be extended or sho ted based on moni-tored test suits and failure hi-story. *Criti I parts shall be replaced os that,-the maxi mum servi ce Iife -wi1n1 t be exceeded during -a aod When the snubber is required to, OPERABLE. The

-parts ri acements shall 'be-documented and the doc ntation shall

,Jbe ret ned in accordance with Specification 6.10.3.

0 HE CREEK V3/4 7-17

_11 TABLE 4.7. 5-1

.SNUBBER VISUAL IN*SPECTION'INTERVAL NUMBER OF UNACICEPTABLE SNUBBERS P Pulation Column A CorurUn B nC or ategory Extend Repeat Re uc, Interval interval Val (Note 1 (Notes 3 (Notes 4 Note s 5 and 2) and 6) and 6) andr UJ 80 0 0 /2 100 o.1

-0 4

.150 \ 0 3 8

.200 \ 2 /13 300 5 2.2 25 400 500 -36

/24 . 48.

750 20\ 40 78 1000 or 29 / 56 109

.greater Note ,: The next visual in ion -interval for a snubber popu-Slation or category, gze shall be determined based upon the previous inspe i n interval and the number of un-acceptable snubbe s fo d during that interval. Snubbers r]

may be categorl d,. bas upon their accessibility during

-power operatio as acces Ibis or inaccessible. These categories ma be examined eparately or jointly. -How-ever, that cision shall b made and documented before

%any inspec on and shall serv as the basis upon which 5:

-the-next inspection interval f that category is 3.

determi d 3

Note .2: Inte olation between population

• category sizes and the nunr .of unacceptable snubbers is rmissible. Use the next I r -integer for the value -of-the 1 it for -Columns A, .B, or if that integer lncludes..a frdctiona value of unacceptable nubbers as determined by Interpolation.

Note .3 If the-number of unacceptable snubbers is ual to or less

-than the number In Column A, the next inspe ion interval may be -twice the previous interval but not- great than -48 months,

._ (;ontinued) 71 HOPE CREEK :347-17a Amendment No.

' ,TABLE

!*'-P'--- 4.7. 5-1 (Continued) oNot4: If the number of unacceptable snubbers is equal to or less an the number in Column B but greater than the number in Column -A the next inspection interval shall, be the same as the previous in rval.

Note 5: If the number of unacceptable snubbers is equal to or reater than he number in Column C, the next inspection interval hail be two-t rds of the previous interval. However, if the n ber of unaccept-ab snubbers is leis than the number in .Column C t greater than the mber in Column B, the next interval shall b reduced propor-tiona by interpolation, that is:

• 1= 0 I0 1 1/]3. U-B /

C-B I ne tinspection -interv 1

'D=prey us inspection itra U = number a unacce

• e snubbers found during th prevlous inspection interval

ýB-number in-Co mn:B C -=numnber in alum C Note S: The provisions of Spe.l ication 4 are applicable for all

-inspection intervals p toand inc ding 48 months.

HOPE CREEK .3/4 7-17b -Amendment No. 50

ADMINISTRATIVE CONTROLS RECORD RETENTION (Continued) 6.10.3 The following records shall be retained for the duration of the unit Operating. License:.

a. Records and drawing changes reflecting unit design modifications made to systems and equipment described in the Final Safety Anajysis Report.

b. Records of new and irradiated fuel inventory, fuel transfers, and assembly burnup histories.

c. Records of -radiation exposure for :all individuals entering radiati6n control areas.

d. Records of gaseous and liquid radioactive material released to the environs.

e. Records of transient or operational cycles for those unit lcomponents identified in Table 5.7.1-1.

f. Records of reactor tests and experiments.

g. Records of training and qualification for current members of the.

unit.staff.

h. Records.of inservice inspections performed pursuant to. these Technical Specifications.

i. Records of quality assurance activities required by the Quality Assurance Program.

j. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to -10 CFR 50.59.

k. Records of SORC meetings .and activities of the Nuclear Review Board (and activities of its predeceseor, the Offsite Safety Review (OSR) staff).

1. Records of the snubber service life monitoring pursuant to

• anhnical Specification .4.7.5.

m. Records of analyses required by the -radiological environmental monitoring program which would -permit evaluation of the accuracy of the-analyses at a later date. This should include procedures effective at specified times and QA records showing that these procedures were followed.-

n. Records of reviews performed for changes made to'th'e OFFSITE DOSE CALCULATIONAL MANUAL and the PROCESS CONTROL PROGRAM.

HOPE CREEK .6-'22 O CE2Amendment No.159

ATTACHMENT 4 Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354 Relocation of Technical Specification 3/4.7.5 and Addition of LCO 3.0.8 Regarding Snubbers Markup of Technical Specification Bases Page Changes (for information only)

TS Bases Pages B 3/4 0-1 B 3/4 0-3a B 3/4 7-2

-B 3/4 7-3 LR-N08-0150 LAR H08-03 Page-2 of 2 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing. their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the .

supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36(d)(2)(ii), and, as such, are -appropriate for control by the licensee.

