LR-N980532, Application for Amend to License NPF-57,revising TS by Replacing Accelerated Testing Requirements of TS Table 4.8.1.2-1 with EDG Performance Monitoring & Delete TS 4.8.1.1.3 Requirement to Submit 30-day Special Rept

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Application for Amend to License NPF-57,revising TS by Replacing Accelerated Testing Requirements of TS Table 4.8.1.2-1 with EDG Performance Monitoring & Delete TS 4.8.1.1.3 Requirement to Submit 30-day Special Rept
ML20198C948
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 12/16/1998
From: Storz L
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198C954 List:
References
GL-94-01, GL-94-1, LCR-H98-11, LR-N980532, NUDOCS 9812220220
Download: ML20198C948 (10)
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  • Pubhc Service Electric and Gas Company '

Louis F. storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senor Vice President . Nuclear Operations DC 61g LCR H98-11 l United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

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REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS l CHANGES TO ACCELERATED TESTINGISPECIAL REPORTING REQUIREMENTS - I GENERIC LETTER 94-01 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company '

hereby requests a revision to the Technical Specifications (TS) for the Hope Creek Generating Station (HC). In accordance with 10CFR50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey.

Implementation of the proposed changes contained in this submittal will replace the I accelerated testing requirements of TS Table 4.8.1.1.2-1 with EDG performance monitoring in accordance with the Maintenance Rule (10CFR50.65) and will delete the TS 4.8.1.1.3 requirement to submit a 30-day Special Report for diesel failures. The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1), using the criteria in 10CFR50.92(c), and a determination has been made that this request involves no significant hazards considerations. The basis for the requested change is provided in Attachment 1 to this letter. A 10CFR50.92 evaluation, with a determination of no significant hazards consideration, is provided in Attachment 2. The marked up Technical Specification pages affected by the proposed changes are provided in Attachment 3.

! The changes are consistent with the TS improvements endorsed by NRC Generic Letter 94-01, " Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," dated May 31,1994. In addition, similar changes have been approved by the NRC for the Salem Generating Station Units 1 and 2 (Amendments 203 and 185, dated January 8,1998), Waterford Steam Electric Station Unit 3 (Amendment 126, dated April 21,1997) and Turkey Point Units 3 and 4 (Amendments 181 and 175, dated December 28,1995).

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9812220220 981216 T PDR ADOCK 05000354 t non o .per

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DEC 161993 Document Control Desk LR-N980532 NRC approval of these changes is requested by June 30,1999. Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the i date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities. Should you have any questions regarding this request, please contact Mr. C. Manges at 609-339-3234.

Sincerely, cyct$

Affidavit Attachments (3)

C Mr. H. Miller, Administrator - Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis Licensing Project Manager- Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Mr. S. Pindale (X24)

USNRC Senior Resident inspector - HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625 95-4933

Document Control Desk LR-N980532 CEM BC Senior Vice President - Nuclear Operations (X04)

Senior Vice President - Nuclear Engineering (N19)

General Manager - Hope Creek Operations (HO7)

Director - QA/NT/EP (X01)

Director - Licensing / Regulation and Fuels (N21)

Director- Design Engineering Manager - Financial Control & Co-Owner Affairs (N07)

Program Manager - Nuclear Review Board (N38)

Manager - Hope Creek Operations (H01)

Manager - System Engineering - Hope Creek (H18) 4 Manager- Hope Creek Licensing (N21)

J. Keenan, Esq. (N21)

NBU RM (N64)

Microfilm Copy Files Nos.1.2.1 (Hope Creek),2.3 (LCR H98-11) 1

REF: LR-N980532 LCR H98-11 STATE OF NEW JERSEY )

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COUNTY OF SALEM )

i L. F. Storz, being duly sworn according to law deposes and says:

I am Senior Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief.

