ML20101F381

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Application for Amend to License NPF-57,consisting of TS Change to Provide Six Hour allowable-out-of-service Time for Discharge Line Keep Filled Alarm Instrumentation Associated W/Low Pressure Coolant Injection Sys
ML20101F381
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 06/15/1992
From: Labruna S
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20101F384 List:
References
NLR-N91209, NUDOCS 9206240431
Download: ML20101F381 (10)
v • d • e


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JUtt1 5 1992 NLR-H91209 LCR 91-17 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen' -

LICENSE AMENDMENT APPLICATION LPCI/ CSS " KEEP FILLED" AIARM INSTRUMEN"" l'Iw 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 amendment of Facility Operating License HPF-57 for the Hope Creek Generating Station in accordance with 10 CFR 50.90. A copy of this submittal has been sont to the state of New Jersey as indicated below pursuant to the requirements of 10 CFR 50.91(b)(1).

The proposed change voald provide an allowable-out-of-service (ACT) tor the Low Pressure Coolant Injection (LPCI) system and Core Spray System (CSS) discharge line " keep filled" alarm $

instrumentation. This would allow monthly sur,eillance tests to be performed on interrelating instrumentation without requiring the CSS and/or LPCI system (s) to be vented.

  1. ~

Attachment 1 includes a description, justification and significant hazards analysis for the proponed change.

Attachment 2 contains marked up Technical Specification (TS) pages which reflect the proposed change.

PSE&G bellaves that this submittal contains sufficient technical justificet. ion 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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e Document control Desk 2 JUN 151992 NLR-N91209 Should you have any questions or comments on this submittal, please do not hesitate to contact us.

Sincerely, h r( frrrc e t Affidavit Attachments (2) 4 C Ms. A. Keller

USNRC Licensing Project Manager - Nope 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 Division of Environmental Quality Bureau of Nuclear Engineering h' CN 415 Trenton, NJ 08625 l

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e JU:41 6 1992 Ref NLR-N91209 LCR 91-17 l l

STATE OF NEW JERSF.Y )

) SS.

COUNTY OF SALEM ) l l S. LaBruna, being duly sworn according to law deposes and says?

1' 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 , concerning the Hopo creek Generating Station, are true to the best of my knowledge, information and bo11ef.

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Subscribed and Sworn-t:o before me this /5 "' day of ( ..jtLRA , 1992 =

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l 11fL(Ahyh. , N Ndtary Publ)lc of New Jersey NOTARY N!ittC Of NEW JERSEY i My Commission expires on "# C*""" " " ""

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ATIACHMENT 1 REQUEST FOR LICENSE AMENDMENT LPCI/ CSS " KEEP FILLED" AIARM INSTRUMENTATION FACILITY OPERATING LICENSE HPs'-57 IlOPE CREEK GENERATING STATION DOCKET NO. 50-354

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NIR-N91209 IDPE CREK ICR 91-17 l

I. Description of the Pro. paged chances This amendment request proposes to provide a six hour allowable-out-of-service time (AoT) for the discharge line " keep filled" alarm instrumentation (hereafter referred to as " keep filled" instrumentation) associated with the Low Pressure Coolant Injection (LPCI) system and Core Spray System (CSS). This would allow monthly surveillance tests to be performed on interrelating instrumentation without requiring the CSS and/or LPCI system (s) .

to be vented.

II. Reason for the Pronosed Chances There are no monthly surveillance requirements associated with the LPCI and CSS " keep filled" instrumentation; consequently, there is no allowable out-of-service time (A0T) specified in Technical Specifications. However, operability of this instrumentation is directly impacted by monthly surveillance testing that is required to be performed on interrelating instrumentation as described below.

Presently, the only guidance provided by Technical Specifications when the " keep filled" instrumentation is rendered inoperable as a result of monthly surveillance testing on interrelating instrumentation is to. vent the affected ECCS subsystem (s). This evolution requires personnel to enter high radiation areas (greater than 100 mrem /hr). PSE&G believes that the potential safety benefits of this requirement are not sufficient to warrant the associated radiological exposure.

l The incorporation of the proposed change would reduce future occupational radiological exposure. This philosophy is consistent with the guidance provided in Regulatory Guide 8.10,

" Operating Philosophy For Maintaining occupational Radiation l Exposures As Low As Reasonably Achievable", which, in part, l

states:

" Modifications to operatir.g and maintenance procedures and to plant equipment and facilities should be made where they will substantially redace exposures at a reasonable cost."

