ML20059A496
| ML20059A496 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 10/18/1993 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20059A500 | List: |
| References | |
| NLR-N93154, NUDOCS 9310260346 | |
| Download: ML20059A496 (10) | |
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Pubhc Sernce Decinc and Gas Company Joseph J. Hagan Put;hc Service Electoc and Gas Company P.O. Box 236. Hancocks Bndge, NJ 08038 609-339-1200 m %unro war oprawm OCT181993 NLR-N93154 LCR 93-06 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDMENT APPLICATION STI/AOT EXTENSIONS FOR SELECTED INSTRUMENTATION-FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 This letter submits an application for amendment to Appendix A of i
Facility Operating License NPF-57 for the Hope Creek Generating i
Station and is being filed in accordance with 10CFR50.90.
The changes that are proposed in this submittal would extend the surveillance test intervals (STIs) and allowed out-of-service times (AOTs) for selected instrumentation. contains l
a detailed description of and justification for the proposed j
changes.
Based upon the justification provided, PSE&G believes that the proposed changes do not involve a significant hazard consideration pursuant to 10CFR50.92.
The technical information contained in Attachment 1 is based upon General Electric Company (GE) Licensing Topical Report (LTR) GENE-770-06-1-A (December i
1992), GE LTR NEDC-31677P-A (July 1990), and GE LTR NEDC-30851P-A (March 1988).
As these changes reflect NRC approved, generic changes contained in the LTRs, PSE&G believes that a detailed NRC branch review or specialist review should not be required. contains marked up Technical Specification pages which reflect the proposed changes.
Upon NRC approval, please issue a license amendment which will be effective upon issuance and shall be implemented within 60 days of issuance.
This latitude permits appropriate procedural modifications necessary to implement the proposed changes.
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Should you have any questions or comments on this submittal,
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please do not hesitate to contact us.
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Mr.
T. T. Martin, Administrator - Region I U.
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Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.
S.
Dembek, Licensing Project Manager l
U.
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Nuclear Regulatory Commission l
One White Flint North 11555 Rockville Pike Rockville, MD 20852 t
Mr.
C. Marschall (SO9) i USNRC Senior Resident Inspector j
Mr.
K. Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
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REF: NLR-N93154 LCR 93-06 i
STATE OF NEW JERSEY
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i COUNTY OF SALEM
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Hagan, being duly sworn according to law deposes and says:
I am 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 the Hope Creek l
Generating Station, are true to the best of my knowledge, f
information and belief.
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Subscribeg l d nd Sworn t b fore me this
!Ol ay of 1993 I MMd-d E
/ otary Public of Ne Jersey v
N SHERRY L CAGLE -
NOTARY PUBUC OF fJEW JERSEY My Commission expires on My Commission Expires March 5,1997 i
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i ATI742ME2ff 1 PPOIOSED QWEES YD THE TEONICAI, SPECIFICATIGE i
LIQ 2EE AME2DElff APPLICATION STI/ACTP DCIDEIGE IDR SIHECTED INS'HDEff1ATICH IDPE QEEK GDERATING STATICH FANT3TY OPERATIIC IJCE2EE NIT-57 NIR-N93154 DOOTT 10. 50-354 ICR 93-06 i
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IFfw.2umCN OF YHE PROIOSED OIA!EES This license amenbent application proposes to changes Technical I
Specifications (TS) ard their associated Bases for selected instrumentation.
j Technical Specification 3/4.3.4.1, "ATWS Recirculation Pump Trip System Instrumentation", and its associated bases are charged such that:
A.
The allowed out-of-service tire (ACT) for surveillance testing specified in Note (a) of Table 3.3.4.1-1 is extended from 2 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
B.
The ACrr for maintenance is extended from one (1) hour to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
C.
The channel functional test requirements specified in Thble 4.3.4.1-1 are extended fran renthly to quarterly for the following trip functions:
1.
Ina Ica, level 2 2.
Reactor Vessel Pressure - High D.
Bases Section 3/4.3.4 is ItNised to reference GE IHR GDE-770-06-1-A which justifies the above proposed changes to the Recirculation Ptrap i
Trip Actuation Instrunentation.
