ML20082C117
| ML20082C117 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 03/30/1995 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20082C121 | List: |
| References | |
| LCR-94-36, LR-N95040, NUDOCS 9504060167 | |
| Download: ML20082C117 (13) | |
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. Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge. NJ 08038 609-339-1200 Vee Pmvient - Nucear Operations MAR 3 01995 LR-N95040 LCR 94-36 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDMENT APPLICATION ELIMINATION OF SELECTED TESPONSE TIME TESTING REQUIREMENTS FACILITY OPERATING LICENiE NPF-57 HOPE CREEK GENERATING S7 ATION 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 involve elimination of selected response time testing requirements from Technical Specifications and associated Bases changes. Specifically, the response time testing (RTT) requirements to be eliminated include the entire instrumentation loops for the Emergency Core Cooling System and Isolation Actuation System (except Main Steam Isolation Valve actuation and radiation loops for Secondary Containment Isolation). Also proposed for elimination are the sensor RTTs for selected Reactor Protection System signals and the Main Steam Isolation Valve (MSIV) 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 hazard consideration pursuant to 10CFR50.92. The proposed Technical Specification changes are supported by the analysis performed by the Boiling Water Reactor Owners' Group (BWROG) and documented in General Electric (GE) Licensing Topical Report (LTR) NEDO-32291, " System Analyses for Elimination of Selected Response Time Testing Requirements" (Reference 1),
demonstrating that other periodic tests required by Technical Specifications, such as channel calibrations, channel checks, channel functional tests, and logic system functional tests ensure that instrument response times are within acceptable limits. The applicability of the referenced analysis to the 9504060167 950330 PDR l
P ADOCK 05000354 U uvv __ PDR -
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Document Centrol Desk 2 MAR 3 01995 LR-N95040 l
l Hope Creek Generating Station has been verified. An NRC Safety Evaluation Report (SER), approving the GE LTR NEDO-32291, was issued on December 28, 1994. Attachment 2 contains marked up Technical Specification pages which reflect the proposed changes.
I As these changes reflect NRC approved, generic changes contained in the LTR, PSE&G believes that a detailed NRC branch review or specialist review should not be required.
Although the NRC's SER does not specifically approve RTT elimination for " Main Steam Line Flow - High (MSIV Closure) ", the i GE LTR NEDO-32291 does support this RTT elimination. Mr. T. A.
l Green of GE discussed this issue with Mr. Paul Loeser of the NRC in a telecon on February 10, 1995 (Reference 5). HCGS is proposing to eliminate the " Main Steam Line Flow - High" sensor RTT. ,
f In response to the NRC Cost Beneficial Licensing Action (CBLA) initiative, 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 change would yield a cost savings of approximately $45,000/yr and $1,395,000 over the life of HCGS.
Also, an amendment request for HCGS submitted on November 30, 1994, " Relocation of TS Tables on Instrument Response Line Limits," stated that PSE&G intended to take advantage of NEDO-32291 upon its approval by the NRC. This amendment request takes advantage of those changes. Because both amendment requests affect the same Technical Specifications, it is requested that they be processed together.
l Upon NRC approval, requested by May 31, 1995, please issue a
! license amendment which will be effective upon issuance and shall be implemented within 60 days 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,
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-1 Documen't Control Desk 3 LR-95040 l MAR f 01995 Affidavit Attachments (2)
LMK/kjb C Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Moran, Licensing Project Manager US Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. R. Summers (SO9)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager IV NJ Department ofLFnirironmental Protection Division of Environtmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 1
e REF: LR-N95040 LCR 94-36 n
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. ,
bn y ;
Subscribed a before me this CD g d Sworn-
' day of [dAMA .
, 1995 le,laxh4 . 01 x m '
N'opary Publ#c Ned-~Jersiey
!. NOTARY PUBLIC 0F NEW JERSEY My Commission expires on My Commission Expires AprB 21,1998 1
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. ATTACHMENT 1 l
. PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS LICENSE' AMENDMENT APPLICATION !
i' ELIMINATION OF. SELECTED RESPONSE TIME TESTING REQUIREMENTS l HOPE t'name GENERATING STATION FACILITY OPERATING LICENSE NPF-57 LR-N95040 t DOCKET NO. 50-354 ICR 94-36 I. DESCRIPTION OF THE PROPOSED CHANGES These proposed changes are to eliminate select'ed response time testing requirements from Technical Specifications and reflect these changes in the associated Bases.
