ML20101G752
| ML20101G752 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/16/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N92070, NUDOCS 9206260272 | |
| Download: ML20101G752 (10) | |
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PuDhc SerWCe r'actnc and Gas conpr9 Star. ley ' eBruna Nrw Semce Dectnc ard Gas Company P O Box 236. tiancocM, Body NJ 06038 609-339-1200 r.
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v,, om NLR-N92070 JUN 161992
Reference:
LCR 89-13 U.S. Nuclear Regt Ttory Commission Attention:
Document Control Desk Washington, DC 20555 Gentlemen:
SUPPLEMENTAL INFORMATION FOR REQUEST FOR AMENDMENT FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 On February 3, 1902, Public Service Electric and Gas Company (PSE&G) transmitted an application to amend Appendix A of Facility Operating License No. NPF-57 in accordance with 10CFR50.90.
This amendment request would eliminate the main steam line isolation and automatic reactor shutdown functions of the main steam line radiation monitor in the Technical Specifications.
Our description of the requested amendment, supporting information
_and analyses for the change, and the basis for a no significant hazards consideration determination, provided with that submittal, are not altered by this supplemental information.
As we stated in our application for amendment, Hope Creek facility is specifically bounded by the assumptions and justifications in General Electric Company Licensing Topical Report, NEDO-31400A,
" Safety Evaluation for Eliminatina the Boilina Water Reactor Main Steam Line Isolation Valve Cloggre Function and SCRAM Function of the Main Steam Line Radiation Monitor" and a BWR Owners Group letter (BWROG 89-31) which provided answers to specific NRC questions regarding the topical report.
The NRC issued their Safety Evaluation Report dated May 15, 1991 accepting this NEDO document for referencing by licensees in their amendment requests.
However, the NRC has raised several plant specjfic questions, the State of New Jersey, through its correspondence to the-NRC, has requested information, and there is a typographical correction to j-be made.
All of these items are addressed in Attachments 1 and 2.
I p30003 9206260272 920616 DR ADOCK 050003 4
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4 Document Control Desk Jutil 61992 NLR-N92070 Additionally, pursuant to the requirements of 10CFR50.91(b) (1),
PSE&G is providing a copy of this arendment request supplement to the State of N*w Jersey.
Should you have any questions regarding this request, we will be pleased to discuss them with you.
Sincerely, fxm<n Attachments Affidavit C
Mr.
T. T. Martin, Administrator USNRC Region I Mr.
S.
Dembek USNRC Licensing Project Manager Mr.
T.
P. Johnson USNRC Senior Resident Inspector Mr.
K. Tosch, Chief, Bureau of-Nuclear Engineering New Jersey Department of Environmental Protection
REFJ NLR-N93070 4
STATE OF NEW JERSEY
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SS.
COUNTY OF SALEM
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Stanley LaBruna, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Opetations of Public Service Electric and Gas Company, and as such, I find the matters set forth in our lettor dated concerning the Hope creek Generating Station, are true to the best of my knowledge, information and belief.
WAffW Subscribed and Sworn to before me this
/(,
day of
.h 1992 ffn+tL 0 $1A Notary Public of flew Jbrsey ELIZABETH J. KIDD Notary Public of New Jersey My Commission expires on My Commission Expiros April 25,1995
T Ref: IG 99-13 t
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}Liip OUFSPIONS CH 3HH SUB71Xif AMIMMENT RIIUIUP 4
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PSE&G requested that the Main Steam Line (MSL) drain valves be ircluded 4
with the MSIVa with regartl to tutavirg the MSL High Radiation isolation signal. What is the radiological inpact on plant personnel of allowing the drain line pathway to remain open on a high MSL radiation condition?
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RISIONSE: The (2")' drain lins run parallel to the -(26") EIs through the steam line tunnel to the turbire building, where the mis omtirne cn to the Main Stop Valves and the drains go to the main candenscru. Biruughout their travel, the EIs ard other steam and drahl lires aru located in j
areas (the steam line tunnel ard contkurer bay atuas) that'aru, due to Nikup: 16 rallation, lockrd closed "lil-Radiation Areas". iherefore, thcru is to appreciable differonce in radiological risk to plant personnel over that of rormal plant ' operating canditions whether the drain lines are j
open or shut on a high radiatico candition in the Els.
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2.
hhy are the background levels so low'on the Offgas Pre-treatment Radiation i
Monitor?
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RESTONSE: The Offgaa Pre-treatment Radiation Manitor is typically located l
after the main acadenser steam jet air ejectors -(as per NEDO 31400A).
