ML20091B868

Application for Amend to License NPF-57,consisting of License Change Request 91-01,revising TS Sections 4.0.5, Applicability, 3.4.3.1, Leakage Detection Sys & 3.4.3.2, Operational Leakage

ML20091B868
Person / Time
Site:	Hope Creek
Issue date:	07/25/1991
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20091B871	List: ML20091B868 ML20091B873
References
NLR-N91127, NUDOCS 9108020228
Download: ML20091B868 (8)

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JUL 2 5 iM1 N1R-N91127 Refrrence: 1,CR 91-01 U.S. Nuclear Regulatory Comminnion At leti t i on : Document Control Dent Washington, DC 20$55 Gentlemen:

REQUEST FOR AMENDMENT FACIblTY OPERATING 1,1 CENSE NPF-57

!! OPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gao Company (PSE&G) hereby transmita an applicationi to ametid Appendix A of racility Opera t i rig License No. NPF-57 in accordance with 10CERSO.40. This iimendmen* request would revice Sections 4.0.5, APPLICABILITY, 3.471, LEAKAGL DETECTION SYSTEMS, and 3.4.3.2, OPERATIONAL LEAE*r.,E, of the !! ope Creek Generating Station (IICG S ) Technical Specifications.

A description of the requested amendment, supporting information and analysea for the change, and t he bacia f or a no significant hazardo consideration determination are provided in Attachment 1.

The Technical Specification pages affected by the proposed change are marked-up in Attachment 2.

Upon NRC approval of this proposed change, PSE&G requesto that the amendment be made effective on the date of inauance, but I implementable within sixty days to provide sufficient time for I

1 associated procedural modifications.

I i Pursuant to the requirements of 10C E R 50. 91 ( b) (1 ) , P S l% G has l provided a copy of this amendment request to t he St at e of New Jersey.

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JUL r5 Iggi Document Cont rol Desk NLR-N91127 Should you have any questionn regatding this requent, we will be pleased to discuas them with you.

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Attachments Alfidavit C Mr. T. T. Martin, Adin1 n i n t ra t or USNRC Region I Mr. S. Do'abek USNRC Licensing Project Manager Mr. T. P. Johnson USNRC Senior Resident Inspector Mr. K. Tasch, Chief, Bureau of Nuc]nar Engineering New Jersey Department of Environmental Pt ot ect ion i

, e REF: NLR-N91127 l

l iTIATE OF NEK JERSEY )

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COUNTY OF SALLM )

Stanley Labruna, being duly worn according to l a w chs pon e n and says:

I am Vic? President - Nuclear Opetationa of Public Service Electric and Gas Company, and an such, I tind the matters not forth in our letter dated JUL 2 5 1991 , concerning the Hope Creek Generating Station, are true to the best of my kriowledge, information and t>olief.

s % c. . u/7 I ,S $ /f_, l" Hie Subsetihod,.nd Sworn to before me this j '/#' day of [df , 1991

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Notary Public of New Jersey

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Ref: LCR 91-01 ATTACilMENT 1 PROPOSED TECIINICAl. SPECIFTCATIONS AND llASES_CilANGE

PROPOSED CHANGE TO THE TECHNICAL SPECIFICATIONS FACILITY OPERATING LICENSE NPF-57 HOPE CREEK CENERATING STATION DOCKET No. 50-354 Ref: LCR 91-01 DESCRIPTION OF THE _ CHANGE As shown on the marked-up Technical Specifications (TS) pages in Attachment 2, PSE&G requests that TS Sections 4.0.5, APPLICABILITY, 3.4.3.1, LEAKAGE DETECTION SYSTEMS, 3/4.4.3.2, OPERATIONAL LEAKAGE, and associated DASES, be revised to satisfy comments in the November 8, 1989 NRC letter (Butler to Miltenberger), and in subsequent telephone conversations with NRC staf t, regarding PSE&G's response to Generic Letter (GL) 88-01.