Specifically, the response time testing (RTT) requirements to be eliminated include the entire instrumentation loops for Emergency Core Cooling System and-the Isolation i Actuation System (except Main Steam Isolation Valve actuation and radiation lonos for Secondary Containment i Isolation). Also proposes for elimination are the sensor RTTs for selected Reactor Protection System signals and the '
Main Steam Isolation Valve (MSIV) actuation instrumentation.
n These proposed changes would also remove those Isolation Actuation System response time limits that correspond to the l l diesel generator start and sequencing times. The diesel generator start and sequencing of loads is tested in accordance with. Surveillance Requirement 4.8.1.1.2.h.4.b.
This change is in accordance with the recommendations for changes identified in item 5.9 of-Generic Letter 93-05. T II. REASON FOR THE PROPOSED CHANGES The BWROG evaluation, GL 93-05, and NUREG-1366 confirm that response time tests are of no safety significance-and cause unnecessary personnel exposure,. reduce availability of safety systems during shutdown and are a significant burden to utility resources. ;
III. JUSTIFICATION FOR THE PROPOSED CHANGES An analysis has been performed by the BWROG (Reference 1) demonstrating that other periodic tests required by .
Technical Specifications, such as channel calibrations, channel checks, channel functional tests, and logic system functional tests provide adequate assurance that instrument response times are within acceptance limits.
The Reference 1 evaluations demonstrate that response time
- testing can be eliminated for the following
- 1) All Emergency Core Cooling System instrument loops;
- 2) All Isolation System actuation instrument loops except for main steam line isolation valves i
9l . .
' Attachment-1 .
LCR 94-36
- Elimination of Selected-Response Time LR-N95040 Testing Requirements (MSIVs);
- 3) Sensors'for. selected Reactor Protection System actuation; and
- 4) -Sensors for MSIV closure actuation.
Regulatory Guide 1.118.(Revision 2) states:
" Response time testing of all safety.related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety equipment is ,
verified by. functional testing, calibration checks or other tests, or both. This is acceptable.if it.can be i demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine tests."
The analysis in Reference 1 was performed for two representative BWRs, and its applicability to Hope Creek Generating Station (HCGS) has been. verified. The confirmation of the applicability of the generic analyses to Hope Creek is based upon the-following:
- 1. PSE&G has maintained its participation and. involvement .I on the BWR Owners Group Response Time Testing Committee n thereby assuring that the development of this generic .
! report encompassed the Hope Creek Generating Station.
- 2. PSE&G has reviewed the applicable GE LTR, NEDO-32291,
" System Analyses for Elimination of Selected Response Time Testing Requirements," and verified its applicability to the Hope. Creek Generating Station.
The analysis includes the identification of potential failure modes of components in the affected instrumentation loops which could potentially impact the instrument loop response time. . In addition, plant operating experiences were reviewed to identify response time failures and how they were detected. The failure modes identified were then evaluated to determine if the effect on response time would be detected by other testing requirements contained in '
Technical Specifications. No response time test failures have been experienced at HCGS.
L The results of the analysis demonstrate that other Technical j Specification testing requirements (channel calibration, 1 channel check, channel functional test, and logic system )
functional test)' ensure that instrument response times are l
- within acceptable limits.
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'e<, Attachment'1 LCR 94-36 lFlimination of Selected Response Time
- LR-N95040 Testing Requirements These other tests are normally sufficient to identify failure modes.or degradations in instrument response time and assure' operation of the analyzed instrument loops within
- acceptance limits.. Furthermore, there are no known failure <
modes-that can be. detected by response time testing.that~
cannot also be detected by other Technical Specification tests.=
A BWROG survey has. concluded that instrument response-time delays of 5 seconds can be reasonably detected by instrument- i technicians. A= safety avaation (Reference 1, Appendix J) has confirmed that. delays of individual specific trip functions of a few seconds have very~1ow safety significance. This realistic bases evaluation showed that a good deal of margin exists in the licensing analysis.
