ML20244B220
| ML20244B220 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/06/1989 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20244B224 | List: |
| References | |
| NLR-N89100, NUDOCS 8906130034 | |
| Download: ML20244B220 (9) | |
Text
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- e Pubhc Service Dectric and Gas Company Steven E. Miltenberger Public Service Electric ad Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 vice pre 6 dent and cNo! Nuclear Oker gggg g, yggg NLR-N89100 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR AMENDMENT PACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 In accordance with 10 CFR 50.90, Public Service Electric and Gas Compar (PSE&G) hereby transmits a Request for Amendment to Facil:
'iperating License NPF-57 for Hope Creek Generating Static.. (HCGS).
This amendment request revises: (a) Technical Specification (TS) Section 3.6.1.2.e and Table 3.6.3-1 to increase the hydrostatic test pressure from 1.0 P(a) to 1.10 P(a) for containment isolation valves provided with a water seal from the suppression pool, (b) rewords Technical Specification 3.6.1.2.e to clearly define as-left penetration leakage for these same valves, and (c) deletes an incorrect cross-reference in Section 4.6.1.2.i.
The Technical Specification changes shown in would: (a) assure compliance with 10 CFR 50, Appendix J, (b) eliminate possible TS misinterpretation, and (c) correct administrative errors in the TS. provides sufficient justification to demonstrate that the proposed changes do not involve a significant hazards l
consideration pursuant to 10 CFR 50.92.
Since the proposed changes either involve an additional limitation, provide i
clarification, or deal with administrative issues, PSE&G believes that a detailed NRC Branch or specialist review is not required and thus the request can be processed as a Category 2 amendment request.
In accordance with the requirements of 10 CFR 50.4(b)(ii), this submittal includes one (1) signed original, including affidavit, and thirty-seven (37) copies.
In accordance with 10 CFR 50.91(b)(1), a copy of this request has been sent to the State of New Jersey as indicated below.
Upon NRC approval, please issue a License Amendment which will be effective upon issuance and shall be implemented within 60 days of issuance.
This latitude permits appropriate procedural modifications necessary to implement-the proposed changes.
A00I 8906130034 890606 i
PDR. ADOCK 05000354 AI p_
PDC l
Document Control Desk 2
06-06-89 NLR-N89100 Should you have any questions or comment on this transmittal, do not hesitate to contact us.
Sincerely, f
Affidavit Attachments (2)
C Mr. C. Y. Shiraki USNRC Licensing Project Manager Mr. G. W.
Meyer USNRC Senior Resident Inspector Mr. W. T.
Russell, Administrator USNRC Region I Mr. K. Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, New Jersey 08625 1
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U' Ref:
STATE OF NEW JERSEY
)
)
SS.
COUNTY OF SALEM-
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Steven E. Miltenberger, being duly sworn,according to-law deposes
- and says:
I am Vice President and Chief Nuclear Officer of Public' Service-Electric and' Gas Company, and.as such,-I-' find the matters set-forth on our letter dated-June 6, 1989 concerning the Hope' Creek Generating Station, are true to'the best of my knowledge, information and belief.
h Aff
.f Subscribed and Sworn to-before me this AL ay of fp>d 1989 Notary Public ol New Jersey BLEEN N. OCHS E
My Commission expires on a iner l
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i ATTACHMENT l' PROPOSED CHANGEf50LTHE? TECHNICAL' SPECIFICATIONS q
FACILITY. OPERATING: LICENSE NPF-57 HOPE CREEK GENERATING STATION NLR N89100-DOCKET NO. 50-354 HCGS~LCR'89-05 1
I.
Identification of the Proposed Change JA.
Revise TechnicalE 8 specification. (TS) c 3.6.1.2.e,. Primary--
Containment Leakage, and Note:4 Eof. Table:3.6.3-1,? Primary-Containment' Isolation Valves, to increase the 10 CFR 50,. Appendix i
J, Type C.waterJtest pressureffrom P-(a) (48.1 psig',fdelta
= pressure).to:1.10:P(a)"(52.9 psig, delta pressure) for containment isolation valves'in'hydrostatically' tested lines.
This' conservative" increase'is necessary tolascure that the.
testing requirement contained ini10 CFR:50, Appendix J.isi H
Technical Specifications.
