ML20059A793
| ML20059A793 | |
| 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 | |
| ML20059A797 | List: |
| References | |
| LCR-93-03, LCR-93-3, NLR-N93015, NUDOCS 9310270124 | |
| Download: ML20059A793 (11) | |
Text
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Pubhc Semce Dectnc and Gas Company Joseph J. Hagan Pubhc Service E ectnc and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 m n-m wam. one w,n 00T181993 NLR-N93015 LCR 93-03 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDMENT APPLICATION STI/AOT EXTENSIONS FOR ISOLATION ACTUATION 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 Facility Operating License NPF-57 for the Hope Creek Generating 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 the isolation actuation instrumentation. contains a detailed description of and justification for the proposed changes.
Based upon the justification provided, PSE&G believes that the proposed changes do not involve a significant hazards consideration pursuant to 10CFR50.92.
The technical information contained in Attachment 1 is based upon General Electric Company (GE) Licensing Topical Report (LTR)
NEDC-30851P-A, Supplement 2 (March 1989) and GE LTR NEDC-31677P-A (July 1990).
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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NLR-N93015 Should you have any questions or comments on this submittal, please do not hesitate to contact us.
Sincer ly, Affidavit Attachments (2)
C Mr.
T.
T.
Martin, Administrator - Region I U.
S.
Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.
S.
Dembek, Licensing Project Manager U.
S.
Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr.
C.
S. Marschall (SO9)
USNRC Senior Resident Inspector Mr.
K.
Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 t
l
b REF: NLR-N93015 LCR 93-03 STATE OF NEW JERSEY
)
)
SS.
COUNTY OF SALEM
)
J.
J.
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 Generating Station, are true to the best of my knowledge, information and belief.
l 1
Subscribed and Sworn to before me j
this / I
dayofh*bJrr_
1993 1
1m,?aAhl hb7 Ac2LL*~~
hotaryPublihofNewJersey i
KIMBERLY Jo BROWN NOTARY PUBLIC OF NEW JE My Commission expires on Mr Commissian troi,es sora s, RSEY
,99, i
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e ATIAC3MDE 1 HORYED QWEES 'IO 'ITE 'lIX3NICAL stic.tr1CATIGE LICDEE IME24IEE2R AHLICATIGT SI'I/IDP D"IDEIGE TUR ISOIATIQ4 ICIIATIGi IIGIRME2flATICN IDIE GEEK GE2IERATDC SIATICH F/cTT PIY OPERATIIG LICE 2EE NPF-57 NIR-N93015 DOCKE.T 10. 50-354 IIR 93-03 I.
[FNOT OF 'I1E PRORYED OWUES
'Ihis license amendment application proposes to charge Technical Specification (TS) 3/4.3.2, "ISOIATION ACIUATION IFETRUME2frATICri" and its associated Bases, such that:
A.
'Ihe allowed out-of-service time (ICT) for surveillance testing specified in Note (a) to Table 3.3.2-1 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 ACTDs for maintenance are extended to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for. isolation instrumentation common to reactor protection system (RPS) instrumentation and to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for isolation instrumentation not common to RPS instrumentation. 'Ihe ACTT remains one hour for situations in which there is a loss of function and there are no operable channels for the given trip function. A footnote is added to Table 3.3.2-1 to identify the trip functions with instrumentation common to RPS instrumentation.
C.
'Ihe test frequency in Footnotes (a) and (b) of Table 4.3.3.1-1 are charged from once per 31 days to once per 92 days.
D.
'Ihe channel functional test requirements specified in Table 4.3.3.1-1 are extended from renthly to quarterly for the folloaing trip functions:
1.
Primary Containment Isolation:
a.
Reactor Vessel Water Invel -
1)
Iva Ina, level 2 2)
Ina Ind 1n4, Invel 1 b.
Drywell Pressure - High c.
Reactor Building Exhaust Radiation - High d.
Manual Initiation 2.
Secordary Containnent Isolation:
a.
Reactor Vessel Water Invel - Ina low, Invel 2 b.
Drywell Pressure - High c.
Refuel Floor Buildirg Exhaust Radiation - High d.
Reactor Building Exhaust Radiation - High e.
Manual Initiation Page 1 of 6
.LCR 93-03 STI/AOT Extensions for Isolation Instrumentation NLR-N93015 L
3.
Main Steam Line Isolation:
a.
Reactor Vessel Water Invel - Im Im Im, Level 1 b.
Main Steam Line Radiation - High, High c.
Main Steam Line Pressure - I m d.
Main Steam Line Flw - High e.