If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

LCO 3.0.8.a applies when one or-more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single-train or subsystem supported system. LCO -3.0.8.a allows 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />sto restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic.event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing -their associated support function and due to the availability of the redundant-train of the supported system.

LCO 3.0.8.b applies when one or more-snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO-3.0.8 should be considered with respect to other plant maintenance activities, and integrated intothe.existing Maintenance Rule process to -the extent possible so that maintenance on any unaffected train or subsystem is

-properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, :but may be a qualitative awareness of the vulnerability of systems and components when one or -more snubbers are not able to -perform their associated support function.

3/4, 0 APPLICABILITY 4

W.

BASES _.

DO Specifications 3.0.1 throuqh stabli s the general requirements applicable to Limi ing Condi 1in- for Operation. These requirements are based on the requirements for Limiting Conditions for Operation stated in the Code of Federal Regulations, 10 CFR 50.36(c)(2):

"Limiting conditions for operation are the lowest functional capability or performance levels of eouipment required for safe operation of the facility, When a limiting condition -for operation of a nuclear reactor i.snot met, the licensee shall shut down the reactor or follow -any remedial action permitted hy the technical specification until the condition can be met."

Specification 3.0.1 establishes the Applicability statement within each individual specification as the requirement for when (i.e., -in which OPERATIONAL CONDITIONS or other specified conditions) conformance to the Limiting -Conditions for Operation is required for :safe operation of the facility. 'The ACTION requirements establish those -remedial measures that must be taken within specified time limits when 'the -requirements -of :a Limiting Condition for Operation-are not .met, It is -not intended that the shutdown.

ACTION requirements be used as an operational convenience which permits (routine) -voluntary removal of a system(s) or component(s) from -service in lieu of other alternatives that would not result in redundant systems -or components being inoperable.

There are two basic types of ACTION requirements. The first specifies the

-remediaI measures that permit continued operatinm of the. facility wwhi ch is -not further restricted by the time limits of the ACTION requirements. In this case, conformance to the ACTION requirements provides an acceptable level of safety for unlimited continued operation as long as the ACTION requirements

.continue to be -met. The second type of ACTION requirement -specifies a time 1imi.t in which -conformance to the -conditions of -the Limiting Condition -for Operation -must be met. Thi-s time limit is 'the allowable outage time to. restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these actions .are not completed within the allow-able outage time limits, a shutdown is required to place the facility in -an OPERATIONAL CONDITION or -other specified condition in which the specification no longer applies.

The specified time limits -of the ACTION requirements are applicable from -the

.poi.nt in time -it is -identified that a Limiting Condition for Operation is not met. The ti-me limits ,of the ACTION requirements are also applicable -when a system or component is removed from service -for surveillance tasting or investigation -of operational. 'rob-lems. Individual.. specifications may include

ýa speci fi ed ti me limit "for 'the. compl eti on of :a Survei-lla nce -Requirement -when

• equipment is removed 'from service. In this :case, the allowable outage time limits of the ACTION requirements are applicable when this limit expires if the surveillance has not been conprieted. -When a shutdown is required'to comply with ACTION requirements:, the -plant may have entered -an OPERATIONAL CONDITION "in which.a new specification becomes-applicable. In this case,. the .I-IHOPE CREEK B W34 0-1.l Aniendmerntd:.fta. ------

SAS jContined)

'soecif-Cartlon 3.0.5 establishes the .allowancefor restoring equipment to _

-servIce under administrative controls when it has beer reoved from s ice or declared inoperable to Comply with ACTIONS. -The sole Purpose of this Specification is to provide an exception to LOD .3.0.2 (e.g., -to not .comply-wi~th the applicable Required Action(s)) to allow the performance of teuting required to restore and demonstrate:

a. The OPERATITY of the equipment being returned to serice; or

b. The OPEPRAZLZMY of other equipment.

The administrative controls ensure the time -the equilpmnt is returned to see-vie in conflict with the requirements of the ACIORS is limited to the -time a -Z utely necessary to pertorm 'the testing required -to restore end decar'nxtratt -the OPEMM3LT of the equipMent. This Specification does not J.r-ovide t~me to perfor any other preventative or corrective maintenance.

An example of demonstrating the OPERUILITY of the equipment .being returned to service is reopening a containment isolation valve that has been .cloed to comply with Raquired Actions and mast be reopened to perform the testing

.required to restore and demonstrate OPOM LzTY.

An example of demonstrating the OPZR*MZLZ of other e-aupmen is taking an

.inoperable channel or trip system out of -the tripped condition to .prevent the trip function from occurring during the pe foumane -ofteAMting rMeuired to restore -OZRABLT of another channel in the other trip system. A sirilaar s- Imp*of- demonstrating the OPERDBUZLZ? of other squipment is taking an

.Inoperabl.e channel -or trip sfYstmotM.fthe7ýtrijpped condition to permit the logic to ,function and Indicate the appropriate response during the ýperformance of tofting rquired. to restore and demonstrate. the OPEUMILTY on another channel in the same trip system.

