LR-N18-0073, Supplement to License Amendment Request for Additional Information, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.

Supplement to License Amendment Request for Additional Information, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.

ML18200A149
Person / Time
Site:	Hope Creek
Issue date:	07/19/2018
From:	Carr E Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR H17-06, LR-N18-0073, TSTF-242
Download: ML18200A149 (11)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 0PSE:G NucleaTLLC 10 CFR 50.90 LR-N18-0073 LAR H17-06 JUL 19 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

Supplement to License Amendment Request for Additional Information, Re: Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control"

References:

1. PSEG letter to NRC, "Application to Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,"'

dated September 21, 2017 (ADAMS Accession No. ML17265A847)

2. NRC email to PSEG, "Hope Creek- Final RAI RE: Revise TS to Adopt TSTF-542," (EPID: L-2017-LLA-0352) dated May 30, 2018 (ADAMS Accession No. ML18150A691)

3. PSEG letter to NRC, "Response to Request for Additional Information, RE: Application to Revise Technical Specifications to Adopt TSTF-542,

'Reactor Pressure Vessel Water Inventory Control,"' dated June 27, 2018 (ADAMS Accession No. ML18178A234)

In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) for Hope Creek Generating Station. The proposed amendment would revise Technical Specifications (TS) to adopt TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." In Reference 2, the Nuclear Regulatory Commission (NRC) requested PSEG to provide additional information in order to evaluate the proposed License Amendment Request to revise Technical Specifications. In Reference 3, PSEG submitted its response to the NRC request for additional information (RAI).

JUL 19 2018 10 CFR 50.90 Page 2 LR-N18-0073 In the response to RAI-2, PSEG proposed to delete the TRIP SETPOINT column in TS Table 3.3.12-1 and provided a revised TS markup of the table. As a result of deleting the TRIP SETPOINT column from Table 3.3.12-2, the following additional changes to the Reference 1 submittal are proposed:

Reference 1. Attachment 1

• Section 2.2, Variation A.B. is deleted as this variation is no longer applicable.

Reference 1. Attachment 2. New Technical Specification (TS) Page 3/4 3-111

• Limiting Condition for Operation (LCO) 3.3.12 is revised consistent with TSTF-542 to eliminate reference to TRIP SETPOINTS as this no longer applies.

• ACTION a., which describes actions required based on TRIP SETPOINTS in Table 3.3.12-2, is deleted as these actions no longer apply.

• ACTION b. is renumbered to ACTION a.

Reference 1. Attachment 3. ACTIONS. New TS Bases Page B 3/4 3-16

• ACTION a. is being deleted corresponding to the deletion of TS 3.3.12 ACTION a.

• ACTION b. is being renumbered to ACTION a. to this letter provides the proposed supplemental TS mark-up page and provides the proposed TS Bases marked-up page. Attachment 3 provides revised camera-ready TS pages. Included in the camera-ready pages is a replacement for TS page 3/4 5-6, provided in Reference 3, to correct a minor typographical error. The remaining TS mark ups and camera-ready TS pages provided in Reference 1, as revised by Reference 3, remain unaffected by this supplement.

The Reference 1 letter requested an implementation period of 180 days following approval of the LAR. Based on industry implementation experience, PSEG is requesting a change to the implementation period from 180 days to prior to entering OPCON 4 for the next Hope Creek refueling outage scheduled for Fall, 2019 (H1R22).

PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please contact Mr. Lee Marabella at (856) 339-1208.

JUL 19 2m,a 10 CFR 50.90 Page 3 LR-N 18-0073 I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Eric Carr Site Vice President Hope Creek Generating Station Attachments:

1. Revised Marked-up Proposed Technical Specification Page

2. Revised Marked-up Proposed Technical Specification Bases Page

3. Revised Camera-ready Technical Specification Pages cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. McEwen, Hope Creek Commitment Tracking Coordinator

10 CFR 50.90 Page 4 LR-N18-0073 (The bcc list should not be submitted as part of the EIE submittal. The bcc shall be on a new page.)

bcc: President and Chief Nuclear Officer, PSEG Nuclear Senior Director, Regulatory Operations and Nuclear Oversight Director, Site Regulatory Compliance Hope Creek Plant Manager Manager, Licensing Records Management

LR-N18-0073 Attachment 1 Revised Marked-up of Proposed Technical Specification Pages The following Technical Specification page for Renewed Facility Operating License NPF-57 is affected by this Supplemental Response:

3/4 3-111

INSTRUMENTATION 3/4.3.12 RPV WATER INVENTORY CONTROL INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.12 The RPV Water Inventory Control (WIC) actuation instrumentation channels shown in Table 3.3.12-1 shall be OPERABLE.

