ML20210P334
| ML20210P334 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/20/1997 |
| From: | Eric Simpson Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20210P339 | List: |
| References | |
| RTR-NUREG-1433 IEB-96-003, IEB-96-3, LCR-H97-15, LR-N97505, NUDOCS 9708270062 | |
| Download: ML20210P334 (10) | |
Text
- _ _ - _ -
g Public Service Electne and Gas cornpany -
E. C. Simpson Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 00038 000-339 @ 00 s.n= vee newns. Nudes EnynewinD AUG 20 997 1
LR-N97505 LCR H97-15 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR' CHANGE TO TECHNICAL SPECIFICATIONS ELIMINATION OF SUPPRESSION POOL WATER VOLUME REFERENCES HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company hereby requests a revision to the Technical Specifications (TS) for the Hope Creek Generating Station.
In accordance with 10CFR50.91(b) (1), a copy of this submittal has been sent to the State of New Jersey.
j The proposed TS revisions represent changes to specifications 3/4.5.3, " Emergency Core Cooling Systems, Suppression Chamber,"
3/4.6.2,'"Depressurization Systems,-Suppression Chamber," and 5.2.1, " Containment Configuration."
The proposed changes delete references to the Hope Creek's suppression pool water volume from the Technical Specifications and are being made to support planned modifications to Emergency Core Cooling System suction strainers in tha upcoming refueling outace.
These plant modifications.tddress issues raised in NRC Bulletin 96-03,
" Potential Plagging of Emergency Core Cooling-Suction Strainers By Debris In Boiling Water Reactors."
-Information pertaining to the suppression pool water volume will be contained in the Updated Final Safety Analysis Report (UFSAR) and TS-Bases as appropriate, and will be subjact to the provisions of 10CFR50.59 for any changes.
Thc resultant TS Limiting Condition for Operation would contain pertinent information.concerning suppression pool parameters equivalent to that retained in NUREG-1433, " Standard Technical Specifications, Ok General Electric Plants, BWR/4."
-The-proposed changes have been evaluated in accordance with 10CFR50. 91 (a) (1), using the criteria in 10CFR50.92 (c), and a determination has been made that this request involves no 3
\\
9708270062 970820 '
PDR ADOCK 05C00354
@ Printedon l}!,!!{!!,!!,
e.
Recycled Paper j
l l'
AUG 2 0 997 1
i L
Cocument Control Desk l LR-N9'7505 l
l significant hazards considerations.
The basis for the requested l
TS changes is provided in Attachment 1 to this letter.
A l
10CFR50.92 evaluation, with a determination of no significant I
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 im pleased to discuss them with you.
i Sincerely.,
,/
/%
P1 Affidavit Attachments (3)
C Mr. H. Miller, Administrator - Region i U.
S. Nuclear Regulatory Commissior.
475 Allendale Road King of Prussia, PA 19406 Mr. D. Jaffe, Licensing Project Manager - HC U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 l
Mr.
S. Morris (X24) l USNRC Senior Resident Inspector - HC l
Mr. K. Tosch, Manager IV Dureau of Nuclear Engineering l
33 Arctic Parkway l
PO Box 415 Trenton, NJ 08625 l
l I
t
a.
REF: LR-N97505 LCR 1197-15 STATE OF NEW JERSEY )
)
SS.
COUNTY OF SALEM
)
E. C. Simpson, being duly sworn according to law deposes and says:
l 1 am Senior Vice President - Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief.
1 7
/
v v
- OTOMd t
g Subscribed and Sworn before me this M M day of i a na A f, 1997
,~
g
,.f LAnn llt.
A R
lDlLA%
NptaryPubl1c(.'hewJersey KIMBEALY JO BROWN NOTA 0V PUDUC Of NEWJERSEY My Commission expires on l
m,---
Document Cantrol Ccck LR-N97505 AttCchment 1 LCR H97-15 4
HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE HPF-57 DOCKET NO. 50-354 SUPPRES8 ION POOL VCLUME REFERENCE ELIMINATION BASIS-FOR REQUESTED CHANGE AND PURPOSE
. Modifications to.the Residual Heat Removal (RHR) and Core Spray H
(CS) systems' suction strainers are being planned at Hope Creek
.to-address issues raised in NRC Bulletin 96-03, " Potential Plugging of Emergency Core Cooling-Suction Strainers by Debris in Boiling-Water Reactors."