PME 1 OF 6 ATTAQlMDTP 1

NUl-N91209 IDPE CRDD< U3191-17 III. Justification for the Pronosed Changga A. Cov}onent Configuration The LPCI/ CSS discharge line fill network is designed to maintain the LPCI and CSS pump discharge lines in a filled condition in order tot 1) minimize the time lag between the signal to start the pumps and the initiation of flow to the reactor pressure vessel (RPV); and 2), prevent water hammer damage to the injection piping during pump starts.

The fill network consists of two independent jockey pumps (CP228 and DP228) and their associated controls and instrumentation.

Jockey Pump CP220 serves LPCI Subsystems A and C and CSS Subsystem A while Jockey Pump DP228 serves LPCI Subsystens B and D and CSS Subsystem B. Power is recolved from separate-Class 1E electrical channels. Although the fill network is safety-related and designed to Seismic Category I criteria, it is not considered an integral part of the ECCS.

Each ECCS injection loop is provided with a separate, isolable fill line, supplied from the Condensate Transfer and Storage System, to permit maintenance of individual ECCS injection loops without disabling other ECCS injection equipment.

B.. Instrumentation Configuration The LPCI and CSS " keep filled" instrumentation consists of the following trip units:

  • 1-BC-PSL-N654A (LPCI Subsystem A)
  • 1-DC-PSL-N654B (LPCI Subsystem B)
  • 1-BC-PSL-N654C (LPCI Subsystem C)
  • - 1-BC-PSL-N654D (LPCI Subsystem D) l -- 1-BE-PSL-N658A (CSS Subsystem A) l
  • 1-BE-PS L-N 658 B (CSS Subsystem B) l IYCE 2 OF 6 ATTAQMDIT 1 I

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NIR-N91209 4 IlOPE CREEK IfR 91-17 The instruments listed above are configured as slave trio units.

Each receives an input signal from a master trio unit which, in turn, receives a signal from a pressure transmitter located in the injection line of the respective ECCS subsystem. The master trip units are designated as follows:  ;

I 1-BC-PISil-N653A (LPCI Subsystem A)

  • 1-BC-PISH-N653B (LPCI Subsystem B)
  • 1-BC-PISil-N653C (LPCI Subsystem C)
  • 1-BC-PISil-N653 D (LPCI Subsystem D)
  • 1-BE-PISil-N654A (CSS Subsystem A)
  • 1-BE-PISil-N 65 4 B (CSS Subsystem B)

Thus, in each LPCI and CSS injection line, there is a pressure transmitter which provides a signal to a master / slave pair of trip units in series.

The master trip units are designated as the " reactor coolant interface valves leakage pressure monitors" (hereafter referred to as leakage pressure monitors) and actuate upon sensing a high nressure condition to indicate potential back leakage from the reactor into the' low pressure injection lines.

The slave trip units, composing the LPCI and CSS " keep filled" instrumentation, actuate upon sensing a low nrossure condition to indicate potential failure of the respective fill network.

Both trip units within each master / slave pair provide input signals to a common control room overhead annunciator. These annunciators are listed below:

PN2 3 OF 6 ATTACHMDTP 1 l .

NIR-N91209 Il0FE CREEK IG 91-17 l

The annunciators listed above subsequently provide initiating inputs, via repeater relays, to activate the following computer digital alarms:

  • RHR PUMP A DISCHARGE PRESSURE
  • RHR PUMP B DISCHARGE PRESSURE
  • RHR PUMP C DISCHARGE PRESSURE
  • RHR PUMP D DISCilARGE PRESSURE
  • CS LOOP A INJECTION LINE PRESS
  • CS LOOP B INJECTION LINE PRESS C. Technical Specification Requirements The LPCI and CSS discharge line " keep filled" alarm instrumentation is encompassed by Specification 3.5.1, "ECCS -

Operating". Within that specification, surveillance 4.5.1 requires a channel calibration of the affected instrumentatinn to be performed at least once per 18 months. There is no allowable-out-of-service time specified. If a " keep filled" instrumentation becomes inoperable, Action f requires the affected LPCI and/or CSS subsystems to be vented in order to verify that the systems are filled with water. This evolution, which is also a 31 day surveillance requirement, requires personnel to enter high radiation areas in order to obtain access to the respective high-point vent valves.

