LR-N20-0015, License Amendment Request to Revise Technical Specification Actions for Suppression Pool Cooling

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License Amendment Request to Revise Technical Specification Actions for Suppression Pool Cooling
ML20128J820
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 05/07/2020
From: Casulli E
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR H19-06, LR-N20-0015
Download: ML20128J820 (14)
v • d • e


Text

10 CFR 50.90 LR-N20-0015 LAR H19-06 May 7, 2020 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License Nos. NPF-57 NRC Docket No. 50-354

Subject:

License Amendment Request to Revise Technical Specification Actions for Suppression Pool Cooling In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for an amendment to the Technical Specifications (TS) for Hope Creek Generating Station (HCGS).

The proposed change will revise the HCGS Technical Specification (TS) 3.6.2.3, Suppression Pool Cooling, to modify the action for one inoperable loop from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days and modify the action for both loops inoperable to add an 8-hour allowed outage time in accordance with Technical Specification Task Force (TSTF) traveler TSTF-230 Revision 1, Add new Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling." These changes will make the HCGS suppression pool cooling actions consistent with NUREG-1433, Revision 4, Standard Technical Specifications - General Electric BWR/4 Plants.

The Enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked up to show the proposed changes.

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

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of New Jersey Official.

There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please contact Mr. Brian Thomas at 856-339-2022.

LR-N20-0015 10 CFR 50.90 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on -- 7

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(Date)

Respectfully, JM7Z-IJ Edward T. Casulli Site Vice President Hope Creek Generating Station

Enclosure:

Evaluation of the Proposed Changes : Mark-up of Proposed Technical Specification Pages cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE PSEG Corporate Commitment Tracking Coordinator Hope Creek Commitment Tracking Coordinator

LR-N20-0015 LAR S19-06 Enclosure Evaluation of the Proposed Changes Table of Contents 1.0

SUMMARY

DESCRIPTION .............................................................................................1 2.0 DETAILED DESCRIPTION..............................................................................................1 2.1 System Design and Operation ...................................................................................1 2.2 Current Technical Specifications Requirements.........................................................2 2.3 Reason for the Proposed Change..............................................................................3 2.4 Description of the Proposed Change .........................................................................3

3.0 TECHNICAL EVALUATION

.............................................................................................5

4.0 REGULATORY EVALUATION

........................................................................................6 4.1 Applicable Regulatory Requirements/Criteria ............................................................6 4.2 Precedents ................................................................................................................6 4.2 No Significant Hazards Consideration .......................................................................7 4.3 Conclusion.................................................................................................................9

5.0 ENVIRONMENTAL CONSIDERATION

...........................................................................9

6.0 REFERENCES

................................................................................................................9 ATTACHMENTS:

1. Mark-up of Proposed Technical Specification Pages

LR-N20-0015 LAR H19-06 Enclosure 1.0

SUMMARY

DESCRIPTION The proposed change will revise the Hope Creek Generating Station (HCGS) Technical Specification (TS) 3.6.2.3, Suppression Pool Cooling, to modify the action for one inoperable loop from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days and modify the action for both loops inoperable to add an 8-hour allowed outage time in accordance with Technical Specification Task Force (TSTF) traveler TSTF-230, Add new Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling."

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation As described in Section 5.4.7 of the Hope Creek UFSAR, the Residual Heat Removal (RHR) system contains two loops ("A" and "B") with heat exchangers designed to remove decay heat from the reactor coolant system during shutdown conditions and maintain containment temperatures following design basis accident and transient scenarios. To control containment temperatures, the RHR System can be operated in the Suppression Pool Cooling (SPC) mode or the Suppression Pool Spray (SPS) mode. While operating in these modes, RHR transfers the containment heat load to the Safety Auxiliaries Cooling System (SACS) via the RHR heat exchangers.

