ML20073J874
| ML20073J874 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/29/1994 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20073J877 | List: |
| References | |
| LCR-94-21, NLR-N94125, NUDOCS 9410070171 | |
| Download: ML20073J874 (6) | |
Text
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Putnc semce sectnc and Gas cm pany Steven E. Mittenberger Pubhc Sm:ce Eloctoc ana Gas Company P O. Box 236, Hancocks Bndge, f 4J 08038 609-339-1100 m%.., a e v o s mou SEP 2 91994 NIR-N94125 LCR 94-21 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDMENT APPLICATION REVISION OF SRM AND IRM CHANNEL CALIBRATION FREQUENCIES HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 This letter submits an application for amendment to Appendix A of Facility Operating License NPF-57 for the Hope Creek Generating
- Station, and is being filed in accordance with 10CFR50.90.
Pursuant to the requirements of 10CFR5 0. 91 (b) ( 1), a copy of this request for amendment has been sent to the State of New Jersey.
The proposed Technical Specification changes contained herein represent changes to Section 3/4.3.6
" Control Rod Block Instrumentation."
This submittal revises the surveillance requirement for channel calibration fr.:quency for the Source Range Monitors and the Intermediate Range Mo. itors from once per 184 days to once per refuel interval.
The proposed changes have been evaluated in accordance with 10CFR50. 91 (a) (1), using the criteria in 10CFR50.92(c), and it has been determined that this request involves no significant hazards considerations.
In response to the NRC Cost Beneficial Licensing Action (CBLA) initiative, Public Service Electric & Gas (PSE&G) met with the NRR Staff on November 12, 1993, to discuss our CBLA Program.
PSE&G considers this submittal a CBLA.
We have estimated that the proposed changes would yield a cost savings of $30,000 per refuel cycle at Hope Creek.
Savings over the life of the plant are estimated to be $630,000.
A description of the requested amendment, supporting information and analyses for the change, and the basis for a no significant hazards consideration determination are provided in Attachment 1.
The Technical Specification pages affected by the proposed change are provided in Attachment 2 with pen and ink changes.
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SEP 2 91994 Document Control Desk NLR-N94125 Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of
- issuance, but implemented within sixty days to provide sufficient time for associated administrative activities.
Should you have any questions regarding this request, we will be pleased to discuss them with you.
Sincerely, O
Affidavit Attachments (2)
C Mr.
T.
T.
Martin, Administrator - Region I U.
S.
Nuclear Regulatory Commission 475 Allendale Road King of Frussia, PA 19406 Mr.
J.
C.
Stone, Licensing Project Manager -
Salem & Hope Creek U.
S.
Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr.
C.
S. Marschall (SO9)
USNRC Senior Resident Inspector Mr.
K.
Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 i
4 95-4933
~
4 REF: NLR-N94125 LCR 94-21 STATE OF NEW JERSEY )
)
SS.
COUNTY OF SALEM
)
S.
E. Miltenberger, being duly sworn according to law deposes and I
says:
I am Vice President and Chief Nuclear Officer 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 l
Generating
- Station, are true to the best of my knowledge, information and belief.
I 11 on-
/
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f l
l Subscribed and Sworn to before me this
/bl day f
jY[mhcL, 1994
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.h4hfUttL1L 1
L )M /// t[1 T
i i y i Notary Public of New Jersey i
KIMDERLY JO BROWN My Commission expires on
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4 ATTACHMENT 1 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS LICENSE AMENDMENT APPLICATION REVISION OF BRM AND IRM CHANNEL CALIBRATION FREQUENCIES FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION NLR-N94125 DOCKFT NO. 50-354 LCR 94-21 I.
DESCRIPTION OF THE PROPOSED CHANGES l
This amendment revises Table 4.3.6-1
" Control Rod Block Instrumentation Surveillance Requirements."
The channel calibration frequencies for the Source Range Monitor (SRM) upscale trip function and the downscale trip function are changed from "SA" once per 184 days to "R"
once per refuel interval.