1C 3.0.5 is applicable to all Technical Specificationsl however, the intent of LCO 3.0.75 is not -to supersede more -specific guidanse cont&aned within any

-individual specification.

Ron 'CREZr- B 3/4 0--3a MOPECREK no. 63 U/4-3eAmendment

PLANT SYSTEMS BASES REACTOR CORE ISOLATION COOLING SYSTEM (Continued)

The surveillance requirements provide adequate assurance that RCIC will be OPERABLE when required. Although all active components are testable and full flow can be demonstrated by recirculation during reactor operation, a ciomplete functional test requires reactor shutdown. The pump discharge piping I intained

.- full to prevent water hammer damage and to start cooling at the earli t possible moment.

3/4.7. SNUBBERS

\ All snubbers .are required OPERABLE to ensure that the structural in rity

• f the reactor coolant system and all .other safety related systems is intained d 'n-and following a .seismic or other event initiating dynamic Ica'_ Snub- '

bers relate cludedsystems from and this inspection then-only program are those installed on* ._.fetr if their failure or failure of tbhystm .on which Snubbers re" classified .and groupod by design-and maac~urer/--but not by size. For exp, mechanical snubbers utilizin ~e{esign.

dh features-of the 2- kip, MO-kip, nd 1O0-kip -capacity :manufactured -" any"AW are ,of,-the same type. The same ign mechanical snubbers antured by Company "

for the purposes of th sTechnir-al .Specification Ioudbe of a different -type, tand size A list and-of h affecte of individauoal system sne rs all withbedet alalled informa tionof snubber t .the plant location in. accordace The deemnto shal b based exis upo i radiationm n:nng levels n h Gud accordance. with n .0Sectioni Te dtoof 10 rdlton

.59 of*n CFR -Part a50.. snubber

. o .shall be made in snubber sxpe with time an htotheor fa ilu of anytInec snubbert on at 1 iOcould

-Ut I

.~ . - usether fcosyaste o be nrt ct an i-o-rslin.alr patoe during atins assg.

Gud . n .0 Te iin-rdeei f subrsalb aei HOPE CREEK , 3/4 7-2 f a mndeent No. 50

• AY7 1F9g2

PLANT SYSTEMS BASES N.BBER. (Continued) "

in, iating event. Inspections performed before that interval has elapsed may be u d as a new reference point to determine the next inspection. Howe er, the re-a ts of such early inspections performed before the original r uired time int val has elasped (nominal time less 25%) may not be used to lengthen the requi d inspection interval. Any inspection whose results re ired a shorter ins ction interval will override the previous schedule.

The .acc'ep ce criteria are to be used in the visual in ection to determine-OPERAB ITY of the snubbers.

To provide assu nce of snubber functional reliabi ty -one of three

-functional testing met ds is used with -the -stated -ac ptance criteria: "

1. Functionally tesi0%- of a type of snubb r with an additional 10%

tested for each ftional testing fa .re, -or

2. Functionally test a s ple size an determine sample acceptance or rejection using Figure -7.5-1,

3. Functionally teý't a repres t ive sample size and determine sample acceptance or rejection usi the stated equation.

Figure 4.7.5-'. was developed sing Id's Sequential Probability Ratio Plan" as described in Quality Co rol and -I ustrial Statistics" by Acheson J.

_Duncan.

Permanent th tions-from the surve lance program for individual snubbers may begrated bthe Comission iable basis for exemption

-ispresented and i ap i cable,.snubber life destru ive-testing was performed to qualify the nubbe or the applicable design Cod ions -at either the :com-pletion of their f ication or at -asubsequent date. S hbbers so-exempted shall be listed i the list-of individual snubbers indicatI gt*he extent of the exemptions.

The se celife of - snubber is evaluated via manufacture input and informatio throughconsideration of the snubber service conditio and asso-ciated i tallation and maintenance records (i.e.,--newly installed. nubber,

.seal re aced, .spring replaced, in high radiation-area, in high tem tr area, tc.). The requirement to monitor the-snubber service life s5i luded to sure that the snubbers periodically undergo-a performance evaluatio in v1 of their age and operating conditions. These records will provide s tis-1cal bases -for future consideration of snubber -service life.

HOPE :CREEK B :3/4 "7-3

.Am endment No.50

ATTACHMENT 5 Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354

,Relocation of Technical Specification 314.7.5 and Addition of LCO 3.0.8 Regarding Snubbers Summary of Commitments The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC-for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR One-Time Programmatic "OUTAGE" Action Prog (Yes/No) (Yes/No)

PSEG will establish the Technical Specification To be implemented Bases for LCO 3.0.8 as adopted with the with the license Yes No applicable license amendment. amendment I