Text

Application for Amend to License NPF-57,revising TS to Improve Consistency Between TS & Plant Configuration, Operation & Testing & Complete Required CA to Resolve TS Discrepancies Identified in CA Program
	ML20137M106
Person / Time
Site:	Davis Besse, Hope Creek
Issue date:	03/31/1997
From:	Storz L; Public Service Enterprise Group
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137M112	List: ML20137M106; ML20137M133;
References
	LCR-H97-11, LR-N97158, NUDOCS 9704080014
	Download: ML20137M106 (12)
	v • d • e

1 e

i Pubhc Service Uectnc and Gas c-~ MAR 311997 Louis F. Storz PutAc Service Dectre and Gas Company P.O. Box 236. Hancocks Bridge, NJ 08038 fX)9-333-5700 Sorwr V(e President . fM! ear Oswatms LR-N97158 l LCR H97-11 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS HOPE CREEK GENERATING STATION EACILITY OPERATING LICENSE NPF-57 ,

DOCKET NO. 50-354 Gentlemen:

In accordance with 10CFR50.90, Public Service Electric & Gas l (PSE&G) Company hereby requests a revision to the Technical !

Specifications (TS) for the Hope Creek Generating Station (HC).

In accordance with 10CFR50.91 (b) (1), a copy of this submittal has been sent to the State of New Jersey. ;

The proposed revisions contained in this submittal resolve TS related issues documented in Hope Creek's Corrective Action Program. Implementation of these proposed changes will: 1) ;

result in a more clearly defined licensing basis for Hope Creek;

2) improve the consistency between the TS and plant configuration, operation and testing; and 3) complete required corrective actions to resolve TS discrepancies identified in the Corrective Action Program. Specifically, the proposed changes ,

are being made to: 1) provide an appropriate LCO and ACTION Statement for the Filtration, Recirculation and Ventilation System (FRVS); and 2) clarify the manner in which FRVS testing is i performed.

The issues concerning the FRVS LCO were documented in LER 97-002-00, dated February 14, 1997. As stated in that LER, administrative controls have been implemented to compensate for the currently inadequate Technical Specification LCO. These I administrative controls ensure that FRVS: 1) is operated and maintained in accordance with its design basis; and 2) ;

operability requirements are consistent with the licensing basis description contained in Hope Creek's UFSAR.

NRC approval of these changes is requested prior to initiation of the next refueling outage to: 1) provide a suitable Technical Specification LCO that protects the FRVS design basis; and 2) 3 permits the elimination of compensatory measures that have been A implemented to maintain FRVS operability requirements. 1 -

9704000014 97o331 , 1 PDR ADOCK 05000354 i

" "" appsppppmP5 Printed on

@ FlecycledPaper

Document. Control Desk ;

LR-N97158 The proposed changes affect the following sections of the Hope Creek TS: 1) 3.6.5.3, " Filtration, Recirculation and Ventilation System (FRVS)"; and 2) Surveillance Requirement 4.6.5.3.2.b.

The proposed changes have been evaluated in accordance with i 10CFR50. 91 (a) (1) , using the criteria in 10CFR50.92 (c), and a ;

+

determination has been made that this request involves no significant hazards considerations. The basis for the requested change is provided in Attachment 1 to this letter. A 10CFR50.92 evaluation, with a determination of no significant hazards consideration, is provided in Attachment 2. The marked up Technical Specification pages affected by the proposed changes are provided in Attachment 3.

Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities.

Should you have any questions regarding this request, we will be pleased to discuss them with you.

I Sincerely, W .

pan -

Affidavit Attachments (3) i I

i

. l Docpment. Control Desk LR-N97158 C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 ,

5 Mr. D. Jaffe, Licensing Project Manager - HC U. S. Nuclear o.egulatory Commission One White Flint North -

11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. R. Summers (X24)

USNRC Senior Resident Inspector - HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway I

CN 415 Trenton, NJ 08625 !

i l

~ . . . . . - . ._ . ~ . _ . _ _ _. _.~ . _ _ .._ __ . _ _ _ . - . _ .

, - * . j t

~ REF: LR-N97158 :

' -LCR H97-11 >

fs . STATE OF NEW JERSEY . ) {

. . - ) SS.

.- COUNTY OF SALEM ) i L.EF.: Storz, being duly sworn according to-law deposes and'says: :

4 -

-lI am Senior Vice President - Nuclear Operations of.Public Service l

1 Electric and Gas Company, and'as such, I find the matters set j forth'in'the above referenced letter, concerning Hope Creek- {

Generating Station, Unit 1; are true to the best of my knowledge, !

) .information'and~ belief.

a a

V / !

ARN ~

1

(. -) l

(

Subscribed and Swo n to'before me !

this d / i day o- AA 1_., , 1997 !

7 :

, i lhb . . n m.