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accurately' reflected in the Hope.CreekiGenerating Station (HCGS)'
B.
=In addition, revise the wordingiof'TSL3.6.1.2.e;and-th:o:two-associated Action Statements to indicate that'the-hydrostatic test criteria applies to penetrationsJasywell;as valves. 'This additionfclearly. defines that the as-left" penetration leakage for in-series valves is calculated =using.the valve with the highest ~ leakage.
C.
Finally, delete the reference to1 Surveillance Requirement-4.6.1.8.3 in TS 4.6.1.2.1 since this surveillance no.Jonger-exists.
Amendment 16 revised the referenced; specification.
II.
Reason for the ProDosed ChanQe l
A.
Public Service Electric and Gas Company ~(PSE&G)'has compared the requirements of 10 CFR 50, Appendix J against'the requirements' contained in the HCGS TS for'hydrostatically; tested containment isolation valves sealed with water from~the 1
suppression pool..The TS' requirement..to test such-valves at a-pressure of'1.0 P(a) does not meet'the requirement in: Appendix J to conduct:such testing at 1.10;P(a). Therefore, thesTechnical
' Specifications should be'revisedito-assure containment; isolation valves are. tested at the correct test pressure.1
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-B.
'The current wording of TS 3.6.1'.2.e could' imply-'thatsthe calculated penetrationLleakagelfor hydrostatically; tested,.
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in-series containment isolation. valves is a sd9mation of1then.two valvesitestedh =since.the calculation offthe as-left penetration.
leakage assumes.a worst case single failure, i.e. the'failureiof-d
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the valve with-the lowest? leakage; penetrationLleakage for-Jin-series. valves'is calculated using.the valve 1with~theLhighest-i d
.Page 1Lofc6 i
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_a;
Hydrostatic Appendix J Testing IICGS LCR~ 89-05 leakage.
By adding a reference to penetrations in TS 3.6.1.2.e, this possible misinterpretation can be eliminated.
C.
With the issuance of Amendment 16, TS.3/4.6.1.8 (Drywell and Suppression Chamber Purge System) was revised;to permit.the operation of-the purge system.
Within.the confines of Amendment 16, original Surveillance Requirements 4.6.1.8.2 and 4.6.1.8,3 were combined under current Surveillance Requirement 4.6.1.8.2.
As a result, the reference to TS 4.6.1.8.3 in TS 4.6.1.2.i can be i
deleted.
Jus'if*catio9 for the Proposed Change III.
t A.
The valves at issue in this change are those which provide containment isolation for lines which penetrate the suppression pool and are water filled following an accident scenario which requires their long-term isolation.-
TS 3.6.1.2.e addresses these valves and requires:
" A combined leakage rate of less than or equal to 10 gpm for all other containment isolation valves in hydrostatically tested lines in Table 3.6.3-1 which penetrate the primary containment, when tested at P(a),
48.1 psig delta pressure."
This requirement is also reiterated in TS Table 3.6.3-1, Note 4.
Ilowever, Paragraph III.C.2 of 10 CPR 50, Appendix J requires:
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"(a) Valves, unless pressurized with a fluid (e.g. water, nitrogen) from a seal system, shall be pressurized with air or nitrogen at a pressure of P(a).
(b) Valves, which are sealed with fluid from a seal system shall be pressurized with that fluid to a pressure not less than 1.10 P(a)."
Since the subject valves are provided with a seal system as discussed in Updated Final Safety Analysis Report (UFSAR) Section 6.2.3, 10 CFR 50 Appendix J, Paragraph III.C.2.b applies and the valves should be tested with water to a test pressure of 1.10 P(a).
Therefore, PSE&G has concluded that the TS for the subject-valves is in error and should require a Type C water test at 1.10 P(a) with the combined leakage not exceeding 10 gpm.
In order to demonstrate that the results of the Type C tests conducted during the last refueling outage (at a pressure of 48.1 psig, 1.0 P(a)) provided satisfactory assurance of containment J
integrity, PSE&G has calculated what the leak rate would have been at a pressure of 52.9 psig (1.10 P(a)).
A conversion calculation has been utilized based upon Equation 3-21 on page 3.5 of Crane Technical Paper No. 410.
