ML20083B959

Application for Amend to App a of License NPF-57,increasing Annual Operational Limit for Drywell & Suppression Chamber Purge Sys from 120 H to 500 H

ML20083B959
Person / Time
Site:	Hope Creek
Issue date:	05/04/1995
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20083B961	List: ML20083B959 ML20083C171
References
LCR-94-32, LR-N95036, NUDOCS 9505150026
Download: ML20083B959 (8)

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• 6 Pubhc Service Dectric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 -

Vee President Nochar Operations MAY 041995 LR-N95036 i LCR 94-32 l l

United States Nuclear Regulatory Commission '

Document Control Desk Washington, DC 20555 Gentlemen:

LICENSE AMENDMENT APPLICATION EXTENSION OF CONTAINIENT VENT AND PURGE VALVE OPERATION HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 l

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 change contained herein represent changes to Section 3/4.6.1.8 "Drywell and Suppression Chamber Purge System." This submittal increases the annual operational limit for the drywell and suppression chamber purge system from 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> to 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />.

The proposed change has 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 change, 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.

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.

120033 9505150026 950504 ..

PDR ADOCK 05000354 n P PDR (

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MAY 041995  :

Document' Control Desk .LR-N95036- l Should you have any questions regarding this request, we.will be l pleased to discuss them with you.

i Sincerely, t i

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. Affidavit  !

. Attachments (2) i C Mr. T. T. Martin, Administrator - Region I i U. S. Nuclear Regulatory Commission l 475 Allendale Road i King of Prussia, PA 19406 l Mr. D. Moran, Licensing Project Manager - Hope Creek j U. S. Nuclear Regulatory Commission -l One White Flint North 11555 Rockville Pike ]

Mail stop 14E21 l Rockville, MD 20852

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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

95-4933 l l J

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1 REF: LR-N95036. 1

.i t LCR 94-32 .i STATE OF NEW JERSEY-) l

') SS l COUNTY ~OF' SALEM ~) {

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J. J.'Hagan, being duly sworn _according to law deposes and says:

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I am Vice President - Nuclear Operations of Public Service' Electric l and Gas Company, and as such, I find the matters set forth in the f above . referenced letter, concerning the Hope Creek Generating l

Station, are true to the best of my knowledge, information and I belief.  !

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i subscri ed and Sworn to before me I this'/ db day of h L A ' , 1995 U j 1

I l A'10 . .N bW1A NbtaryPubl[c[$fkewJersey l I

KIMBERLY Jo gyngy l My Commission expires on u,cffPUBUC 0f NEWJERSEy  !

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p ATTACHMENT 1 i PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS LICENSE AMENDMENT APPLICATION '

EXTENSION OF CONTAINMENT VENT AND PURGE VALVE OPERATION HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 . LR-N95036 DOCKET NO. 50-354 LCR 94-32 L I. DESCRIPTION OF THE PROPOSED CHANGE This amendment revises Specification 3/4.6.1.6 "Drywell and Suppression Chamber Purge System" and its associated Bases section by extending the annual 120 hour0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> operational limit to i 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />. i l

4 II. REASONS FOR THE CHANGE The proposed change to the Technical Specifications will provide additional operating flexibility. During the year 1994, Hope Creek required the services of the drywell and-suppression chamber purge system on a number of occasions (e.g., the 1994 refueling outage, the recirculation pump seal ,

replacement, etc.). Total purge system operation reached 116 l hours by the month of October leaving only four hours for the ,

next inerting/deinerting cycle, containment and/or suppression chamber purge, or operation of the containment prepurge '

cleanup system (CPCS). The added 380 hours0.0044 days <br />0.106 hours <br />6.283069e-4 weeks <br />1.4459e-4 months <br /> will help obviate similar situations.

i III. JUSTIFICATION FOR CHANGE The limit on containment vent / purge valve operations is intended to reduce the probability of a LOCA occurrence when these valves are open providing a potential pathway to the i environment for radiological effluents. NRC guidance on this  :

issue is provided in Standard Review Plan (SRP) S6.2.4

" Containment Isolation System" and supplemented by a Containment Systems Branch (CSB) technical position CSB 6-4

" Containment Purging During Normal Plant Operations."

For plants under construction prior to July 1, 1975 a provision was made in SRP S6.2.4, regarding the size of the purge system used during normal plant operation and the need for justification of the system size by acceptable dose consequence analysis, to allow a waiver of these branch technical positions if the applicant committed to a 90 hour0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> i per year operating limit. This limit would apply while a plant is in the startup, power, hot standby or hot shutdown modes of operation. However, in Generic Letter (GL) 83-02 the

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ATTACHMENT 1 LR-N95036

-EXTENSION OF CONTAINMENT VENT AND LCR 94-32 1 PURGE VALVE OPERATION l i

NRC granted that the " allowable time period in each year for  !

purge / vent operation at each plant will be considered on a  !

case-by-case basis." [

Such variances to the allowable operating limit ' for the s containment purge system could be based on plant specific ..

equipment configurations, site meteorology, radiological source term for the reactor type, etc. San Onofre had a limit  ;

of 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> while Perry extended their limit to 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> of purge operation. The NRC acknowledged in BTP CSB 6-4 that

" containment purge and vent systems provide plant operation  ;

flexibility . . . " and that "the need for purging has not always been anticipated in the design of plants...." However, the NRC has also taken the position that " plant designs must not I rely on their use on a routine basis" and that large  ;

containment purge and vent lines (e.g. , 42 inches in diameter) i "should be restricted to cold shutdown conditions and  :

refueling operations and they must be sealed closed in all i other operational modes."

