ML20059P003

Grants 900928 Request for Regional Waiver of Compliance Re Safety Auxiliaries Cooling Sys

ML20059P003
Person / Time
Site:	Hope Creek
Issue date:	10/05/1990
From:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Miltenberger S Public Service Enterprise Group
References
NUDOCS 9010240335
Download: ML20059P003 (3)

Text

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OCT 0 51990

Docket No. 50-3541 t

Public Service Electric & Gas Company

' ATTN: Mr. Steven E. Miltenberger V'ce President and Chief Nuclear Officer Post Office Box 236

-Hancocks Bridge, New Jersey 08038 Gentlemen:

Subject:

Regional Waiver of Compliance Related to the Safety Auxiliaries Cooling System, Hope Creek This responds to your September 28, 1990 letter requesting a Regional Waiver

'of Compliance in arder to allow continued oparation of the Hope. Creek Nuclear Generating Station. A copy of your request-with attachments is enclosed for reference.

Af ter' careful consideration of your request, the NRC has concluded that the proposed 24-hour extension of Technical Specification 3.7.11.a to allow com-pletion of the replacement of the 'A' Safety Auxiliaries Cooling Pump'(SACS) is i

-warranted based on the continued operability of the remaining three of four SACS pumps,-the-enhanced measures to deal with the. loss of another SACS pump, and the low probability of such a pump failure within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. extension.

i This relief granted will not put the plant into an unsafe condition.

A Regional Waiver'of Compliance is hereby granted from the requirements of Hope-Creek Technical Specification 3.7.1.1.a.1 for an additional 24-hours, on a one-time-only basis, with the following provisions:

1.

A roving fire watch will be implemented during this extension to l

compensate for the potential loss of the "B" SACS loop by fire.

2.

Operator awareness and. response to the system realignments of the-Emergency Diesel Generator and Filtration, Recirculation and Ventilation System cooling necessitated by loss of the "C"

SACS pump shall be enhanced through written guidance and pre-shift briefings prior to 1

implementation of this extension.

3.

This Waiver will expire and a shutdown must be initiated at any time

.during the 24-hour extension upon determining that any redundant ECCS equipment is inoperable.

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. 4, This Waiver is effective at 9:11 a.m. on September 29, 1990,- and' expires at 9:11 a.m. on September 30, 1990.

This Regional. Waiver and the provisions detailed' above were-discussed by.

-Mr. P. Swetland of this office and Mr. R. Hovey on September 28, 1990.

As-also discussed with Mr. Hovey, the staff found that your original request of September 28, 1990 did not contain sufficient technical detail or analysis for i

the staff to reach a decision on your request.

Therefore, the staff review necessarily included: 1) an unusual amount of verbal discussion with your staff to obtain additional detail, 2) the definition of compensatory measures not outlined in your letter, and 3) a request for a supplemental letter from you. We recommend you review this matter for lessons learned, f

Sincerely, ORIGINAL SIGNED BY:

d Charles W. Hehl, Director Division of Reactor Projects

Enclosure:

As Stated cc w/ enc 1:

S. LaBruna, Vice President-Nuclear S. Ungerer, Manager, Joint Generation Projects Department, Atlantic Electric t

Company

.J. Hagen, General Manager - Hope Creek Operations.

B. Preston, General Manager - Licensing and Regulation i

J. Robb, Director, Joint Dwner Affairs A. Tapert, Program Administrator R. Fryling, Jr., Esquire M. Wetterhahn, Esquire J. Lipot, State of New Jersey Lower A110 ways Creek Township Public Document Room (PDR)

Local'Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Jersey bec w/ enc 1:

Region I Docket Room (with concurrences)

W. Hehl, DRP R, Blough, DRP P. Swetland, DRP J. Caldwell, EDO T. Murley, NRR J. Partlow, NRR S. Varga, NRR J.~Lieberman, OE A. Mendiola, NRR OPPICIAL DECOOD CODy MODE CDEEy WOC - 9002,0,0 09/28/90

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4 U emc 6e,vice . ElectflC and Get Coaveay. l Cnley 09 tuna. PuoJe Service Electnc anc Oas Company P.O. Bor 236, Hencocks Bndge, Nj08038 609 339 4800 .:e *res se*t %cw CWenn FI september 28, 1990 NLR-N90192 United States Nuclear Regulatorv Commission l - Document control Desk h Washington, DC-20555 centlemen: REQUEST.FOR REGIONAL WAIVER OF COMPLIANCE e TECHNICAL SPECIFICATIONS 3.7.1.1 FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET No. 50-354 Public Service Electric.and Gas Company (PSE&O) hereby requests Regional Waiver of Compliance from the. provisions of Technical Specification, (TS) 3.7.1.1.a. As discussed in. Attachment i to this letter,.PSEEG's conclusion is that granting this request L would involve neither a significant hazards consideration nor any -irreversible environmental consequsnces. L This. relief is requested to allow s,ifficient time to complete the replacer.ent cf the 'A' safety Aux 111 aries' Cooling Pumpn(8?.C8) and to demonstrate its operability without requiring. unit shutdewn. The SACS-pump casing, which was discovered to have a hair-line crack, has been replaced and pump reassembly is near completion. E However, final pump / motor alignment.and a baseline pump l performanceLtest-to demonstrate operability remain to be done which may, should any unexpected delay occur, extend beyond the

72. hour repair time permitted by the~TS ACTION statement.