Technical Specification 3/4.3.4.2, "End-of-Cycle Recirculation Punp Trip System Instrumentation", and its associated bases are changed such that:
A.
The ACTf for surveillance testirx3 specified in Note (a) of Table 3.3.4.2-1 is extended frtrn 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
B.
The AOT for maintenance is extended from one (1) hour to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
C.
The channel functional test requirenents specified in Table 4.3.4.2.1-1 from nonthly to quarterly for the following trip functions:
1.
Turbine Stop Valve - Closure 2.
Turbine Control Valve - Fast Closure Page 1 of 7
.~ Attachment 1 LCR 93-06 STI/AOT Extensions for Selected Instrumentation NLR-N93154 D.
Bases Section 3/4.3.4 is revired to reference GE LTR GDE-770-06-1-A stich justifics the above proposed charges to the Recirculation Pump Trip Actuation Instrumentation.
Technical Specification 3/4.3.9, "Feedwater/ Main Turbine Trip System Actuation Instrumentation", and its associated bases are charged such that:
A.
Specify the ADT for surveillance testing by addirq Note (*) to the Surveillance Requirenents and addirg a reference to Note (*) to Surveillance Requirenent 4.3.9.1.
Note (*) A Channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required surveillance without placity the trip system in the tripped cordition.
B.
The channel functional test fregaency in Table 4.3.9.1-1 is charged frum renthly to quarterly.
C.
Bases Section 3/4.3.9 is revised to reference GE L'IR GDE-770-06-1-A which justifies the above proposed changes to the Feedwater/ Main Turbine Trip System Actuation Instrumentation.
Technical Specification 3/4.4.2.1, " Safety / Relief Valves", arx3 its associated bases are charged such that:
A.
'Ihe channel functional test frequency in 4.4.2.1.a is changed from once per 31 days to once per 92 days.
B.
Bases Section 3/4.4.2 is revised to reference the GE LTR GDE-770-06-1-A khich justifies the above proposed changes to the Safety / Relief Valves.
'Ibchnical Specification 3/4.4.2.2, " Safety / Relief Valves Im-Im Set Function", ard its associated bases are charged such that:
A.
Specify the ACT for surveillance testirq by adding Note (**) to the Surveillance Requirenents and adding a reference to Note (**) to the Surveillance Requirement 4.4.2.2.1.
Note (**) A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required surveillance without placiJy the trip system in the tripped cordition.
B.
'Ibe channel functional test frequency in 4.4.2.2.1.a is charged from on per 31 days to once per 92 days.
C.
Bases Section 3/4.4.2 is revised to reference the GE LTR GDE-770-06-1-A which justifies the above proposed clages to the Safety / Relief Valves.
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Atta'chment 1 IIR 93-06 STI/AOT Extensions for Selected Instrumentation NLR-N93154 The proposed TS changes described above are consistent with the changes proposed and approved in the referenced GE dmnt and associated IEC safety evaluation report (References 1 - 2).
1 II.
REASON FOR 'llE PROIOSED OWGPS The primary reason for proposing these changes is to ensure consistency with the STI and Aar charges for the reactor protection system instrtrentation, emergency core cooling system (ECX:S) instrumentation and isolation actuation ins *mtation. The STI and ACT relaxations ircluded in GE LTR GDE-770-06-1-A (Refe.m 1) are similar in camponents, configuration, and function to the STI and A0r relaxations analyzed in previous NRC approved GE LTRs, NEDC-30851P-A and NEDC-31677P-A (References 3 and 4 respectively). The technical anennmnt of these previously IEC approved GE LTRs, and therefore GE LTR GDE-770-06-1-A, indicated a positive benefit and net improvement in overall plant safety and operation. This conclusion was based upon consideration of the following factors:
A.
Potential for inadvertent scrans B.
Excessive test actuation cycles (equipment wearout)
C.
Diversion of plant personnel D.
Potential for test-caused failures E.
