ML20059F792

Application for Amend to License NPF-57 Requesting Rev to TS 3.3.7.5-1, Accident Monitoring Instrumentation & Section 3/4.6.2.1, Suppression Chamber

ML20059F792
Person / Time
Site:	Hope Creek
Issue date:	10/26/1993
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059F794	List: ML20059F792 ML20059F821
References
LCR-93-04, LCR-93-4, NLR-N93100, NUDOCS 9311050082
Download: ML20059F792 (9)

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Compa'iy Joseph J. Hagan Pubhc Semce Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 v.w hwnant. Ack,a, owni.ons DCT 261993 NLR-N93100 1

Reference:

LCR 93-04 U.S.

Nuclear Regulatory Commission j

Attention:

Document Control Desk Washington, DC 20555 Gentlemen:

i REQUEST FOR AMENDMENT HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 l

i Public Service Electric and Gas Company (PSE&G) hereby transmits an application to amend Appendix A of Facility Operating License' NPF 57 for the Hope Creek Generating Station (HCGS) in accordance

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with 10CFR50.90.

This amendment request would revise HCGS Technical Specifications i

Table 3.3.7.5-1, Accident Monitoring Instrumentation, and Section 3/4.6.2.1, Suppression Chamber.

A description of the requested amendment, supporting information and analyses for the change, and the basis for a no significant hazards consideration determination-l are provided in Attachment 1.

The Technical Specification pages affected by the proposed change are marked-up in Attachment 2.

Pursuant to the requ'irements of 10CFR50.91(b) (1), PSE&G has provided a copy of this amendment request to the State of New

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Jersey.

i Upon NRC approval of this proposed change, PSE&G requests that the l

amendment be made effective on the date of issuance, but'

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implementable within 60 days to provide sufficient time'for the l

performance of associated administrative activities.

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l PDR ADOCK 05000354 ll P

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I OCT 261993

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Document Control Desk '

NLR-N93100 l

Should you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely,

__7 Attachments Affidavit i

C Mr.

T.

T.

Martin, Administrator USNRC Region I Mr.

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Dembek USNRC Licensing Project Manager Mr.

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Marschall i

USNRC Senior Resident Inspector

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Mr.

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Tosch, Manager IV Bureau of Nuclear Engineering New Jersey Department of Environmental Protection d

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t REF: NLR-N93100 l

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r STATE OF NEW JERSEY

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SS.

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COUNTY OF SALEM

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Joseph J. Hagan, being duly sworn according to law deposes and says:

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I am Vice President - Nuclear Operations of Public Service

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Electric and Gas Company, and as such, I find the matters set forth in our letter, referenced above, concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.

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Subscrjbed and Sw tp before me l

t is _M/rAA day of ffdh / a 0 1993 i

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I Notary Publicgof Ne'TT Jersey KlMBERLY JD BROWN My Commiasion expires on ff0TARY PUBilC OF NEW JERSFY "1 LNassion Expires Aptd 21,1993 i

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Ref: I.CR 93-04 y

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PRDREED TEUNIGL SPDCIFICATIONS OPNGlE t

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PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS FACILITY OPERATING LICENSE NPF-57

, HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Ref: LCR 93-04 r

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utduumON OF 'DE OWE As shcun on the marked-up Technical Specifications (TS) pages in Ath+=>nt 2, PSE&G requests that:

+ TABLE 3.3.7.5-1, Accident Monitorirx3 Instrumentation, be revised to reduce the MINDLM QWNELS OPERABLE requirumnt for Suppression Pool Water Tenperature Instruments frun two (2) to one (1),

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+ 2e Footnote section be revised such that Footnote (a) arxi (c) are deleted, and Footnote (b) shxild be renamed as footnote (##) as well as its superscript at Instrunent #14. S e Footnotes also should be sequentially restructured to ratch Table 3.3.7.5-1.

• Accident Monitoring ACTION STATD4DTIS be modified to provide more reasonable arri consistent AOT's - which will also agree with the correspondiag ACTIONS for Post Accident Monitoring Instrumentation in the Improved GE BWR/4 STS.