The measured leak rate, at a' test pressure of 48.1 psig and accounting for the maximum l
pathway leakage, totaled 2.4 gpm; while the calculated leak rate, Page 2 of 6
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Hydrostatic Ap; ondix J Testing :
HCGS bCR-89 which could be expected if testing were performed at 52.9 psig, would have been 2.5 gpm.
The difference in' leakage rates is less than 5% and when compared to the maximum leakage limit of 10 gpm, the difference is a negligible 1%.
..As a result, PSE&G has concluded that.the hydrostatic' testing conducted.during the last refueling outage, at a test. pressure of 1.0 P(a), is representative of the_ leakage which could have been expected if testing was' performed at a pressure of 1.10 P(a).
Since the hydrostatic test pressure requirement of 10 CFR 50, Appendix J must be met, a change to the TS.is required to increase the test pressure from 1.0 P(a) to 1.10 P(a) for' hydrostatically tested containment isolation valves.
Attachment 2 contains the necessary TS changes.
B.
A second change to TS 3.6.1.2.e is necessary to indicate?
that the 10 gpm leak rate criteria applies to penetrations and valves in order to account for in-series containment-isolation valves. :When testing containment penetrations with in-series valves, the as-left leakage for the subject 2 penetration is calculated using the valve with the highest leakage (1.e. a worst case single failure of the valve with the lowest leakage.is assumed.)
The. current TS wording could be' misconstrued to:mean that, for penetrations with in-series valves, the as-left leakage rate is the sum total of all valves in theLgiven penetration.
In order to eliminate this ambiguity, a reference to penetrations-should be added to this specification as shown in Attachment 2.
The proposed wording would-be the same as wording contained in TS 3.6.1.2.b which' identifies-the requirement to maintain containment isolation valve leakage "...less than or equal to 0.60 L(a) for all penetrations and all valves..."
Since this specification makes specific mention of "all penetrations and all valves," when in-series valves in a given anetration are tested the as-left leakage rate assigned to the nuaject penetration is calculated using' the valve with the highe:
leakage.
From a physical standpoint, even if one of two valves in a given penetration is' leaking at rate greater than the other, the leakage rate of the entire penetration cannot-be any greater than the' leakage associated with the valve with the lowest leakage.
However, applying single' failure criterion. requires assuming the failure of.the valve with the lowest leakage.
Hence, the leakage j
rate calculated for'the penetration uses the leakage associated with the valve with the highest leakage.
C.
Amendment 16 revised the Drywell and Suppression Chamber
' Purge System specification"to' permit the-operation.of the-I
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purge system for up to 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> per' year.
Original Surveillance
- Requirements 4.6.1.8.2 and 4.6.1.8.3 discussed the test q
requirements for the purge supply'and exhaust valves with resilient material seals.
Amendment 16 combined these-two test criteria under current Surveillance Requirement 4.6.1.8.2.
.Therefore, TS 4.6.1.2.i must be revised to' delete the reference Page 3 of 6'
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- Hydrostatic Appendix J Testing HCGS LCR 89 l l
to TS 4.6.1.8.3.
The_ remaining reference to Surveillance Requirement 4.6.1.8.2 assures that the proper cross-reference between the two TS exists.
This change is simply an administrative revision to TS 4.6.1.2.i.
IV.
Significant Hazards Consideration Evaluation The proposed changes to the Technical Specifications:
1.
Do not involve.a significant increase in the probability or consequences of an ar-4 dent previously evaluated.
A.
The maximum calculated accident pressure for the drywell is identified in UFSAR Section-6.2.1.1.3.1 as. 48.1 psig (P(a)).
This pressure is assumed to occur in the event of a design basis accident, a recirculation system line break.
UFSAR Section 15.6.5.5.1.2.2 assumes that the radiological consequences associated with such an accident are in part limited by the integrity of the primary containment.
Since the subject. valves form a part of the primary containment, it is necessary to periodically test their leakage.
The proposed change simply increases the hydrostatic test pressure and does not affect the 10 gpm TS leakage criteria nor alter the TS required actions in the event that such'a limit'is exceeded.