REASON FOR THE CHANGE GL 88-01 proposed certain changes to be incorporated into the TS. Based on NRC review of the PSE&G response to the GL, and ensuing telephone discussions between NRC staff and PSE&G personnel, the changes contained in this request were mutually found to satisfy the intent of the Generic Letter.

JUSTIFICATION FOR TFS CHANGE The inclusion of the GL 88-01 Inservice Inspection Program requirements on schedule, methods, personnel and sample expansion in TS Section 4.0.5, APPLICABILITY, constitutes the addition of a more conservative specification and is in direct conformance with the Generic Letter proposal.

The evaluation of PSE&G's response to the GL, performed by Viking Systems International (VSI) for NRC, found that while PSE&G's interpretation and practices regarding TG 3.4.3.1, LEAKAGE DETECTION SYSTEMS, are acceptable.

. ..the actual wording in the Technical Specification is conf using and open to interpretation...". Theref ore, the proposed changes to TS 3.4.3.1 include separation of the leakage detection systems into three groups. This action permits a clear identification of individual OPERABILITY requirements and ACTIONS for each of the five leakage detection systems, thereby eliminating

the confusion and need for interpretation. The three groups are

The drywell floor and _eguipment drain sump monitoring system - GL 88-01 Staf f Position No.3 on Leak Detection states, "For plants operating with any IGSCC Category D, C, F, or G welds, at least one of the leakage measurement instruments associated with each sump shall be operable, and the outage time for inoperable instruments shall be limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or immediately initiate an orderly shutdown." This position applies to the dryvell floor and equipment drain rump monitoring system and is, accordingly, incorporated in the proposed change for this system. However, a provision for continued l operation for up to 30 days is added - provided all other leakage detection systems are OPERABLE and provided that a manual calculation, as described in Operating Department Procedure, HC.0P-ST.SK-001(Q), (see Attachment 3) is perf ormed at least once every four hours. This provision, included in the NRC i final draf t, NUREG 1433, of the BWR 4 Standard Technical Specifications,

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permits time to perf orm repairs and recognizes that an alternate method of quantifying leakage (performed by licensed control room personnel) is available, but prevents operation for a long period of time with a degraded leakage detection system.

The drywell atmospheric caseous radioactivity monitoring system - This system, ___

recommended by Regulatory Guide (RG) 1.45, is the only leak detection system

, that provides actual radiological information to control room operators. As currently required in TS 3.4.3.1, with this system inoperable, operation can continue for up to 30 days provided drywell atmosphere grab sampling and analyses are performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The TS requirements and actions for this system remain unchanged in this submittal.

The drywell coolers condensate flow late, drywell temperature and drlwel_1_

pressure monitoring sJatems - These systems, in conjunction with the dryvell floor and equipment drain sump and drywell atmosphere gaseous radioactivity monitoring systems, were reviewed by NRC staff and, in Section 5.2.5 of the Hope Creek Safety Evaluation Report (NUREG-1048), found acceptable and to satisfy the requirements of General Design criteria (GDC) 2 and 30, and the guidelines of RG 1.29, Positions C.1 and C.2, and RG 1.45, Positions C.1 through C.9.

The drywell air cooler condensate flow rate, drywell temperature, and drywall pressure monitoring systems do not provide any radiological information to control room operators, yet the current TS 3.4.3.1 ACTION requires grab samples of the dryvell atmosphere be obtained and analyzed when any of these systems is inoperable. The proposed change would eliminate the grab sampling requirement as long as the dryvell atmosphere gaseous radioactivity monitoring system is OPERABLE. These three systems provide dissimilar, yet somewhat redundant indication (not quantification) of RCS leakage; that is, an RCS leak of significance would likely raise drywell temperature and pressure, and cause increased condensate flow f rom the drywell coolers. Positive iraications on any two of these parameters would be sufficient to substantirle an RCS leak and positive indications on any one system would instigate '.urther evaluation of drywell and RCS conditions. Therefore, continued oporrtion with only two of these three detection systems operable, and further lcss of one additional system for up to 30 days, provided that the drywell floor and equipment drain surp and drywell atmosphere gaseous radioactivity monitoring systems are OPERABLE, would not constitute a significant loss of leak detection capabilities. The corresponding Limiting Condition fot Operation Section in the final draft, NUREG 1433, of the BWR 4 Standard Technical Specifications, requires only the drywell floor and equipment sump flow monitor, one drywell radiological monitor, and drywell cooler condensate flow monitor. That draft specification reflects the latest thinking on adequate leak detection systems and is supportive of the proposed changes in this request.

