ML20199C268

Safety Evaluation Supporting Amend 110 to License NPF-57

ML20199C268
Person / Time
Site:	Hope Creek
Issue date:	11/06/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20199C257	List: ML20199C253 ML20199C268
References
NUDOCS 9711190283
Download: ML20199C268 (5)

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o UNITE] STATES y-1 NUCLEAR REGULATORY COMMIS810N wAsHawof oN, D.C. F dHIO01 SAFETY EVALUATIOh M THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.110 TO FACILITY OPERATING LICENSE NO. NPF-57 PUBLIC SERVICE (LECTRIC & GAS COMPANY ATLANTIC CITY ELECTRIC COMPANY HOPE CREEK GENERATING STATION DOCKET NO. 50-354

1.0 INTRODUCTION

By letter dated August 20, 1997, the Public Service Electric & Gas Company (the licensee) submitted a request for changer, to the Hope Creek Generating Station. Technical Specification (TSs). The requested amendment would change the TSs to provide for:

1) the relocation of suppression chamber volume references in Limiting Condition for Operation (LCO) 3.5.3 to the Hope Creek (HC) Updated Final Safety Analysis Report (UFSAR) and TS Bases as appropriate;

2) the revision of the suppression chamber volume currently listed in LCO 3.5.3.b; 3) the relocation of the suppression chamber volume references in LC0 3.6.2.1.a.1 to the UFSAR and TS Bases; and 4) the revision to the suppression chamber volume reference in TS 5.2.1 to reference the TS Bases section where this information will reside.

2.0 DISCUSSION tiith regard to the proposed relocation of the Torus water volume requirements, the licensee has proposed the relocation of the Torus water volume, specified in TSs 3.5.3, 3.6.2.1.a.1 and 5.2.1 to the UFSAR. Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state TSs to be included as part of the license. The Commission's regulatory requirements related to the content of TSs are set forth in 10 CFR 50.36. That regulation requires that the TSs include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulat'on does not specify the particular requirements to be included in a plant's TSs.

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-t-The regulation does set forth four criteria to be used in determining whether f

a limiting condition for operation is required to be included in the TS:lcate j

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follows:

(1)

Installed in u runentation that is used to detect, and ind in the control room, a significant abnormal degradation of the reactor coolant 4

pressure boundary; (2) a pror.ess variable, des'gn feature, or operating l

restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge j

to the integrity of a fission product barrier; (3) a structure, system, or i

component t1at is part of the primary success path and which functions or j

actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents-a challenge to the integrity of a fission product probabilis(4)astructure, system,orcomponentwhichoperatingexperienceor barriera I

tic safety assessment has shown to be significant to public health and safety.

Existing TS requirements which fall within or satisfy any of the l

criteria must be retained in the TSs, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.

The application also addresses a proposed change to the existing Torus water volume as specified in TS 3.5.3.b, and minor wording changes to the TS that

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are necessitated by removal of the Torus water volume requirements.

In addition, the licensee has preposed a change to TS 5.2.1 that would reference the TS Bases to identify the location of the requirements for Torus water volume.

3.0 EVALUATION The August 20, 1997 application seeks to relocate the Torus Water volume from TS 3.5.3, 3.6.2.1.a.1 and 5.2.1 tt the UFSAR. The Torus, also referred to as i

the suppression chamber, is a toru -shaped tank located below, and connected t

- to, the drywell that contains the-reactor pressure vessel and connected piping. During normal operation, the Torus absorbs heat from safety-relief t

valves and other sources. Under Loss-of-Coolant accident conditions, the Torus suppresses drywell pressure and provides a source of water for long-term core cooling. The staff's review of the proposed changes determined that the relocation of the Torus water volume does not eliminate the requirements for the licensee to ensure that the Torus water volume is properly matatained.-

Once the Torus water volume is relocated from the TSs to the UFSAR, the licensec must continue to evaluate any changes to it in accordance with 10 CFR i

50.59. Should the licensee's detemination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, i

(2) the creation of a possibility for an accident or malfunction of a-different tyn than any evaluated previously, or (3) a reduction in the margin of safety, NY approval and a license amendment would be required prior to implementation of the change. NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to updated L

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final safety analysis report commitments and to take any remedial action that l

may be appropriate. Furthermore, there is a direct relationship between torus and torus water level. The TS will continue to j

water volume Cinventory) level limit for ECCS purposes and minimum / maximum specify a sintmum water i

level lidits for containment functional purposes. This will provide assurance that the licensee will bring the plant to a safe condition in the event that the water volume (inventory) is outside acceptable limits for the operating condition.

