ML20217C195
| ML20217C195 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/18/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217C193 | List: |
| References | |
| NUDOCS 9710010253 | |
| Download: ML20217C195 (4) | |
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NUCLEAR REGULATORY COMMISSION g
WASHINGTON, D.C. SoHHoot SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.104 TO FAtlllTY OPERATING LICENSE NO. NPF-57 PUBLIC SERVICE ELECTRIC & GAS CMP &1 ATLANTIC CITY ELECTRIC COMPANY l
HOPE CREEK GENERATING STATION DOCKET NO. 50-354
1.0 INTRODUCTION
By letter dated April 1, 1997, as supplemented by letter dated May 30, 1997, the Public Service Electric & Gas Company (PSE&G. the licensee) submitted a request for changes to the Hope Creek Generating Station, Technical Spe:ification (TSs) and the license.
The requested changes would provide i
cha19es to Technical Specifications (TSs) 4.6.1.1, " Primary Containment Integrity;" 3/4.6.1.2, " Primary Containment Leakage;" 3/4.6.1.3, " Primary Containment Air Locks;" 4.6.1.5.1, " Primary Containment Structural Integrity;"
and 4.6.1.8.2, "Drywell and Suppression Chamber Purge System." This amendment would also change the Bases for 3/4.6.1.2, " Primary Containment Leakage;"
3/4.6.1.3, " Primary Containment Air Locks;" 3.4.6.1.5, " Primary Containment Structural Integrity;" Section 6, " Administrative Controls;" and License Condition 2.D of Facility Operating License NPF-57. A new TS, 6.8.4.f.
" Primary Containment Leakage Rate Testing Program," would be added. These changes modify the TSs and the Facility Operating License to adopt the performance based containment leak rate testing requirements (Option B) of 10 CFR Part 50, Appendix J and reference Regulatory Guide (RG) 1.163,
" Performance-Based Containment Leak Test Program," dated September 1995, which specifies a method acceptable to the NRC for complying with Option B.
2.0 BACKGROUNQ Compliance with 10 CFR Part 50, Appendix J, provides assurance that the prinary containment, including those systems and components which penetrate the primary containment, do not exceed the allowable leakage rate specified in the TS and Bases.
The allowable leakage rate is determined so that the leakage assumed in the safety analyses is not exceeded.
On February 4, 1992, the NRC published a notice in the Federal Reaister (57 FR 4166) discussing a planned initiative to begin eliminating requirements marginal to safety which impose a significant regulatory burden.
Appendix J of 10 CFR Part 50 was considered for this initiative and the staff undertook a study of possible changes to this regulation. The study examined the previous performance history of domestic containments and examined the effect on risk of a revision to the requirements of Appendix J.
1he results of this study are reported in NUREG-1493, " Performance-Based Leak-Test Program."
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0 1 Based on the results of this study, the staff developed a performance-based approach to containment leakage rate testing. On September 12, 1995, the NRC approved issuance of this revision to 10 CFR Part 50, Ap)endix J, which was subsequently published in the Federal _ Reaister on Septem)er 20, 1995, and became effective on October 26, 1995. The revision added Option B,
" Performance-Based Requirements," to Appendix J to allow licensees to voluntarily replace the prescriptive testing requirements of Appendix J with testing requirements based on both overall and individual component leakage rate performance.
RG 1.163 was developed as a method acceptable to the NRC staff for implementing Option B.
This RG states that the Nuclear Energy Institute (NEI) guidance document NEl 94-01, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," )rovides methods acceptable to the NRC staff for complying with Option B witi four exceptions which are described therein.
Option B requires that the RG or another im>1ementation document used by a licensee to develop a performance-based lea cage testing program must be included, by general reference, in the plant TSs.
The licensee has referenced RG 1.163 in the proposed Hope Creek TSs.
RG 1.163 specifies an extension in Type A test frequency to at least one test in 10 years based upon two consecutive successful tests. Type B tests may be extended up to a maximum interval of 10 years based upon completion of two consecutive successful tests and Type C tests may be extended up to 5 years based on two consecutive successful tests.
By letter dated October 20, 1995, NEI proposed TSs to implement Option B.
After some discussion, the staff and NEI agreed on final TSs, which were attached to a letter to D. Modien, NEI, from C. Grimes, NRC, dated November 2, 1995. These TSs are to serve as a model for licensees to develop plant-specific TSs in preparing amendment requests to implement Option B.