Potential increased risk from shutdown due to limiting conditions of operation Contributing factors A through E are referenced in Section 5.6 of Refercnce 4 and their impact on plant safety is discussed in detail in Section 4.2 of Reference 6.
III. JINTIFICATICH FOR 71E PROPOSED OWGES The procedure used by the BWR Owners' Group (BWROG), in Reference 1, to justify STI and AUT relaxation for selected instrumentation was to demonstrate similarity in camponents, configuration, and function with previously reviewed actuation instrumentation for which STI and Aar relaxations were approved. This proccdure was applied to all of the identified selected instruments.
The generic GE analyses contained in References 1 evaluated the effect of the proposed changes to the STIs and Aars for selected instrunentation and demonstrated that: 1) any increase in risk is judged to be offset by the benefits associated with the similar approved STIs and Aars, 2) that the effect on failure frequencies was negligible, and 3) that the bases for changes can be bound by previously approved bases for the same changes for instrumentation that was similar in camponents, configuration, and function. FurtherT: ore, when the factors described in Section II of this submittal are considered, the overall effect on plant safety is judged to be an improvement.
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Atta'chment 1 LCR 93-06 STI/AOT Extensions for Selected Instrumentation NLR-N93154 Reference 2 concluded that the associated GE report provided an acceptable basis for extending STIs and AOTs for the selected J
instrumentation; however, this NRC safety evaluation report (SER) also required that two issues be addressed to justify the applicability of the l
generic analysis to individual plants when specific facility Technical j
Specifications are considered for revision. These issues were: 1) l confimation of the applicability of the generic analyses to the specific plant and 2) confimation that any increase in instrument drift due to the extended STIs is properly accounted for in the setpoint calculation methodology. W e following discussion provides information to address these issues.
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i A.
Confimation of the Applicability of the Generic Analyses Our confirmation of the applicability of the generic analyses to Hope Creek is based upon the following:
1.
PSE&G has maintained its participation and involvenent on the Bh'R Owners Group Technical Specification Improvement Cummittees l
thereby assuring that the developnent of these generic reports 2
erenss the Hope Creek Generating Station.
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PSE&G has reviewed the applicable GE LTRs and verified their j
applicability to the Hope Creek Generating Station.
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B.
Confimation that Instrunent Drift is Properly Considered he NRC staff has provided guidance on addressing the issue of instrur:ent drift in Reference 5.
Eis guidance indicated that:
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"... licensees need only confim that the setpoint drift which could i
j be expected under the extended STIs has been studied and either (1) i has been shown to remain within the existing allowance in the RFS and ESFAS instrunent setpoint calculation or (2) that the allowance j
ard setpoint have been adjusted to account for the additional i
expected drift."
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In order to satisfy this requirenent, PSE&G applied a two fold approach j
to the issue of instruncnt drift. W is two fold approach involved the following:
l 1.
The setpoint calculations for all instrumentation affected by the charges proposed in this anendment application, with the exception of the Turbine Control Valve - Fast Closure (TCVFC) and the Turbine Stop Valve - Closure (TSVC), were reviewed. Results of this review irdicate that, in all cases, the loop (setpoint) drift calculation was based on an eighteen month interval; therefore, the proposed STI extensions from monthly to quarterly are well bounded by the existing setpoint calculations.
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Atta'chment 1 LC.R 9 3-0 6 STI/AOT Extensions for Selected Instrumentation NLR-N 93154 he monthly surveillance tests for the 'ICVEC ard the TSVC tests the mechanical operability of the valves. W ere is no drift associated with the circuits tested in these surveillances in accordance with Regulatory Guide 1.105, because they are mechanical limit switches. Merefore drift is not a relevant concern.
2.
For the analog instrumentation, data for each trip unit consisted of "as found" and "as left" trip setpoint settirgs over a twelve month period. W e actual observed drift over the twelve month period, in all cases, was fourd to be conservatively bounded by the total loop allowance for a six ronth period.
For the 'ICVFC and the TSVC, surveillance test data over a twelve month period was reviewed to confirm that no rework was required during that period. he surveillance extension from monthly to gaarterly is bounded by this 12 month period.
IV.