As stated in PSE&G's letter, LR-
- N 97 0 092,.- dated May 20,-1997, these modifications will be installed during Hope Creek's upcoming refueling outage (RF07).
To support these-modifications, PSE&G performed calculations to determine the impact-that this modification would_have on the suppression chamber water volume.
These calculations determined that the suppression chamber water volume listed in TS 3.5.3 b (applicable in Operational Conditions 4 and 5, COLD SHUTDOWN and REFUELING) need to be revised in order to permit installation of the new strainers using the provisions of 10CFR50.59.
This TS change is required since the introduction of the submerged structures and components for the RHR and CS strainer installation would-render the suppression pool volume for the corresponding suppression pool level-limit contained in TS 3.5.3.b incorrect.
In order to provide a uniform level of information concerning suppression _ pool parameters in the TS for other Operational Conditions and to further improve consistency with NUREG-1433,
" Standard Technical Specifications, General Electric Plants, BWR/4," the references pertaining to suppression pool water volume in other TS are also being removed.
The. elimination of these other-suppression pool volume references.in the TS and retention in the UFSAR and TS Bases require any proposed changes to be subjected to'the provisions of-10CFR50.59.
The changes proposed in this submittal consist of:
- 1) the relocation of.suppressicn pool volume references in Limiting
' Condition for Operation (LCO) 3.5.3 to_the UFSAR and TS Bases as appropriate;'.O the1 revision of the suppression-pool volume currently listed in LCO 3.5.3.b; 3) the relocation of the suppression pool volume references in LCO 3.6.2.1.a.1 to the-UFSAR and-TS Bases as app;opriate; and 4) theLrevision to the j_
suppression poni volume 1 reference in TS 5.2.1 to reference the TS Bases section.
Pege 1 of 4 i
le
..a.-...
-.a=-.
~
D:cunent C:ntrol D:Ch LR-N97505 AttCchment 1 LCR H97-15 BACKGROUND On May 6, 1996, the NRC issued NRC Bulletin 96-03 to BWR licensees, which described events at other BWRs where plugging or clogging of Emergency Core Cooling System (ECCS) suction strainers occurred.
In the Bulletin, the NRC stated that the potential exists for BWR ECCS pumps to lose net positive suction head (NPSH) margin due to clogging of the suction strainers by LOCA-generated debris.
The NRC requested licensees to implement appropriate procedural measures and plant modification to minimize the potential for clogging of ECCS suppression pool l
suction strainers by this LOCA generated debris.
l On May 20, 1997, via letter LR-N970092, PSE&G provided Hope Creek's proposed resolution to the issues identified in NRC Bulletin 96-03.
This resolution consists of the installation (during the next refueling outage, RFO7) of large capacity passive strainers on the CS and RHR system pump suction lines to ensure long term operability of the ECCS.
The design of the passive strainers utilized the Boiling Water Reactor Owners Group (BWROG) Utility Resolution Guidance (URG) as the basis for sizing the passive ECCS suction strainers.
PSE&G's May 20th response also stated that evaluations concerning the need to change the TS to account for the volume of water displaced by the replacement strainers would take place after the final strainer design was determined.
In performing these evaluations, PSE&G has concluded that the submerged structures and components for the new strainers would impact the suppression pool water volume listed in the TS for Operational Conditions 4 and 5.
To resolve these licensing basis issues, PSE&G_has proposed that the references to the suppression pool volume during Operational Conditions 4 and 5 be revised and relocated from the TS to the UFSAR and that the other references to suppression pool volume be removed from the TS and retained in the UFSAR and TS Bases.
Justification for this resolution is contained in the following paragraphs.
Approval of these proposed changes would enable PSE&G to implement the ECCS suction strainer modifications using the provisions of 10CFR50.59.
