ML20077R937
| ML20077R937 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 01/11/1995 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20077R939 | List: |
| References | |
| LCR-94-25, NLR-N94173, NUDOCS 9501230203 | |
| Download: ML20077R937 (8) | |
Text
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PutAc Serv 6ce Doctric and Gaa company Joseph J. Hagen Public Service Doctric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 SO9-339-1200 t%m Presdord. Nuasar Opersons
'JAN111995 NLR-N94173 LCR 94-25 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDMENT APPLICATION REMOVAL OF TURBINE OVERSPEED PROTECTION l
FROM THE TECHNICAL SPECIFICATIONS 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 10CFR50. 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 3/4.3.8 " Turbine Overspeed Protection System." The proposed revision removes this specification from the Technical Specifications and relocates the Bases to the Hope Creek Updated Final Safety Analysis Report (UFSAR) and the Surveillance Requirements to the applicable surveillance procedures.
The Limiting Conditions for Operation (LCOs) will be eliminated. While 10CFR50.36 will no longer provide the determination of acceptable functional capability / performance for safe operation of the Turbine Overspeed Protection System, operation and maintenance of this system will be commensurate with its safety significance.
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.
A description of the requested amendment, supporting information and analyses for the changes, and the basis for a no significant hazards consideration determination are provided in Attachment 1.
The Technical Specification pages affected by the proposed changes are provided in Attachment 2 with pen and ink changes.
i 95N 235203 950112 gDR ADOCK 05000354
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UAN111995 Document Control Desk NLR-N94173 In accordance with the guidance presented in the " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" as published in the Federal Register (58 FR 39132),
the proposed changes have received a multidisciplinary review by responsible technical supervisory personnel, including onsite operations personnel.
Upon NRC approval of these proposed changes, 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, J.
HaTan Vice President Nuclear Operations 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 Regu.atory Commission One White Flint Norch 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 l
REF: NLR-N94173 LCR 94-25 STATE OF NEW JERSEY )
)
SS.
COUNTY OF SALEM
)
J.
J. Hagan, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Operations 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.
x SubscribedandSh1 to before me this h b day o)Dd/Ull4(P; 1995 0
C / kAnht</oNkW blcum.
4liodaryPublichf/NWJersey KIMBERLY JO BROWN NOTARY PUBLIC Of NEWJERSEY My Commission expires on My camminian troires Antil n inna
I ATTACHMENT 1 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS LICENSE AMENDMENT APPLICATION REMOVAL OF TURBINE OVERSPEED PROTECTION FROM THE TECHNICAL SPECIFICATIONS FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION NLR-N94173 DOCKET NO. 50-354 LCR 94-25 I.
DESCRIPTION OF THE PROPOSED CHANGES This amendment removes Specification 3/4.3.8
" Turbine Overspeed Protection System" and its associated Bases from the Technical Specifications with corresponding changes to the Table of Contents.
II.
HEASONS FOR THE CHANGES The proposed changes to the Technical Specifications conforms with.the NRC's
" Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," dated July 22, 1993. During the development of NUREGe1433 " Standard Technical Specifications, General Electric Plants, BWR/4" the NRC issued a letter to the B&W Owners Group, T.E.
Murley to W.S.
Wilgus dated May 9, 1988, which identified the Turbine Overspeed Protection System specification as a Limiting Conditions for Operation (LCO) which may be relocated to other licensee-controlled documentation contingent upon NRC staff approval of the location of and controls over the relocated requirement.
Through this submittal, PSE&G is requesting implementation of the NRC's recommendation regarding the relocation of the Turbine Overspeed Protection System specification. Along with the relocation of the Bases to the Hope Creek Updated Final Safety Analysis Report (UFSAR) and the Surveillance Requirements to the applicable surveillance procedures, this submittal eliminates the LCO's.
Removal of this specification from the Technical Specifications would reduce regulatory
- burden, since future changes to the Turbine overspeed Protection System would be conducted using the 10CFR50.59 process.
III. JUSTIFICATION FOR CHANGES The purpose of overspeed protection is to minimize the possible generation of turbine fragment missiles.
Excessive overspeed could potentially result in tne generation of missiles which could impact and damage safety related
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ATTACHMENT l' NLR-N94173 REMOVAL OF TURBINE OVERSPEED PROTECTION LCR 94-25 i
FROM THE TECHNICAL SPECIFICATIONS components, equipment, systems or structures, depending on the
-size and trajectory of the missiles.
This concern is specifically identified in General Design Criterion 4,
of Appendix A,
to 10CFR50, which requires that structures, systems, and components important to safety be appropriately.
protected against the effects of missiles that might result from equipment f ailures. Guidance for addressing this concern is provided in Regulatory Guide (RG) 1.115 " Protection Against i
Low-Trajectory Turbine Missiles."
With the conclusion of the Technical Specification Improvement Program the NRC issued it's final policy statement on technical specification improvements for nuclear power reactors.