Condenser Vacutn - Im f.
Main Steam Line Tunnel Temperature - High g.
Manual Initiation 4.
Reactor Water Cleanup System Isolation:
a.
RWal Delta Flw - High b.
RWCU Delta Fl w - High, Timer c.
RWCIJ Area Temperature - High d.
RWCU Area Ventilation Delta Temperature - High e.
SICS Initiation f.
Reactor Vessel Water Invel - Im Is,. Invel 2 g.
Manual Initiation 5.
Reactor Core Isolation Coolirg System Isolation: '
a.
RCIC Steam Line Delta Pmssum (Flw) - High b.
RCIC Steam Line Iblta Pressure (Flm) - High, Timer c.
RCIC Steam Supply Pressure - Im d.
RCIC Turbine Exhaust Diaphragm Pressure - High ROIC Pump Rocn Temperature - High e.
f.
RCIC Pump Roam Ventilation Ducts Delta Temperature - High g.
RCIC Pipe Routing Area Temperature - High h.
RCIC Torus Campartment Temperature'- High i.
Drywell Pressure - High 6.
High Pressure Coolant Injection System Isolation:
a.
HPCI Steam Line Delta Pressure (Flow) - High
{
b.
HPCI Steam Line Delta Pressure (Flow) - High, Timer c.
RCIC Steam Supply Pmssure - Ina d.
HPCI Turbine Exhaust Diaphragm Pressure - High e.
lHCI Punp Roam Tenperature - High f.
HPCI Pump Room Ventilation Ducts Delta Temperatum - High g.
HPCI Pipe Routing Area Tenperature - High h.
HPCI 'Ibrus Compartment TLwtum - High 1.
Drywell Pressure - High j
7.
RHR System Shutdown Cboling itxie Isolation:
a.
Reactor Vessel Water IcVel - Im, Level 3 b.
Reactor Vessel (RHR Cut-in Permissive) Pressure - High c.
Manual Initiation E.
Bases Section 3/4.3.2 is revised to reference the General Electric (GE) Licensing Topical Reports (LTRs) which justify the above proposed changes to the isolation actuation instrumentation.
Page 2 of 6
LCR 93-03 STI/AOT Extensions for Isolation Instrumentation NLR-N93015 We proposed TS changes described above are consistent with the changes proposed and approved in the referenced GE documents and associated NRC safety evaluation reports (References 1 - 4) with the exception that the subsequent enhancenents included in Refemnoe 5 have been adoptai, the loss of function issue has been addressed, and a footnote has been added to identify which trip functions have instrumentation common to RFS.
II.
RFXIN IUR 711E PROPOSED OWCES
'Ihe technical==wnt of the proposcd changes contained in the GE LTRs indicates a positive benefit and net improvement in overall plant safety and operation. 'Ihis conclusion was based upon consideration of I
the impact of the changes on the isolation failure frequency as well as i
impact of the follcwing factors:
A.
Potential for inadvertent scrams B.
Excessive test actuation cycles (equipment wearcut)
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 Reference 2 and their impact on plant safety is discussed in detail in Section 4.2 of Reference 6.
III. JUSTTFICATION FOR THE HOTOGID OWEES h e generic GE analyses contained in References 1 and 2 evaluated the effect of the proposed changes to the STIs arx1 ACTS for the isolation actuation instrunentation ard demonstrated that the isolation failure frequency (IFF) is not significantly affected by the proposed changes.
The calculated change in IFF for the proposed changes meets the established acceptance criterion for ensuring negligible change to the l
IFF. Furtherrore, when the factors described in Section II of this submittal are considered, in addition to the IFF, the overall effect on l
plant safety is judged to be an improvement.
Rr nrunces 1 and 4 concluded that the associated GE reports provide an aweptable basis for exterding STIs and Aars for isolation actuation instrumentation; hcuever, these NRC safety evaluation reports (SERs) also required that two issues be addressed to justify the applicability of the generic analysis to individual plants when specific facility Technical Specifications are considered for revision. Wese issues were:
1) confirmation of the applicability of the generic analyses to the specific plant and 2) confirmtion thet any increase in instrument drift due to the extended STIs is properly accounted for in the setpoint calculation methcdology. The following discussion provides information to address these issues.
Page 3 of 6
')
i
l LCR 93-03 STI/AOT Extensions for Isolation Instrumentation NLR-N93015 9
A.
ConfirTnation of the Applicability of the Generic Analyses our confirmation of the applicability of the generic analyses to Hope Creek is based upon the followi m:
1.