. Within a trip function, redundancy exists in the form of individual instrument channels'(e.g., 1 out of'2 twice) or system redundancy (e.g., more than one train capable of
- performing.the same function) and diversity. exists in most safety trip functions (e.g., neutron flux, water level, drywell pressure) . Also, for most of these instruments the '
response nimes are insignificant compared to the safety system actuation times.
Therefore, elimination of response time testing for the following is justified:-
3 1) All Emergency Core Cooling System instrumentation loops;
- 2) All Isolation System actuation instrumentation loops ,
except for main steam line isolation valves (MSIVs);
- 3) Sensors for selected Reactor Protection System actuation; and
- 4) Sensors for MSIV closure' actuation.
The NRC Safe ty Evaluation Report (Reference 2) concluded j that the astiociated GE LTR (Reference 1) provided an i acceptable 'aasis for the elimination of the response time
, testing as listed above, with the exception of " Main Steam Line Flow - High (MSIV Closure)." This issue was discussed i
in a to'. econ between Mr. T. A. Green (GE) and Mr. Paul '
Iceser (USNRC) (Reference 5). PSE&G feels that sufficient I justification for its elimination was provided in the GE LTR NEDO-32291 and in this submittal. Therefore, PSE&G is requesting elimination of response time testing-for " Main Steam Line Flow - HighL(MSIV Closure)."
The NRC's SER (Reference 2) required that the following statements be made. The actions taken by PSE&G to satisfy each of these statements are also described.
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N Atttchment0 1". .
LCR 94-36 Erisinaticn ~ of: Colectcd R0cponco Time LR-N95040.
M* Testing' Requirements
'PSE&G'does' follow the~ recommendations from EPRI NP-7243
. " Investigation of Response Time Testing Requirements" and therefore is requiring the following action:'
(a)~ Request: . Prior to installation of~a new' _.
transmitter / switch or'following refurbishment of a
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transmitter / switch (e.g. , sensor cell or variable '
a damping components), a hydraulic RTT shall'be performed to determine an initial sensor-specific response time' value. ,
Response: This requirement is ensured by an administrative procedure which requires a hydraulic RTT' be performed following replacement-or partial ~ rework of
- a. transmitter / switch. This procedure is controlled by +
the Administrative Section'of the HCGS Technical' Specifications.
(b) Request: For transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initial installation and after any maintenance or modification activity that could damage
- the lines.. >
Response: This statement is not applicable'to HCGS.'
- There are no. transmitters or switches.that'use capillary tubes for which PSE&G is requesting elimination of RTT.
In addition, PSE&G addresses the remaining SER requirements as follows:
(a) Request: That calibration is being done-with equipment designed to provide a step function or fast ramp in the process variable.
Response: Steps will be added to the calibration
. procedures to ensure the following. For transmitters, I&c Maintenance technicians increase the input process variable to 100% of the calibrated span using air pressure. Then the pressure is relieved nearly instantaneously to 0% by opening the bleed valve and simultaneously monitoring the' sensor output. For the
~
trip. unit, a potentiometer is used to simulate the input process variable which, when it traverses the.
setpoint, nearly instantaneously' yields an output function.
. (b) Request: That provisions have been made to ensure that operators and technicians are aware of the consequences of instrument response time degradation, aad that applicable procedures have been reviewed t.nd revised.as necessary to assure that technicians moni cor for response time degradation during the performance of I calibrations and functional tests.
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1 AttCchment l' .
LCR 94 ?" El'icin0tien of 831ected RocponSo Time = LR-N95040. )
1 Tooting Rcquircaento !
. Responses Consequences of instrument response time B 3 degradation will be incorporated into the 1994/1995:
Licensed Operator Requalification cycle. Coverage willi
-include a lab assignment' utilizing.a-control loop to enhance understanding.