The resulting definitive point of BTP CSB 6-4 regarding the -

design and use of containment purge systems, on a nonroutine  ;

basis, is that:  :

"in the event of a loss-of-coolant accident, assuming the i purge valves are open and subsequently close, the >

radiological consequences calculated in accordance with l Regulatory Guide 1.3 and 1.4 would not exceed the 10 CFR '

Part 100 guideline values. Also, the maximum time for valve closure should not exceed five seconds to assure that the purge valves would be closed before the onset of [

fuel failures following a LOCA."

To determine the allowable time period for operating the drywell and suppression chamber purge system a probabilistic risk assessment (PRA) was performed (Reference 1). This  !

analysis ascertained the existing purge system operating' l margin while remaining within the scope of established LOCA  !

analyses (i.e., no changes to previously estimated LOCA doses for the control room, exclusion area boundary, or low i population zone boundary). r i

The PRA analysis determined the allowable increase in purge  !

system operations without increasing the possibility of a release due to a large break LOCA during such operations.

Considering only the pipe break event (i . e . , no fuel damage) the analysis indicated an allowable operating limit of 178 hours0.00206 days <br />0.0494 hours <br />2.943122e-4 weeks <br />6.7729e-5 months <br /> per year. This increase of 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> for containment '

purge system operation would still limit the possibility of  ;

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n ATTACHMENT 1 LR-N95036 EXTENSION OF CONTAINMENT VENT AND LCR 94-32 PURGE VALVE OPERATION any releases due to a large reactor coolant pressure boundary breach within the containment to less than 1.0E-07.

'The analysis was then extended to take into account the probability of fuel failure coincident with a large break LOCA, in this case the release of the entire gas gap activity.

T"e constraint of 1.0E-07 or less for the probability of mission products being released was retained.

The results of this analysis indicate that the operating limit for the drywell and suppression chamber purge system can be increased to 4589 hours0.0531 days <br />1.275 hours <br />0.00759 weeks <br />0.00175 months <br /> per year without increasing the possibility of a release with associated core damage that would exceed 10CFR100 limits. This analysis assumes the use of only one supply (inlet) line and one exhaust (vent) line as recommended in BTP CSB 6-4 acceptance criterion B.1.b and agreed to by PSE&G during the implementation of Amendment 16, approved by SER dated March 30, 1988, which permitted operation of the drywell and suppression chamber purge system up to a limit of 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> per year.

Therefore, PSE&G's request for an operating limit of 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> per year, approximately 10% of the PRA value, would provide sufficient operating flexibility while retaining a wide margin of conservatism. In addition, any resulting releases from a LOCA which occurs while these valves are open will remain bounded by the current LOCA analyses. Finally, considering the double barrier design of the purge system, to meet General Design Criterion 54, any single active component failure (i.e. , a purge valve f ails open) during a LOCA coincident with a safe shutdown earthquake would continue to meet the recom-mendations of BTP CSB 6-4.

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 change:

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

The proposed change involves no hardware changes and no changes to existing structures. Increasing the annual operational limit of the drywell and suppression chamber purge system will not increase the probability of a loss-

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LR-N95036. l F

EETENSION OF CONTAINNENT VENT AND LCR 94-32 -l' PURGE VALVE OPERATION' i

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of-coolant accident. While increased usage of the purge system will result in a slight increase in the possibility - l that these valves will be open during a LOCA, it will not? j alter or impact previous LOCA analyses.. l t

2. Will not create the possibility of a new or different kind.  !

of accident _from any previously evaluated.

.j The proposed change. will ;not result in an unanalyzed  !

condition. ..While the increase in purge system operation .I will slightly increase the possibility of the containment ,

vent and purge valves being.open at the onset of a-LOCA l event, the valves have been - established as. capable . of  ;

isolating the' containment within five seconds. This'is L well within the bounds of existing LOCA analyses which -;

assume an open duration of 175 seconds. Therefore, this 1 change will not require a new or different accident analysis. .

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

The proposed change will not alter existing systems, i equipment, . . components, or structures. ..The method _ of _;

operating the drywell and suppression chamber purge system  !

will not be altered by the increased annual usage. While- I there is a slight increase in the possibility of purge l operations at the anset of a LOCA, any resulting release would be insignificant and bounded by existing .LOCA ,

analyses. Operation of the drywell and suppression _i chamber purge system based on these proposed change will'  ;

remain within the guidance provided in- the NRC's Branch l Technical Position CSB 6-4.

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V. CONCLUSIONS J l

Based on the above,.PSE&G has determined that the proposed .l change does not involve a significant hazards consideration, j VI. REFERENCES 1 1

1. PSE&G Memorandum, J.F. Scott to W.D. Pon, dated '

November 30, 1994, (SCI-94-0833) " Assessment of the HCGS '

Technical Specification 3/4.6.1.8" l

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ATTACHMENT 2 TECHNICAL SPECIFICATION PAGES WITH PEN AND INK CHANGES LICENSE. AMENDMENT APPLICATION EXTENSION OF CONTAINMENT VENT AND PURGE VALVE OPERATION HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 LR-N95036 DOCKET NO. 50-354 LCR 94-32 i The following Technical Specifications for Facility Operating [

License No. NPF-57 are affected by this License Amendment Request:

Technical Soecification Pace 3/4.6.1.8 3/4 6-11  ;

B 3/4.6,1.8 B 3/4 6-2 .

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