ML20245D795

Application for Amend to License NPF-57,revising Tech Spec Table 3.3.7.5-1 Re Allowable out-of-svc Times for Inoperable Primary Containment Isolation Valves & Associated Position Indication Instrumentation.Fee Paid

ML20245D795
Person / Time
Site:	Hope Creek
Issue date:	09/28/1988
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20245D800	List: ML20245D795 ML20245D814
References
NLR-N88153, NUDOCS 8810070161
Download: ML20245D795 (11)

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Pubhc Service Electnc and Gas Company Stiven E. Mittenberger Pubhc Service Electoc and Gas Company P O. Box 236. Hancccks Bndge, NJ 08038 609-339-4199 vice pwaeni and Ch.cf Nuctoar Off>cer September 28, 1988 NLR-N88153 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR AMENDMENT FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 In accordance with the requirements of 10CFR 50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits a Request for Amendment to Facility Operating License NPF-57 for Hope Creek Generating Station (HCGS). This amendment request revises Technical Specification Table 3.3.7.5-1 to permit actions consistent with Technical Specification 3.6.3 regarding allowable out-of-service times for inoperable primary containment isolation valves and their associated position indication instrumentation.

The change.would avert the currently required plant shutdown in the event that position indication instrumentation for a primary containment isolation valve in an otherwise isolated penetration is declared inoperable. Attachment 1 provides adequate justification to demonstrate that the proposed change follows the guidance contained in NUREG-0800 (the Standard Review Plan),

Section 6.2.4.II.f and does not involve a significant hazards consideration pursuant to 10CFR 50.92. Therefore, PSE&G believes that the proposed change does not require a detailed NRC Branch / specialist review and can be processed as a Category 2 (Item 6) amendment request.

In accordance with the requirements of 10CFR 50.4 (b) (ii), this submittal includes one (1) signed original, including affidavit and thirty-seven (37) copies. In accordance with 10CFR 50.91(b)(1), a copy of this request has been sent to the State of New Jersey as indicated below. In accordance with the requirements of 10CFR 170.21, a check in the amount of $150.00 is enclosed.

1 h00f I I 8810070161 880928 /jOD PDR ADOCK 05000354 W [ec k P PNU J%U 2763

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09-28-88

' Document Control Desk 2 Should you have any questions or comments on this transmittal, do not hesitate to contact us.

Sincerely, i {ww Attachments (2)

Affidavit C Mr. G. W. Rivenbark Licensing Project Manager Mr. G. W. Meyer Senior Eesident Inspector Mr. W. T. Russell, Administrator Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 i

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l STATE OF NEW JERSEY )

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COUNTY OF SALEM )

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 in our letter dated September 28, 1988 , concerning Hope Creek Generating Station, are true to the best of my knowledge, information and belief.

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V Subscribed and Sworn to before me this O Ib day of // h , 1988 i

h Notary Public of New Jersey BLEEN M. OCHS NOTMY PUBUC OF NEW JER$EY My Commission expires on na; t- - -- r.22 m 16.1992

ATTACHMENT 1 .

PROPOSED CHANGE TO THE TECHNICAL SPECIFICATIONS FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 LCR 88-02 I. Identification of the Proposed Change Revise ACTION 82(a) and 82(b) of Technical Specific . ion Table 3.3.7.5-1, Accident Monitoring Instrumentati.n, by adding a cross-reference to' ACTION a.2 and a.3 of Technical Specification 3.6.3, Primary Containment Isolation Valver.

This change provides a consistent approach between two ,

conflicting actions for inoperable primary containment isolation valves and their associated position indication instrumentation (Instrument 14 of Table 3.3.7.5-1).

Attachment 2 contains the appropriately revised Technical Specification page. .

j II. Reason for the change Over tFs course of the past two years, Hope Creek Generating Station (HCGS) has encountered several instances in which position indication for a containment isolation valve in an isolated penetration has been declared inoperable. Efforts to restore the indication to an operable status have at times been difficult due to such problems as trouble shooting and part availabi)fr.y within the time contraints imposed by Technical Specitsuation Table 3.3.7.5-1. As a result, PSE&G has reviewed the necessity for plant shutdown due to inoperable position indication, and for the case in which the subject penetration is isolated, does not find the shutdown requirement justified. As discussed below in Section III, sufficient justification exists to warrant a change to the current Technical Specification to remove this requirement. Such a change would result in considerable manpower savings in the event of any similar situations in the future and of course, avert the unnecessary requirement to shutdown HCGS.

III. Justification for the Proposed Ch.tnge Technical Specification 3.6.3, ACTION (a) permits primary containment isolation valves to remain inoperable provided i

I that another isolation valve in the affected penetration is OPERABLE, and within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, if the inoperable valve cannot be restored to OPERABLE status the penetration must be isolated by either a deactivated automatic valve, a closed manual valve or a blind flange.