7TZlAA Notary Publiy df New Jersey :

KIMBERLY J0 BROWN O NOTARY PUBUC 0F NEW JERSEY j W Wssion Empires April 21,1998 My. Commission expires on i

~

f i

i

~'

{

i. ,

s k

i 4

C ,

. , 3o , ,. . - _ __ --- .

Document Control D:ck LR-N97158 Attcchment 1 LCR H97-11 2

4 HOPE CREEK GENERATING STATION EACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 i REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS)

BASIS FOR REQUESTED CHANGE: :

1 The changes proposed in this request: 1) provide an appropriate LCO and ACTION Statement for the Filtration, Recirculation and Ventilation System (FRVS); and 2) clarify the manner in which FRVS testing is performed. These changes are being made to: 1) provide a more clearly defined licensing basis for Hope Creek; 2) provide a suitable Technical Specification LCO which protects the ,

FRVS design and licensing basis; and 3) complete required ,

corrective actions to resolve TS discrepancies identified in the Hope Creek Corrective Action Program.

REQUESTED CHANGE AND PURPOSE:

FRVS Recirculation Subsystem LCO Changes As shown in Attachment 3 of this letter, LCO 3.6.5.3.2 is being revised to include all six FRVS recirculation units installed at Hope Creek. In addition, the ACTION Statements for that LCO are being revised to: 1) provide a seven day allowable outage time (AOT) for either one or two inoperable FRVS recirculation units in ACTION Statement (a.); 2) provide an appropriate action for Operational Condition

which reflects the new LCO; and 3) provide a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months shutdown action requirement when three or more FRVS recirculation units are inoperable. The purpose of these changes is to: 1) establish appropriate AOTs for FRVS recirculation units within the TS; and 2) preclude the need to enter TS 3.0.3 during situations where three or more FRVS recirculation units are inoperable.

Surveillance Requirement 4.6.5.3.2.b Clarification Currently, Surveillance Requirement 4.6.5.3.2.b specifies testing of the FRVS recirculation units with their heaters "on" in order to reduce buildup of moisture on the unit's carbon adsorbers and HEPA filters. As indicated in Attachment 3 of this letter, this surveillance requirement is being revised to more precisely state that the FRVS recirculation unit heaters must be " operable" during the 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months test. The purpose of this change is to provide accurate and clearly defined criteria for performing this surveillance requirement within the Hope Creek TS.

Page 1 of 5

Document Crntrsl D;;k LR-N97158

- Attachment 1 LCR H97-11 BACKGROUND:

The proposed TS revisions will be discussed separately as indicated below:

FRVS Recirculation Subsystem LCO Changes On January 17, 1997, during preparation of a 10CFR50.59 safety >

evaluation to support a plant modification, an inconsistency was discovered between the FRVS Recirculation Subsystem TS and the design basis documents of the FRVS. In assessing this inconsistency, PSE&G concluded that the LCO for the FRVS Recirculation Subsystem does not assure the availability of the prescribed number of FRVS recirculation units to fulfill system functions in conjunction with a postulated single failure as described in the updated Final Safety Analysis Report (UFSAR).

In accordance with 10CFR50.73 requirements, PSE&G notified the NRC of this issue via LER 97-002-00, dated February 14, 1997.

In that LER, PSE&G discussed how the current LCO requires only five (out of six total) recirculation units to be operable to support indefinite continued plant operation. However, operation in the Technical Specification permitted configuration does not ensure that the number of FRVS recirculation units assumed in the UFSAR would be available to mitigate the consequences of a design basis accident. Specifically, PSE&G determined that: 1) four l FRVS recirculation units are assumed to mitigate the consequences )

of postulated accidents; 2) indefinite plant operation with five ;

operable FRVS recirculation units requires that a single failure ,

be postulated coincident with a design basis accident; and 3) a j single failure in the FRVS Recirculation Subsystem support 1 systems can result in less than the assumed number of FRVS !

recirculation units being available to mitigate an accident. l Therefore, PSE&G has concluded that an LCO for six FRVS recirculation units is required to appropriately control FRVS I Recirculation Subsystem availability to maintain system operation ;

within its design basis.

Surveillance Requirement 4.6.5.3.2.b Clarification !

On August 28, 1991, PSE&G transmitted LER 91-007-02 to the NRC to document three occurrences where TS 3.0.3 was entered due to inoperable FRVS recirculation units. In that LER, PSE&G stated that the method for performing FRVS surveillances at the time 4 contributed to the FRVS failures documented in the LER.

Specifically, PSE&G concluded that performing Surveillance Requirement 4.6.5.3.2.b with the heaters operating (energized and Page 2 of 5

Document Control D ek LR-N97158 Attachment 1 LCR H97-11

, t 4 dissipating heat): 1) resulted in a degradation of the ;

electrical components in the FRVS recirculation unit; and 2) did not' represent actual system operation during accident mitigation. ,

One of the corrective actions taken for these events included a i i

revision to FRVS surveillance procedure HC.OP-ST.GU-0001(Q) .