Any leakage associated with the subject valves would still be into a cloced system outside primary containment from which, leakage is still processed and filtered by the Filtration, Recirculation, and Ventilation System (FRVS) in the Reactor Building prior to discharge to the environment.
Again this change does not affect the function of the FRVS nor the leakage criteria from engineered safety features components outside the primary containment.
?aragraph III.C.2 requires a hydrostatic test pressure of 110% of the maximum calculated accident pressure.
In the case of HCGS, this requirement translates into a test pressure of 52.9 psig.
However, the HCGS TS currently only specify a test pressure of 1.0 P(a), 48.1 psig; therefore, a TS change is necessary to comply with Appendix J testing requirements.
From the discussion provided, PSE&G has concluded that the proposed change involves an additional limitation - namely that the subject valves must be capable of withstanding a test
- pressure 10% greater than that currently required while still I
only permitted to leak, in total, no more than 10 gpm.
Since the I
proposed change does not affect this leakage criteria nor the I
actions required in the event the criteria is'not' meet, PSE&G has j
concluded that the proposed change does not involve a significant i
increase in the probability or consequences of an accident
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previously evaluated.
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Hydrostatic; Appendix'J-Te3 ting'
i B.
PSE&G has been-and will-continue'to test and measure the leakage associated with each containment penetration in order-to arsure that containment integrity isLmaintained.
However, the' wording of TS 3.G.l.2.e could be' misconstrued to require hydrostatic leakage from.each in-series containment:
1 solation valve to be included in the total leakage criteria of:
10 gpm.. Such an interpretation ignores the fact that'leakagel
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associated with a such'a penetration'is calculated using the-1 valve with the highest leakage.
Therefore, the proposed change:
1 would provide sufficient. clarity to correctly' permit penetration.
l leakage: rates to be used in 'the -10 gpm' leakage: criteria.
Since this change does not affect the physical condition associated
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with penetration? leakage nor the criteria for total hydrostatic
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t leakage, PSE&G has concluded that the proposed change doesJnot q
involve'a significant increase in the probability or' consequences.
d of an accident previously evaluated.
C.
.The proposed change is administrative in' nature and does not affect the requirement to demonstrate operability of1 purge supply and exhaust valves with resilient seals..Therefore, PSE&G q
has concluded that the proposed change does not involve a 1
significant increase in the probability or consequences of an
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accident previously. evaluated.
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2.
Do'not create' the' possibility of a new or different kind of accident from any' accident previously evaluated.
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A.
The proposed changes do not involve any plant modifications B.
other than the increase in the test pressure for the. subject C.
valves.
In addition, the testing configuration is not changing and the results of hydrostatic tests must still.
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meet the 10 gpm leakage criteria stipulated in the.TS.
The requirements specified in the associated TS Action Statements L
should leakage exceed the acceptance criteria are not affected by the proposed changes.
As a result, PSE&G has concluded that the proposed changes do not create the possibility of a new or i
different kind of accident from any accident previously
- evaluated.
1 3.
Do not involve a significant reduction in.a margin of' safety.
A.
The proposed changes are necessary to: (a) comply with the B.
requirements of 10 CFR 50, Appendix J, (b) clearly' indicate-C.
the method of determining total hydrostatic leakage,'and
(. c):
correct administrative errors in the TS.
As a recult,Ethe-4 margin-of safety is not compromisediby the" proposed cnanges. 1In -
the case of the increased testspressure, an additional-margin of-1 safety is'provided since testing hydrostatically; sealed' valves at a test pressure 110% greater than the maximum accident. pressure provides greater assurance that the maximum leakage expected from the valve (s) will not exceed conditions expected'to. occur during
- or following an accident.
.As'a' result, PSE&G has' concluded-that' L.
Page 5.of 6.
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.{-
Hydrostatic Appendix'J-Testing HCGS LCR 89-05 the proposed. changes do not. involve-a significant reduction in a
- margin of safety.
V.
Conclusions As discussed in' Item IV above, PSE&G has concluded that the proposed changes to the Technical' Specifications do'not involve a significant hazards consideration since the changes-(1) do not involve a significant increase in.the probability or. consequences of an accident previously evaluated, (ii) do not create the possibility of'a new or different' kind of accident from any accident previously evaluated, and (iii) do not. involve a significant reduction in a margin of safety.-
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