The leakage pressure monitors are encompassed by Specification 3.4.3.2, " Operational Leakage". Within that specification, surveillance 4. 4. 3. 2. 3 requires channel functional tests at least once per 31 days and channel calibrations at least once per 18 months for the affected monitors which are listed in Table 3.4.3.2-2. Action d allows a monitor to be inoperable for up to seven days; if it cannot be restored to operable status within seven days, the pressure in the respective discharge line must be verified to be less than the alarm setpoint at least once per twelve hourst if the monitor cannot be restored to operable status within 30 days, the plant must be placed in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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NIR-N91209

, HORB QEIX bO191-17 l

Because of the master / slave configuration described above, a LPCI or CSS " keep filled" instrumentation channel (slave trip unit) is rendered inoperable whenever its associated leakage pressure i monitor channel (master trip unit) is inoperable. This occurs  ;

during the monthly channel functional tests of the leakage pressure monitors required by Specification 4.4.3.2.3.a. Thus, although there are no monthly surveillance test requirements for the " keep filled" instrumentation, operability of this instrumentation is directly impacted by the monthly surveillance tests required to be performed on the interrelated leakage pressure annitor instrumentation.

D. Proposed Change i Based upon the preceding discussion, PSE&G is hereby proposing to provide an allowable-out-of-service time (A0T) in Specification 3.5.1 for the LPCI and CSS " keep filled" instrumentation. This AOT would apply only if the affected " keep filled" instrumentation is inoperable due to the performanco of required .

surveillance testing. This includes testing of the leakage '

pressure monitors in accordance with Specification 4.4.3.2.3.

! If the " keep filled" instrumentation becomes inoperable for reasons other than surveillance testing, or cannot be returned to operable status within cix hours, the requirement to vent the affected ECCS subsystems would still exist.

i Additionally, the six hour A0T would apply only if the " keep filled" instrumentation associated with at least one other LPCI or CCS subsystem serviced by the affected " keep filled" system reraains operable. This would ensure that failure of a " keep filled" system associated with an inoperable channel would still be annunciated by a redundant channel of instrumentation associated with an interconnected ECCS subsystem. If the " keep filled" portion of the affected LPCI or CSS subsystem is isolated L from the other subsystems serviced by the respective fill j network, the proposed AoT would not apply.

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liLR-N91209 il01E CREEK ICR 91-17 IV. Slanificant Hazards Consideration Evaluation 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 i changest

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

The proposed amendment does not involve a physical or procedural change to any structure, component or system that significantly affects the probability or consequences of any accident or malfunction or equipment important to safety previously evaluated in the Updated Final Safety Analysis Report (UFSAR). The proposed change will provide a reasonable period of time to accomplish required surveillance testing while assuring continued operability of redundant instrumentation.

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

The proposed revision will not involve any physical changes to the plant. Additionally, the A0T will apply only if redundant instrumentation remains operable thereby ensuring that failure of the affected " keep fill" system will still be annunciated.

3. Will not involve a dignificant reduction in a margin of

-safety.-

The proposed A0T will reduce radiological exposure of plant personnel. Insofar as the A0T will apply only for surveillance testing and only if redundant annunciation remains operable, this change can be made with no significant change in the margin of safety.

3 V. Conclusion Based on the preceding 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 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 reduc ~c ion in a margin of safety.

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r e l ATTACH 11ENT.1 RFQUEST FOR LICENSE AMENDMENT LITI/ CSS " KEEP FILLED" AIARM INSTRUMENTATION FACILITY OPERATING LICENSE NPP-57 IlOPE CREEK GENERATING STATION DOCKET NO. 50-354

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