This revision required the FRVS heaters to be on and energized, 4

'but did not require the FRVS heaters to be continuously dissipating heat, when this surveillance was conducted. To '

. justify this change, PSE&G had concluded, in part, that: 1) this surveillance method reflected actual standby conditions of the i FRVS Recirculation Subsystem; 2) this surveillance method was consistent with methods performed at other facilities; 3) testing under the previous method with heaters operating had resulted in component temperatures exceeding their environmental ;

qualifications and postulated post-accident conditions; 4) !

operability testing of the FRVS unit heaters was appropriately 3

tested by other TS surveillances; and 5) the surveillance method

! was consistent with the guidance contained in the Hope Creek licensing and design bases by being consistent with USNRC >

Regulatory Guide 1.52, " Design, Testing and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup ,

System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants." The FRVS recirculation units have been :

tested with the heaters: 1) operable; and 2) set at the demand o necessary to " reduce the buildup of moisture."

In 1996, questions concerning the method for performing Surveillance Requirement 4.6.5.3.2.b were entered into the Corrective Action Program. This question prompted a re-review of <

the conclusions reached when revising the aforementioned i surveillance procedure in 1991. This review reaffirmed PSE&G's l

, position for satisfying this surveillance test; however, PSE&G l concluded that a TS change should be processed to preclude any further questions concerning the basis for performing this surveillance test. Approval of the changes proposed in this submittal would clearly define the licensing basis for satisfying this surveillance requirement.

Page 3 of 5

, --e-~ . - -

r-

D cument Centrol D0ck LR-N97158 Attachment 1 LCR H97-11 1

1

. JUSTIFICATION OF REQUESTED CHANGES ,

The proposed TS revisions will be discussed separately as follows:

FRVS Recirculation Subsystem LCO Changes l LCO 3.6.5.3.2 is being revised to: . 1) establish appropriate AOTs for inoperable FRVS recirculation units within the TS; and 2) -

preclude the need to enter TS 3.0.3 during situations where three 7 or'more FRVS recirculation units are inoperable. Based upon the '

information contained in the following paragraphs, PSE&G has concluded that these proposed changes are justified. 2 Incorporating a sixth FRVS unit into the TS LCO provides consistency between the Hope Creek TS and the post-accident assumptions for FRVS Recirculation Subsystem operation already !'

contained in the UFSAR and reflected in the Hope Creek SER i

' (NUREG-1048). A conservatively short AOT for the sixth unit will

- ensure that the required minimum number of FRVS recirculation j units will be available (in addition to postulated single ;

failures) to mitigate the consequences of accidents described in ,

the UFSAR. PSE&G believes that an AOT of seven days is _

~

sufficiently conservative since: 1) it is consistent with the AOT already established in the Hope Creek TS with only four FRVS recirculation units operable; and 2) it is equivalent to the AOTs !

established in the BWR/4 Standard Technical Specifications and '

the Improved Standard Technical Specifications (NUREG-1433) for one inoperable train of a two train Standby Gas Treatment system. !

Currently, the Hope Creek TS do not have an ACTION Statement that specifically addresses plant operation with less than four FRVS ;

recirculation units operable. If less than four FRVS l recirculation units are operable, then the provisions of TS 3.0.3 l' are utilized to control continued plant operation. PSE&G believes that a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months HOT SHUTDOWN ACTION Statement is more

_ appropriate for this level of FRVS Recirculation Subsystem degradation since it is more conservative than the requirements e of TS 3.0.3 for placing the unit in a safe shutdown condition. .

Implementation of these proposed changes will result in a j reduction in the regulatory reporting burden for Hope Creek l whenever less than four FRVS recirculation units are operable.

Surveillance Requirement 4.6.5.3.2.b Clarification The revision to Surveillance Requirement 4.6.5.3.2.b is being ,

made to provide an accurate'and clearly defined basis for ,

performing this surveillance requirement. The proposed changes Page 4 of 5 1

..v

~ , , ,

4 D cument Ccntrol Dock LR-N97158 l LCR H97-11 Attcchment 1 i

implement PSE&G's existing interpretation of the TS requirements .

and therefore do not alter the manner in which this surveillance i test is currently performed. 6 The proposed changes result in a surveillance requirement that clearly states that the FRVS heaters must be operable (i.e., j

~

cycling on and off as required to reduce the buildup of moisture on.the carbon adsorbers and HEPA filters) when this monthly surveillance is conducted. PSE&G has concluded that this ;

surveillance test method: 1) appropriately reflects actual j standby conditions of the FRVS Recirculation Subsystem; 2) is j consistent with. methods performed at other facilities (as ;

acknowledged during the' development of the Improved Technical .