The Hope. Creek Controls Technicians training program-presently includes instruction on the consequences of
. instrument response time degradation, and the need to monitor for response time degradation during the performance of calibrations and functional tests. The training program will be' enhanced to include the new procedure requirement to simultaneously monitor both the input signal and the output trip. functions of the unit under test and to include the importance that communication plays in ensuring response. time degradation is properly identified. Continuing training will be held for all Hope' Creek Controls Technicians currently' qualified to perform surveillance testing to ensure they are trained on the new '
commitments.
A note will be added to affected Channel Calibration and Fanctional Test procedures that requires the input-signal and.the output trip functions to be monitored simultaneously to ensdre that'the trip unit performance ,
has not degraded and that good communication and coordination is used if-more than one person is required to perform the test.
To ensure that the calibration / functional testing effectively establishes acceptable instrumentation performance in lieu of a specific RTT, the following features will be included:
- By inputting a standard value over the operating range, the technician can observe.any abnormal changes in' calibration / functional span and operational range of the instrumentation.
- By observing the expected output when an input signal is injected, the technician can determine.
that the instrumentation is responding properly.
- By checking calibration / functional points between zero and 100% of calibrated span, 4
the technician ensures that the instrumentation responds instantaneously with the injection of a test signal and, the technician ensures the instrumentation performs in accordance with the instruments' 4
design characteristics (i.e., linear or logarithmic).
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'Att:chment 1, .. ..
} ICR 94-36
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Eficinttien ofjColectcd R0cponSo Time. LR-N95040-
- Testing Requirements-By' observing the response from 'a trip signal
. initiated during'a functional test, the technician
~
is able to detect a response time delay in the
[ actuation'of an alarm, light, or relay contacti status.
'The above (*)' statements are either expected skills of maintenance technicians, currently covered in HCGS procedures, to be incorporated into HCGS procedures,.or to be incorporated in~ initial and recurring maintenance technician training before implementing this change.
(c) Request: That surveillance' testing procedures have been-reviewed and' revised if necessary to ensure calibrations and functional tests are being performed in a manner that allows simultaneous monitoring.of both the input and output response of units under test,.
Response: To simultaneously monitor )oth the input signal and output response of the units under test, a sign-off step will be added to applicable procedures that.says the input signal and output trip functions ,
appear to occur at the same time. To ensure an evaluation of the affected loop components that exhibit degraded response time during calibration and .
functional tests would be, performed before the loop is returned to service, a step of this nature'will be addedLto the appropriate procedures.
(d) Request: That for any request involving the elimination of RTT for Rosemount pressure transmitters, PSE&G'is~in full compliance with the' guidelines of Supplement 1 to Bulletin 90-01, " Loss of Fill-Oil in "
Transmitters Manufactured by Rosemount."
Response: .In an NRC SER, dated December 2, 1994, the i
NRC confirms that Hope Creek-Generating Station has satisfied the requested actions of NRC Bulletin 90-01, Supplement 1.
(e) Request: That for those instruments where the n manufacturer recommends periodic RTT as well as
, calibration to ensure correct function', PSE&G has ensured that elimination of RTT is nevertheless acceptable for the particular application.
Response: This statement is not applicable to HCGS.
There are no instruments for which PSE&G is requesting p elimination of RTT, where the manufacturer recommends periodic RTT as well as calibration to ensure correct
! function.
l The above statements are justification that PSE&G can meet l o the NRC requested commitments and that the requested '
l elimination of selected response time testing is justified.
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Atthchment'1. . . LCR 94 EliainttiCn of S31ccted Rscponco Time LR-N95040 TestingLRequirements
. , .The following is.justificationffor elimination of Isolation i
. Actuation System instrumentation response time: limits.that correspond to the diesel ~ generator start and sequencing of-loads. Safety analyses. assume that instrument channel actuation for non-MSIV channels occurs simultaneously with .
diesel start and sequencing. Therefore, the chance is l remote that a channel's response; time.(that is typically less than a second) would degrade to the point where it. i exceeds'the 13.second diesel start.ti.is'without a failure i that would be detectable in other ways.
This testing has the potential to increase the risk of plant' trips and equipment damage due-to the large number of lifted leads, jumpers,-and pulled fuses required to simulate the necessary system conditions. These conditions create a significant increase ~in the potential for errors. .