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l However, if in addition to the inoperable primary I containment isolation valve, the position indication instrumentation for the subject valve is also inoperable and cannot be restored to OPERABLE status, ACTION 82(a) or 82(b) for Technical. Specification Table 3.3.7.5-1 requires a plant shutdown within either 30 or 7 days, respectively (depending on whether eitner or both position indication channels are iraperable.) As long as power has been removed from the l inoperable automatic valve or local manual action is l necessary to open a manual valve or remove a blind flange, a change in position of the subject inoperable valve is precluded (except under the administrative controls permitted in Technical Specification 3.6.3, Footnote *).

Therefore, in this situation, position indication serves no function as the penetration is isolated pursuant to Technical Specification 3.6.3. In fact, Updated Final Safety Analysin Report (UFSAR) Section 6.2.4.2 recognizes this situation in stating that:

"The containment isolation system is designed with provisions for administrative control, to ensure that the proper position of all nonpowered or power removed isolation valves is maintained."

This control is verified in Technical Specification 4.6.1.1:

"At least once per 31 days by verifying that all primary containment penetrations not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in position..."

In effect, if a penetration is closed pursuant to ACTION a.2 or a.3 of Technical Specification 3.6.3, a 31 day surveillance assures that the penetration remains closed and therefore verifies that the administrative controls in place remain effective. Consequently, the isolation provided by the requirements of ACTION a.2 and a.3 will remain in effect via administrative :ontrols. Accordingly, ACTION 82(a) and 82(b) should be modified such that the requirement to shutdown or restore to OPERABLE status an inoperable channel (s) of position indication within either 30 or 7 days, respectively, is necessary only if the affected penetration has not been isolated in accordance with ACTION a.2 or a.3 of Technical Specification 3.6.3. Attachment 2 provides an insert which accomplishes this modification by separating ACTION 82(a) and 82(b) into two sentences, the latter sentence (i.e. the shutdown requirement) applying only if the affected penetration has not been isolated in accordance with Technical Specification 3.6.3. This change would link Specifications 3.3.7.5 and 3.6.3 when a primary containment isolation valve and its associated position indication instrumentation are inoperabic, thereby removing Page 2

the current shutdown requirement which provides an inconsistent approach to corrective action.

III-A. Discussion of the Affects of the Proposed Change The following scenerios represent the permutations of operable and inoperable primary containment isolation valves and their position indication instrumentation. A discussion of the affects of the proposed change is provided:

scenerio 1 - Both containment isolation valves in a given penetration are OPERABLE; however, either or both position indication instruments for either or both valves are declared inoperable. If both containment isolation valves are OPERABLE in a given penetration, then the requirements of the Limiting condition for Operation (LCO) in Technical Specification 3.6.3 are satisfied and accordingly the given penetration has not been isolated pursuant to ACTION a.2 or a.3. Hence, if position indication instruments for either or both valves are declared inoperable, then the statement within the revised ACTION 82(a) or 82(b) of Technical Specification Table 3.3.7.5-1 regarding plant shutdown within either 30 or 7 days, respectively, is applicable. The current requirements of ACTION 82(a) and 82(b) reflect this same requirement and thus the proposed change does not affect this scenerio.

Scenerio 2 - One containment isolation valve in a given penetration is inoperable and either or both of the position indication instruments for the inoperable valve are also inoperable. If a containment isolation valve in a given penetration is declared inoperable, then the LCO for Technical Specification 3.6.3 is not satisfied and ACTION (a) is applicable. Assuming the valves cannot be restored to an OPERABLE status, ACTION a.2 or a.3 requires the penetration to be isolated. If either or both position indication instruments for the inoperable valve are or become inoperable, the proposed change to ACTION 82(a) and 82(b) would permit continued plant operation rather than the current 30 or 7 day allowable out-of-service time (AOT),

respectively. Based on the fact that the penetration is in the safe configuration with regard to containment isolation and must be maintained in the isolated position, the action requiring shutdown due to inoperable position indication is not necessary (assuming that the inoperability of the i

isolated system does not require a plant shutdown.)

Scenerio 3 - A case similar to Scenerio 2 except that

( position indication instrumentation for the OPERABLE valve is inoperable while the inoperable valve has f OPERABLE position indication instrumentation. In any i situation in which a primary containment isolation valve in a subject penetration is inoperable and cannot be restored to OPERABLE status, ACTION a.2 or a.3 of Technical Page 3 m_--__ __ _

Specificati n 3.6.3 is applicable and requires the subject penetration to be isolated. With the penetration maintained in the safe configuration with regard to containment isolation provisions, the requirement for OPERABLE position indication instrumentation for either containment isolation valve (whether or not the valve itself is OPERABLE) is not necessary. The proposed change to ACTION 82(a) and 82(b) indicates that if the subject penetration is isolated in accordance with Technical Specification 3.6.3, continued plant operation is permitted rather than applying the current AOT and shutdown requirement.

Scenerio 4 - A case similar to Scenerio 2 except either or both position indication instruments are inoperable for both the OPERABLE and the inoperable containment isolation valves. The same argument applied in scenerio 2 and scenerio 3 is still valid: (a) the penetration is isolated and in a safe configuration, (b) position indication for either or both valves is not necessary since the valve is maintained in the isolated position, and thus (c) the shutdown requirement currently contained in ACTION 82(a) and 82(b) is not necessary. The proposed change to ACTION 82(a) and 82(b) eliminates the shutdown requirement for this type of scenerio.