The RHR System consists of four pumps, two heat exchangers, and associated piping, valves, and instrumentation that can be used to cool the Nuclear Steam Supply System (NSSS) in a variety of situations. During normal shutdown and reactor servicing (shutdown cooling mode),

the RHR system removes residual and decay heat. One mode of RHR operation allows the removal of heat from the primary containment following a loss-of-coolant accident (LOCA).

Following a Design Basis Accident (DBA), the SPC mode removes heat from the suppression pool. The suppression pool is designed to absorb the sudden input of heat from the primary system. In the long term, the pool continues to absorb residual heat generated by fuel in the reactor core. Pursuant to 10 CFR 50, Appendix A, General Design Criteria (GDC) 38, a means must be provided to remove heat from the suppression pool so that the temperature inside the primary containment remains within design limits. This function is provided by two redundant RHR suppression pool cooling loops. Each RHR suppression pool cooling loop takes suction from the suppression pool, pumps the water through the associated RHR heat exchanger and returns the water to the suppression pool. One SPC loop is capable of removing the heat from containment and maintaining the suppression pool with the temperature limits as discussed in section 3.0.

2.2 Current Technical Specification Requirements The current HCGS TS limiting condition for operation (LCO) for suppression pool cooling is as follows:

3.6.2.3 The suppression pool cooling mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a. One OPERABLE RHR pump, and 1

LR-N20-0015 LAR H19-06 Enclosure

b. An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger.

ACTION:

a. With one suppression pool cooling loop inoperable, restore the inoperable loop 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 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 />.
b. With both suppression pool cooling loops inoperable, be in at least HOT SHUTDOWN within 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 next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2.3 Reason for Proposed Change The extension of the one loop of suppression pool cooling AOT will allow online repairs that could not be accomplished within the current AOT. Although the suppression pool cooling function is required during operation to mitigate the consequences of a design basis accident and maintain the suppression pool temperature below temperature limits, this is mainly a standby function. During an outage the RHR heat exchanger is placed in service to perform the shutdown cooling function of the RHR system.

Adding an allowance of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for both loops of RHR suppression pool cooling inoperable is considered appropriate since an immediate plant shutdown has the potential for resulting in a unit scram and discharge of steam to the suppression pool, when both suppression pool cooling loops are inoperable and incapable of removing the generated heat. The 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provides some time to restore one of the loops prior to requiring a unit shutdown (reducing the likelihood of the potential problem described above).

2.4 Description of Proposed Change TS 3.6.2.3 Action a will be revised to extend the allowed outage time from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days for one inoperable suppression pool cooling loop. TS 3.6.2.3 Action b, for both trains of suppression pool cooling inoperable, will be revised to add an 8-hour allowed outage time. The actual TS markups are provided in Attachment 1. These changes will make the HCGS technical specification actions consistent with NUREG-1433, Revision 4.

3.0 TECHNICAL EVALUATION

3.1 Extend AOT to 7 days for a single loop of SPC Inoperable Following a design basis accident (DBA), the SPC system removes heat from the suppression pool. The suppression pool is designed to absorb the sudden input of heat from the primary system as the reactor pressure vessel is depressurized. In the long term, the pool continues to absorb residual heat generated by fuel in the reactor core. RHR suppression pool cooling is the means provided to remove heat from the suppression pool so that the temperature inside the primary containment remains within design limits.

2

LR-N20-0015 LAR H19-06 Enclosure For long term cooling, one RHR loop with flow through the RHR heat exchanger, with cooling from the SACS loop, is required. The containment analysis demonstrates that one loop of RHR suppression pool cooling with a RHR heat exchanger K-value of 307 Btu/sec-°F will maintain suppression pool temperature within limits. The updated containment analysis was provided as part of the HCGS extended power uprate as discussed below.

On September 18, 2006 (ADAMS Accession No. ML062680451), PSEG submitted the Safety Analysis Report for HCGS Constant Pressure Power Uprate (CPPU) as Attachment 4 (NEDC-33076P, Reference 2). This report is referred to as the PUSAR.