The -requested duration of'this waiver is 24 hours, beginning at 0911 hours on September 29, 1990 until 0911 hours of the next day to provide sufficient time margin'for the uncertainties of pump / motor alignment. l Absent a Regional Waiver of Compliance, TS 3.7.1.1 would require the station to enter a 12 hour shutdown ACTION at 0911 hours on September 29, 1990. PSE&G therefore requests expeditious review of this submittal. O ' c $OfQLO.ca34-6%7

Document Control Desk 9/28/90 NLR-N90192 This request has been reviewed and recommended for approval'by the Hope Creek Genetating Station Station Operations Review Committee. Sincerely, TMwfh4 Attachment ^ f .c Mr. 8. Dombek j USNRC Licensing Project Manager 1 Mr. T. P. Johnson USNRC Senior Resident Inspector Mr.-W. T. Russell, Administrator USNRC Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering 1 j a I i i i

7 NLR-N90192 ATTACHMENT 1 TECHNICAL SPECIFICATION-3.7.1.1 i Hope Creek Technical specification 3.7.1.1 requires that two-separate and independent Safety Auxiliaries Cooling System (SACS) The subsystems be Operable in Operational Conditions 1, 2 and 3. associated ACTION statement requires that with one SACS pump inoperable, the pump must be returned to OPERABLE within 72 hours or the plant must be be in at least NOT SHUTDOWW within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.

SUMMARY

OF CURRENT SITUATION 26,1990, P8E&O personnel declared the At 0911 hours on September 'A' SACS pump inoperable due to a through-wall crack in the lower Since the structural integrity of an ASME Class 3 pump casing. ' component was involved, in accordance with a previous agreement 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, At PSE&G determined that pump casing replacement was prudent.the new pump c the time of preparation of this request, However, due to been installed and reassembly is in progress. the amount of rigging necessary to accomplish the casing change-out and the time loss introduced by the initial weld repairthe

effort, and OPERABILITY testing within the TS-permitted 72 hnura.

The flaw was This situation could not be reasonably avoided. detected by Hope Creek Generating Station (HCGS) p the small wet spot on the 'A' SAC 8 pump while working near it, worker notified supervision, who investigated the problem and PSE&O had no reason to determined the nature of the flaw. It was believe that a code weld repair would not be possible. only after pump disassembly and internal grinding that theThe extent of casting flaw was identified. in turn, placed the a change in direction on the repair which, successful replaceme REQUEST FOR REGIONAL WAIVER OF COMPLI ANCE I of Hope Creek Generating Station Technical specific l. Specifically, it is requested that the allowable time period to I SACS pump tc CPERABLE atatue be extended an l -restore the 'A' nna-tiee-only basis,

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t COMPENSATORY MEABt1RR8 The-remaining SACS pumps are in operation; however, no additional measures have been taken. JUSTIFICATION FOR THE PROPOSED WAIVER OF COMPLIANCE Justification for Proposed Time Duration of the Reaueal The time necessary for completion of the 8ACS pump replacement and testing is greater than the 72 hours permitted by Techni Based upon a review j Specifications. time to complete the alignment and testing. of our Hope Creek Generating Station-specific Probabilistic Risk the impact of the requested 24 hour extension i Assessment (PRA),upon core melt frequency has been found to be ins omall. 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 extensier, Absent the for completion of the' pump replacement and testing. j requested relief, a plant shutdown will be required. Determination _gf No Sionificant Hazards consideration This proposed Waiver of compliance: Does not involve a significant increase in the probability or consecuences of any accident previously evaluated. 1) The remaining SACS equipment is OPERABLE and in service. Equipment history on the SACS pumps, as well as the BACS h exchangers and pipinrigadditional 24 hour outage time on the 'A' SACS pump has been factored into our Hope Creek-specific PRA Ar: very dependable. model, resulting in no significant increase in the probability or consequences of the malfunction of equipment important to safety or of any core damage accidents. Does.not create the possibility of a new or different kind of accident from any accident previously evaluated. 2) Bufficient SAC 8 heat removal capability is currently available An additional 24 hour delay in for normal plant operation. completing the repair of a SACS pump will not create any new or different kind of accident.

