ML20077D285

Application for Amend to License NPF-57,relocating Tables of Response Time Limits for Reactor Protection Sys Instrumentation,Isolation Actuation Instrumentation & ECCS Actuation Instrumentation

ML20077D285
Person / Time
Site:	Hope Creek
Issue date:	11/30/1994
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20077D292	List: ML20077D285 ML20077D293
References
LCR-94-09, LCR-94-9, NLR-N94177, NUDOCS 9412080154
Download: ML20077D285 (7)

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Pubhc Service  ;

. Electnc and Gas Cornpary Stanley LaBruna Public Service Elecinc and Gas Company P.O. Box 236, Han:ocks Bridge, NJ 08038 609-339-1700 ,

w,...*""""' l NOV 3 01994 NLR-N94177 LCR 94-09  ;

United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 '

Ge.ntlemen:

LICENSE AMENDMENT APPLICATION RELOCATION OF TECHNICAL SPECIFICATION TABLES ON INSTRUMENT RESPONSE TIME LIMITS FACILITY OPERATING LICENSE NPF-57  ;

HOPE CREEK GENERATING STATION 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. The proposed changes would revise the Hope Creek Technical Specifications by relocating the tables of response time limits for the Reactor Protection System (RPS). Instrumentation, the '

Isolation Actuation Instrumentation, and the Emergency Core Cooling System (ECCS) Actuation Instrumentation. Attachment 1 contains-a detailed description of and justification for the proposed changes. Based upon the justification provided, PSE&G believes that the proposed changes do not involve a significant  ;

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hazard consideration pursuant to 10CFR50.92. This proposed change is a "line-item" technical specification improvement and ,

follows the guidance of the draft generic communication that was published in Generic Letter (GL) 93-08. As these changes reflect l NRC approved, generic recommendations, PSE&G believes that a detailed NRC branch review or specialist review should not be-required.

PSE&G notes that changes similar to those proposed herein have I been approved by the NRC for Baltimore Gas and Electric Company in an SER dated February 10, 1994. j i

Attachment 2 contains marked up Technical Specification pages l which reflect the proposed changes.

Upon NRC approval, please issue a license amendment which will be effective upon issuance and shall be implemented within 60 days _i 0800m %s 9412090154 941130 i PDR ADOCK 05000354 P PDR ( - I

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NOV 3 01994 Document Control Desk 2 NLR-N94177 of issuance. This latitude permits appropriate procedural modifications necessary to implement the proposed changes.

Should you have any questions or comments on this submittal, please do not hesitate to contact us.

Sincerely, 1/#"

Affidavit Attachments (2)

C Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Poad King of Prussia, PA 19406 Mr. D. Moran, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. R. Summers (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

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REF: NLR-N94177 LCR 94-09 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

S. LaBruna, being duly sworn according to law deposes and says:

I am Vice President - Nuclear Engineering 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 Generating Station, are true to the best of my knowledge, information and belief.

f -how Subscr bed and Sworn tto before me this( ()dh day f 77 CRC #7/#4 , 1994 O Jf)lliL{L/ bN Y/auLn Notary PublicVQf lew Jersey KIMBERLY JO BROWN My Commission expires on ,y0TARY PUBLIC Of NEW JERSEY muu orn:3 ugu e ,, m33

l ATTACEMENT 1 PROPOSED CRANGES TO THE TECHNICAL SPECIFICATIONS LICENSE AMENDMENT APPLICATION RELOCATION OF TECHNICAL SPECIFICATION TABLES ON INSTRUMENT RESPONSE TIME LIMITS FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION NLR-N94177 DOCKET NO. 50-354 LOR s4-09 i

I. DESCRIPTION OF THE PROPOSED CRANGES  !

The proposed amendment would revise the Technical Specifications for Hope Creek Generating Station by relocating the tables of response time limits for the Reactor Protection System (RPS), the Isolation System, and the Emergency Core Cooling System (ECCS) instrumentation from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR). This proposed amendment is a "line-item" technical specification improvement and follows the guidance of Generic Letter 93-08 (Reference 1).

l II. REASON FOR THE PROPOSED CHANGES The proposed amendment will allow changes to the response time limits for the RPS, the Isolation System, and the ECCS instruments to be processed under administrative controls in accordance with the provisions of 10CFR50.59 without the need to process a license amendment request. Changes to these limits would then be submitted as an update to the UFSAR as required by 10CFR50.71(e). Related changes to plant procedures would be subject to the provisions that control changes to plant procedures as stated in the Administrative Controls Section of the Technical Specifications. The response time limits will be included in the next update to the UFSAR.