SIGIIFICATTT HAZARDS RNSIIERATION EVAIDATIG4 PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed amendnent to determine whether the request involves a significant hazards consideration. We have determined that operation of the Hope Creek i
Generating Station in accordance with the propoced changes:
1.
Will not involve a significant increase in the probability or consequenoes of an accident previously evaluated.
To justify the STI and ADT relaxation for the selected instrunentation mentioned atxwe, GDIE-770-06-1-A (Reference 1) denonstrates the similarity in components, configuration, and function with previously reviewed instrunentation for which STI and i
ACT relaxations were approved. Se analysis for the previously -
approved STI ard ACT relaxation approvals are in NEDC-30851FA ard NEDC-31677P-A (References 3 and 4, respectively). When all contributirg factors are considered, the net impact of the proposed charges is to improve plant safety. R ese generic analyses have j
been verified to be applicable to the HCGS as indicated in Section III above. Since the proposed changes have a net beneficial ignet on plant safety when all factors are considered, the proposed charges will not significantly increase the probability or consequences of a previously analyzed accident.
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i Atta'chment 1 LCR 93-06 STI/AOT Extensions for Selected Instrumentation NLR-N93154 i
2.
Will not cmate the possibility of a new or different kini of accident frun any accident previously evaluated.
Increasing the AOrs and STIs for the selected instnmentation does not alter the function of the equipment nor involve any type of plant modification. Additionally, no new modes of plant operation are involved with these charges. 'Ihe proposed changes therefore will not create the possibility of a new or different kind of accident frun any accident previously evaluated.
3.
Will not involve a significant rtduction in a margin of safety.
As requested by the BWR Owners' Group, GE performed analyses to evaluate the effect of the proposed changes on plant safety. 'Ihe NRC staff has reviewed and approved the generic studies contained in GE LTRs NEDC-30851P-A, NEDC-31677P-A, and GENE-770-06-1-A and has concurred with the BWR Owners Group that the propcsed changes do not significantly affect the plant safety. Furthermore, the overall level of plant safety will be improved by the proposed changes. It can therefore be concluded that the proposed changes will not significantly reduce a margin of safety.
V.
CXNCWSION As discussed above, PSE&G has concluded that the proposed changes to the Technical Specifications do not involve a significant hazards consideration since the changes: (i) do not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) do not create the possibility of a new or different kind of accident frun any accident previously evaluated, ard (iii) do not involve a significant reduction in a margin of safety.
VI.
Kr2D<rDCES 1.
GDIE-770-06-1-A, "Ihses for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation
'Itchnical Specifications", dated December 1992.
2.
Iatter to R. D. Binz (BWROG) from C. E. Rossi, dated July 21, 1992 (transmits NRC safety evaluation report for GENE-770-06-1).
3.
NEDC-30851P-A, " Technical Specification Irprovement Analyses for BNR l
Reactor Protection System", March 1988.
4.
NEDC-31677P-A, " Technical Specification Improvement Analysis For BWR Isolation Actuation Instrumentation", July 1990.
5.
Ietter from C. E. Rossi (NRR) to R. F. Janecek (BWROG), " Staff Guidance for Licensea Determination that the Drift Characteristics for Instrumentation Used in RPS Channels are BouMed by NEDC-30851P Assumptions When the Functional Test Interval is ExteMed frun Monthly to Quarterly", dated April 27, 1988.
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Atta'chment 1 LCR-93-06 STI/AOT Extensions for Selected Instrumentation NLR-N93154 i
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NEDC-30936P-A, "WR Owners' Group Technical Specification i
Improvement Methodology (With Derurobation fc,r IER ECCS Actuation Instrumentacion) Part 2", dated December 1988.
7.
PSE&G Internal Menorandum EIE-92-0667 fran Robert Sardy, Hope Creek I&C, to C. Manges, Nuclear Licensing, dated D er 9, 1992.
8.
PSE&G Internal Menorandum ELE-93-0489 fran Robert Sandy, Hope Creek I&C, to L. Castagna, Nuclear Licensirg, dated October 5,1993.
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