PUSAR Section 4.1.1 discusses the post-LOCA containment pressure and temperature response and states that the long term analysis is directed primarily at the suppression pool temperature response considering the decay heat addition to the suppression pool. Section 4.1.1.1 of the PUSAR states that the long-term bulk pool temperature response with CPPU was evaluated for the DBA LOCA. The CPPU analysis was performed using an RHR heat exchanger K-value (a measure of heat exchanger efficiency) of 307 BTU/sec-°F/HX and safety auxiliary cooling system (SACS) temperature of 100°F. The calculated peak bulk suppression pool temperature shown in PUSAR Table 4-1 is 212.3 °F which is below the design limit.

The NRC Safety Evaluation Report (Amendment 174) for the CPPU Extended Power Uprate (EPU) states in part:

The NRC staff has reviewed the licensees assessment of the containment temperature and pressure transient and concludes that the licensee has adequately accounted for the increase of mass and energy resulting from the proposed EPU. The NRC staff further concludes that containment systems will continue to provide sufficient pressure and temperature mitigation capability to ensure that containment integrity is maintained.

Extending the allowed outage time (AOT) for a single train of SPC from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days is consistent with NUREG-1433 Revision 4, Standard Technical Specifications, General Electric BWR/4 Plants. The current HCGS TS were based on NUREG-0123, Standard Technical Specifications for General Electric Boiling Water Reactors. During the conversion of NUREG-0123 to NUREG-1433, the allowed outage time of LCO 3.6.2.3 Action A. was increased from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days. The justification for this change is stated as follows:

The restoration time is extended to 7 days. This time is consistent with the restoration time for an inoperable ECCS subsystem. The redundancy and diversity of the ECCS design has justified a 7 day Completion Time for one subsystem being inoperable. The components of the LPCI ECCS subsystem also are required to be OPERABLE for various other functions (suppression pool cooling, containment spray, etc.) and the ITS presents the ACTIONS for one inoperable subsystem in each of these Specifications with the same 7 day Completion time. These functions (ultimately containment and decay heat removal functions) have designed diversity and redundancy in various suppression pool cooling, containment spray, and containment ventilation systems, supporting the engineering judgement that a 7 day AOT for one inoperable loop is sufficient.

As discussed in the bases of NUREG-1433, 3

LR-N20-0015 LAR H19-06 Enclosure With one RHR suppression pool cooling subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

Based on the above, a single train of SPC is sufficient to meet the DBA containment cooling requirements and maintain the suppression pool with temperature limits.

3.2 Adopt TSTF-230 Revision 1 to Extend AOT for both trains of SPC inoperable PSEG has reviewed TSTF-230, Revision 1 and has determined that the proposed change and its justification are applicable to HCGS. The current TS require a unit shutdown in the event both RHR suppression pool cooling loops become inoperable. The proposed change would allow 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore one RHR suppression pool cooling loop to OPERABLE status before initiating a unit shutdown. The proposed 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time is considered appropriate since an immediate plant shutdown has the potential for resulting in a unit scram and discharge of steam to the suppression pool when both suppression pool cooling loops are inoperable and incapable of removing the generated heat.

The 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore one train of SPC is consistent with current HCGS TS 3.6.2.2 action b for both loops of suppression pool spray being inoperable.

3.3 Risk Insights for extending the SPC AOTs Although this license amendment request is not a risk-informed request and therefore a risk evaluation is not required, PSEG is providing risk insights related to the proposed change. This risk analysis was performed to demonstrate with reasonable assurance that the proposed AOT change is within the current risk acceptance guidelines in Regulatory Guide (RG) 1.174 and RG 1.177. The risk analysis was based on the CDF (core damage frequency) and incremental conditional core damage probability (ICCDP), and LERF (large early release frequency) and incremental conditional large early release probability (ICLERP) for the unavailability of each train of the RHR SPC mode of operation as well as unavailability of both trains of RHR SPC.

This analysis demonstrates the acceptability, from a risk perspective, of a change to the AOTs for Hope Creek TS 3.6.2.3 from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days for one loop inoperable and 8-hours for both loops inoperable. The insights are similar to those reported in NUREG-1433.

