ML20098D646

Application for Amend to License NPF-57,proposing Exception to Spec 4.0.4 for IRMs & SRMs When Operational Conditions 2 or 3 Is Entered from Condition 1

ML20098D646
Person / Time
Site:	Hope Creek
Issue date:	05/19/1992
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20098D647	List: ML20098D646 ML20098D649
References
LCR-92-02, LCR-92-2, NLR-N92068, NUDOCS 9205290209
Download: ML20098D646 (10)

Text

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8 PUbhc SPTVWi:

Elechie and Gas

. Company Star. ley LaBruna Pubhc Servce Dechc a,c Gas Company P.0, Box 236. H37CCcks Bridy NJ 08038 609-339 1200

.vumumt u nr owas c tucf 1 D B32 NLR-N92068 LCR 92-02 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LICENSE AMENDMENT APPLICATION EXCEI' PIONS TO SPECIFICATION 4. 0.4 FOR SRMS AND IRMS FACILITY OPERATING LICENSE NPF-57 IIOPE CREEK GENERATING STATION DOCKET NO.-50-354 Public Service Electric and Gas Company (PSE&G) hereby submits a request for amendmeni 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  : ate of New Jersey as indicated below pursuant to the requirements of 10 CFR 50.91(b) (1) .

- This license change request proposes to allow an exception to Specification 4.0.4 for the IRMs and SRMs when operational

. condition 2 or 3 is entered from operational condition 1.

- Additionally, two administrative changes are proposed.

Attachment 1 ir.cludes a description,-justification and significant hazards analysis for the proposed change. Attachment 2 contains marked up Technical Specification (TS) pages which reflect ~the proposed change.

Upon NRC approval, please issue a License Amendment which will be effective upon issuance and shall be implemented within 60 days of issuance.

Should you have any questions or comments on this submittal, please do not hesitate to contact u.s.

Sincerely, es

. . rj 92 54 npt, M'

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i Document Control Desk 2 E M 1 9 I33' NLR-N92068 Affidavit Attachments.(2).

C' Mr. S. Dembek USNRC Licensing Project Manager - Hope-Creek Mr. T. Johnson USNRC Senior Resident Inspector Mr. T. T. Martin

-Administrator - USNRC Region I Mr. Kent Tosch Chief - New Jersey Department of Environmental Protection Divis '9n of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton,-NJ 08625 t

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Ref: NLR-N92068 LCR 92-02 STATE OF NEW JERSEY )

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COUNTY OF-SALEM )

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 MAY 191992 , concerning the Hope creek Generating Station, are true to the best of my knowledge, information and belief.

f N ~Ehc i-Subscrg A9 this I7 1 and daySworg//l4L4b.cfore of ,

me 1992

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S'hk[ [v L e)fotary Public of vf ew Jersey SHERRY L CAGLE NOTARY PUBUC OF flew JERSEY My Commission Expires March 5.1997 i

My Commission expires on f

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l ArLAswXt1T._1 REQUEST FOR LICENSE AMENDMENT EXCEPTIONS TO SPECIFICATION 4.0.4 FOR SRMS AND IRMS FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 u

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NLR-N92068 HOPE CREK ICR 92-02 I. Description of the Proposed Chances

1. Revise Specification 3.3.1, " Reactor Protection System Instrumentation", to provide an exception to the provisions of Specification 4.0.4 for entry into operational condition 2 or 3 from operational condition 1 for the Intermediate Range Monitors (IRMs) .

2. Revise Specification 3.3.6, " Control Rod Biocx Instrumentation", to provide an exception to the provisions of Specification 4.0.4 for entry into operational condition 2 from operational condition 1 for the SRMs (Source Range Monitors) and IRMs.

3. Revise Specification 3.3.7.6, " Source Range Monitors", to provide an exception to the provisions of Specification 4.0.4 for entry into operational condition 2 or 3 from operational condition 1 for the SRMs.

4. Administratively revise Table 1.2, " Operational Conditions",

to permit the reacter mode switch to be placed in the Refueling position, while in Hot or Cold Shutdown, to test the switch interlock functions and related instrumentation.

Currently, only the Run and Startup/ Hot Stanaby switch '

positions are specified for this purpose.