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v Subscribed and Sworn to before me this /tdX day of 1)rcrfnhec1998 h>wi b ' A&J Notary Public of New Jersey DEUNHS D. MADDEN Egiros My Commission expires on os 2m i

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D:cumsnt Control D:0k LR-N980532 Attachmtnt 1 LCR H98-11 HOPE CREEK GENERATING STATION l FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS)

BASIS FOR REQUESTED CHANGE:

Public Service Electric and Gas Company (PSE&G), under Facility Operating License No. NPF-57 for the Hope Creek Generating Station, requests that the Technical Specifications (TSs) contained in Appendix A to the Operating License be amended as proposed herein to revise TS Surveilbnce Requirements 4.8.1.1.2 and 4.8.1.1.3, Table 4.8.1.1.2-1, and the associated Bases. The proposed changes replace the accelerated testing requirements with Emergency Diesel Generator (EDG) performance monitoring i in accordance with the Maintenance Rule (10CFR50.65) and delete the requirement to submit a 30-day Special Report for diesel failures. The associated Bases change identifies that the Regulatory Guide 1.108 critena for determining and reporting valid tests and failures and the accelerated testing provisions are superseded by Maintenance Rule implementation.

The proposed changes are endorsed by Generic Letter 94-01 " Removal of Accelerated l Testing and Special Reporting Requirements for Emergency Diesel Generators". The

! generic letter concludes that implementation of the Maintenance Rule, including the applicable regulatory guidance, provides a program to assure EDG performance. In

! addition, the generic letter notes that the reporting requirenients of 10CFR50.72 and 10CFR50.73 will continue to require reporting of EDG failures.

The proposed changes to the TS Surveillance Requirements are indicated on the marked-up TS pages contained in Attachment 3 of this submittal.

R_EQUESTED CHANGE, PURPOSE AND BACKGROUND:

l Genenc Letter 94-01 endorses changes to remove the EDG accelerated testing and special reporting requirements from the TSs. The basis for removal of the accelerated testing requirements is the implementation of a maintenance program for monitoring and maintaining EDG perforrnance in accordance with the provisioris of the Maintenance Rule and consistent with the guidance of Regulatory Guide 1.160. The basis for removal of the special reporting requirements is the required compliance with i the provisions of 10CFR50.72 and 10CFR50.73.

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l , Dacum:nt Centrol Dack LR-N980532 Attachm nt1 LCR H98-11 The proposed changes adopt the endorsed changes of Generic Letter 94-01.

Specifically, TS Surveillance Requirement 4.8.1.1.2,4.8.1.1.3, Table 4.8.1.1.2-1, and the associated Bases are modified to replace the accelerated testing requirements with EDG performance monitoring in accordance with the Maintenance Rule and to delete the requirement to submit a 30-day Special Report for diesel failures. The changes enable EDG maintenance to be dictated by performance, as monitored in accordance with the maintenance rule, rather than by imposing the accelerated surveillance test requirements contained in Tab:e 4.8.1.1.2-1 and eliminate the administrative burden of reporting EDG failures by deferring to the reporting criteria of 10CFR50.72 and 10CFR50.73.

l L JUSTIFICATION OF REQUECTED CHANGES:

NRC Ger aric Letter 94-01 endorses the elimination of accelerated EDG testing from the TSs based upon implementation of the Maintenance Rule for the EDGs. PSE&G l

has implemented the Maintenance Rule and conforms to the guidance of Regulatory Guide 1.160, Revision 2, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," for the Hope Creek EDGs, including the following key elements identified in Generic Letter 94-01:

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. Performance criteria for EDG reliability and unavailability, under paragraph (a)(2) of 10CFR50.65; e Appropriate root cause determination and corrective action following a single maintenance-preventable failure; and l

. Goals and EDG performance monitoring under paragraph (a)(1) of 10CFR50.65 if any performance criterion is not met, or if a repeat maintenance-preventable failure occurs.

l The reporting requirements of 10CFR50.72 and 50.73 obviate the need to report l individual failures of EDGs via Special Reports.

The associated Bases changes are provided for clarification.

The proposed changes are consistent with the NRC-endorsed line item TS improvements and are similar to those approved for the Salem Generating Station Units j 1 and 2 (Amendments 203 and 185, dated January 8,1998), the Waterford Steam l Electric Station, Unit 3 (Amendment 126, dated April 21,1997) and Turkey Point Units 3 and 4 (Amendment 181 and 175, dated December 28,1995).

