ML20011E196

Application for Amend to License NPF-57,consisting of License Change Request 90-01,removing 3.25 Limit on Extending Surveillance Intervals in Tech Spec 4.1.2,per Generic Ltr 89-14

ML20011E196
Person / Time
Site:	Hope Creek
Issue date:	01/31/1990
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20011E197	List: ML20011E196 ML20011E199
References
GL-89-14, NLR-N90002, NUDOCS 9002090028
Download: ML20011E196 (7)

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Public Service Electric and Oas i Company ,

Stanley LaBruna Put>Iic Service Electric and Gas Cornpany P.O. Box 236. Hancocks Bridge. NJ 08038 609-339-4800

. % v<e u n .naveauc w<ns e January 31, 1990 NLR-N90002

Reference:

LCR 90-01

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U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR AMENDNENT FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and. Gas Company (PSE&G) hereby transmits

-an application.to amend Appendix A of Facility Operating License No.-NPF-57.in accordance with 10CFR50.90. In accordance with the provisions of Generic Letter 89-14, this requested amendment would remove the 3.25. limit on extending surveillance intervals in Technical Specification 4.0.2.

A descriptionlof the requested amendment, supporting information and. analyses for the change, and the basis for a no significant hazards considerations determination are provided in Attachment 1.- The Technical-Specification pages affected by the proposed change are marked-up in Attachment 2.

Based on the our determination that the proposed change does not involve a significant hazards consideration pursuant to 10CFR50.92.and that there-are no issues involved in this request

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that-would require any further detailed technical branch reviews, PSE&G believes that.the proposed amendment would be properly classified, in accordance with the current NRC Amendment Review Procedures, as a Category 2 change. Additionally, pursuant to the requirements of 10CFR50.91 (b) (1), PSE&G has provided a copy of this amendment request to the State of New Jersey.

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e Document Control Desk 1-31-90 '

NLR-N90002 Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but implementable within sixty days to provide sufficient time for.

associated ~ procedural modifications. ,

sincerely, Attachments Affidavit C Mr. W. T. Russell, Administrator USNRC Region I Mr. C. Y. Shiraki USNRC Licensing Project Manager Mr. T. P. Johnson Senior Resident Inspector Mr. K. Tosch, Chief Bureau of Nuclear Engineering New Jersey Department of Environmental Protection l

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7 LCR 90 ,t STATE OF NEW JERSEY  ;

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' COUNTY OF SALEM )' i S. ; LaBruna,- being duly sworn according ,to law deposes and says: .

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'I.am Vice President - Nuclear Operations of Public Service Electric and~ Gas Company, and as'such,=I. find the matters set -

forth in'our letter dated January 31, 1990 concerning the )

Hope'. Creek Generating Station, are true to the best'of my -

knowledge,! information and b'elief. I n -i L

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Subscribed and Sworn to before me -

this 3/ day of , 1990 0 /

.M tary Publb of New Jersey 1

LARAINE Y. BEARD

' Notary Public of New Jersey My Commission Expires May 1,1991

.My. Commission expires on t

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4 Reference LCR 90 n ATTACIDENT 1 ,

PROPOSED LICENSE AMENDBEENT 5 i

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a FACILITY OPERATING LICENSE'NPF-57 NIA-N90002

. HOPE CREEK GENERATING STATION DOCKET NO. 50-354-

Reference:

LCR 90-01 1

, DESCRIPTION OF THE CHANGE As shown on the marked-up Technical Specifications pages in Attachment 2,  !

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1. Revise Technical Specification 4.0.2 to read as follows: ,

"4.0.2 -Each Surveillance Requirement shall be 1 performed within its specified surveillance interval i with a maximum allowable extension not to exceed 25

, percent of-the specified surveillance interval."  !

2. Revise the Bases Section for Specification 4.0.2 to I read as follows:

" Specification 4.0.2 establishes the limit for which  !

the specified time interval for Surveillance Requirements may be. extended. It permits an allowable extension of the normal surveillance interval to i facilitate surveillance scheduling and consideration of l plant operating conditions that may not be suitable for  !

conducting the surveillance; e.g., transient conditions  ;

or-other ongoing surveillance or maintenance  :

activities. It also provides flexibility to accommodate 1 the length of a outage and are specified with an  !

18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to-  ;

extend' surveillance intervals.beyond that specified for surveillances that are not performed during refueling outages. The limitation-of recognition that the most probable-result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is ,

sufficient to ensure significantly degraded beyond that '

obtained from the specified surveillance interval."

