ML20086G534
| ML20086G534 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/25/1991 |
| From: | Public Service Enterprise Group |
| To: | |
| Shared Package | |
| ML20086G503 | List: |
| References | |
| NLR-N91199, NUDOCS 9112050146 | |
| Download: ML20086G534 (7) | |
Text
b HOPE CREEK GENERATING' STATION
'4 l +5 UNITED STATES NUCLEAR RLGULATORY COMMISSION l
In the Matter of Public Service actric-and Gas Company Docket No. 50-354 Hope Creek Generating Station APPLICATION FOR AMENDMENT TO 7
OPERATING LICENSE Pursuant-to Section 50.90 of the Regulations of the Nuclear Regulatory Commission.- Public Service Electric and Gas, holder of Facility Operating
. License No. NPF 57 hereby requests the Technical Specifications, set forth in Appendix A to the-license, be amended to permit an increase in the allowable leak rate for_ the main steam isolation valves (MSIVs) _and deletion of the Technical-Specification requirements for.the MSIV__ Sealing System.
Specifically,.PSE&G requests that:-
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Allowable leak rate specified -in the Technical Specifications Section 3.6.1.2 be changed from 46.0 total. standard cubic foot per hour -
(sefh) to 200 scfh per_ main steam line.
This. proposed change reflects a-higher, but still conservative allowable leak rate for the MSIVs.
5-k p [050146 9j2u,3 fiDOCK 03000354 PDR
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y HOPE CREEK GENERATING STATION 2.
Section~3,6.1.2a to be administratively amended to add a footnote exempting MSly leakages from the overall integrated leakage rate, in
-concurrence with this application for. license. amendment, PSE&G has applied for-- specific exemption _to Appendix J of 10CFR50.
3.
Sections 3.6.1.4 and Bases 3/4.6.1.4 be amended to permit the deletion of the MSly Sealing Sptem from the Technical ulternate to Regulatory Guide 9ecifications.
PSE&G propoF i
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v lve Leakage Control. Systems 1.96, " Design of Main Ster-- '
- o. n t a
ints."
Utilization of the I
for Boiling Water Reactor main stean lines and condense e
nate method for MSly leakage treatment, has been e.
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+ more effective than the leakage control systems in-tc W ity,
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4.
Table 3.6.31 be ' amended to permit the deletion of the MSIV Sealing System valves from the Technical Specifications.
S.
The index, Section 3.6.1.4 and 4.6.1.4 and Bases 3/4.6.1.4 be administratively amended to rearrange section and page numbering.
The proposed changes to the Technical Specifications are: set forth in.
The proposed changes are a result-of the extensive work performed by the BWR
-Owners' Group _. (BWROG)-in support of the resolution of Generic Issue C-8 "MSIV -
L.eakage and LCS-Failure". -GE report NEDC-31858P Rev. I provides technical
-justification on a generic basis to support these proposed-changes.
-Based on:the BWROG evaluation of MSIV leakage performance, the current
-Technical Specification allowable MSIV leak rate is ' extremely limiting and-routinely requires the repair and re-testing of MSIVs. 1This unnecessary-repair significantly' impacts the maintenance work load, often contributes to outage extensions, and'has in the past adversely affected the operability of 6-
KOPE CREEK GENERAllNG STATION the MSIVs.
BWR outage planners routinely schedule several days of contingency to repair and retest the MSIVs.
In addition, the needless dose exposure to maintenance personnel is inconsistent with As low As Reasonably Achievable (AtARA) requirements.
There have also been many Licensee Event Reports written for MSIV leakages exceeding the Technical Specification limit.
The proposed changes will reduce unnecessary MSIV repair costs, avoid unnecessary dose exposur(. to maintenance personnel, reduce outage durations, and extend the effective service life of the MSIVs.
In addition, the proposed increase in the MSly leakage limit has potential to significantly reduce r',tcurring valve leakages, and minimize the possibility of needless repair which can compromise plant safety.
Based on BWROG evaluation, the MSIV Sealing System is extremely difficult to maintain.
The system contains extensive logic and instru'nentation, requiring frequent calibration to meet the Technical Specification requirements.
Furthermore, at MSIV leakage rates greater than 100 scfh, the System will not function following a postulated design basis LOCA.
The proposed changes involve a replacement of the existing LCS with the more reliable and effective main steam drain line and condenter for MSIV leakage treatment.
This treatment method is effective to treat MSly leakage over an expanded operating range.
Except for the requirement to establish a proper flow path from the main steam isolation valves to the condenser, the proposed method is passive and does not require any logic control and interlocks. The method is consistent with the philosophy of protection by multiple leak-tight barriers used in containment design for limiting fission product release to the environment. Therefore, the proposed method is highly reliable for MSIV leakage treatment.
The existing MSIV Sealing System has limitations for mitigating MSIV leakage.