3.4 Conclusion The allowed outage time extension from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days for one inoperable loop of suppression pool cooling will continue to meet the minimum requirements for mitigation of a DBA. The changes to the allowed outage times for one loop and both loops of SPC will make the HCGS TS actions consistent with NUREG-1433.

4

LR-N20-0015 LAR H19-06 Enclosure

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36(c) provides that TS will include Limiting Conditions for Operation (LCOs) which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee will shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. The proposed change involves extension of the suppression pool cooling allowed outage times. The LCOs themselves remain unchanged, as do the required remedial actions or shut down requirements in accordance with 10 CFR 50.36(c). Therefore, the proposed changes are consistent with current regulations.

Although not the direct subject matter of this requested amendment, the following 10 CFR 50, Appendix A, General Design Criteria apply to the systems covered by the proposed changes in this amendment application.

10 CFR 50, Appendix A, General Design Criteria (GDC)

CRITERION 38 - CONTAINMENT HEAT REMOVAL "A system to remove heat from the reactor containment shall be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss of coolant accident and maintain them at acceptably low levels. Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure."

CRITERION 44 - COOLING WATER "A system to transfer heat from structures, systems, and components important to safety, to an ultimate heat sink shall be provided. The system safety function shall be to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions. Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure."

Following implementation of the proposed changes, HCGS will remain in compliance with GDC 38, and 44.

4.2 Precedents Extending the allowed outage time from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days for one loop of SPC being inoperable is consistent with the NUREG-1433. In a letter from Nuclear Management Company, LLC to the NRC dated June 29, 2005, Monticello requested a license amendment to convert to the Improved Technical Specifications (NUREG-1433) (ADAMS Accession No.

5

LR-N20-0015 LAR H19-06 Enclosure ML051960175). In Volume 11 of the license amendment request (ADAMS Accession No. ML051990510), Monticello requested that the allowed outage time for one loop of SPC be revised from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days. The Monticello license amendment request was approved as Amendment No. 146 dated June 5, 2006 (ADAMS Accession No. ML061240241).

In a letter from Tennessee Valley Authority (TVA) to the NRC dated November 6, 2000, Browns Ferry Units 1, 2, and 3 requested a license amendment to adopt TSTF-230 Revision 1 to allow two RHR suppression pool cooling loops to be inoperable for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (ADAMS Accession No. ML003769048). The Browns Ferry license amendment request was approved as Amendment Nos. 241, 272, and 230 dated June 8, 2001 (ADAMS Accession No. ML011590526).

In a letter from PPL Susquehanna, LLC to the NRC dated September 23, 2002, Susquehanna Units 1 and 2 requested a license amendment to adopt TSTF-230 Revision 1 to add an action to allow both RHR suppression pool cooling to be inoperable for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (ADAMS Accession No. ML022760102). The Susquehanna license amendment request was approved as Amendment Nos. 207 and 181 dated January 16, 2003 (ADAMS Accession No. ML030160876).

In a letter from Entergy Operations, Inc. to the NRC dated January 21, 2009, River Bend Station Unit 1 requested a license amendment to adopt TSTF-230 to add an action to allow both RHR suppression pool cooling to be inoperable for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (ADAMS Accession No. ML090270198).

The River Bend Station license amendment request was approved as Amendment No. 165 dated August 11, 2009 (ADAMS Accession No. ML092010370) 4.3 No Significant Hazards Consideration PSEG requests an amendment to the Hope Creek Operating License. The proposed amendment involves a change to extend the Allowed Outage Time (AOT) for one inoperable loop of Suppression Pool Cooling (SPC) function of the Residual Heat Removal (RHR) system from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days.

PSEG has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92, and determined that the proposed changes do not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards:

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

Response: No.