JUSTIFICATION OF REQUESTED CHANGES:
I l
The details concerning the design of the new ECCS suction strainers are contained in PSE&G's letter LR-N970092, dated May 20, 1997, and LR-N970415, dated July 18, 1997.
Page 2 of 4
i C ',-
t D:oument Contr31 D30k-LR-H97505 LCR H97-15 i
j Operational Conditions 4 and 5
- The revision and elimination of the suppression pool-volume reference contained in TS 3.5.3.b would:
- 1) result in an LCO that is more consistent with that contained in the Improved i
Technical Specifications (NUREG-1433); and 2) have no adverse l
impact on the ability of the suppression pool or supported i
Emergency Core Cooling System (ECCS) components to perform their intended safety functions in those operational conditions.
As j
already stated in the Hope Creek TS Bases 3/4.5.3:
1 e
"In OPERATIONAL CONDITION 4 and 5 tho' suppression chamber 8
minimum required water volume is reduced occause the reactor coolant is maintained at or below 200 degrees F-(except as-provided by TS 3.10.8).
Since pressure. suppression is not i
required below 212 degrees F, the minimum-water volume is l
based on NPSH, recirculation volume and vortex prevention plus a safety margin for conservatism."
l i
TS 3.5.3 b states that there should be 57,390 cubic feet of water in the suppressien chamber when the suppression chamber has an 4
indicated water level of 5 inches.
The volume displaced by the s
new strainers is approximately 150 cubic feet or about 0.3% of the volume of water in the suppression pool at the minimum l
indicated level.
Through qualitative. assessments of ECCS l
- performance-with the proposed suction strainer modifications, PSE&G has concluded that the reduction in water volume due-to the installation-of the.new strainers at the minimum indicated j
suppression pool water. level (corresponding to a volume of 57,232
{
-cubic feet) will-have.no detrimental impact in_ Operational Conditions 4 and 5.
By retaining the 5 inch minimum-suppression-l pool water level limit within the TS, adequate provisions for:
Retaining ~only the minimum required suppression pool level limit.in the TS-for Operational 4
f Conditions 4 and 5 would be consistent with the= Improved y
Technical Specifications and is sufficient (without a-minimum specified volume.which will be relocated to the UFSAR) to' ensure-i operability.of the suppression pool and its-supported components, Operational Conditions 1, 2 and 3 g
t The removal and relocation of the suppression pool volume references from the TS to the UFSAR and Bases for Operational' Conditions 1, 2 and 3 is also. consistent with the. Improved-
. Technical'.ipecifications.
For these changes, PSE&G will retain references to the suppression pool volume at the indicated level of 74.5 inches in the_UFSAR and TS Bases.
Any changes to this -
I L
-Page 3 of 4 I
r
'-,.,,m-.,
u -,,,
,,,k,,,,,-,
_-_.y-,,m,~.,
w'i. -w
-.-+-y,Q,,..<J~,,mn.~~l~~
,n,,,,-.,,eminn,,--,-y,,,
r 4,,,.,
D:cument C:ntrol D ck LR-N97505 AttOchment 1 LCR H97-15 Volume would be evaluated using the provisions of 10CFR50.59.
For the planned RF07 ECCS suction strainer modifications, PSE&G has concluded that there will be no reduction in the 118,000 cubic feet water volume (as defined in UFSAR Table 6.2-1) assumed at the minimum 74.5" minimum water level (since there is actually more than 118,000 cubic feet of water at the minimum specified level), therefore no adverse impact on suppression pool parameters would occur.
Retaining only the minimum required suppression pool level limit in the TS for Operational Conditions 1, 2 and 3 would be consistent with the Improved Technical Specifications and is sufficient (without a minimum specified volume) to ensure operability of the suppression pool and its supported components.
PSE&G believes that the above conclusions justify the TS changes being proposed in this submittal and will not challenge the systems, structures and components from performing their safety functions.
CONCLUSIONS:
PSE&G has concluded that these proposed changes are adequately justified and result in No Significant Hazards Considerations as described in Attachment 2 of this letter.
Page 4 of 4
L D:cument Centrol D00k LR-N97505 Attochment 2 LCR H97-15 i
?