The NRC concluded that the purpose of the Technical Specifications is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of i
an abnormal situation or event giving rise to an immediate threat to the public health and safety by identifying those issues that are of controlling importance to safety and establishing on them certain limiting conditions of operation j
which can not be changed without prior NRC approval.
This policy statement included a set of criteria which delineated those constraints on design and operation derived from the UFSAR and that belonged in the Technical Specifications in accordance with 10CFR50.36.
Specifically, these criteria are as follows:
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary, i
I e
A process
- variable, design
- feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier, 9
A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier, e
A structure,
- system, or component which operating i
experience or probabilistic safety assessment has shown to be significant to public health and safety.
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ATTACHMENT 1 NLR-N94173 REMOVAL OF TURBINE OVERSPEED PROTECTION LCR 94-25 FROM THE TECHNICAL SPECIFICATIONS While the turbine overspeed protection system prevents the generation of potentially damaging missiles due to a failure or transient that could result in an overspeed condition, the-turbine overspeed event itself does not constitute a
significant abnormal degradation of the reactor coolant pressure boundary nor is it a design basis accident or transient. Therefore, the turbine overspeed protection system does not contain -installed instrumentation that is used to
- detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary nor is it a process variable that is an initial condition of a Design Basis Accident or Transient.that either assumes the i
failure of or presents a challenge = to the integrity of a fission product barrier.
The turbine overspeed protection system is also not a system, component or structure that is part of the primary success path for mitigating a Design Basis i
Accidect or Transient that either assumes the failure of or i
presents a challenge to the integrity of a fission product barrier.
In regards to the probability of a turbine missile causing i
damage to a safety-related system / structure, the frequency of such an event ^ can be expressed as the product of the probability of a turbine failure resulting in the ejection of a missile (per year), the probability that such an ejected missile will strike a target with safety-related significance (per f ailure), and the probability that such an impact will damage the target (per strike).
In determining this probability, the NRC staff concluded in Hope Creek's SER (NUREG-1048) that "the probability of unacceptable damage to safety-related structures, systems, and components from turbine missiles is acceptably low (i.e., less l
4 than 10 per year) provided that the total turbine-missile-l generation probability is maintained throughout the life of the plant by acceptable inspection and test programs. " The i
relocation of the Turbine Overspeed Protection System specifications to the UFSAR and surveillance procedures will not eliminate the in-place inspection and testing programs.
Hope Creek will continue to inspect and test in accordance with the turbine manufacturer's recommendations, guidance provided by the ASME Code, and good engineering practice based l
on plant operating experience.
{
As established by the NRC when determining those i
specifications which may be relocated to licensee-controlled documentation, PSE&G believes that this submittal for relocating the Turbine Overspeed Protection System l
f
ATTACHMENT 1 NLR-N94173 REMOVAL OF TURBINE OVERSPEED PROTECTION LCR 94-25 FROM THE TECHNICAL SPECIFICATIONS specification from the Technical Specifications to the UFSAR and applicable surveillance procedures (both controlled by 10CFR50.59 requirements) is justified.
These changes reduce regulatory burden while maintaining existing levels of plant safety.
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 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 existing structures, and no changes to the operation of any systems or components.
Specifically, the deletion of the LCO's by this submittal will not alter established turbine overspeed protection system operation.
Procedural guidance will be provided in the event of an inoperable control, stop, or intermediate valve to place the system in a safe condition.
The relocation of this specification to the UFSAR and surveillance procedures will continue to ensure that the probability of unacceptable damage to safety-related structures, systems, and components from turbine missiles remains acceptably low.
Relocation of this specification's Bases and Surveillance Requirements to the UFSAR and surveillance procedures, respectively, and the deletion of the LCO's represents 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.
The proposed changes are procedural in nature concerning the location of the descriptive information and surveillance requirements for the turbine overspeed protection system. Removing these specifications from the Technical Specifications and placing them in the UFSAR and surveillance procedures will not alter the operation of the turbine overspeed protection system or its ability to perform its intended function.
Procedural guidance will be provided to assist in placing the system in a safe condition while maintenance and testing of this system
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' ATTACHMENT'1 NLR-N94173 I
REMOVAL OF TURBINE O N(SPEED PROTECTION LCR 94-25 FROM THE TECHNICAL SPECIFICATIONS wt'l continue in accordance with the turbine manufacturers recommendations taking into. consideration plant operating experience and ASME guidance.
Therefore, these changes 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 relocate the Turbine overspeed Protection System portion of the Technical Specifications to the UFSAR and surveillance procedures in accordance with guidance provided bv the NRC Final Policy Statement regarding the improvement of Techni%1 Specifications.
The-requirements that will reside in the UFSAR for the turbine overspeed protection system will ensure that the system remains capable of protecting against excessive I
turbine overspeed.
Therefore, the proposed changes will not involve a significant reduction in any margins of safety.
V.
CONCLUSIONS Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.
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