ML20078C814

Application for Amend to License NPF-57,to Revise Surveillance Requirement 4.1.3.1.2.b Re CR Immovable as Result of Excessive Friction or Mechanical Interference

ML20078C814
Person / Time
Site:	Hope Creek
Issue date:	01/20/1995
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20078C817	List: ML20078C814 ML20078C830
References
LCR-94-33, NLR-N94233, NUDOCS 9501270116
Download: ML20078C814 (6)

Text

... . -. --

4 Pubhc Service Electrc and Gas j Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 2M. Hancocks Bndge, NJ 08038 609-339-1200 ve...,. . u . o-.

JAN 2 01995 i'

NLR-N94233 i LCR 94-33 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LICENSE AMENDMENT APPLICATION REVISION OF CONTROL ROD MOVEMENT TEST REQUIREMENT HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 j DOCKET NO. 50-354 1 This Jetter 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 cent to the State of New Jersey.

The proposed Technical Specification change contained herein represents a change to Section 3/4.1.3 " Control Rods." This submittal revises surveillance requirement 4.1.3.1.2.b for when a control rod is immovable because of excessive friction or mechanical interference. The other control rods shall be tested within twenty four hours and every seven days thereaf ter as opposed to the current requirement of testing every twenty four hours.

l The proposed change has been evaluated in accordance with 1 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 change, and the basis for a no significant hazards consideration determination are provided in Attachment 1.

The Technical Specification page affected by the proposed change is provided in Attachment 2 with pen and ink changes.

260022 9501270116 950120 PDR ADOCK 05000354 .

PDR '

P {,

l 1

7 i * .

I '

j .

JAN 2 01995  !

! Document Control Des;  ;

NLR-N94233 -

l l 4

l 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 -

i associated administrative activities.

i l Should you have any questions regarding this request, we will be l pleased to discuss them with you.

i

! l Since ely, j l

! e: )

l J. ag ul l Vice resndent  !

i l Nucle erations J l i

t l

I Affidavit Attachments (2) l C Mr. T. T. Martin, Administrator - Region I i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 3

Mr. D. Moran, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White. Flint North

! 11555 Rockville Pike i Rockville, MD 20852 ,

1 i

l Mr. R. Summers (SO9)

USNRC Senior Resident Inspector l i Mr. K. Tosch, Manager IV l NJ Department of Environmental Protection 4 Division of Environmental Quality l Bureau of Nuclear Engineering j CN 415 Trentua, NJ 08625 i

k j

i y - - - , -,

i

• I l .

i -

l REF: NLR-N94233 l LCR 94-33 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 Compeny, 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.

1 l

/ I Subscribed and or to before me this h day 1124/hb .1995 V b d o m iu A J, m- , -

cu m .

No,tary Public f New Jersey KlMBERLY JO BROWN NOTARY PUBLIC Of NEW JERSEY My Commission expires on H is a W 21, m

l i

l ATTACHMENT 1 PROPOSED CHANGES TO TECHNICAL SPEC.;FICATIONS t

LICENSE AMENDMENT APPLICATION REVISION OF CONTROL ROD MOVEMENT TEST REQUIREMENT HOPE CREEK GENERATING STATION l FACILITY OPERATING LICENSE NPF-57 NLR-N94233 l DOCKET NO. 50-354 LCR 94-33 D I

I. DESCRIPTION OF THE PROPOSED CHANGE  ;

l This amendment revises Surveillance Requirement 4.1.3.1.2.b by I replacing the words "At least once per" with "Within."

l i

II. REASONS FOR THE CHANGE The proposed change to the Technical Specifications is 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 recommendation regarding the frequency of subsequent

, control rod movement tests when a control rod is found l immovable as a result of excessive friction or mechanical interference.

l l

l l III. JUSTIFICATION FOR CHANGE The control rods provide negative reactivity for controlling reactor operations and are capable of rapidly establishing a subcritical configuration (e . g . , during power transients).

The intent of the control rod movement test is to provide confirmation of cperability for all withdrawn control rods.

The current Hope Creek Surveillance Requirement calls for the performance of a movement test for all withdrawn control rods every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if any control rod is determined to be

immovable due to excessive friction or mechanical interference. This surveillance would require a significant allocation of plant resources.

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 thi s 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 amour.

of testing that the Technical Specificatione require during power operation.

l l

I

NTTACEMENT 1 NLR-N94233 REVISION OF CONTROL ROD LCR 94-33 MOVEMENT TEST REQUIREMENT One of the recommendations in GL 93-05 was the extension of control rod movement tests from daily to weekly when any control rod is found immovable due to excessive friction or mechanical interference. This recommendation was discussed-further in NUREG-1366 " Improvements to Technical Specifications Surveillance Requirements," dated December 1992. The NRC's findings, which included 7 review of the Nuclear Plant Reliability Data System (NPRLv), was that the control rod movement tests took a significant amount of time and personnel resources to perform. Also, a search using NPRDS failed to find a single situation in which an immovable control rod was discovered as a result of this test.

Based upon these findings, the NRC concluded that the control rod movement test frequency for all withdrawn rods could be extended without reducing safety while decreasing equipment degradation and removing unnecessary burdens on personnel resources. The initial movement test would be required within twenty four hours after a control rod had been determined immovable due to excessive friction or mechanical interference. Subsequent control rod movement tests would then be performed every seven days.

Considering the NRC's aforementioned position and the associated benefits, PSE&G believes that the propcsed change is justifiable. Based upon a review of Surveillance Requirement results for the past 3 years for control rod movement tests, PSE&G concludes that the proposed change is compatible with plant operating experience and is consistent with the guidance provided by Generic Letter 93-05.

IV. DETERMINATION OF NO SIGNTFICANT 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 j accordance with the proposed change: i l

1. Will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change involves no hardware changes, no '

changes to the operation of any syctems or components, and I no changes to existing structures. The revision of the 1 control rod movement test frequency represents a change that does not affect plant safety and does not alter existing accident analyses. I 1

l i .

~

! ATTACHMELf 1 NLR-N94233 l REVISION OF CONTROL ROD LCR 94-33 l MOVEMENT TEST REQUIREMENT ,

i I

l

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

The proposed change is procedural in nature concerning the frequency of control rod movement tests for all withdrawn control rods af ter a control red has been determined to be immovable due to excessive friction or mechanical interference. The methodology for determining additional immovable control rods remain unchanged. The proposed change while slightly increasing the possibility of an undetected immovable control rod 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 change is in accordance with recommendations provided by the NRC regarding the improvement of Technical Specifications. This change 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 .

change does not involve a significant hazards consideration. I 4