Additionally, to satisfy the non-MSIV isolation system response time testing requirements, extensive staff-hours are expended during each refueling outage without a
- commensurate gain in safety.
Industry research has determined that failures and degradation which could affect response time in these systems are normally detected through calibrations, functional tests, logic system functional tests, and channel checks. Therefore, HCGS proposes to eliminate response time testing of isolation actuation system instrumentation where l the required response time corresponds to the diesel-start .;
j and sequencing time. j IV. SIGNIFICANT HAZARDS CONSIDERATION EVAIDATION -j 4 PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed .
amendment to determine whether the request involves a l 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 purpose of the proposed Technical Specification change is to eliminate response time testing ,
requirements for selected instrumentation'in the !
Reactor Protection System, Isolation System, and I Emergency Core Cooling System. However, because of the l continued application of other existing Technical i specification requirements such as channel l calibrations, channel checks, channel functional tests, and logic system functional tests, the response time of l these systems will be maintained within the acceptance limits assumed in plant safety analyses and required i for successful mitigation of an initiating event. The ,
proposed Technical Specification changes do not affect the capability of the associated systems to perform 1 Page 7 of 9 i
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'Ai;thchment l' .
LCR 94-36
'Elicinatien.of Solcctcd R3cpon 3 Tiao- LR-N95040' LTesting Requirements *
- their intended function within their required response.
time.
The BWR Owners' Group has completed an evaluatibn (NEDO-32291, " System Analyses for the Elimination of Selected Response Time Testing Requirements") which1 demonstrates that response time testing is redundant to
-the other Technical Specification requirements listed in the preceding paragraph. These other tests are sufficient to identify failure modes or degradation in instruments response time and ensure operation of the associated systems within acceptance limits. There are no known failure modes that can be detected by response time. testing that cannot be detected by the other Technical Specification tests. Hope Creek ~ Generating Station is specifically bounded by the assumptions and justifications in General Electric Company Licensing Topical Report, NEDO-32291, " System Analyses for Elimination of Selected Response Time Testing Requirements.".
- 2. Will not create the possibility of a new or different kind of accident from any accident previously
, evaluated.
As discussed above, the proposed Technical Specification changes do not affect the capability of the associated systems to perform their intended function within the acceptance limits assumed in plant r safety analyses and required for successful mitigation
- of an initiating event. The proposed elimination of
- response time testing would not result in any.new-equipment, operating modes, or plant configurations.
- 3. Will not involve a significant reduction in.a margin of safety.
The current Technical Specification response times are based on the maximum allowable values assumed in the plant safety analyses. These analyses conservatively establish the margin of safety. As described above,.
the proposed Technical Specification changes do not affect the capability of the associated systems to perform their. intended functions within the allowed response time used as the basis for the plant safety analyses. Plant and system response to an initiating event will remain in compliance within the assumptions of the safety analyses, and therefore the margin of safety is not affected.
Although not explicitly' evaluated, the proposed Technical Specification changes will provide an improvement to plant safety and operation by:
a) Reducing the time safety systems are unavailable Page 8 of 9
jI, l LAttRchment 1
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LOR 94-36 -
. El'icinaticn of SalCctect R2cpan2e Time
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.LR-N95040 Testing Requirements j b) . Reducing safety system actuations ;
a .
I c)' Reducing shutdown risk
, d) ' Limiting radiation exposure to plant personnel a) Eliminating the diversion'of key personnel to conduct unnecessary testing.
. Y. CONCLUSION As discussed above, PSEEG 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.
i.
VI. REFERENCES
- 1. NEDO-32291, " System Analyses for the Elimination of Selected Response Time Testing Requirements", January 1994.
dated December 28, 1994 (transmits NRC safety >
evaluation report from NEDO-32291).
- 3. Generic Letter (GL) 93-05, "Line-item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation," Dated September 27,-1993.
- 4. NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements,"' dated December 1992.
- 5. Letter to P. J. Loeser (USNRC) from T. A. Green (BWROG), dated February 10, 1995 (Request for Revision of NRC Safety Evaluation Report).
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