The same changes are made for the Intermediate Range Monitor (IRM) upscale and downscale trip functions.
II.
REASONS FOR THE CHANGE The proposed changes to the Technical Specifications are consistent with the NRC's recommendation of improving the Technical Specifications by reducing surveillance requirements for testing during power operation, Generic Letter (GL) 93-05.
Through this submittal, PSE&G is requesting implementation of the NRC's recommendations regarding the channel calibration frequencies of SRM and IRM trip functions.
III. JUSTIFICATION FOR CHANGES The control rod block functions are provided to prevent excessive control rod withdrawal.
Current Hope Creek Surveillance Requirements for SRM and IRM channel calibrations specify an interval of once per 184 days.
In GL 93-05 the NRC announced its completion of a
comprehensive examination of surveillance requirements in technical specifications that require testing during power operation.
The results of this effort, part of the NRC's Technical Specification Improvement Program (TSIP), indicated that while the majority of the testing at power was important, safety could still be improved while decreasing equipment degradation and removing unnecessary burdens on personnel resources by reducing the amount of testing that the Technical Specifications require during power operation.
One of the recommendations in GL 93-05 was the extension of channel calibrations for SRM and IRM upscale and downscale trip functions to once each refueling interval.
This
ATTACEMENT 1 NLR-N94125 l
REVISION OF BRM AND IRM CHANNEL LCR 94-21 4
CALIBRATION FREQUENCIES recommendation was discussed further in NUREG-1366
" Improvements to Technical Specifications Surveillance Requirements," dated December 1992. The NRC's findings, which j
included a review of set point trend data for IRMs, was that there was very little drift in equipment calibration.
A further consideration was that the IRMs were also being calibrated for compliance with operability requirements for Limiting Conditions for Operability (LCO) for Peactor Protection System (RPS) instrumentation.
Based upon the set point trend data and supported by the current RPS IRM Surveillance Requirement channel calibration frequency of once per refuel interval, the NRC concluded that the channel calibration frequencies for control rod block functions by SRMs and IRMs could be changed to once per refuel interval.
Considering the NRC's aforementioned position and the benefits of reduce regulatory burden while maintaining existing levels of plant safety, PSE&G believes that the proposed changes are justifiable.
Based upon a review of Surveillance Requirement results for the past 3 years for SRM and IRM channel calibrations, PSE&G concludes that the proposed changes are compatible with plant operating experience and are consistent with the guidance provided by Generic Letter 93-05.
IV.
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION PSE&G has, pursuant to 10CFR50.92, reviewed the proposed amendment to determine whether our request involves a
significant hazards consideration.
We have determined that the operation of the Hope Creek Generating Station in i
accordance with the proposed changes:
1.
Will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes involve no hardware changes, no changes to the operation of any systems or components, and no changes to existing structures.
The revision of channel calibration frequencies for the SRM and IRM trip function portion of the control rod block instrumentation represent changes that do not affect plant safety and do not alter existing accident analyses.
2.
Will not create the possibility of a new or different kind of accident from any previously evaluated.
^
i i
ATTACHMENT 1 NLR-N94125 REVISION OF BRM AND IRM CHANNEL LCR 94-21 CALIBRATION FREQUENCIES The proposed changes are procedural in nature concerning the calibration frequency of instrumentation that have historically shown little set point drift.
The channel calibration methodology for the SRM and IRM control rod block trip functions remain unchanged.
The proposed changes while slightly increasing the possibility of an undetected instrument error will not create a new or unevaluated accident or operating condition.
3.
Will not involve a significant reduction in a margin of safety.
The proposed changes are in accordance with recommendations provided by the NRC regarding the improvement of Technical Specifications.
These changes will result in the perpetuation of current safety margins while reducing regulatory burden and decreasing equipment degradation.
V.
CONCLUSIONS Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.
l 1