Operation of the system increases containment pressure and thereby increases the containment leakage. The MSly Sealing System requires multiple logic controls, interlocks, timers, containment isolation valves, and other equipment to ensure containment integrity and protection from the high pressure main steam lines.
Based on plant operating experience, the system does not provide a high degree of reliability.
Also the system has limited capacity and does not function at moderate MSIV leakage rates above 100 scfh. )
HOPE CREEK GENERATING STATION I
Even though the resulting off-site doses may be slightly higher for low MSIV leakage rates, the ef fectiveness of the proposed method even for leakage rates greater than the proposed increased allowable limits, ensures off site dose limits to the public are not exceeded.
Overall, the proposed treatment method can handle MSly leakage over an expanded operating range, and will thereby resolve
, safety concern that the LCS will not function at MSly leakage rates higher than the LCS capacity.
Thus, a margin of safety exists.
Furthermore, it is clearly a safety improvement to replace a system with known limitations with the alternate main steam piping and condenser treatment pathway, which has been shown to have excellent reliability.
Plant-specific supporting information and results of the radiological analysis that justify the proposed changes are included as Enclosure 2.
As concluded in the supporting information, the increased MSIV allowable leak rate of 200 scfh and the deletion of the MSIV Sealing System, will not adversely affect the performance of the primary containment isolation function.
A plant specific radiological analysis has been performed utilizing the main steam piping and condenser rs an alternate treatment path for MSIV leakage.
This radiological analysis demonstrates that the proposed changes result in an acceptable increase to the dose exposures previously calculated for a design basis loss-of-Coolant Accident (LOCA).
The revised LOCA dose exposures remain well within the guidelines of 10CFR100 for the offsite doses and 10CFR50, Appendix A (General Design Criteria 19) for the control room doses.
PSE&G will institute into the MSIV maintenance and test program, the requirement that any MSIV exceeding the proposed 200 scfh limit, will be repaired and re-tested to meet a leakage rate of less than or equal to 11.5 scfh.
This will assure continuation of high quality repair and refurbishment efforts to improve the overall performance and reliability of the MSIVs.
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The proposed change will require a minor plant design change to allow specified main steam drain valves to be opened even if off-site power is not available.
Applicable no. mal plant operating procedures and emergency operating procedures shall be reviewed and revised accordingly.
r HOPE CREEK GENERATING STATION Upon approval of the proposed MSIV Sealing System deletion from the Technical Specifications, PSE&G will install blind flanges in the inboard system lines, so that the associated isolation valves can be exempted from local leak rate testing.
The outboard system lines and valves will be disabled to prevent the inadvertent use of this system.
In lieu of the safety related MSIV Sealing System, MSIV leakage will be transported via the drain lines to the condenser and processed in accordance with Secticn 4.3 of NEDC-31858P Rev. 1.
Furthermore, PSE&G will incorporate the applicable alternate leakage treatment methods, consistent with GE document NE00 30324 " Potential Operator Actions to Control MSIV Leakage", into the Operational Procedures and Emergency Operational Procedures at Hope Creek Generating Station.
PSE&G will also perform a verification of seismic adequacy of the main steam piping and condenser, consistent with the guidelines discussed in Section 6.7 of NEDC 31858P Rev.1, to provide reasonable assurance of the structural integrity of these components.
Pursuant to 10CFR50.92, an analysis which demonstra s that the proposed changes do not involve a significant hazards consideration, is included as i.
The proposed changes have been reviewed in accordance with Section 6.5 of the Technical Specifications.
The proposed changes will not authorize any change in the types of effluents or in the authorized power level of the facility. is an application for exemption to Appendix A of 10CFR100, and Enclosure 5 is an application for exemption to Appendix J of 10CFR50.
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.g.
HOPE CREEK GENERAllNG STATION DiCLQll)EL1 Egh]_i_q_Sgtvice E1 ec t ric And_Qn LICENSE N0 NPF 57 DOCKET NO. 50-3M ERQPp31Q_QlA%[L]LIL(lij[lLAl S P EC I F I C AT I ONS Replace the following pages with the attached revised page(s).
These pages are provided in their entirety with marginal marking to indicate the changes.
1.
Page xi 2.
Page 3/4 62 3.
Page 3/4 6-3 4.
Page 3/4 6-7 5,
Page 3/4 6-20 6.
Page B 3/4 6-1 i
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1 I I
1
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Ref'erunCO: IG 91-02 INSERTS FOR TECHNICAL SPECifl_ CATION - 3.6.1,2 INSERT 1 (except for main steam isolation valvesa)
INSERT 2 Less tnan or equal to 200 scfh per main steam line when tested at 25 psig.
INSERT 3 200 scfh for any individual main steam line, or INSERT 4 11.5 seth on the affected main steam line, and l
l INSERT FOR TECHNICAL SPECIFICATION - 3.6.1.4-l l
INSERT 5 l~
THIS PAGE INTENTIONALLY BLANK l
Section 3.6.1.4 is reserved f or f uture use and to preserve subsequent Section numbering 1.