ML20059A893

Forwards IST Requirements Relief Request in Support of Commitment to Modify Level Instrumentation to Ensure Level Indication Remains Accurate During Depressurization Events, Per NRC Bulletin 93-003

ML20059A893
Person / Time
Site:	Hope Creek
Issue date:	12/20/1993
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-93-003, IEB-93-3, NLR-N93186, NUDOCS 9401030192
Download: ML20059A893 (5)

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' Ekoc and Gas Drrpmy Joseph J. Hagan Public Service Dectne and Gas Company . P.O. Box 236 Hancecks Bridge, NJ 08038 609 339-1200 1 va emow u.ww sm DEC 201993 NLR-N93186 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

IN-SERVICE TESTING REQUIREMENTS RELIEF REQUEST.

HOPE CREEK GENERATING STATION DOCKET NO. 50-354 In response to Bulletin 93-03, " Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs, "Public Service Electric and Gas (PSE&G) committed to modify the Hope Creek level instrumentation to ensure level indication remains accurate during depressurization events. As stated in our response dated July 30, 1993, PSE&G will complete this modification prior to startup from the next entry into cold shutdown after July 30, 1993.

At the writing of this letter, Hope Creek has entered into cold shutdown and this modification has been installed.

This modification includes the installation of eight check valves. These eight check valves will be incorporated into the Hope Creek In-Service Testing (IST) Program. Initial testing-was completed as part of the installation prior to plant startup.

Under present requirements, these valves should be tested on a192 day frequency or identified as requiring testing at cold shutdown only. This testing frequency would unnecessarily challenge plant safety systems.or require that the safety system initiation logic be disabled during valve tests.- . Consequently, PSE&G is proposing alternate testing and requesting your review and approval of the attached relief request. This relief request is similar_to'a relief request previously approved in the NRC Safety Evaluation Report issued for the Hope Creek IST program by letter dated  ;

September 27, 1990 (Section 4.1.4.1 of the SER).

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( i l 9401030192 931220 $$ l PDR ADOCK 05000354 $1  ;

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DEC 201993 Document Control Desk 2 NLR-N93186 This relief request is being submitted pursuant to the provisions' of 10 CFR 50.55a (g) (5) (iii) , -nd in accordance with Technical Specification 4.0.5.a for the Hope Creek Generating Station.

This relief request represents a revision toLour In-Service Testing (IST)~ Program as currently approved in your letter dated September 27, 1990.

Should you have any questions, we will be pleased to discu/s'them with you.

Sincerely, Affidavit Attachment (1)

C Mr. J. Stone (Acting Hope Creek Project Manager)

Mr. C. Marschall USNRC Senior Resident Inspector Mr. T. Martin,. Administrator USNRC Region I Mr. K. Tosch, Manager IV NJ Department of Environmental Protection & Energy Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 4

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l REF: NLR-N93186 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. i Subscribed and Sworn to before me this 80 UA day of DAcum h/A ., 1993 f O

Mi vi fd)ki A GllAAk Nbtart t*ubb.chof New Jersey KIMBERLY J0 BROWN NOTARY PUBilC OF NEW JERSEY -

My Commission expires on m re,m,;. ;.m r.n;- ana n 1998 I

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ATTACHMENT ONE IN-SERVICE TESTING REQUIREMENTS RELIEF. REQUEST 1 HOPE CREEK GENERATING STATION  ;

DOCKET NO. 50-354 i

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NLR-N93186

.. ' COMPONENTS:

1BBV232 1BBV246 1BBV233 1BBV247 1BBV239 1BBV253 1BBV240 1BBV254 The modification to address Bulletin 93-03 will install small diameter piping frem the control rod drive (CRD) system to each of the four Reactor Water Level Instrumentation reference legs. ,

The flow injected from the CRD system will serve to purge noncondensible gases from the reference legs during normal. ,

operation to prevent loss of inventory in the reference leg during rapid depressurization events. Two check valves will be installed in series in each of the four lines from the CRD system ,

to the Reactor Water Level Instrumentation reference legs.-

FUNCTION:

The check valves function to close upon loss of control rod drive' (CRD) backfill flow to prevent loss of Reactor Water Level indication.

TEST REOUIREMENT:

Subarticle INV-3521 requires check valves to be exercised once every 3 months, except as provided by IWV-3522.

BASIS FOR RELIEF:

These check valves cannot be exercised during power operations.

These valves are in instrument sensing lines that initiate logic circuits or process control parameters that are required during power operation and cold shutdown conditions. Testing of these ,

valves at the 3 month frequency would either disable safety system initiation logic or unnecessarily challenge safety r systems. Testing of these valves at cold shutdown conditions I would similarly either disable shutdown safety system initiation ,

logic or. unnecessarily challenge safety systems used-for decay heat removal.

These check valves are not 10CFR50, Appendix J, Type C tested, i nor do they have individual seat leakage acceptance criteria.

The pressure boundary is tested as part of the 10CFR50 Appendix J, Type A test (i.e. Category C check valves).  ;

Relief is therefore requested from these Code requirements. l 1

ALTERNATE TESTING:

These valves shall be exercised to the closed position at a frequency of every 18 months.

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