HOPE. CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 i
DOCKET NO. 50-354 SUPPRESSION POOL VOLUME REFERENCE DELETION 8 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Hope Creek Generating Station 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 1
provided_below.-
REQUESTED CHANGE
-The proposed changes in this request consist oft
- 1) the f
relocation of suppression pool volume references in Limiting Condition for Operation (LCO) 3.5.3-to the UFSAR and TS Bases as appropriate; 2) the revision of the suppression pool volume currently listed in LCO 3.5.3.b; 3) the relocation of the i
suppression pool' volume references in LCO 3.6.2.1.a.1 to the UFSAR and TS Bases; and 4) the revision to the suppression pool volume reference in TS 5.2.1 to reference the Technical i
Specification Bases section where this information will reside.
mAsIs -
j 1.
The proposed changes do not involve a significant ' increase in the probability or consequences of an accident previously eval ua ted.
j The proposed TS revisions involvet
- 1) no changes to the i
-operation of any systems or components in normal or accident operating conditions; and 2),no significant changes to existing structures, systems or components.
The installation of the new strainers will be justified separately using the provisions of 10CFR50.59.
The relocation of Technical Specification references to suppression pool volume to the UFSAR and/or TS Bases will not i
adversely impact the safety-related functions of the suppression pool:or its supported systems.since any changes to suppression pool volume will be subject to 10CFR50.59 provisions.
The. impact of the new strainers on ECCS performance in Operational
. Conditions 4 and 5 has been-determined to be negligible, with less than a 0.3% decrease in_ suppression pool water-volume at the-
~
minimum specified suppression pool water 1evel. limit.
In addition, suppression pool volume is not a parameter _ involved in l
I Page 1 of 3 9
l
.... = -,.
D:cument Centrol D ck LR-N97505 AttOchment 2 LCR H97-15
'the initiation of any accident.
Therefore these changes will not significantly increase the probability of an accident previously evaluated.
To the extent practicable, those proposed changes were developed consistent with the changes approved by the NRC when developing NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4", with the intent of having the relocated information controlled in other plant documents subject to 10CFR50.59 provisions.
Since the plant systems associated with these proposed changes will still be capable oft
- 1) meeting all applicable design basis requirements; and 2) retain the capability to mitigate the consequences of accidents described in the HC UFSAR, the proposed changes were determined to be justified.
Therefore, these changes will not involve a significant increase in the consequences of an accident previously evaluated.
2.
The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Neither the relocation of Technical Specification references to suppression pool volume nor the revision of the suppression pool volume references for Operational Conditions 4 and 5 (COLD SHUTDOWN and REFUELING) will adversely impact the operation of any safety related component or equipment.
Since the proposed changes involve:
- 1) no changes to the operation of any systems or components; and 2) no significant changes to existing structures, systems or components, there can be no impact on the occurrence of any accident.
To the extent practicable, these proposed changes were developed consistent with the changes approved by the NRC when developing NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4", with the intent of having the relocated information controlled in other plant documents subject to 10CFR50.59 provisions.
Furthermore, there is no change in 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.
Removal and relocation of the Technical Specification references to suppression pool volume is consistent, to the extent practicable, with the changes approved by the NRC when developing NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4".
The information retained in the Technical Specifications for minimum suppression pool water level and the Page 2 of 3 J
D cument C ntrol D00k LR-H97505 AttOohment 2 LCR H97-15 information retained in the UFSAR and Technical Specification Bases will ensure that the suppression pool and supported components will remain capable of performing their intended safety functions.
Any changes to suppression pool volume information retained in the UFSAR or Technical Specification Bases will be subject to the provisions of 10CFR50.59 and a separate safety evaluation would be developed to suppott any proposed changes that would subsequently be made.
The impact of the new strainers on ECCS performance in Operational Conditions 4 and 5 has been determined to be negligible, with less than a 0.3%
decrease in suppression pool water volume in the minimum specified suppression pool water level limit.
By retaining the 5 inch minimum suppression pool water level limit within the TS, adequate provisions for:
Therefore, the changes contained in this request do not result in a significant reduction in a margin of safety.
CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.
Page 3 of 3 l
l l