Since the purpane of this monitor is to detect fuel failures, this detector was, by IKES design,' located inLa position approximately halfway l
(kun the lo snimts holdup line to augmented offgas trmtment to eliminate L
the marking of the measuumasit of. interest by N glevels. While the j
approximately 5 mirute delay time results in thb very low backgrumi levels, the mtnitor is very sensitive to fissicn product release.
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in why, in Table 2a of your amendment request,' the 'lEDO _ report. has Expig/ values for dapersion - for the~ Control Rod Drop Accident (CRDA) 3.
two Stardakd Review Plan (SRP) case and for the CRDA without MSIV closure; but the HCGS UFSAR column of the inble only uses'one value.
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RESIONSE: ihe NE[P doctment CRDA - SRP case nmnd rulease of radioactivity from the condenser through turbine seals, etc. as a ground releare ard the.
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CRDA without E IV cl irg the Offgasptment System as an olevated -
i release. - Uhe IKES UEEAR value of 1.9E-provided in tim Table is the; overall.5% value for the. si th Rrg.
GuideL.1.145 :(Wrkvit canditions). ~ Yhis most conservative HOGSboundary calcula 1 '
is less, than either of the two NEDO 31400A bounding values. 'It is xd.
for both cases because it'is the boundire value.for our plant and because cttr offgas treatment systcsn discharge.ls not an elevated release (.a_ll HOGS l
releases are considered as grourd level)..
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%e Stato of New Jersey's IMteau of Nuclear Engineering (ME) in their L
letter to the NRC dated Apri2 6,1992, reiterated one of the NRC criteria-for licensees to be able to reference NEIX) 31400A in their amenclment requests. - That requirement is that reasonable assurance be pmvided t'nt significantly increased levels of radioactivity in the main steam lines will be controlled expeditiously to limit both ocx:upational and j
environmental releases. The N E also stated that our submittal did not give them reasonable assurance that elevated levels of radioactivity will be controlled.
RESIWSE: PSE&G believes that our original respmse to the subject criteria purided "... sufficient evidmoe finnis= anted or w_--W rearatim
_w--has or amivalent -ih=1ts) to provide reasonable naarrance..."
required to mable the NRC staff to grant cazr requested amendamt.
PSE&G's saduntttal stated that IKES has, in place, existing- (imolumstadfM).
g -*Lnen for ruapading to hich radiaticm canditions in the steam lins.
PSEEG also stated that those p winus have bem_ reviewed for any &arges that might be rmmaamy as a result ~of the rupested ammdment's being apprtwed and that they would be tygaded (ocannitamt) to address the additicznl inpact of the pupmisi amen &amt whm it is apprtwed for HOGS.
However, to provide more detailed nasarrance to the NRC and ENE that our existirq r w-tires (whid we airrently rely upm for high steam line -
radiatim and other abnormal railological canditions) along with our-nrummitted revisions (tpan receipt of the amendment) will contime to- _
expeditiously limit nmymticmal does and evixus===d41 releases, we have expanded our original response, below:
IKES has, in place, emergency and abnormal procedures that currently ensure that any significant increase in the ' level of radioactivi'y in the main steam c
lines is prurptly controlled to limit environmental releases and on-site (occupational)'avp=tres. These procedures, 'as well as others that PSE&G -
consideral to have any potential to be inpacted by the proposed amendment, (listed in Table A)-have'been reviewed and will.-be revised, as identified in our review, to reflect the deletion of the scram and MSIV and main steam drain
-line isolation functions of_ the Main Steam Line Radiation Monitor-(MHRM).
The review and identified revisions ensure that the procedures continue to be applicable, correct, arri that they provide direction for aggressive actions to limit occupational =e m and environmental releases in the event'of high radioactivity in the. main steam lines.
Additionally, any operator training affected by the proposed charge has been evaluated for. upgrading. Current operator actions-to control environmental releases arx1 on-site _ exposures due to high radiation in the main steam lines are directed by our Emergency Procedures which are in conformance with the WROG Emergency Procedure Guidelines (EIGs). - EEG operator actions inpactal by the proposed charge were diamowi, to the NRC staff's satisfaction, by the WROG arri GE during the NRC review of NEDO 31400A.'- It is, essentially, those acticos-(that were the. subject of the discussions) which will be modified in our sucidures to reflect the absence of an autcmatic scram and MS1V-and main-steam drainline isolation functions on high steam line radiation conditions.
We, therefore, are ccnfident that our operators will continue to expeditiously-limit environmental releases and on-site _ exposures during' conditions of high radiation in the main steam lines.