APPLICABILITY: As shown in Table 3.3.12-1 ACTION:

a. With one or more channels inoperable, take the ACTION referenced in Table 3.3.12-1 for the channel immediately.

SURVEILLANCE REQUIREMENTS 4.3.12 Each RPV WIC actuation instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and LOGIC SYSTEM FUNCTIONAL TEST at the frequencies shown in Table 4.3.12.1-1.

HOPE CREEK 3/4 3-111 Amendment No. XXX

LR-N18-0073 Attachment 2 Revised Marked-up Proposed Technical Specification Bases Page The following Technical Specification Bases page for Renewed Facility Operating License NPF-57 is affected by this Supplemental Response:

B 3/4 3-16

INSTRUMENTATION BASES 3/4.3.12 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION (Continued)

ACTIONS ACTION a. directs taking the appropriate ACTION referenced in Table 3.3.12-1. The applicable ACTION referenced in the Table is Function dependent.

TABLE 3.3.12-1 ACTION 83 Low reactor vessel pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The allowed outage time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

TABLE 3.3.12-1 ACTION 84 If a Core Spray or Low Pressure Coolant Injection Pump Discharge Flow - Low bypass function is inoperable, there is a risk that the associated low pressure ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve to ensure the pump does not overheat. If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The allowed outage time is appropriate given the ability to manually start the ECCS pumps and open the injection valves and to manually ensure the pump does not overheat.

With the ACTION and associated allowed outage time of ACTION 83 or 84 not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

TABLE 3.3.12-1 ACTION 85 RHR System Shutdown Cooling Mode Isolation, Reactor Vessel Water Level - Low, Level 3, and Reactor Water Cleanup System Isolation, Reactor Vessel Water Level - Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. If the instrumentation is inoperable, ACTION 85 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation and requires calculation of DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetration flow paths.

SURVEILLANCE REQUIREMENTS 4.3.12 states that each RPV WIC actuation instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and LOGIC SYSTEM FUNCTIONAL TEST at the frequencies shown in Table 4.3.12-1.

HOPE CREEK B 3/4 3-16 Amendment No xxx

LR-N18-0073 Attachment 3 Revised Camera-ready Technical Specification Pages The following Technical Specification page for Renewed Facility Operating License NPF-57 is affected by this Supplemental Response:

3/4 3-111 3/4 5-6

INSTRUMENTATION 3/4.3.12 RPV WATER INVENTORY CONTROL INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.12 The RPV Water Inventory Control (WIC) actuation instrumentation channels shown in Table 3.3.12-1 shall be OPERABLE.

APPLICABILITY: As shown in Table 3.3.12-1 ACTION:

a. With one or more channels inoperable, take the ACTION referenced in Table 3.3.12-1 for the channel immediately.

SURVEILLANCE REQUIREMENTS 4.3.12 Each RPV WIC actuation instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and LOGIC SYSTEM FUNCTIONAL TEST at the frequencies shown in Table 4.3.12.1-1.

HOPE CREEK 3/4 3-111 Amendment No. XXX

EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL 3/4 5.2 RPV WATER INVENTORY CONTROL LIMITING CONDITION FOR OPERATION 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> AND At least one of the following low pressure ECCS subsystems shall be OPERABLE:

a. Core spray system subsystem comprised of:

1. Two OPERABLE core spray pumps, and

2. An OPERABLE flow path capable of taking suction from at least one of the following water sources and transferring the water through the spray sparger to the reactor vessel:

a) From the suppression chamber, or b) When the suppression chamber water level is less than the limit or is drained, from the condensate storage tank containing at least 135,000 available gallons of water.

b. Low pressure coolant injection (LPCI) system subsystem comprised of:

1. One OPERABLE LPCI pump, and

2. An OPERABLE flow path capable of taking suction from the suppression chamber and transferring the water to the reactor vessel. **

APPLICABILITY: OPERATIONAL CONDITION 4 and 5.

ACTION:

a. With none of the above low pressure ECCS subsystems OPERABLE, immediately suspend CORE ALTERATIONS and restore a subsystem to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Otherwise, immediately initiate action to establish a method of water injection capable of operating without offsite electrical power.

b. Deleted.

• Deleted.

• • A LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

HOPE CREEK 3/4 5-6 Amendment xxx