+ ACTIGJs and Surveillance Requirements contained in TS 3/4.6.2.1, for suppression chamber tenperaturn and level instruments, be removed (also in agreement with the Improved GE BG/4 STS).

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REASOf FOR 'IYE OWG mis change corrects a typographical error, removes an outdated note, ard makes the subject TS table and a related TS section agree with the current industry ard NRC agreed-upon standards for BG4 plant TS - as provided in the Improved GE BWR/4 STS, Rev. O.

A lack of uniformity in the HCCS TS - between sone of the specifications khich are the subject of this request - has existed for some time and has, prior to this request, ly.en resolved by use of a clarifying TS interpretation. Se l

inccrporation of the Improved BWR/4 STS sections coues Ealing to the H03S TS i

of concern adds the r-mry consistency and clarity to eliminate the need for i

any interpretation, yet remains bounded by the HOGS Regulatory Guide 1.97 Safety Evaluation Report.

l III. JWTIFICATICH FOR 'ITE OWG 2e Suppression Chamber Water Temperaturn Instrumentation consists of two channels of eight temperature detectors each (plus installed spares) which are averaged electronically to provide two average bulk water temperatures. Rese can be read at several locations inside, ard outside, the control room. In the event that one channel's averaging circuit W inoperable, the outputs of each of the irdividual tenperature detectors can be read, nnnually averaged, and then conpared to the remaining OPERABIE channel in the Control Room and/or to Renote Shutdown Panel irxiication of Suppression Chamber Water Tenperature.

III. JUSTIFICATIOT FOR 'IHE OIAICE, cont'd Hope Creek UFSAR Section 1.8.1.97.2 describes the suppression chamber (pool) temperature indications as Type A, Category 1.

Regulatory Guide 1.97 provides for plant specific determination of Type A variables which are those intruments

...to be monitored that provide the primry information required to permit the control rtxn operators to take the specified manually controlled actions for which no automatic control is pIwided ard that are required for safety systems to ammnlish their safety furtion for design basis events".

The Type A variables are required to be Category 1.

Other Type A indications listed in the HOGS UFSAR are:

r Containment Hydrogen & Oxygen Monitoring RP/ Pressure RP/ level Suppression Pool Water IcVel Drywell Prm;ure All of these Type A parareters are listed in HQE TS TABIE 3.3.7.5-1 with a mininn operable chanmls requirerent of one (1). There is no explanation for j

the two (2) minirtn channels operable requirenent for suppression pool water

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temperature other than typcgraphical error. There is sufficient redundancy and r

flexibility in the suppression pool temperature instrumentation design, as described previously, to demonstrate an acceptable level of reliability for that instrunentation.

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i Extending the allowable out of service time (AUT) for the suppression chamber water temperature instments as well as the AC7Ts for all of the other UFSAR Type A, Category 1 variables in the same TS TABIE to agree with the GE NR/4 SIS is justified since all of these instruments have sufficient redundancy and each of the reasured parameters are of comparable importaroe for monitoring the

...primry information required to permit the control rocca operators to take

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the specified nanually mntrolled actions for which no automtic control is provided and that are required for safety systems to accomplish their safety function for design basis events". Further, modifying the Accident Monitoring ACTIG1 STATDENIS in the HOGS TS to agree with the corresponding ACTIONS for Post Accident Monitoring Instrumentation in the Improved GE NR/4 STS, Rev 0 is consistent with current irdustry and NRC agreement that, "...due to the passive nature of these instrunents and the operators' ability to respond to an accident utilizirg alternate instruments ard rethods for monitoring, it is not appropriate to irpose stringent out of service tines".

i 1he Table 3.3.7.5-1 footnote charges are consistent with the intent and I

continuity of the other requested rrdifications.

1 Reroval of the ACTIONS and surveillancoes in TS 3/4.6.2.1 pertainirg to the temperature and level instruments is justified since instrunents that provide alarra ard mordterirg functions only - except those khich, to satisfy. Reg. Guide j

1.97 requirements, are already in TS Table 3.3.7.5-1 (such as these) are not included in the L" proved GE BWR/4 STS, Rev. O.

They represent part of routine operational monitorirq ard are applicable to plant specific controls ard do not reprurnt instruments which support operability.