AppeMix A of Reference 1 and AppeMix E of Reference 2 identify Public Service Electric aM Gas Company / Hope Creek as a-participati g utility / plant in the Isolation Actuation Technical Specification Improvement Analysis. PSE&G has maintained its participation and involvement on the BWR Owners Group Technical Specification Improvement Ccamittees thereby assuring that the development of these generic reports enccrapass the Hope Creek Generating Station.
2.
PSE&G has reviewed the applicable GE LTRs and has verified their applicability to the Hope Creek Generating Station.
B.
Confirmation that Instrument Drift is Properly Cbnsidered
'Ihe NRC staff has provided guidance on addressing the issue of instrument drift in Reference 7.
'Ihis guidance indicated that:
... licensees need only confirm that the setpoint drift which could be expected under the extended STIs has been studied and either (1) has been shown to remain within the existing allowance in the RPS and ESFAS instrument setpoint calculation or (2) that the allowance and setpoint have been adjusted to account for the additional expected drift."
In order to satisfy this requirement, PSE&G applied a two fold approach to the issue of instrument drift. 'Ihis two fold approach involved the following:
1.
'Ihe setpoint calculations for all instrumentation affected by the changes proposed in this amendment application were reviewed.
Results of this review indicate tint, in all cases, the loop (setpoint) drift calculation was based on an eighteen month interval; therefore, the proposed STI extensions frcm monthly to quarterly are well bounded by the existing setpoint calculations.
2.
The surveillance tests for the NUMAC instrumentation (used for Trip Functions 3.f, 4.a - d, 5.e - h, am 6.e - h) and the radiation monitoring system examine digital conponents-in the instrument loop.
Since these m aponents are digital, there is no associated inherent drift. 'Ibe drift for the component will therefore always be zero, t
independent of the interval at which it is tested.
For the remaining analog instrumentation, data for each trip unit consisted of the "as found" and "as left" trip setpoint settings -
over a twelve month period. 'Ihe actual observed drift over the twelve nonth period, in all cases, was found to be conservatively t
bcunded by the total loop allowance for a six nonth period. 'Ihe results of this evaluation are docunented in References 8 and 9 and are available for NRC staff revies.
Page 4 of 6 i
I I
. Attachment 1 LCR 93-03 1
STI/AOT Extensions for Isolation Instrumentation NLR-N93015 IV.
SIGNIFICANT HAZATUE (IJNS11TRATION EVAIIIATION PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed amendment to.
determine whether the request involves a significant hazards consideration.. We have determined that operation of the Hope Creek Generating Station in accordance with the proposed changes:
1.
Will not involve a significant increase in the ptranhility or ocmaoquences of an acriamt previcusly evaluated.
]
'Ihe proposed changes to the isolation actuation instrumentation were j
judgcd to potentially affect plant safety through their impact on the isolation failure frequency (IFF). 'Ibe generic analyses contained in Licensing 'Ibpical Report (IlrR) NEDC-30851P-A, Supplement 2 and LTR NEDC-31677P-A aswM the impact of charging-the isolation actuation instrumentation surveillance _ test intervals i
(STIs) and allowed out-of-service times (AUIs) on the IFF. 'Ihe analyses cx>ntained in these LTRs d6TeroLrate that the proposed changes have a negligible effect on the IFF, and when all contributing factors are considered, the net impact of the proposed changes is to improve plant safety. 'Ibese generic analyses.have.
been verified to be applicable to the HCES as indicated in Section III above. Since the proposed charges do not significantly affect the IFF and have a beneficial impact on plant safety when all factors are considered, the proposed changes will not significantly increase the probability or consequences of a previously analyzed accident.
2.
Will not create the possibility of a new or different kind of I
accident from any accident previously evaluated.
Increasing the ACTS and STIs for the icolation actuation instrumentation does not alter the fu. tion of the equipmnt performing the isolation functions nor involve any type or plant.
modification. Additionally, no new modes of plant operation are.
involved with these changes. 'Ihe prerwma changes therefore will not create the possibility of a new or different kind of accident from any accident previously evaluated.
'i 3.
Will not involve a significant rtxluction.in a margin of safety. -
]
i The proposed changes to the isolation actuation instrumentation were judged to potentially affect plant safety thttugh.their-impact on the IFF. As requested by the BhiR Owners' Group, GE performed analyses to evaluate the effect of the proposed changes on the IFF.