The proposed TS changes to extend the time period that one loop of suppression pool cooling (SPC) can be out of service or allow 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore one SPC loop to OPERABLE status when both SPC loops have been determined to be inoperable will not increase the probability of an accident since the change does not alter the design or operation of the suppression pool cooling system. Required Actions and their associated Completion Times are not initiating conditions for any accident previously evaluated. Therefore, this change can have no impact on the plant that would make an accident more likely to occur due to the inoperability.

During transients or events which require SPC to be operating, there is sufficient capacity in the remaining operable loop to maintain the suppression pool temperature within analyzed limits during accident conditions. With one SPC loop, the minimum 6

LR-N20-0015 LAR H19-06 Enclosure equipment required to mitigate the consequences of an accident will remain operable.

Therefore the consequences of an accident previously evaluated will not be increased.

With both SPC loops inoperable, the proposed 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> allowed outage time provides some time to restore required loop(s) to OPERABLE status, yet is short enough that operating an additional 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> does not pose a significant risk. The Required Actions in the proposed change have been developed to provide assurance that appropriate remedial actions are taken in response to the degraded condition, considering the operability status of the SPC System and the capability of minimizing the risk associated with continued operation. As a result, neither the probability nor the consequences of any accident previously evaluated are significantly increased.

Therefore, the proposed extension of the AOT for a single loop of SPC and addition of an 8-hour AOT for both loops of SPC being inoperable do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed TS changes to extend the time period that one loop of SPC can be out of service or allow 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore one SPC loop to OPERABLE status when both SPC loops have been determined to be inoperable will not create the possibility of a different type of accident. The extension of these time durations do not result in any hardware changes to any structures, systems or components in the plant and hence does not create any new accident initiators. The SPC mode of RHR is an accident mitigation function.

Since the extension of the allowed outage times for SPC does not create any additional accident initiators for the plant, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The SPC AOT for a single loop being inoperable ensures that sufficient safety-related structures systems and components are available to respond to design basis accident conditions and that sufficient cooling/heat rejection capability for the suppression pool is maintained coincident with a loss of offsite power (LOP). During transients or events which require SPC to be operating, there is sufficient capacity in the remaining operable loop to maintain suppression pool temperature within analyzed limits during accident conditions.

The increased time allowed for restoring a required inoperable RHR SPC loop when both loops are inoperable is acceptable based on the small probability of an event requiring the suppression pool cooling loops to function and the desire to restore required loops prior to requiring the initiation of a plant shutdown. Delaying a plant shutdown will minimize the potential for a scram which then could potentially result in a 7

LR-N20-0015 LAR H19-06 Enclosure need for a SPC loop when it is inoperable. As such, any reduction in a margin of safety will be insignificant and offset by the benefit gained from providing additional time to restore required loop(s), thus avoiding potential plant transients during shutdown.

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

Based upon 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.

4.4 Conclusion Therefore, 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 Commissions 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.

5.0 ENVIRONMENTAL CONSIDERATION

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 CFR 20, 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 the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed 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.

6.0 REFERENCES

1. NUREG-1433, Revision 4, Standard Technical Specifications, General Electric BWR/4 Plants.
2. General Electric NEDC-33076P, Revision 2, "Safety Analysis Report for Hope Creek Constant Pressure Power Uprate", August 2006, (ADAMS Accession Number ML062690073)
3. NRC letter to PSEG, "Hope Creek Generating Station - Issuance of Amendment Re:

Extended Power Uprate (TAC No. MD3002)," dated May 14, 2008 (ADAMS Accession No. ML081230581 Cover Letter and ML081230640 Safety Evaluation Report)

4. TSTF-230, Revision 1, Add new Condition B to LCO 3.6.2.3, "RHR Suppression Pool Cooling, dated June 15, 1999 (ADAMS Accession No. ML040570110)
5. Letter from Nuclear Management Company, LLC to the NRC, License Amendment Request: Conversion of Current Technical Specifications (CTS) to Improved Technical Specifications (ITS), dated June 29, 2005, (ADAMS Accession No. ML051960175) 8