MTAOMNT 1 (Cont'd),
TABIE A-IIDPE GETE EMDCDKN (ID). ArfKY@iAL (AB). NUK11?IAim IESTUEER bND SYSTFM oIY:RATIN (SO) IWXI2MES ITosWBE NUMBGB TRITE op-in.zz-lol(Q)
REACIM WHEPS VESSEL CamOL op-m.zz-io3 (Q)
REAcim HmDDC 00tmOL op-m.zz-104 (Q)
RADIomrIVE REII:ASE ONmDL on-m.zz-202 (Q) mEICDKN IEEESSURIzATIN op-m.zZ-207(Q)
LEVEI/IWCR CONIROL oe-AB.zz-loo (Q)
IIIGI REACIM 0001 AMP ACTIVfrY oP-An.zz-102(Q).
moPItD ammon IoD op-AB.zz-127(Q) oFFGAS SYSIEM - IIIG RADIATIN op-AB.zz-203(Q)
MAIN srEAM LINE - IIIW RADIATIN op-AB.zz-208(Q)
MAIN CONDENSER - Im VAWUM oP-AR.zz-olo(Q) ovEmEAD ANNUNCIATM WMDN BOX CS oP-AR.zz-oll(Q) oVDUIEAD AMGCIATM WINDN DOX C6 oP-sO.sM-ool(Q)
ISOIATIN SYSTDG oPERATIN
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Ref: LCR 89-13 A7 TAC M NP 2 WORU11N UD WIGINAI, ATTAOMNP 3 i
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1 AT17CMDI1' 3 OJNDITIONS The NRC staff concluded that the removal of the MSIRM trips that aatamatically shut down the reactor and close the MSIVs is acceptable and that the Licensing Topical Report, NEEO 31400A, could be referenced in support of our amendment request provided that:
1.
The assumptions with regard to input values mde in the generic arulysis of the LTR are boundits for the plant...
Table 1 of this attachment provides a conparison of key input paramters and Tables 2a, ard 2b ctopare doce nmvsent between the llope Creek Generatiry Station (IKES) UFSAR ard NEDO 31400A analysis assunpticris, 2.
Reasonable assurance is provided that significantly increased levels of radioactivity in the main steam lines will be controlled expeditiously to limit both occupational and environmental releases...
IKES has, in place, proccdures that ensure that any significant increase in the levels of radioactivity in the main steam lines is prmptly controlled to limit envirur.cntal releases ard enmite (cocupational) exposures. Thace procedures have been reviewed ard will be upgrad(d, as rer try, upon receipt of the requested amendmnt, to ensuru their continued applicability ard correctnocs.
3.
The MSUN ard offgas radiation monitor setpoints are standardized at 1,5 times the nitrogen-16 background dose rate at the monitor locations and should either or both exceed their alarm setpoint, the reactor coolant will be promptly sampled to determine activity levels and the possible need for additional corrective actions...
The NSUM setpoint is 1.5 times the N background at the monitor location.
That alarm would trigger entry into the abnormM proccdure, OP-AB.ZZ-203, which requires a reactor coolant sample be obtained and analyzed. The Offgas Radiation Ibnitor alarm is set to satisfy HOCS TS 4.11.2.7.P.b by alarming at 50% increase (1.5 Hmm)* the runinal steady-state fission cp3 release frun tic reactor coolant, after factority out any increases due to charges in thermal power level. This TS then requires isotopic analysis of a representative gas sanple taken frcun near the disctntge of the main condenser air ejector ard
'ould tricypr critry into one or more abnormal procxdures - which, in turn, prescribe further nMitional corrective actions.
- The offgas pre-treatment radiation monitor alarm is set at 1.5 times background or 10 mr/hr. whichever is erreater. This 10 mr/hr caveat has been fourd necessary to eliminate numerous spurious alarms (with their atterdant distractions of the control room operators) due to current background levels so low (4 to 5 mr/hr) that circuit noise or minor changes in offgas flowrate
At.tachment 3 - Cont'd-,
can initiate an alarm. The 10 mr/hr alarm setpoint corresponds to.05% of the limit of 330 millicuries /second specified in TS 3.11.2.7.
It is in accordance with this TS that the offgas radiation monitor alarm is set.
Historically, as a point of reference, one leaking fuel pin has produced several thousand mr/hr levels on the offgas radiation monitor at HOGS.
Therefore, the current alarm set point of 10 mr/hr provides conservative irdication. As backgrourd levels increase with clant age, the 10 mr/hr alarm will eventually be supplantcd by the 1.5 times background alarm setpoint.
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