The staff's review has concluded that 10 CFR 50.36 does not require the Torus water volume to be retained in the TSs.

Torus water level, alone, satisfies the requirements of Crf terton 2 of 10 CFR 50.36 as discussed above. Moreover, Torus water level is an observable " process variable" which is available to the plant operators while Torus water volume must be calculated; thus, Torus water level is more appropriate as one observable measure of Torus operability.

The Torus water level will continue to be specified in TS 3.5.3a and b, and 3.6.2.1.a.l.

However, the staff determined that the inclusion of the Torus water volume is an operaticaal detail related to the licensee's safety analyses which are adequately controlled by the requirements of 10 CFR i

50.59. Therefore, the continued processing of license amendments related to revisions of the affected TS 3.5.3, 3.6.2.1.a.1 and 5.2.1 where the revisions to those requirements do not involve an unreviewed safety question under 10 4

CFR 50.59, would afford no significant benefit with regard to protecting the t

public health and safety. Accordingly, the relocation of the Torus Water l

volume from TS 3.5.3, 3.6.2.1.a.1 and 5.2.1 to the UFSAR is acceptable.

With regard to the Torus water volume specified in TS 3.5.3.b. for OPERATIONAL CONDITIONS 4 and 5 (COLD SHUTDOWN AND REFUELING, respectively), the licensee is proposir.3 that the minimum specified Torus water volume be reduced from 57,390 cubic feet to 57,232 cubic feet, a reduction of 0.3%. The proposed Torus water volume reduction is needed to support installation of improved Torus suction strainers in accordance with NRC's Generic Letter 96-03, i

" Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling Water Reactors", May 6, 1996. As indt.:ated in TS Bases 3/4.5.3, the minimum Torus water volume under OPERATIONAL CONDITIONS 4 and 5 is based upon not positive suction head (NPSH), recirculation volume, vortex prevention and a safety margin. The licensee has performed a qualitative assessment of Emergency Core Cooling System performance under OPERATIONAL CONDITIONS 4 and 5 and has concluded that a reduction of 0.3% Torus water volume will have no-i detrimental effects on safety system performance. The NRC Staff agrees with the licensee's assessment, considering the relatively small ange in Torus Water volume, and finds the change to be acceptable.

- The licensee has also proposed minor wording changes to Th 3.5.3 and 3.6.2.1.a.1 that are necessitated by remova of the Torus water volume requirements.

For example, the phrase "at least" would be inserted in the

. text of TS 3.5.3, before the indicated Torus water level, to retain the meaning of the TS requirement. These changes are minor, are of an administrative and clarifying nature, and-do not effect the TS requirements.

Accordingly, these proposed changes to the TS are acceptable.

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i Finally, the licensee has proposed an addition to TS 5.2.1 that would reference the TS Bases to identify the location of the requirements for Torus water volume.

At the current time, TS Bases 3/4.6.2 contains the applicable Torus Water volume, which is not changed by the proposed TS. This reference is helpful to the TS user, is administrative in nature, and does not effect any safety requirement in the TS.

Based upon the above, the proposed change to TS 5.2.1 is acceptable.

The relocation of the Torus water level to the UFSAR will be undertaken in accordance with a license condition contained in Appendix C to the Facility Operating License, NPF-57, for Hope Creek Generating Station.

By letter dated October 28, 1997, the licensee indicated their agreement with the subject license condition.

4.0 STATE CONSULTATION

in accordance with the Commission's regulations, the New Jersey State Official was notified of the proposed issuance of the amendment.

In an October 24, 1997 telephone conversation, the State official, Mr. R. Pinney noted that, while the Torus volume had been removed from TS 3.6.2.1, TS 4.6.2.1.a still requires that the Torus volume be verified to be within specified limits every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During a subsequent inspection, 'st was determined that the licensee is required, by procedure, to determine that the Torus level is within specified lier.f ts every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. A note appears at the bottom of the procedure data sheet which correlates acceptable Torus level to an acceptable Torus volume.

Thus, the licensee can comply with TS 3.6.2.1, as amended, and TS 4.6.2.1.a.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility componer.t located within the restricted atea as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or c;mulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (62 FR 50010). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR St.22(c)(9).

Pursuant to 10 CFR St.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

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6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

there is reasonable assurance that the health ar.d safety of the i

public w(1)l not be endangered by operation in the proposed manner, (2) such il 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:

D. H. Jaffe Date: November 6, 1997 l

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