The proposed changes to the above TS Sections - which eliminate the current ambiguities and assign more reasonable ACTION requirements to each of the Leakage Detection Systems - are clearer and more appropriite, yet retain the

. necessary conservatism, i

The existing TS 3.4.3.2, OPERATIONAL LEAK. AGE, has limits of 5 gpm unidentified leakage-and'25 gpm identified leakage. The staf f position stated in GL 88-01 would incorporate an additional unidentified leakage limit of "2 gpm increase in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period or less". This requirement is part of the proposed changes-in this request.

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HCGS has an existing procedure (oee Attachment 3) that prescribes specific leak location and isolation techniques. PSE&G proposes that a requirement to implement these preplanned leak resolution actions upon detection of any increase in leakage that exceeds the proposed limit and that a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period in which to identify, isolate or reduce the leakage rate to below the limit be incorporated into the OPERATIONAL LEAKAGE TS. Theci proposed provisions, as shown in the marked-up TS Pages in Attachment 2, have been modelled upon the final draft, NUREG 1433, of the BWR 4 Standard Technical Specifications. They will meet the intent of the staff's position by providing plant specific, readily implementable, actions regarding the Generic Let ter-recommended limit.

TS 3/4.4.3.2, OPERATIONAL LEAKAGE, Surveillance Requirement 4.4.3.2.1 b currently requires monitoring of the drywell floor and equipment drain sump flow rate at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In conformance with the NRC staff position, modified in the above mentioned November 8,1989 NRC letter, this proposed change requires moritoring the flow rate at least once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Since, at HCGS, the drywell floor and equipment drain sump flow rate, as well as the drywell atmospheric gaseous radioactivity, drywell coolers condensate flow rate and drywell pressure (TS 4.4.3.2.1.a, c, and d) have always been monitored on an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> f requency, this proposed change revises the requirement f or each of these parameters to the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> f requency f or consistency. This change is conservative; in that, it increases the frequency of monitoring.

10CFRSO.92 SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS Pursuant to 10CFR5p.92, PSE&G has, in reviewing the proposed amendment to determine whether our request involves a significant hazards consideration, determined the following:

The operation of Hope Creek Generating Station _1HCGS) in accordance with_the proposed change vill not involve a si_gnificant increase in the_ probability or consequences of an accident previously evaluated.

The propoced amendment does not involve a physical or procedural change to any structure, component or system that has any significant effect on probability or consequences of any accident or malfunction of equipment important to safety previously evaluated in the Updated Final Safety Analysis Report (UFSAR). The proposed changes will add clarifications, alternative actions, and new requirements to the TS that are suggested by SRC staff in Generic Letter 88-01, in their Safety Evaluation of the PSE&G response to that Generic Letter and in the NRC's final draft of NUREG 1433, Standard BWR 4 Technical Specifications.

The operation of Hope Creek Generating Station (HCGS) in accordance with the proposed change vill not create the possibility of a new or_ dif f erent _ kind of accident from any previously evaluated1 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.

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The operation of Hope Creek Generating Station _1HCGSl_1n accordance with the propofed change uoes not involve a significant reduction in a margit of safety.

The proposcd changes provide clarifications and additional, conservative, reyrirements to the TS, and address the Generic Letter 88-01 issues. Where existing TS requirements would be relaxed or modified, there has been no significant reduction in the information provided to control room operators and existing procedures provide necessary guidance so that manual determinations can be made to quantify leakage rates. Margins of safety are, therefore, not adversely atfected by the proposed change.

Cpnclusion:

B sed upon the above, we have deterniined that this proposed change does not involve a Significant Hazards Consideration.

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