S. Revise Specification 3.4.1.2, " Jet Pumps", to correct a typographical error in Sarveillance Requirement 4.4.1.2.b.3 by changing " difference-to-lower plenur differential pressure" to " diffuser-to-lcuer plenum differential pressure".

II. Reason for the Proposed Chanaeg The interlocks associated with the SRMs and IRMs are bypassed when the reactor mode switch is in the Run position. Therefore, unless the instrumentation is temporarily modified by inserting jumpers or lifting leads, the mode switch must be out of the Run position in order to functionally test the subject instrumentation in accordance with the applicable surveillance requirements. This can only be accomplished after entering the operational conditions in which the surveillance requirements apply.

Consequently, in order to conduct a routine plant shutdown, either the subject instrumentation must be temporarily modified or the associated action statements must be invoked.

P7GE 1 OF 6 ATTAGIMENT 1 1

F ULR-N92068 IDPE CREEK LCR 92-02 Temporary modifications of the subject instrumentation, such as lifting leads and/or installing jumpers, permits the instrumentation to be tested while the mode switch is in the Run position. However, this also increases the likelihood of failure and/or inadvertent actuation and is therefore considered to be impractical and not warranted to assure plant safety. l The action statements associated with the rod block and Reactor Protection System (RPS) instrumentation require the insertion of a rod withdrawal block, which could potentially and unnecessarily complicate plant operation and the insertion of a half scram which increases the probability of unwarranted transients.

The action statements associated with the SRM specification do not address the condition in which more than two SRMs are inoperable. Therefore, if the required functional testing cannot ,

be completed during a routine plant shutdown prior to the point '

at which reactor power decreases below range 2 of the IRMs, the provisions of Specification 3.0.3 must be invoked. Although plant shutdown could continue, it is not prudent to intentionally enter Specification 3.0.3 to conduct routine plant evolutions.

Additionally, this also could potentially and unnecessarily complicate plant operation.

Based on'the preceding discussion, the proposed change is being requested to permit an exception to the requirements of Specification 4.0.4 such that the required surveillance testing of the SRMs and IRMs can be performed after the plant is placed into operational Condition 2 or 3 from operational Condition 1.

This would permit the performance of routine plant shutdowns without requiring temporary modifications of the subject instrumentation or invoking the requirements of the associated action statnments.

III. Justification for the Proposed Chances Hope Creek License Amend 72nt No. 19 incorporated the recommendations of Generic Letter 87-09 pertaining to the applicability of limiting conditions for operation and surveillance requirements of Technical Specification Sections 3.0 and 4.0. The Generic Letter states, in part:

"A second conflict could arise because, when Surveillance Requirements can only be completed after entry into a mode or specified condition for which the Surveillance Requirements apply, an exception to the requirements of Specification 4.0.4 is allowed."

PN3E 2 OF 6 ATTAGEEtTT 1

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4 NLR-N92068 HOPE CEEK ICR 92-02 Insofar as the_ circuitry of the SRMs and IRMs precludes functional testing in operational Condition 1 because all rod block and scram functions are bypassed when the mode switch is in Run, the surveillance requirements for these instruments can only be completed -after entry into operational Condition 2 during normal reactor shutdown, or Operational Condition 3 following a reactor scram. Therefore, an exception to the provisions of ,

Specification 4.0.4, as proposed in this submittal, is consistent with the preceding excerpt from Generic Letter 87-09. The proposed exception would only apply during t.he performance of a plant shutdown (ie. entry into Operational Condition 2 0 - 3 from Operational Condition 1).

The Generic Letter goes on to state:

"However, upon entry into this mode or condition, the requirements of Specification 4.0.3 may not be met because the Surveillance Requirements may m

• have been performed within the allowed surveillance i ,r,al. Tnerefore, to avoid any conflict between Specifications 4.0.3 and 4.0.4, the staff wants to make clear: (a) that it is not the intent of Specification 4.0.' that the Actioa Requirements preclude the performance of st.veillances allowed under any exception to Specification 4.0.4; and (b) that the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Specification 4.0.3 for the applicability _of Action Requirements now provides an appropriate time limit for the completion of those Surveillance Requirements that become applicable as a consequence of allowance of any exception to Specificaticn 4.0.4."