LR-N20-0015 LAR H19-06 Enclosure

6. NRC letter to Nuclear Management Company LLC , Monticello Nuclear Generating Plant (MNGP) - Issuance of Amendment for the Conversion to the Improved Technical Specifications with Beyond-Scope Issues (TAC Nos. MC7505, MC7597 through MC7611, and MC8887, (Amendment No. 146) dated June 5, 2006 (ADAMS Accession No. ML061240241)
7. Letter from Tennessee Valley Authority (TVA) to the NRC, Browns Ferry Nuclear Plant (BFN) - Units 1, 2, and 3 - Technical Specifications (TS) Change 411 - Incorporation of TS Task Force (TSTF) Item 230 Revision 1 - Revise TS 3.6.2.3 - RHR Suppression Pool Cooling - TAC Nos. MA0319, MA0320, and MA0321, dated November 6, 2000 (ADAMS Accession No. ML003769048).
8. NRC letter to Tennessee Valley Authority, Browns Ferry Nuclear Plant, Units 1, 2, and 3

- Issuance Amendments Regarding Residual Heat Removal Suppression Pool Cooling (TAC Nos. MB0319, MB0320 and MB0321), (Amendment Nos. 241, 272, and 230) dated June 8, 2001 (ADAMS Accession No. ML011590526).

9. Letter from PPL Susquehanna, LLC to the NRC, Susquehanna Steam Electric Station Proposed Amendment No. 249 to License NFP-14 and Proposed Amendment No. 214 to License NFP-22: Adoption of NRC Approved Generic Changes to Improved Technical Specifications (RHR Suppression Pool Cooling), dated September 23, 2002 (ADAMS Accession No. ML022760102)
10. NRC letter to PPL Susquehanna LLC, Susquehanna Steam Electric Station, Units 1 and 2 - Issuance of Amendments Regarding Residual Heat Removal Suppression Pool Cooling (TAC Nos. MB6452 and MB6453), (Amendment Nos. 207 and 181) dated January 16, 2003 (ADAMS Accession No. ML030160876)
11. Letter from Entergy Operations, Inc. to the NRC, License Amendment Request 2009-01, Application for Technical Specifications (TS) Change to Adopt NRC Approved Generic Changes TSTF-163, TSTF-222, TSTF-230, and TSTF-306 to the Improved Technical Specifications, River Bend Station, Unit 1, dated January 21, 2009 (ADAMS Accession No. ML090270198)
12. Letter from NRC to Entergy Operations, Inc., River Bend Station, Unit 1 - Issuance of Amendment Re: Adoption of Technical Specification Task Force Improved Standard Technical Specification Change Travelers TSTF-163, TSTF-222, TSTF-230, and TSTF-306 (TAC No. ME0406), (Amendment No. 165), dated August 11, 2009 (ADAMS Accession No. ML092010370) 9

LR-N20-0015 LAR H19-06 Attachment 1 Mark-up of Proposed Technical Specification Pages The following Technical Specifications pages for Renewed Facility Operating License NPF-57 are affected by this change request:

Technical Specification Page 3.6.2.3, Suppression Pool Cooling 3/4 6-16 1

CONTAINMENT SYSTEMS SUPPRESSION POOL COOLING LIMITING CONDITION FOR OPERATION 3.6.2.3 The suppression pool cooling mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a. One OPERABLE RHR pump, and
b. An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2 and 3.

ACTION: 7 days

a. With one suppression pool cooling loop inoperable, restore the inoperable loop 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 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 />.

following

b. With both suppression pool cooling loops inoperable, be in at least HOT SHUTDOWN within 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 next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

the next restore one RHR suppression pool cooling loop to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or SURVEILLANCE REQUIREMENTS 4.6.2.3 The suppression pool cooling mode of the RHR system shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by 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.
b. By verifying that each of the required RHR pumps develops a flow of at least 10, 160 gpm on recirculation flow through the RHR heat exchanger (after consideration of flow through the closed bypass valve) and the suppression pool when tested pursuant to the INSERVICE TESTING PROGRAM.
  • Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

HOPE CREEK 3/4 6-16 Amendment No. 205

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