>? . 3)- Does not involve a significant reduction in a margin of safety. Based upon our PRA review of this request, permitting an additional 24 hours in which to complete the replacement and . testing of. the SACS pump will cause no significant reduction in 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 SAC 8 temperature of 95 degrees. Current temperatures are 68 degrees river water temperature and 70 degrees 8ACS temperature thus providing additional margins. 1 Determination that the Reauest does not Involve Irreversibla Environmental Cona.equences The requested waiver does not allow for any increase in effluents that may be released offsite, does 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.

cenne seMee Electric and Gee company ' Steeley Latrune - Nblic Sevce Electric anc Gas Company P.O Box 236 Hancocks Bridge, NJ 08038 809 339 4800 yes P w comuewopem : October 1, 1990 NLR-N90193 1 United States Nuclear Regulatory Commission Document Control Desk Washington,-DC 20555 Gentlemen SUPPLEMENTAL INFORMATION REQUEST FOR REGIONAL WAIVER OF COMPLIANCE -TECHNICAL SPECIFICATIONS 3.7.1.1 -FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION -DOCKET No. 50-354 Public Service Electric and Gas Company (PSE&G) hereby provides additional information in support of our request for Regional Waiver of Compliance dated September 28, 1990. This additional material:is in response to specific questions raised during a-telephone conference call on the date of our original request.. A 24 hour Regional Waiver of Compliance from the provisions of Technical Specification, (Ts) 3.7.1.1.a became effective at 0911 hours on September 29, 1990 and was in effect until 1555 hours on September 29,-1990, at which time the 'A' Safety Auxiliaries cooling system (SACS) pump was restored to OPERABLE status. p lThe Waiver of Compliance was granted subject to the following conditions: l Dedicated roving fire watches were established during l; the extended allowable'out-of-service time (ACT) as a precaution against any fire that could potentially affect the operability of the 'B' SACS loop, operator awareness was enhanced and required response for system realignments of Emergency Diesel Generator and Filtration Recirculation and Ventilation System cooling in the event of a potential loss of the 'C' SACS pump or 'B' SACS loop was reviewed through written guidance and pre-shift brlefings prior to implementation of the of the ACT extension, i l. W*

d 'c._._.__._. / \\ ) Document Control Desk - 10/1/90 i NLR-N90193 The Waiver would expire and a plant shutdown would be required to be initiated at any time during the 24 hour extension upon determination of inoperability for any redundant ECCS equipment, and' The Waiver was effective at 0911 on September 29, 1990 and expired at 0911 hours on September 30, 1990. Furthermore, Attachments 1 through 4 expand upon four areas of our Waiver justification. This supplemental information has been reviewed by the Hope Creek Generating Station Station Operations Review Committee and recommended for submittal. sincerely, Attachment C Mr. 8. Dombek USNRC Licensing Project Manager Mr. T. P. Johnson USNRC Senior Resident Inspector Mr. T. T. Martin, Administrator USNRC Region I Mr. Kent.Tosch, Chief i New Jersey Department of Environmental Protection Bureau of Nuclear Engineering

NLR-N90xxx cu-a-7 maaIB Fem 72 HOUR ADT - TmuIen EPRef tfcaTION 3.7.1.1 The Hope Creek safety Auxiliaries cooling System ($Acs) consists of two redundant piping loops. Eeoh loop, containing two-504 pumps and two 50% heat exchangers (HXs), provides cooling to one loop of SACS equipment which normally includes two emergencyA minimum o diesel generators (EDGs). required to cool the Design Bssis Accident minimum (three out of four) required EDGs. In the avant that ana esca loan is unavailable, two EDGs will not be cooled until 8ACS nross-tie valving is local / manually repc'sitioned to provide cooling from Sines, during any event that the operating sacs loop. auto-starts the EDos, all dissol temperature trips are bypassed, the diesels with no cooling will'run to destructions the time assumed for'this to happen is 3 minutes for loss of load and 5 minutes to engine seizure. The time assumed for a single NRC action outside the control room is 20 minutest therefore, staff required the SACS Technical specification 3.7.1.1 to specify-that all four SACS pumps /HX ("two separate and independent Safety Auxiliaries cooling System subsystems") be OPERABLE in Operational Conditions 1, 2 and-3 and that the associated ACTION statements require that with ena SACS pump or heat exchanger inoperable, the pump /HX sust be' restored to CPERABLE within 72 hours or the plant must be in at.least NOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within t following 24 hours., I ~.

l l '1 Attachment a Annandia 3 Hope Creek Appendix R shutdown methods are provided in'UFSAR l section 9A. In addition, UFSAR Section 9A.1 (General Criteria) identifies that no other plant accidents or severe natural' phenomena need be assumed to occur concurrently with a postulated fire. The Appendix R safe shutdown analysis accounts for two of the four SACS. HopeCreekgumpsbeingdamagedbyapostulatedfire. s Appendix R program ensures that at least two SACS pumps are available to perform shutdown' functions during a postulated fire. With SACS pump A inoperable, operability assurance of SACS pumps B and D is required during the extended Technical Specification time frame. To provide this assurance, fire watch patrols were assigned to the following areas:

1. All rooms in Reactor Building El. 54', 77' and 102';

2. All rooms in Control and Diesel Building;

3. Remote shutdown room.

Fire watch patrols provide surveillance of the areas for hazardous conditions not normally detected by installed fire protection systems. Such conditions include: obvious activities by plant personnel that could increase o the: fire hazard in the area; ) Conditions likely to cause a fire, such as spills of o flammable liquids or major malfunctioning of equipment; o-Conditions likely to adversely affect fire protection, such as blocked access routes; o Major accumulation of transient combustible materials. Fire watch patrols ensure prompt notification of fire occurrence and to provide first aid-fire fighting activities -) until the arrival of the dedicated site fire brigade. The . fire watch and installed fire protection systems provided reasonable assurance that the probability of fire occurrence which may have potentially damaged the required pumps during the extended-24 hours was extremely remote. i L

1 ATTacEMENT a 7 1 1 EVALUAT10M As a safety related system, the Safety Auxiliaries cooling system (SACS) is included in the Hope Creek PRA. The SACS system is modeled in the PRA such that changes to individual sacs component unavailabilities may be made, thereby allowing their overall effect on core damage frequency to be quantified. To support the current request for an extension of the $ACS pump outage LCo, the PRA model was utilized to determine the effect of the $ACS LCO extension on core damage frequency. The PRA model includes events to reflect the probability of components being out of service due to test and maintenance (TN). The existing reliability data utilized by the PRA for SACS pump TM unavailability is 5.6E-3, which corresponds to an out of service time of 49 hours per pump per year. This value reflects plant experience and is lower than the Tech spec LCO of 72 hours. It was requested that a 24 hour extension be given to the i existing 72 hour LCo, resulting in a total out of service period of 96 hours. This period corresponds to an unavailability of 1.1E-2. The 1.1E-2 unavailability value was substituted into the PRA model in place of the existing SACS pump TM unavailability value of 5.6E-3. The PRA model was run to determine the overall effect on core damage frequency due only to the SACS TM value change.- The result was a delta core damage frequency increase of.7.7E-8, i which is approximately three orders of magnitude below the overall core damage frequency of 1.42E-4. It should be recalled that this delta reflects the change from the existing sacs pump TM unavailability (corresponding to 49 p hours), not the Tech spec LCO of 72 hours. Therefore, the calculated delta core damage frequency reflects an increase of 47 hours (for the same total of 96 hours) which will provide a -conservative calculation for the delta value. It is apparent that the change in calculated core dandge frequency, due to L extending the SACS LCo an additional 24 hours, is relatively small. i l

o.- l l L m L NLR-N90 AfrAGDENT 4 oPanaron MITIahTInn Acrzona only two EDGs are required.for safe shutdown for a Fire / Loss of Power event. A Fire is not considered in conjunction with a LOCA. However, actions to be taken by plant operators are provided below for any occurrence during the extended ACT that could result in only one sac 8 pump or only one SACS loop in operation. In the operating Department Hight Order Book, effective for the period encompassing the Waiver of Cogliance, the Hope Creek operations Manager described plant vulnerabilities due to being L in a degraded 8AC8 configuration. The dieoussion included j l l a fire affecting 'B' 8ACS loop oprability while the 'A' SACS pump is also inoperable could leave only the 'C' sacs pump operable and that, under certain conditions, system j loading could result in this single pump running-out which, in turn, could deprive the two EDGs required for plant shutdown of cooling, I in the event that the 'C' SACS pump became inoperable, in addition to the 'A' SACS pump, cooling water to the EDGs and-the Filtration, Recirculation and Ventilation System (FRV8) would require realignment to the operable SACS loop to ensure cooling to these and other vital componente. l The Night orders required thatt A dedicated roving fire watch be established for the SACS i pump / heat exchanger areas as a precaution against any fire that could potentially affect the operability of the 'B' l SACS loop, Equipment Operators assigned to the Reactor and Auxiliary Buildings be alerted to be prepared to quickly realign cooling water to the EDGs and the FRV8, and to-expeditiously throttle SAC 8 flow to the RNR NX to 4,000 gpa to prevent SACS pump run-out. Specific operating Procedures, including step numbers and, for throttling operations, the specific valve number were included, A briefing with shift crews be conducted prior to assuming shift duties during the Waiver period to discuss the above issues and required operator actions and to ensure operators reviewed, and had copies of, the appropriate procedures, were familiar with valve locations, and had all necessary i ladders, tools, and other equipment, and The Resident Inspector be informed when the SACS action statement was exited. l -}}