By permitting an exception to the provisions of Specification 4.0.4 during plant shutdown, the pluTt may be placed into Operational Condition 2 or 3 prior to performance of the surveillance. requirements for the SRMs and IRMs without the invocation of the associated action statements which include the l

insertion of rod blocks and half scrams. Once the plant is placed-into Operational Condition 2 or 3, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time allowance of Specification 4.0.3 would apply as discussed in the preceding excerpt from Generic Letter 87-09. During this time period, the surveillance requirements are required to be j completed.

l l Lastly, the proposed revisions include two administrative changes, i The first pertains to the definition of each of the operational conditions as specified in Table 1.2. This table currently contains a provision, in the form of a note, which permits the reactor mode switch to be placed in the Run or Startup/ Hot Standby position while in operational condition 3, 4, or 5 to test the switch interlock functions and related instrumentation.

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NIR-N92068 I HOPE CREEK IER 92-02 The note further specifies that while the mode switch is in either of these positions, the control rods must be verified to remain _ fully inserted by a second licensed operator or other technically qua' ified member of the unit technical staf f.

A preferred method of performing this testing while in hot or cold shutdown is to place the mode switch in Refueling. By enabling the one-rod-out interlock, this switch position automatically provides an additional margin of safety beyond the required administrative controls in preventing the occurrence of inadvertent rod withdrawal events.

The proposed change would modify the note to permit the mode switch to be placed in the Refueling position while retaining the ,

option of placing it in the Run or Startup/ Hot Standby positions. l This will provide the operational flexibility to accommodate potential situations which specifically require the mode switch ,

to be in Run or Startup/ Hot Standby while in operational l condition 3 oc 4.

Lastly, a correction of a typographical error in Surveillance Requirement 4.4.1.2.b.3 is proposed. The correct nomenclature of the non-calibrated jet pump instrumentation is " diffuser-to-lower j plenum differential pressure". q l

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PAIS 4 OF 6 ATTAONEtfl' 1 l

4 NIR-N92068 HOPE CREEK LCR 92-02 IV. Sionifigant Hazards Consideration Evaluation PSE&G has, purst nt 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.

During performance of plant shutdowns, operability of the subject instrumentation will be confirmed in a timely manner by surveillance testing in accordance with the time requirements of Specification 4.0.3.

Furthermore, the proposed change would permit the performance of routine plant shutdowns without the invocation of the action requirements associated with the SRM and IRM specifications which include the insertion of rob blocks and half scrans and potential voluntary entry into Specification 3.0.3. This would consequently decrease the probability of unwarranted transients.

The proposed change to permit the reactor mode switch to be placed in the Refueling position while in operational condition 3 or 4 to conduct testing provides the operational flexibility to operate the plant in a more conservative manner than presently required by the subject specification.

2. Will not create the possibility of a new or different kind of accident ' rom any accident previously evaluated.

Neither the operation nor the function of the SRMs, IRMs, reactor mode switch interlocks, or instrumentation f associated with the reactor mode switch will be modified by the proposed change. Performance of confirmatory, routine ,

surveillance testing will not create the possibility of a new or different event.

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

1 The proposed changes would permit the performance of routine plant shutdowns without requiring either: 1) the temporary modification of the subject instrumentation which would increase the likelihood of failure or inadvertent actuation, or 2) the invocation-of the associated action statements which could increase the probability of unwarranted transients and could unnecessarily complicate plant operation.

PAGE 5 OF 6 ATTACH 4E2TI' i

NIR-W92068 If0PE CREEK IIR 92-02 Tts proposed chango to permit the reactor modo switer to be placed in the Refueling position while in operational condition 3 or 4 to conduct testing provides an additional margin of safety in that the subject testing can be performed while the one-rod-out interlock is enabled.

V. Conclusion Based on the oreceding discussion, PSE&G has concluded that the proposed change to the Technical Specifications does not involve a significant hazards consideration insofar as the change (1) does not involve a significant increase in the probability or consequences of ar. accident previously evaluated, (ii) does not create the possibility of a new or different kind of accident frc. any accident previously evaluated, and (iii) does not involve a signifJeant reduction in a ,iargin of safety, f

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