Specifications); 3) ensures that FRVS recirculation uni' l component temperatures do not exceed their environment - 1 (

qualifications and postulated post-accident conditions; and 4) ;

does not conflict with the guidance contained in USNRC Regulatory !

Guide 1.52, " Design, Testing and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air :

Filtration and Adsorption Units of Light-Water-cooled Nuclear

]

Power Plants." Since the FRVS recirculation units will continue .

to be tested with the heaters: 1) operable; and 2) set at the :

demand necessary to " reduce the buildup of moisture," PSE&G believes that the proposed changes to clarify the TS are justified.

CONCLUSIONS:

The changes proposed in this request are being made to resolve compliance related issues involving Hope Creek's licensing basis.

PSE&G concludes that these proposed changes are adequately justified and result in No Significant Hazards Considerations as described in Attachment 2 of this letter.

i 1

Page 5 of 5

. . - . - . - - , ~ . . - - - , . . . - . . . - . - . - .

Document Control Dack LR-N97158 Att0chment 2 LCR H97-11 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 -

REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS) .

10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the !

proposed changes to the Hope Creek Generating Station (:HC)

Technical Specifications do not involve a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below.

REQUESTED CHANGE The proposed changes affect the following sections of the Hope i Creek TS: 1) Limiting Condition for Operation (LCO) 3.6.5.3,

" Filtration, Recirculation and Ventilation System (FRVS)"; and 2)

Surveillance Requirement 4.6.5.3.2.b. Specifically, these changes are being made to: 1) provide an appropriate LCO and .

ACTION Statement for the Filtration, Recirculation and Ventilation System (FRVS); and 2) clarify the manner in which l FRVS testing is performed. l BASIS

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously eval ua ted.

The proposed TS revisions involve: 1) no hardware changes; 2) no significant changes to the operation of any systems or components in normal or accident operating conditions; and 3) no changes to existing structures, systems or components. Therefore these changes will not increase the probability of an accident previously evaluated.. Since the plant systems associated with these proposed changes will still be capable of: 1) meeting all applicable design basis requirements; and 2) retaining the capability to mitigate the consequences of accidents described in the HC UFSAR, the proposed changes were determined to be justified. As a result, these changes will not involve a significant increase.in the consequences of an accident previously evaluated.

Page 1 of 3

t t

Document C:ntral D30k LR-N97158 Attachment 2 LCR H97-11 ,

2. The proposed change does not create the possibility of a new l or different kind of accident from any accident previously i eval ua ted.

~

The proposed changes. contained in this submittal will not -

adversely impact the operation of any safety related component or equipment. Since the proposed changes involve: 1) no hardware changes; 2) no significant changes to the operation of any systems or components; and 3) no changes to existing structures, i systems or components, there can be no impact on the potential. .

occurrence of any accident. Furthermore, there is no change in i plant testing proposed in this change request which could initiate an event. Therefore, these changes will not create the possibility of a new or different kind of accident from any +

accident previously evaluated. .

3. The proposed change does not involve a significant reduction ;

'in a margin of safety.

The proposed changes for the TS related to the Filtration >

Recirculation and Ventilation System (FRVS) Recirculation Subsystem provide consistency between the Hope Creek TS and post- l accident descriptions of the FRVS Recirculation Subsystem !

operation already contained in the UFSAR and reflected in the ,

Hope Creek SER (NUREG-1048). PSE&G believes that the proposed >

allowed outage times and ACTION Statements for the FRVS Recirculation Subsystem: 1) will ensure that the required minimum number of FRVS recirculation units will be available to !

mitigate the consequences of accidents described in the UFSAR; ;

and 2) provide appropriate direction and time requirements for i placing the unit in a safe shutdown condition when the system is degraded. Therefore, the changes contained in this request do not result in a significant reduction in a margin of safety.

The revisions to Surveillance Requirement 4.6.5.3.2.b provide an ,

accurate and clearly defined basis for performing this ;

surveillance test. The proposed changes implement PSE&G's existing interpretation of the TS requirements and therefore do '

not alter the manner in which this surveillance test is currently being performed. PSE&G has concluded that this surveillance test method appropriately tests the FRVS Recirculation Subsystem. ;

Since the FRVS recirculation units will continue to be tested with the heaters: 1) operable; and 2) set at the demand necessary to " reduce the buildup of moisture," PSE&G believes that the proposed changes to clarify the TS are justified. !

Therefore, the changes contained in this request do not result in f a significant reduction in a margin of safety. i 1

Page 2 of 3 e < - - - ,

Document Control Dark LR-N97158 Attcchment 2 LCR H97-11 CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

Page 3 of 3

ML20137M106

Text

Navigation menu

Search