The NRC staff has reviewed ard approved the generic study contained.
l in LTRs NEDC-30851P-A, Supplement 2 and NEDC-31677P-A and hasi concurred with the BhR owners Group that the proposed changes do not-significantly affect the IFF. Furthermore, the overall level of j
plant safety will be improved by the s uposed changes..It can j
therefore be concluded that the proposed changes will not significantly reduce a margin of safety.
q Page 5 of 6 T
LCR 93-03 STI/AOT Extensions for Isolation Instrumentation NLR-N93015 V.
CI2KIUSION l
As di<:rwd above, PSE&G has concluded that the proposed changes to the
'Ibchnical 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 i
evaluated, (ii) do not create the possibility of a new or different kind l
d of accident from any accident previously evaluated, and (iii) do not involve a significant reduction in a nargin of safety.
VI.
m 2 u cWCPS 1.
NEDC-30851P-A, Supplement 2, " Technical Specification Improvement l
Analysis for BE Isolation Actuation Instrumentation Ctrunon to RPS I
and EOG Instrunentation", dated March 1989 2.
NEDC-31677P-A, " Technical Specification Improvement Analysis for ER Isolation Actuation Instrumentation", dated July 1990 3.
letter to D. N. Grace from C. E. Rossi dated January 6, 1989 (transmits NRC safety evaluation report for NEDC-30851P-A, Supplement 2) 4.
letter to S. D. Floyd frun C. E. Rossi dated June 18, 1990 (transmits NRC safety evaluation report for hTDC-31677P-A) 5.
GE Document No. OG90-579-32A, letter frun W. P. Sullivan (GE) to USNRC, " Implementation Enhancements to Technical Specification Changes Given in Isolation Actuation Instrumentation Analysis",
dated June 25, 1990 6.
NEDC-30936P-A, "BR CXmers' Group 'Ibchnical Specification Improvement Methodology (W.ith Dunbixation for BWR ECCS Actuation Instrumentation) Part 2", dated Dn<mhpr 1988 7.
Letter frun C. E. Rossi (NRR) to R. F. Janecek (BWROG), " Staff Guidance for Licensee Detennination that the Drift Characteristics for Instrunentation Used in RPS Channels are Bounded by NEDC-30851P Assunptions When the Functional Test Interval is Extended frun Monthly to Quarterly", dated April 27, 1988 8.
PSE&G Internal Memorandum ELE-92-0667 frun Robert Sardy, Hope Creek I&C, to C. Manges, Nuclear Licensing, dated December 9, 1992 9.
PSE&G Internal Menorandum ELE-93-0489 frun Robert Sardy, Hope Creek I&C, to L. Castagna, Nuclear Licensing, datwl October 5, 1993 Page 6 of 6 1
i I
__.-_____-___-______a
LCR 93-03 Marked Up TS Pages NLR-N93015 4
DGEFU' A b.
With the number of OPERABIE channels less than required by the minimm OPERABLE channels per trip system requirement for one trip system, either 1) place the inoperable channel (s) in the tripped condition within a)
I hour for trip functions without an OPERABIE channel, b) 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for trip functions common to RPS instrumentation, ard 1
c) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for trip functions not common to RPS
)
instrumentation, or 2) take the ACTION required by Table 3.3.2-1.
+
'Ihe provisions of Specification 3.0.4 are not applicable.
c.
With the number of OPERABIE channels less than required by the minimum OPERABIE channels per trip system requirement for both trip systems, 1) place the inoperable channel (s) in one trip system in the j
tripped condition within one hour ard
[
t 2) a)
place the inoperable channel (s) in the remaining trip system in the tripped cordition within 1)
I hour for trip functions without an OPERABIE
- channel, 2) 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for trip functions common tc RPS instrumentation, and
?
3) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for trip functions not common to RPS instrumentation, i
or b) take the ACTION required by Table 3.3.2-1.
'Ihe provisions of Specification 3.0.4 are not applicable.
I P
Insert Page 1 of 2
LCR 93-03 Marked Up TS Pages NLR-N93015 IIEERT B Specified surveillance intervals and surveillance ard maintenance outage times have men determined in accordance with NEDC-30851P-A, Supplement 2,
" Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation Cbmmon to RPS and EOCS Instrumentation", and NEDC-31677P-A, "Tbchnical Specification Improvenent Analysis for BRR Isolation Actuation Instrunentation". The safety evaluation reports documentirg NFC approval of NEDC-30851P-A, Supplement 2 and NFDC-31677P-A are contained in letters to D. N. Grace from C. E. Rossi dated January 6,1989 and to S. D. Floyd frun C. E. Rossi dated June 18, 1990.
1 i
Insert Page 2 of 2
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