For a licensee to determine the performance of each component, factors that are indicative of or affect performance, such as an administrative leakage limit, must-be established. The administrative limit is selected to be indicative of the potential onset of component degradation. Although these limits are subject to NRC inspection to assure that they are selected in a reasonable manner, they are not TS requirements.
Failure to meet an administrative limit requires the licensee to return to the minimum value of the test interval.
Option B requires that the licensee maintain records to show that the criteria for Type A, B, and C tests have been met.
In addition, the licensee must maintain comparisons of the performance of the overall containment system and the individual components to show that the test intervals are adequate. These records are subject to NRC inspection.
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3.0 EVALUATION The licensee's April 1 and May 30, 1997, letters to the NRC propose to establish a ' Primary Containment Leakage Rate Testing Program" and propose to add this program to the TSs. The program references RG 1.163, which specifies methods acceptable to the NRC for complying with Option B.
This requires changes to License Condition 2.D and to existing TS 4.6.1.1, 3/4.6.1.2.
3/4.6.1.3, 4.6.1.5.1, and 4.6.1.8.2, and the addition of the " Primary Containment Leakage Rate Testing Program" as 15 6.8.4.f.
Section e, " Diesel Fuel Oil Testing Program," was added by Amendment No. 100, dated July 24, 1997; therefore, this new section is now Section f.
Corresponding bases were also modified.
Option B permits a licensee to choose Type A; or Type B and C; or Type A, B, and C;_ testing to be done on a performance basis. The licensee has elected to perform Type A, B, and C testing on a performance basis.
The changes to License Condition 2.0 are made to expunge any references to specific paragraphs within Option A of Appendix J.
The staff finds that these references are no longer valid since the licensee will be complying with i
i Option B.
Also deleted is the exemption from the requirement of Paragra)h III.D.2(b)(ii) of Appendix J, e::empting overall containment air lock lea (age testing unless maintenance has been performed on the air lock that could affect air lock sealing ca> ability.
The staff finds that this exemption would no longer be necessary wit) the adoption of Option B, since_0ption B does not have the requirement, put forth in Paragraph III.D.2(b)(ii) of Appendix J, for testing of air locks opened during periods when containment integrity is not required.
The changes to existing TS 4.6.1.1,3/4.6.1.2,3/4.6.1.3,4.6.1.5.1,and 4.6.1.8.2, delete the prescriptive test requirements, criteria, and surveillance intervals taken from Option A of Appendix J, and reference the
. Primary Containment Leakage Rate Testing Program, in accordance with Option B, and are therefore acceptable.
The new TS 6.8.4.f adds by reference the Primary Containment Leakage Rate Testing Program, and gives the peak calculated containment internal pressure for the design basis loss of coolant accident, the maximum allowable primary containment leakage rate, and acceptance criteria for leakage rate testing and air lock testing. -TS 6.8.4 also states that the provisions of Specification
'4.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program, therefore making the deletion of existing TS 4.6.1.2.j acceptable. The new TS 6.8.4.f is in compliance with the requirements of Option B and consistent with the guidance of RG 1.163, and is therefore acceptable.
The TS changes proposed by the licensee are in compliance with the requirements of Option B and consistent with the guidance of RG 1.163.
Further, despite the different format of the licensee's current TSs, all of the elements of the model TS guidance provided in the NRC letter to NEI dated, November 2,1995, are included in the proposed TSs.
The staff therefore concludes that the proposed TS changes are acceptable.
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4-The changes to TS Bases 3/4.6.1.2, 3/4.6.1.3, and 3/4.6.1.5 replace references to the requirements of Appendix J, Option A, with references to the Primary Containment Leakage Rate Testing Program. There are also clarifications made to Bases 3/4.6.1.2. These changes are acceptable with regard to the adoption of Option B.
4.0 STATE CONSULTATION
i In accordance with the Commission's regulations, the New Jersey State Official was notified of the proposed issuance of the amendment.
By letter dated July 31, 1997, the State official indicated that they had no comments.
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5.0 ENVIRONMENTAL CONSIDERATION
The amendment 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 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 Comission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public coment on such finding (62 FR 43375). The amendment also relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10).
Pursuant to 10 CFR 51.22 no environmental impact statement or environmental assessment need be prepa(b)d in connection with the re issuance of the amendment.
6.0- CONCLUSION The Comission 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 hianner, (2) such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendment will not be inimical to the comon defense and security or to the health and safety of the public.
Principal Contributor:
J. Pulsipher Date:
September 18, 1997
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