Upon NRC approval of the BWR Owners Group document, " System Analyses for Elimination of Selected Response Time Testing )

Requirements," NEDO-32291, PSE&G intends to take advantage  !

of the response time testing changes and eliminations addressed in this BWR Owners Group document under administrative controls in accordance with the provisions of 10CFR50.59.

III. JUSTIFICATION FOR THE PROPOSED CHANGES The RPS, the Isolation System, and the ECCS instrumentation l are used to mitigate the consequences of accidents and Page 1 of 3

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Attachment 1 NLR-N94177 Relocation of Technical Specification Tables on LCR 94-09 Instrument Response Time Limits provide the necessary signals to actuate the safety equipment needed to mitigate accidents and transients. The relocation of the response time tables from the Technical Specifications to the UFSAR will not affect this safety function in that these changes do not change the operability or surveillance requirements for these instruments from the existing Technical Specification requirements. The plant procedures for response time testing include acceptance criteria that reflect the RPS, Isolation System, and ECCS response time limits in the tables being relocated from the Technical Specifications to the UFSAR. Changes to the response time limits will be processed under the administrative controls of 10CFR50.59.

IV. RJGNIFICANT NAZARDS CONSIDERATION EVALUATION PSE&G has, pursuant to 10CFR50.92, reviewed the proposed amendment to determine whether the requer.t involves a significant hazards consideration. We have determined that operation of the Hope Creek Generating Station in accordance with the proposed changes:

1. Will not involve a significant increase in the  !

probability or consequences of an accident previously >

evaluated.

The Reactor Protection System (RPS), the Isolation System, and the Emergency Core Cooling System (ECCS) >

instrumentation are used to mitigate the consequences of accidents and provide the necessary signals to actuate the safety equipment needed to mitigate accidents and transients. The proposed changes i relocate the RPS, the Isolation System, and the ECCS instrument response times from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR) but will not change the operability or surveillance requirements for these instruments. With these proposed changes, revisions to the response times for these instruments can be made pursuant to 10CFR50.59. The proposed changes will not alter any  ;

accident initiators or the consequences of any analyzed accident. 'Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Will not create the possibility of a new or different kind of accident from any accident previously Page 2 of 3

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, Attachment 1 NLR-N94177  !

Relocation of Technical Specification Tables on LCR 94-09 Instrument Response Time Limits evaluated.

The proposed changes relocate the RPS, the Isolation System, and the ECCS instrumentation response time I limits from the Technical Specifications to the UFSAR l but does not change the function of those instruments.

The proposed changes do not represent a change in the configuration or operation of the plant. No new hardware is being added to the plant as part of the proposed changes. The Technical Specifications will continue to require the same operability and surveillance requirements to be met for these instruments. Therefore, the proposed changes do not create the possibility of a new or different type of accident from any accident previously evaluated.

3. Will not involve a significant reduction in a margin of safety.

The proposed changes will not affect the functions of the RPS, the Isolation System, or the ECCS instruments.

Relocating the response time limits will not alter the operability or the surveillance requirements on these instruments. The administrative change control provisions for the UFSAR and the plant procedures written pursuant to 10CFR50.59 are adequate to control future revisions to the response time limits.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

V. CONCLUSION As discussed above, PSE&G has concluded that the proposed changes to the Technical Specifications do not involve a significant hazards consideration since the changes: (i) do not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) do not create the possibility of a new or different kind of accident from any accident previously evaluated, and (iii) do not involve a significant reduction in a margin of safety.

VI. REFERENCES

1. Generic Letter 93-08, " Relocation of Technical Specification Tables of Instrument Response Time Limits",

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Attachment'l NLR-N94177 Relocation of Technical Specification Tables on LCR 94-09 Instrument Response Time Limits dated December 19, 1993.

2. NEDO-32291, " System Analyses for Elimination of Selected Response Time Testing Requirements", dated January 1994. l l

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