ML20070U653

Application for Amend to License NPF-57,increasing Allowable Leak Rate for MSIV & Deleting MSIV Sealing Sys

ML20070U653
Person / Time
Site:	Hope Creek
Issue date:	04/03/1991
From:	Public Service Enterprise Group
To:
Shared Package
ML20070U644	List: ML20070U642 ML20070U653 ML20070U659
References
NUDOCS 9104090231
Download: ML20070U653 (4)

Text

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HOP [ CRl[K GLN[RA!!NG STATION UNITED STAi[S NUCLEAR REGULATORY COMMISSION In the Matter of Public Service Electric and Gas Company Docket No. 50 354 i

Hope Creek Gener6 ting Station 1 APPLICATION FOR AMLNDhiHT TO OPLRAllNG LICENSE Pursuant to Section' 50.90 of the Regulations of the Nuclear Regulatory -

Commission, Public Service Electric and Gas, holder of facility Operating 1.icense No. NPF 57 hereby requests the Technical Specifications, . set forth in Appendix A to. the license, be amended to permit an increase in the allowable

. leak- rate for the main steam isolation valves (MSIVs) and deletion of the Technical ~--Spuification requirements for the MSIV Scaling System.

Specifically, PSE&G requests that:

1. Allowabic leak rate specified in the Technical Specifications Section 3.6.1.2 be changed from 46.0 total standard cubic foot per hour (scfh) to'200.scfh per main steam _line. This proposed change reflects a higher, but still conservative allowable leak rate for the MSIVs.

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HOPE CR((K GENERATING STATION l

2. Section 3.6.1.2a to be administratively amended to add a footnote exempting MSly leakages from the overall integrated leakage rate. In concurrence with this application for license amendment, PSE&G has applied for specific exemption to Appendix J of 10CFR Part 50.

3. Sections 3.6.1.4 and Bases 3/4.6.1.4 be amended to permit the deletion of the MS!V Scaling System from the Technical Specifications. PSE&G proposes an alternate to Regulatory Guide  ;

1.96, " Design of Main Steam Isolation Valve Leakage Control Systems for Boiling Water Reactor Nuclear Power Plants." Vtilization of the main steam lines and condenser, as an alternate method for MSIV l

leakage treatment, has been demonstrated to be more effective than the leakage control systems in terms of reliability.

4. Table 3.6.31 be amended to permit the deletion of the MSIV Scaling System valves from the Technical Specifications.

5. The index, Section 3.6.1.4 and 4.6.1.4 and Bases 3/4.6.1.4 be administrative 1y an. ended to rearrange section and page numbering.

The proposed changes to the Technical Specifications are set forth in Enclosure 1.

The proposed changes are a result of the extensive work performed by the BWR Owners' Group (BWROG) in support of the rasolution of Generic issue C 8 "MSIV Leakage and LCS failure". GE report NEDC 31858P provides technical justification on a generic basis to support these proposed changes.

Based on the BWROG evaluation of MSIV leakage performance, the current Technical Specification allowable MSIV leak rate is extremely limiting and routinely requires the repair and re-testing of MSlVs. This unnecessary repair significantly impacts the maintenance work load, often contributes to outage extensions, and has in the past adversely affected-the operability of

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H0pE CREEK GENERATING S1A110N i

the MS!Vs. BWR outage planners routinely schedule several days of contingency to repair and retest the MSIVs. In addition, the needless dose exposure to ,

maintenance personnel is inconsistent with As low As Reasonably Achievable (ALARA) requirements. There have also been many Licensee Event Reports written for MSIV leakages exceeding the Technical Specification limit. The proposed changes will reduce unnecessary MSly repair costs, avoid unnecessary dose exposure to maintenance personnel, reduce outage durations, and extend the effective service life of the MSIVs. In addition, the proposed increase in the MSIV leakage limit has potential to significantly reduce recurring valve leakages, and minimize the possibility of needless repair which can compromise plant safety.

Based on BWROG evaluation, the MSIV Scaling System is extremely difficult to maintain. The system contains extensive logic and instrumentation, requiring frequent calibration to meet the Technical Specification requirements, furthermore, at MSIV leakage rates greater than 100 scfh, the System will not function following a postulated design basis LOCA. The BWROG has demonstrated that alternate pathways are available to effectively process excessive MSlV leakages, and that these alternate pathways can be employed in lieu of existing leakage control systems. Deletion of the MSly Scaling System will resolve the safety concern raised by Generic issue C 8 regarding the LCS effectiveness at MS!V leakage rates higher than the LCS design capacity.

Plant specific supporting information and results of the radiological analysis that justify the proposed changes are included as Enclosure 2. As concluded in-the supporting information, the increased MSly allowable leak rate of 200 scfh and the deletion of the MSly Scaling System, will not adversely affect the performance of the primary containment isolation function. A plant-specific radiological analysis has been performed utflizing the mcin condenser as an alternate treatment path for MSly leakage. This radiological analysis demonstrates that the proposed ,Sanges result in an acceptable increase'to the_ dose exposures previously calculated for a design basis

HOPE CRLEK GENIRATING STATION Loss of-Coolant Accident (LOCA). The revised LOCA dose exposures remain well within ti.e guidelines of 10CTR Part 100 for the of fsite doses and 10CFR Part 50, Appendix A (General Design Criteria 19) for the control room doses.

PSE&G will institute into the MSiv maintenance and test program, the requirement that any MSIV exceeding the proposed 200 scfh limit, will be repaired and re-tested to meet a leakage rate of less than or equal to 11,5 scfh, This will assure continuation of high quality repair and refurbishment efforts to improve the overall performance and reliability of the MSIVs.

The proposed change will require a minor plant design change to allow specified main steam drain valves to be opened even if off site power is not available. Applicable normal plant operating procedures and emergency operating procedures shall be reviewed and revised accordingly.

(lpon approval of the proposed MSIV Sealing System deletion from the Technical Specifications, PSE&G will install blind flanges in the inboard system lines, so that the associated isolation valves can be exempted from local leak rate testing. The outboard system lines and valves will be disabled to prevent the inadvertent use of this system, in lieu of the safety related MSIV Sealing System, MSIV leakage will be transported via the drain lines to the condenser and processed in accordance with Section 4,3 of NEDC 31858P, <

furthermore, PSE&G will incorporate the applicable alternate leakage treatment methtO, consistent with GE document HE00 30324 Potential Operator Actions to Control MSIV Leakage", into the Operational Procedures and Emergency Operational Procedures at Hope Creek Generating Station, Pursuant to 10CFR50.92, an analysis which demonstrates that the proposed changes do not involve a significant hazards consideration, is included as Enclosure 3. The proposed changes have been reviewed in accordance with Section 6.5 of the Technical Specifications. The proposed changes will not authorize any change in the types of effluents or in the authorized power level of the facility, Enclosure 4 is an application for exemption to Appendix A of 10CFR100, and Enclosure 5 is an application for exemption to Appendix J of 10CfR50.

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