ML20059N072
| ML20059N072 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/28/1990 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N90192, NUDOCS 9010100031 | |
| Download: ML20059N072 (5) | |
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1 Public Service Doctric and Gas --
Company =
l Stanley LaBruna Public Service Electric and GaiCompahy P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800 i
Vc, Prestent - Nuclear Operahons September 28, 1990 NLR-N90192 l
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-t United States ' Nuclear Regulatory Ccmmission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR REGIONAL WAIVER OF COMPLIANCE TECHNICAL SPECIFICATIONS 3.7.1.1 FACILITY OPERATING LICENSE NPF HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company-(PSE&G) hereby requests Regional Waiver of Compliance from the provisions of Technical.
Specification, (TS) 3.7.l.1.a.
As discussed in Attachment 1 to-this letter, PSE&G's conclusion is that granting this request would involve neither_a significant hazards consideration nor any irreversible environmental consequences.
i This relief'is requented to allow sufficient time to complete the replacement of the
'A' Safety Auxiliaries Cooling. Pump (SACS) and to demonstrate its operability without requiring unit shutdown.
The SACS pump casing, which was discovered to have a hair-line-l.-
crack, has been replaced and pump reassembly ils near completion.
l However, final pump / motor alignment and a baseline pump performance test to demonstrate operability remain to be done which may, should any unexpected delay occur, extend beyond the i
72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> repair time permitted by:the TS ACTION statement.
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requested _ duration of this waiver is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, beginning at 0911 hours0.0105 days <br />0.253 hours <br />0.00151 weeks <br />3.466355e-4 months <br /> on September 29, 1990 until 0911Lhours of'the next day to-provide sufficient time margin for the uncertainties-of pump /
motor' alignment.
Absent a Regional Waiver of Compliance, TS 3.7.1.1 would require the station to enter a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shutdown ACTION at 0911 hours0.0105 days <br />0.253 hours <br />0.00151 weeks <br />3.466355e-4 months <br /> on September 29, 1990.
PSE&G therefore requests expeditious review.
of this submittal.
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9010100031 900928 PDR ADOCK 05000354
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i Document. Control Desk 9/28/90 NLR-N90192 This request:has been reviewed and recommended for approval by-
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the Hope Creek Generating Station Station Operations Review Committee.
Sincerely, p[,
Attachment-s C
Mr.-S.
Dembek USNRC Licensing Project Manager
'l Mr.-T.
P. Johnson USNRC Senior Resident Inspector Mr. W. T. Russell, Administrator USNRC Region I Mr. Kent Tosch, Chief j
New Jersey Department of Environmental Protection Bureau of Nuclear Engineering-l l
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NLR-N90192
-ATTACHMENT 1 TBCHNICAL SPECIFICATION 3.7.1.1 Hope Cr&ck Technical Specification 3.7.l 1 requires that two separate and independent
- Safety Auxiliaries Cooling System (CACS) subsystems be Operable,in' Operational Conditions 1, 2 and 3.-
The associated ACTION-statement. requires that withLone SACS pump inoperable, the pump must be returned to OPERABLE within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
i or the plant must,be1 be in at least HOT SHUTDOWN 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 COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
SUMMARY
OF CURRENT'8ITUATION At 0911 hours0.0105 days <br />0.253 hours <br />0.00151 weeks <br />3.466355e-4 months <br /> on September 26,'1990, PSE&G personnel declared the
'A' SACS. pump inoperable due to a through-wall crack in the lower pump casing.
Since the structural; integrity of an ASME Class 3 component was involved, in accordance with a previous agreementi with Region'I, a one hour report was'made.
Initial repair efforts were-focused upon an ASME Code welded repair of the crack.- During the grinding-out of the flaw area, a casting defect (void) was found.
Due to the extent of this flaw, l
PSE&G determined.that pump casing replacement was prudent.
At the time'of preparation of this request, the newl pump casing has, been installed'and reassembly is-in progress..However, due to the amount of rigging necessary to accomplish the casing change-l out and the time loss introduced by'the initial weld repair-effort, there may not be sufficient. time to complete reassembly =
and OPERABILITY' testing within the TS-permitted 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
This situation could not be reasonably avoided.
The flaw was detected by Hope Creek Generating Station: (HCGS) personnel by virtue of a plant-worker's inquisitiveness; wherein, noticing a small wet spot on the 'A
SACS pump while working near.it, the worker notified' supervision, who investigated the problem and determined the nature of the flaw.
PSE&G had no reason to believe that a code weld repair.would-not.be possible.
It was 1
I only after pump disassembly and internal grinding that the
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casting flaw was identified.
The. extent of-the flaw then caused j
a change in direction on the repair which,,in turn, placed the successful. replacement and testing completion time in jeopardy.-
REQUEST FOR. REGIONAL WAIVER-OF-COMPLIANCE PSE&G hereby requests a waiver of compliance for the requirements of Hope Creek Generating Station Technical Specification 13.7.1.1.
Specifically, it is requested that the allowable time period'to restore the
'A' SACS pump to OPERABLE status be extended an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on a one-time-only basis.
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COMPENSATORY MEASURES The remainingLSACS' pumps are in operation; however, no additional measures have been.taken.
j JUSTIFICATION FOR THE PROPOSED WAIVER'OF COMPLIANCE l
{ustification for Proposed Time Duration of the Reauest:
The' time necessary for completion of the SACS pump replacement and testing is greater than=the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />' permitted by Technical.
Specifications.
An additional ~24 hours will provide sufficientt time to complete the alignment and testing.
Based.upon a review of our Hope Creek Generating Station-specific Probabilistic! Risk j
Assessment'(PRA), the impact.of the requested 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension upon core melt frequency has been found to be insignificant 1y
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small.
As. described in the following sections, there is no significant hazard to the public nor-are there any irreversible environmental consequences introduced by granting the requested time extension for completion of the pump replacement and testing.
Absent the requested relief, a plant shutdown will be required.
Determination of No Bianificant Hazards Consideration i
l This proposed Waiver of Compliance:
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Does not involve a significant increase.in'the probability or consequences of any accident previously-evaluated.-
The remaining SACS equipment-is OPERABLE and.in service.
l Equipment history on the SACS pumps,.as well as-the SACS heat l
exchangers and piping, shows that the-SACS subsystems have been very dependable.
Ar additional 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> outage time on the A'
i SACS pump has been factored into our Hope Creek-specific.PRA r
model, resulting in no significant increase in the-probability-or
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or of any core damage accidents.
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Does not create.the possibility of a new or different kind of accident from any accident previously evaluated.
Sufficient SACS heat removal capability is currently available for normal plant operation.
An additional 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay in completing the repair of a SACS pump will not create any new or different kind of accident.
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Does not involve a significant. reduction.in a margin of-safety.
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Based upon our PRA review of this request,1 permitting.an additioncl 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in which,tx) complete the replacement and i
testing:of the SACS pump will cause no significant: reduction in J
the margins of safety as discussed ~in~the bases for the' Technical' Specifications.
Additionally, HCGS accident analyses assume a Delaware River temperature of 85 degrees and a: SACS temperature:
of 95 degrees.
Current temperatures are 68'degre~es river. water J
temperature and 70 degrees SACSjtemperature-thus providing additional margins.
Determination that the Reauest does not Involve =1rreversible Environmental Consecuences The requested waiver does not allow for any. increase in effluents that may be released offsite, d'oes not involve an increase in radiation exposure to personnel, and does not involve a Significant Hazards Consideration.
.Therefore, the request does' not involve'any irreversible environmental consequences.
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