ML20205P770
| ML20205P770 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/14/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20205P767 | List: |
| References | |
| NUDOCS 9904200347 | |
| Download: ML20205P770 (4) | |
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t UNITED STATES j
j NUCLEAR REGULATORY COMMISSION f
WASHINGTON. D.C. 20555-.0001
,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.119 TO FACILITY OPERATING LICENSE NO. NPF-57 EUBLIC SERVICE ELECTRIC & GAS COMPANY ATLANTIC CITY ELECTRIC COMPANY HOPE CREEK GENERATING STATION DOCKET NO. 50-354
1.0 INTRODUCTION
By letter dated December 16,1998, as supplemented March 22,1999, the Public Service Electric & Gas Company (the licensee) submitted a request for changes to the Hope Creek Generating Station (HCGS), Technical Specifications (TSs). The requested changes would revise Surveillance Requirements (SRs) 4.8.1.1.2 and 4.8.1.1.3, Table 4.8.1.1.21, and the associated Bases. Specifically, the proposed TS amendment would modify SR 4.8.1.1.2 by replacing the accelerated emergency diesel generator (EDG) testing requirements (i.e., Table 4.8.1.1.2-1) with a maintenance program that monitors EDG performance in accordance with the maintenance rule (i.e., Section 50.65 of Title 10 of the Code of Federal Reoulations (10 CFR 50.65),
- Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Planti'). The proposed TS amendment would also eliminate SR 4.8.1.1.3, which specifies the reporting requirements for EDG failures, since EDG failures would be reported by the requirements of 10 CFR 50.72 (notification requirements) and 10 CFR 50.73 (licensee event reporting system)instead, in addition, the associated TS Bases would be changed to indicate that the Regulatory Guide (RG) 1.108 criteria for determining and reporting valid tests and failures and the accelerated testing of the EDGs have been superseded by implementation of the maintenance rule. The March 22,1999, letter provided clarifying information that did not change the initial proposed no significant hazards consideration detemiination.
2.0 BACKGROUND
i On May 31,1994, the U.S. Nuclear Regulatory Commission issued Generic Letter (GL) 94 01,
" Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," which advised licensees that they may request a license amendment to remove accelerated testing and special reporting requirements for EDGs from pl' t TSs. It also provided guidance on preparing the amendment request and the model l S for this improvement. Generic Letter 94-01 stated that the staff's approval would be contingent upon the licensee's commitment to implement a maintenance program for monitoring and maintaining EDG performance in accordance with the provisions of the maintenance rule, 10 CFR 50.65, and the guidance contained in RG 1.160,
- Monitoring the Effectiveness of Meintenance at Nuclear Power Plants." Generic Letter 94-01 further stated that the fulfillment 9904200347 990414 PDR ADOCK 05000354 P
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- of this commitment need not necessarily result in a new or a separate EDG maintenance program, but rather could be implemented by the modification of existing maintenance program requir;ments that include EDGs.
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The licensee stated that similar changes have been approved by the staff for Salem Nuclear l
Generating Station, Units 1 and 2; Waterford Steam Electric Station, Unit 3; and Turkey Point, 1
Units 3 and 4.
l 3.0 EVALUATION The staff has reviewed the proposed TS SR modifications and changes tc the Bases section I
as described below.
3.1 Modification of SR 4.8.1.1.2 and Deletion of Table 4.8.1.1.2-1 The current SR 4.8.1.1.2 states that:
l 4.8.1.1.2 Each of the above required diesel generators shall be demonstrated OPERABLE:
- a.
In accordance with the frequency specified in Table 4.8.1.1.2-1 on a l
STAGGERED TEST BASIS by:
The licensee proposes to delete the above EDG accelerated test frequency, which refers to an EDG test schedule provided in Table 4.8.1.1.2-1, and proposes to modify the test frequency as follows:
4.8.1.1.2 Each of the above required diesel generators shall be demonstrated OPERABLE:
- a.
At least once per 3'. days on a STAGGERED TEST EiASIS by:
The licensee contends that the proposed change is consistent with the TS improvement endorsed by GL 94-01 because GL 94-01 allows licensees to eliminate the accelerated EDG
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testing from the TSs once the maintenance rule has been implemented. The licensee states j
i that it has now implemented a maintenance program for monitoring and maintaining EDG performance in accordance with the provisions of the maintenance rule and the guidance of RG 1.160, including the following key elements applicable to EDGs:
. Performance criteria for EDG reliability and unavailability, under paragraph (a)(2) of 10 CFR 50.65; Appropriate root cause determination and corrective action following a single i
maintenance-preventable failure; and I
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. Goals and EDG performance monitoring under paragraph (a)(1) of 10 CFR 50.65 if any perf armance criterion is not met, or if a repeat maintenance-preventable failure occurs.
The staff has reviewed the proposed modification to SR 4.8.1.1.2 that allows the licenses to relocate accelerated EDG tesiing requirements from the plant TS to the maintenance program and to delete Table 4.8.1.1.2-1. Based on the fact that: (1) the licensee has implemented the maintenance rule (which went into effect July 1996) and conforms to the guidance of RG 1.160, and (2) the licensee's EDG maintenance program includes the three key elements previously listed that were identified for EDGs in GL 94-01, the staff finds that there is an adequate basis for ensuring EDG performance. As for the deletion of the diesel generator test schedule (i.e., Table 4.8.1.1.2-1), which actually removes the requirement for accelerated EDG testing, the staff has compared the proposed modification with the model EDG TS provided in GL 94-01 and finds them to be identical. The staff concludes that the proposed modification of SR 4.8.1.1.2 and the deletion of Table 4.8.1.1.2-1 from the TSs will ensure that the EDGs would perform their intended functions and would minimize failures; therefore, the proposed changes are acceptable.
3.2 Deletion of Reportina Reauirements of SR 4.8.1.1.3 and Chanae to the Bases Currently, SR 4.8.1.1.3 requires that all EDG f ailures, valid or nonvalid, be reported to the NRC within 30 days. This SR also prescribes that the report shall include certain information, based on the recommendation of Regulatory Position C.3.b of RG 1.108, Revision 1, August 1977.
With the issuance of GL 94-01, the licensee proposes to (1) eliminate this administrative burden of reporting EDG failures by deleting SR 4.8.1.1.3 and (2) revise the TS Bases section to reflect the above TS change.
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The staff reviewed the proposed deletion of SR 4.8.1.1.3 and the proposed change in the TS Bases that inserted a sentence, that states, Regulatory Guide 1.108 criteria for determining and reporting valid tests and failures and accelerated diesel generator testing have been superseded by implementation of the Maintenance Rule for diesel generators per 10CFR50.65." The staff finds that the proposed deletion of SR 4.8.1.1.3 is consistent with the
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changes endorsed by GL 94-01, and also agrees with the licensee that the repurting requirements of 10 CFR 50.72 and 10 CFR 50.73 are adequate for reporting EDG failures, thereby avoiding duplication of reporting EDG failures. The staff concludes that the deletion of i
SR 4.8.1.1.3 and the change to the TS Bases are acceptable.
4.0 STATE CONSULTATION
1 in accordance with the Commission's regulations, the New Jersey State Official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
l The amendment changes surveillance requirements. The NRC staff has determined that the I
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 cumulative occupational radiation exposure. The Commission has previously is. Sued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (64 FR 2251). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmentalimpact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
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 amer.dment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: P. Kang Date: April 14,1999 i
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