ML20090B335
| ML20090B335 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/24/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20090B338 | List: |
| References | |
| GL-90-09, GL-90-9, LCR-91-18, NLR-N91220, NUDOCS 9203030332 | |
| Download: ML20090B335 (7) | |
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Put>hc Service Elecinc and Gas Company Stanley LaBruna PetnIC Serge [tecinc and Geis Corppany P.O Box 236. Hancorks Dndge. NJ 0B038 009 339-1200 m,w - a w FEB 2 4 1992 NLR-N91220
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LCR 93-18 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDHENT APPLICATION SNUBBER VISUAL INSPECTION INTERVALS FACILITY OPERATING LICENSE NPP-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) hereby submits a request for amendment of Facility Operating License NPF-57 for the Hope Creek Generating Station in accordance with 10 CFR 50.90.
A copy of this submittal has been sent to the state of New Jersey as indicated below pursuant to the requirements of 10 CFR 50.91(b) (1).
The proposed change would revise the requirements for snubber visual inspection intervals.
This amendment request has been developed, and is being submitted, in accordance with the guidance provided in NRC Generic Letter 90-09, " Alternative Requirements For Snubber Visual Inspection Intervals and Corrective Actions". includes a description, justification and significant hazards analysis for the proposed change. contains marked up Technical Specification (TS) pages which reflect the proposed change.
PSE&G believes that this subhtittal contains sufficient technical justification to conclude that a detailed specialist review should not be required and that the proposed change can be classified as a Category 2 change.
Upon NRC approval, please issue a License Amendment which will be effective upon issuance and shall be implemented within 60 days of issuance.
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NLR-N91220 Should you have any questions or comments on this submittal, please do not hesitate to contact us.
Sincerely, W h'A4<-se Affidavit Attachments (2)
C Mr. T. T. Martin, Administrator - Region I U.
S.
Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.
S.
Dembek, Licensing Project Manager U..S.
Nuclear Regulatory Commission MS 14 E-Li Washington, DC 20555 Mr. T. P. Johnson-(SOS) 10SNRC Senior Resident Inspector Mr.
K. Tosch, Chief NJ Oepartment of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN'415 Trenton, NJ 08625 l'
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NLR-N91220 LCR 91-18 STATE OF NEW JERSEY
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SS.
COUNTY OF. SALEM
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S._LaBruna, 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 on-our letter dated FEB 2 4 199 concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.
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Subscribed and Sworn to before me this-M f/ day of A A< w, 1992 f
NML D YN Notarv Pdblic of Jfew 3ersey EllZABETH J. KIDD Notary Public of New Jersey My C mm sson Expires April 25,1995 My commission expires on 1
I; l.
d ATTACHMENT 1.
REQUEST FOR LICENSE AMENDMENT l
SNUBBER VISUAL INSPECTION-INTERVALS i
I FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 l-f
KLR~N91220 Il0PE CREEK ICR 91-18 I.
Descrintion of the Pronosed Chances This amendment request proposes to revise the snubber visual inspection requirements which are delineated in Specification 4,7.5.
The 5'.oposed changes fully incorporate all recommendatd ans delineated in Generic Letter 90-09 which apply to the Hope Creek Generating Station.
II.
Reason for the Pronosed Chances Specification 4.7.5 presently delineates a schedule for snubber visual inspections that is based on the number of inoperable snubbers found during the previous visual inspection, irrespective of the size of the population that was tested.
Insofar as Hope Creek has a large number of snubbers, 1186 total, this schedule has proven to be excessively restrictive.
Compliance with this schedule requires a significant amount of resources and subjects personnel to unnecessary-radiological exposure.
During the third refueling outage conducted in Winter, 1991, performance of snubber visual inspections accounted for 3.092 man rems.
The proposed changes contained in-this submittal would incorporate an alternate schedule for snubber visual inspections which was recommended by the NRC in Generic Letter 90-09.
This alternate schedule is based on the number of unacceptable snubbers found during the previous inspection in proportion to the sizes of the various snubber populations or categories.
The incorporation of the alternate snubber visual inspection i
schedule in accordance with Generic Letter 90-09 would reduce future occupational radiological exposure.
This philosophy la consistent with the guidance provided in Regulatory Guide 8.10, l
" Operating Philosophy-For Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable", which, in part, states:
" Modifications to operating and maintenance procedures and to plant equipment and facilities should be made where they will substantially reduce exposures at a reasonable cost."
PSE&G is therefore requesting these changes.
PNE 1 OF 3 ATTAWMEtTT 1
t NIR-N91230 IDPE CREEK IG 91-18 III. Justification for the Pronosed Chanagg All changes proposed in this submittal are encompassed by the discussion and recommendations contained in Generic Letter 90-09.
With the exception of minor grammatical and/or administrative differences, all changes that.are proposed for the Hope Creek Technical Specifications in Attachment 2 are identical to the changes recommended by the NRC in Enclosure B of Generic Letter 90-09 which apply to Hope Creek.
For each difference that exists, an explanation is provided below.
Please note that only the differences-that effect the proposed changes are discussed.
The sentence in recommended Specification 4.7.9.c pertaining to "... common hydraulic fluid reservoir..." does not apply to Hope Creek and consequently does not appear in the plant's specifications; therefore, the changes affecting this j
sentence do not appear in this submittal.
The intent of the last sentence in Hope Creek specification 4.7.5.c pertaining to "... snubbers common to more than one system..." is fully encompassed and mere clearly delineated by the changes in recommended specification 4.7.9.c.
This submittal therefore seeks to replace this sentence in its entirety with the recommended changes.
Table 4.7-2 in the recommended specifications has been
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changed to Table 4.7.5-1 in order to maintain consistency with the numbering system used in the Hope Creek specifications.
A typographical error was corrected in Note 4 of the Table
("that" was changed to "than").
For clarity and ease of use, the verbiage in Note 5 of the table which explains how the previous interval shall be reduced proportionally by interpolation has been re-formatted as a mathematical formula.
Hope Creek Basis 3/4.7.5 has been changed to reflect the incorporation of Generic Letter 90-09.
Ph2 2 OF 3 ATTAQiMDTI' 1
NIR-N91220 IDPE CREEK ICR 91-18 IV.
Sianificant Hazards Consideration Evaluatign PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed amendment to determine whether our request involves a 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 proposed changes will, in accordance with Generic Letter 90-09, incorporate an alternate snubber visual inspection schedule which maintains the same confidence level as the existing schedule.
2.
Will not create the possibility of a new or different kind l
of accident from any accident previously etaluated.
There are no physical changes to the plant or to the manner in which the plant is operated involved in the proposed revision.
Therefore, no new or different accident is created by the proposed change.
3.
Will not involve a significant reduction in a margin of safety.
Insofar-as the alternate snubber visual inspection schedule proposed in this submittal will maintain the same confidence level as the current schedule, there will be no resultant change in any margin of safety, V.
Conclusion Based on the precedi1q discussion, PSE&G has concluded that the proposed change to the Technical Specifications does not involve a significant hazards consideration insofar as the change: (i) does not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) does not create the possibility of a new or different kind of accident from any accident previously evaluated, and (iii) does not involve a significant reduction in a margin of safety.
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