REASON FOR THE CHANGE This alternative to the requirements of Specification 4.0.2 will remove an unnecessary restriction on extending surveillance requirements and will result in a benefit to safety when plant conditions are not conducive to the safe conduct of surveillance requirements. The removal of the 3-.25 limit will provide greater flexibility in the use of the provision for extending surveillance intervals, reduce administrative burden associated with its use, and'have a positive effect on safety.

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JUSTIFICATION FOR THE CHANGE NLR-N90002 L >

The requested change was proposed by Commonwealth Edison Company j for the LaSalle, Plant and approved by the NRC staff on_a lead-plant basis. Guidance for other licensee amendment requests L

has been provided in Generic Letter 89-14. As stated in the h Generic Letter, experience has shown that the 18-month h surveillance interval, with the provision-of Technical Specification 4.0.2 to. extend it by 25 percent, is usually  :

a< -sufficient-to accommodate normal variations in the length of a e fuel cycle.- However, the NRC staff has routinely granted T- requests for one-time exceptions to the 3.25 limit on extending i

refueling surveillances because the risk to safety is low in

-contrast to the. alternative of a forced shutdown to perform these '

surveillances. Therefore, the 3.25 limitation'on extending.

surveillance intervals has not been a practical limit on the use of the 25 percent. allowance for refueling outage surveillance interval extensions.

The NRC staff has concluded that the removal of the 3.25 limit from Specification 4.0.2 results in a greater benefit to safety than limiting the use of the 25% allowance to extend surveillance r intervals. This safety benefit can be demonstrated by extending I the interval of a. surveillance that, if performed rigidly to its schedule, would. require its performance under conditions that are  :'

not suitable for. performing the surveillance. Examples of this include conditions present during plant operating transients or '

times when safety-systems are out of service because of ongoing surveillance testing.or matatenance activities. In such cases, the safety benefit of allowing an 25-percent extension of the surveillance interval would outweigh any benefit derived by. >

. limiting three consecutive surveillance intervals to the 3.25 ,

limit. Additionally, the requested change would provide relief  ;

of the administrative burdens associated with tracking the use of the.25-percent allowance to. ensure compliance with the'3.25 limlt . - Based upon the above, the NRC staff has concluded that removal of the 3.25 limit will have an overall positive impact.on safety.

10CFR50.92 SIGNIFICANT HAZARDS CONSIDERATION ANGYSIS ,

PSE&G has, pursuant to 10CFR50.92, reviewed the proposed amendment to determine whether our request involved a significant ,

hazards consideration.

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.The anaratien'of mana Creek nanavatinrr Station fBNn) in '

annardanam wnth tha nr-4 ahanae wall not-involve a I mienifiamat < ner==== in the nrah=hility or n=*- mana== of an acciAmnt nrSVianaly gyglugtaA, l

As stated'in Generic Letter 89-14, the removal of the 3~.25 limit t'

.from Specification 4.0.2 results in a greater benefit:to safety than limiting the use of the 25 percent allowance to extend surveillance intervals. The proposed change will remove a '

limitation:in the TS which has been determined by the NRC staff to be impractical and does not-involve a physical or procedural 1

change that will significantly impact any structure, component or system that.affects the probability or consequences of any accident or malfunction of equipment important to safety ,

previously evaluated in the Update Final Safety Analysis Report *

(USFAR). J The oneration of Bone Creek Generatiner Station (BN2) in g

accordance with the nroner-d chanae wnll not create the nossibility of a new or different kind of accident from any previously evaluated.

' The proposed change does not adversely affect the design or operation of any system or component important safety. No -

physical plant modifications or new operational configurations result from this change. Therefore, it may be concluded that the proposed change ~does not create the possibility of a new or L different. kind of accident from any previously evaluated. .

LM? The operation of Hone Creek Canaratina Station (HCC-B) in T I accordpam with tha nrone--d change does not involve a sianificant reduction in a marain safety.

As stated in Generic Letter 89-14, the use of the allowance to extend surveillance intervals by 25 percent-can result.in a significant safety benefit. This safety benefit is obtained when a surveillance interval is extended at'a time when conditions are 2 not suitable for performing the surveillance. The safety benefit 1 of allowing.the use of the 25 percentsallowance to extend.a l

, surveillance: interval outweighs any benefit derived by limiting- l three (3) consecutive surveillance intervals to the 3.25 limit.

Therefore, it may be concluded that the proposed change does not involve a significant reduction in a margin of safety.

Conclusion:

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i Based upon the above and on the conformance of this request to J

the guidance provided in Generic Letter 89-14, we have determine y that this proposed-change'does not involve a Significant Hazards L Consideration.

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