ML20114C090
| ML20114C090 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/24/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20114C083 | List: |
| References | |
| NUDOCS 9209010168 | |
| Download: ML20114C090 (4) | |
Text
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i SAFETY EVALVATIQtLJ1 1HE OFFICE OF NUCLEAR REACTOR REGVL ElQti RELATED TO AMENDMENT NO. u 10 FACIL1TY OPERATING LICENSE NO. 1PE_.51 E98LIC SERVICE ELECTRIC & QAS COMPANY AIL @illC CITY ELECTRIC COMPANY H0pE CREEK GENERATING STATION DOCKEI NO. 50-354 1.0.lNTRODUCTIQti By letter dated May 19, 1992, as supplemented by letter dated August 5, 1992, the Public Service Electric & Gas Company and Atlantic City Electric Company (the licensees) submitted a request to amend the Hope Creek Generating Station (HCGS) Technical Specification (TS).
The requested changes would allow an exception to TS 4.0.4 for the Intermediate Range Monitors (IRMs) and Source Range Monitors (SRMs) when Operational Conditiun 2 or 3 is entered from Operaticaal Condition 1, Additionally, two administrative changes were proposed.
The August 5,1992 letter provided clarifying information that did not change the initial proposed no significant hazards consideration determination.
Specifically, the licensee proposcd the fellowing changes:
1.
Revise TS 3.3.1, " Reactor Protection System Instrumentation," to provide an exception to the provisions of TS 4.0.4 for entry into Operational Condition 2 or 3 from Operational Condition 1 for the IRMs.
2.
Revise TS 3.3 6, " Control Rod Block Instrumentation," to provide an exception to the provisions of TS 4.0.4 for entry into Operation Condition 2 from Operational Condition 1 for the SRMs and IRMs.
3.
Revise TS 3.3.7.6, " Source Range Monitors," to prcvide an exception to the provisions of TS 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 reactor 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 Stadt'y switch positions are specified for this purpose.
5.
Revise TS 3.4.1.2, " Jet Pumps," to correct a typographical error in Surveillance Requirement 4.4.1.2.b.3 by changing " difference-to-lower plenum differential pressure" to " diffuser-to-lower plenum differential pressure."
9209010168 920824 PDR ADOCK 05000354 P
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. 2.0 EVALVATION 15 Section 4.0.4 states that an Operational Condition may not be entered unless the associated surveillance requirements have been performcd. This proposed amendment would provide an exception.to TS 4.0.4 for the IRMs and SRMs for entry into Operationel Condition 2 or 3 from Operational Condition 1 (mode switch in run).
The design of the IRM and SRM instrument circuits prevents the performance of channel functional tests or calibrations when the mode switch is in run because all rod block and scram functions are bypassed.
Consequently, in order to conduct a routine plant-shutdown, either the subject instrumentation must be temporarily modified or the associated action statement must be invoked.
Temporary modifications,-such as installing jumpers and/or lif ting leads, would be required before testing could be performed with the mode switch in the run position, which would increase the likelihood of failure or inadvertent actuation.
The action str ements associated with the 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.
Th uefore, 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 intentional / enter Specification 3.0.3 to conduct routine plant evolutions.
Additionally, this couid potentially and unnecessarily complicate plant operation.
While there is a very low safety significance in allowing the reactor mode to 3
be changed from Operational Condition 1 to Operational Condition 2 or 3 without first performing channel fu'ictional tests or calibrations, it is important to perform these surveillances as soon as the plant is in a condition where the testing is feasible.
in GL 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," the NRC staff position was that a 24-hour allowance to permit completing missed surveillance requirements was reasonable and appropriate.
Permitting an exception to the provisions of Specification 4.0.4 during plant shutdown allows the plant to 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 insertion of rod blocks and hal f ' scrams. Once the plant is placed into Operational Condition 2 or 3, the surveillance requirements are required to be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This exception would only apply during the performance of a plant shutdown (i.e.
entry into Operational Condition 2 or 3 from Operational Condition 1).
The staff finds this specific exception to TS Section 4.0. A acceptable.
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i lhe licensee also requested two administrative changes. One of the proposed i
administrative revisions pertains to 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 L
Condition 3, 4, or 5 to test the switch interlock functions and related
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instrumentation.
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 qualified member of the unit technical staff.
)
A method preferred by the licensee of performing this testing while in hot or cold shutdown is to place the mode switch in Refueling.
By enabling the one-4 j
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 mode switch would be placed in the Refuel position, in lieu of the Run or Startup/ Hot Standby positions, for testing only when this configuration would verify the operability of all the same switch contacts, interlocks, and instrumentation a, when the test is performed with the reactor mode switch in the Run or Startup/ Hot Standby positions, and only when the one-rod-out interlock is operable.
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 i
the Run or Start.up/ Hot Standby positions.
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 Condition i
3 or 4.
The second t.dministrative change is a correction of a typographical error in Surveillance Requirement 4.4.1.2.b.3.
The staff finds these administrative changes acceptable.
3.0 STATE CONSULTATIOR f
I in accordance with the Commission's regulations, the New Jersey State Official i
was notified of the proposed issuance of the amendment.
The State official i
had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amer : nt changes a requirement with respect to installation or use of a facility component located within the restricted area as defined =in 10 CFR Part 20 and changes surveillance requirements.
The NRC staff-has determined that the amendment involves no significant incraase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no si occupational radiation exposure.gnificant increase in individual or cumulative The Commission has previously issued a proposed finding that the amendment' involves no significant hazards s
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. consideration, and there has been no public comment on such finding (57 FR 24678).
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR bl.22(b) no environmental impact statement or environmental asse:sment need be prepared in connection with the issuance of the amendment.
5.0 LONCLUSION The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
A. Keller Date: August 24, 1992
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