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10CIP50.92 SIGTIFICANT HN2ARDR GESIIERATICH ANALYSIS PSE&G has, pursuant to 10CFR50.92, reviewed the proposed areninent to determine whether our request involves a significant hazards consideration. We have deternined that:

1. The meration of the IIcoe Crtek Generatirri Station UKI;S) in amordance with the umud chame will not involve a sittnificant increase in the Urttability j

or wuxiuences of an accident previously evaluated.

i The proposed arendment does not involve a physical or procedural charge for any structure, maporeut, or system that affects the probability or consequences of any accident or malfunction of equignent important to safety previously evaluated in the Updated Final Safety Analysis Report (UFSAR). The proposed change will, in agreement with the Imprtwed GE HG/4 Standard TS, require a minimum of one (1) channel operable for the suppression pool water temperature instrumentation in TS Table 3.3.7.5-1 and remove duplicative and unt m e.ary ACTIGis and Surveillances from TS 3.6.2.1.

Additionally, in the event that the minimum channel requirenent is not ret (for accident monitoring instruments which correspond to accident ronitorirg instruments in the GE BG/4 STS) the charges would require that at least the minimum number of required channels be restored to OPERABLE conditions in a reasonable time, as defined by the l

irproved STS. These charges would eliminate the present disparity between the subject TS sections and make the ACI'IQis for other accident monitoring instruments agree with the Irproved ILW4 STS - thereby ensuring clarity and consistency between the specifications. Since these proposed revisions will neither significantly rodify, nor degrade, accident monitoring capabilities, they will not affect the consequences or probability of occurence of any accident or malfunction of equipnent important to safety.

2. 'Ihe operation of the Hope Creek Generatim Statim 01 CGS) in accordance with the p1uuu] charne will not create the Ixx;sibility of a now or different kird I

of accident frun any previously evaluated.

l There are no physical charges to the plant or to the ranner in which the plant is operated involved in the proposed revision. Therefore, no new or different i

kird of accident is created by the proposed change.

3. The operation of the Hope Creek Generatirn Statim GIOGS) in accorthnoe with the umuul chame does not involve a sicznificant reduction in a martrin of safety.

The proposed revision will, by rakirg the affected TS agree with the Improved IEW4 SIS, add clarity ard consistency to the specifications and will have no signficant impact upon nargins of safety.

Conclusicn; j

Bascd upon the foregoirg evaluation, we have determined that this proposed change does not involve a Significant Hazanis Consideration.

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.I; Ref: ICR 93-04 i

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ATD42 MENT 2 INSERIS NfD MARKED 4JP PAGFS l

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4 DEERIS FOR PFDFOSID QDNGES L

DEERT 1 DEIRT 2 INSERT 3 1

80 DGERT 4 Average bulk pool temperature Acoustic nonitoring and tailpipe taperature f

High range noble gas ronitors

1. 1. one channel consists of the open limit switch, aM the other channel consists of the closed limit switch DEERP 5 ACTION 80 -

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With the number of OPERABE channels less than the Required Number of Qiannels shown in Table 3.3.7.5-1, restore the inoperable channel to OPERABE status within 30 days, or imediately initiate l

actions in accordance with Specification 6.9.2.a.

b.

With the nunber of OPERABE channels less than the Minimum Number of Qiannels shown in 'Ibble 3.3.7.5-1, (except for the Primary Containment Hydrogen / Oxygen Cbncentration Analyzer aM Monitor aM the Drywell Atnosphere Post Accident Radiation Monitor) restore at least one inoperable channel to OPERABE status within 7 days, or be in at least IDT SIUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> aM in CDID SIBIIXJWN in the followirg 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c.

With the number of OPERABE Primary Contairment Hy&ufuVOxygen Concentration Analyzer aM Monitor channels less than the Minimum l

Nunber of Channels requirenent shown in Table 3.3.7.5-1, restore at least one inoperable channel to OPERAB E status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or be in at least IUT SIUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in 00ID SHUIDOWN in the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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With the number of OPERABE Drywell Atrosphere Post Accident Radiation Monitor channels less than the Minimun NtInber of Channels requiremnt shown in Table 3.3.7.5-1, initiate action in accordance with ACTION 81, below.

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