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D: cum:nt Centr:I Ds2k LR-N980532 Attachm:nt 1 LCR H98-11 CONCLUSION:

The proposed changes to the TSs enable EDG maintenance to be dictated by performance, as monitored in accordance with the maintenance rule, rather than by imposing the existing accelerated surveillance test requirements and eliminate the administrative burden of reporting EDG failures by deferring to the reporting criteria of 10CFR50.72 and 10CFR50.73. The changes are consistent with the changes endorsed by the NRC in Generic Letter 94-01, and Hope Creek complies with the stated conditions for approval (i.e., implementation of a maintenance program for monitoring and maintaining EDG performance in accordance with the Maintenance Rule and consistent with the associated regulatory guidance).

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D cumsnt Contral Dsk LR-N980532 l Attachm:nt 2 LCR H98-11 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS) l 10CFR50.92 EVALUATION

, i l Public Service Electric & Gas has concluded that the proposed changes to the Hope l Creek Generating Station Technical Specifications do not involve a significant hazards consideration. In support of this determination, an evaluation of each of the three )

i standards set forth in 10CFR50.92 is provided below.

I REQUESTED CHANGE l

The proposed changes adopt the endorsed changes of Generic Letter 94-01.

Specifically, TS Surveillance Requirements 4.8.1.1.2,4.8.1.1.3, Table 4.8.1.1.2-1, and the associated Bases are modified to replace the accelerated testing requirements with  ;

Emergency Diesel Generator (EDG) performance monitoring in accordance with the '

Maintenance Rule (10CFR50.65) and to delete the requirement to submit a 30-day l

Special Report for EDG failures. The Bases are also modified to reflect the proposed changes. l l I r

l BASIS l

1. The proposed change does not involve a significant increase in the l probability or consequences of an accidentpreviously evaluated.

f The proposed TS changes c'o not involve any physical changes to plant structures,  !

systems, or components. PSE&G has implemented the provisions of the Maintenance

Rule for diesel generators, including the associated regulatory guidance, thereby l establishing a program that assures diesel generator performance. The elements of i
the program include the performance of detailed root cause analysis of individual failures, effective corrective actions taken in response to individual failures, and )

implementation of preventive maintenance consistent with the Maintenance Rule.  ;

Monitoring the effectiveness of diesel generator maintenance and continuing l

surveillance testing in accordance with the proposed TS changes will ensure that the j diesel generators will perform their intended functions and will minimize failures. The accelerated testing requirements are therefore no longer considered to be necessary Page 1 of 2

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D:cumsnt Contral D:ck

~ LR-N980532 l Attachment 2 LCR H98-11

and are deleted. The requirements of 10CFR50.72 and 10CFR50.73 ensure that diesel generator failures are properly reported. The special reporting requirements are therefore unnecessary and are deleted. Based on the above information, the changes will not adversely affect the assurance of diesel generator reliability or operability, and j there is no significant increase in the probability or consequences of any accident previously evaluated.
2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously analyzed.

The proposed TS changes do not involve any physical changes to the design of plant I systems, structures or components, nor do the changes involve a change in plant operation. The diesel generators will continue to function as designed to mitigate the consequences of an accident. Eliminating the accelerated testing requirements and special reporting requirements does not permit plant operation in a configuration that would create a different type of malfunction to the diesel generators than any previously evaluated. In addition, the proposed TS changes do not alter the conclusions described in the UFSAR regarding the safety related functions of the diesel generators or their support systems. No new failure modes will be introduced. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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3. The proposed change does not involve a significant reduction in a margin l ofsafety. '

This request does not involve an adverse impact on diesel generator design, operation, or reliability. Since monitoring and maintenance is being performed in conformance with 10CFR50.65, modifying the surveillance testing frequency requirements does not adversely affect the reliability of the diesel generators. Deletion of the special reporting requirements does not impact operability or reliability of the diesel generator. Since the  ;

diesel generator function is not affected by the proposed change, this request does not i involve a significant reduction in a margin of safety.

1 CONCLUSION Based on the above, PSE&G has deterrnined tha; the proposed changes do not involve  !

i a significant hazards consideration.

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. Docum2nt Central De;k LR-N980532 Attachm!nt 3 LCR H98-11 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS)

TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Facility Operating License No. NPF-57 are affected by this change request:

Technical Specification Page 4.8.1.1.2 3/4 8-4 4.8.1.1.3 3/4 8-9 Table 4.8.1.1.2-1 3/4 8-10 Bases for 3/4.8.1,3/4.8.2 and 3/4.8.3 B 3/4 8-1c

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