Scenerio 5 -

Both of the containment isolation valves in a given penetration are inoperable and either or both of the position indication instruments for either or both of the valves are inoperable. This scenerio is analyzed for two cases, first when the subject penetration is initially open and second when the subject penetration is initially closed. In summary, the proposed change to ACTION 82(a) and 82(b) of Technical Specification Table 3.3.7.5-1 would not require a plant shutdown so long as the subject penetration was isolated in accordance with ACTION a.2 or a.3 of Technical Specification 3.6.3.

- First, if both of the containment isolation valves for a given penetration are declared inoperable when the subject penetration is open, ACTION (a) of Technical Specification 3.6.3 requires a plant shutdown if the penetration cannot be isolated. If the penetration can be isolated, the only requirement of ACTION (a) is to isolate and maintain closed the penetration. Therefore, if either or both channels of position indication instrumentation for either or both of the valves are or become inoperable, the proposed change to ACTION 82(a) and 82(b) would not require a plant shutdown because the penetration is isolated and the containment isolation provision is assured. A plant shutdown requirement still exists within Technical Specification 3.6.3, ACTION (a) if the subject penetration cannot be maintained closed.

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Second, if the penetration was initially closed when the two valves are declared inoperable then the requirement of Technical Specification 3.6.3 is to maintain 03e penetration j isolated in accordance with ACTION a.2 or a.3. Therefore, 1 I

if position indication instrumentation for either or both valves was also inoperable or becomes inoperable, the proposed change to ACTION 82(a) and 82(b) would not require a plant shutdown because the penetration is isolated and the  !

containment isolation provision is assured. A plant shutdown requirement still exists within Technical Specification 3.6.3 if the penetration cannot be maintained closed.

IV. Significant Hazards Consideration Analysis The proposed change to the HCGS Technical Specifications:

1) Does not involve a significant inlrease in the probability or consequences of an accident previously evaluated.

As required by ACTION (a) of Technical Specification 3.6.3, should a primary containment isolation valve be declared inoperable the affected penetration must be isolated. This isolation can be accomplished by either deactivating at least one automatic valve, closing at least one manual valve or installing a blind flange in the affected pene' stion.

Furthermore, the system for which the inoperable .alve provides containment isolation must also be declared inoperable and the appropriate ACTION statements for that system performed. Assuming that the plant can continue to operate under these conditions, the concern which must be addressed as a result of this proposed change is whether or not the probability or consequences of an accident previously evaluated are significantly increased when the position indication instrumentation for an otherwise inoperable containment isolation valve is permitted to remain inoperable longer than the currently imposed 30 or 7 days, per ACTION 82(a) and 82(b) of Technical Specification Table 3.3.7.5-1, respectively.

The requirement to isolate the affected penetration due to an inoperable valve establishes containment isolation for that penetration. This action establishes a safe configuration for continued cperation assuming of course that the affected system is not required to remain OPERABLE.

For those systems which can be isolated without jeopardizing continued safe operation, the need for monitoring containment isolation is no longer necessary as isolation has already been achieved.

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Therefore, it can be concluded that if the provisions of Technical Specification 3.6.3, ACTION a.2 or a.3 are in effect:

i) the penetration is in a safe configuration with regards to the provisions for containment isolation - closed,

11) spurious movement of the valve is precluded by either the lack of power, the need for local manual operation, or the presence of an installed blind flange, and iii) administrative controls and surveillance requirements exist to assure continued containment isolation.

The current requirements of ACTION 82 ef Technical Specification Table 3.3.7.5-1 regarding AOT for primary containment isolation valve position indication instrumentation v.rve no purpose with regard to assurance of containment integrity if and only if the associated penetration is isolated pursuant to Technical Specification 3.6.3, ACTION a.2 or a.3. This function is adequately controlled under the auspices of Technical Specifications 4.6.1.1 and the administrative controls already in place.

Consequently, extending the AOT for inoperable position indication in penetrations isolated as described above does not represent an increase in the probability or consequences of a previously evaluated accident since containment isolation (the accident function of concern) is already achieved ano assured.

(2) Does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change doen not negate the requirement for containment integrity or isolation but simply makes use of the existing Technical Specifications which require such.

By extending the provisions for isolated penetrations to the required actions for associated inoperable position indication simply takes advantage of the physical constraints and administrative controls already imposed.

Furthermore, the proposed change does not require any plant modification nor design change but merely permits a specific case of inoperability to exist while plant operation continues. This condition is well bounded in terms of the extent to which inoperability is permitted. Additionally, the flexibility provided by this proposed change will not result in a change to the operational characteristic of any system or process. The inoperability of primary containment isolation valve position indication instrumentation is already permitted for the currently identified AOT. This Page 6 L__________

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change simp y extends the AOT as long as other compensating measures are in effect.

Therefore, it can be concluded that the proposed change does )

not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Does not involve a significant reduction in a margin of safety.

The increase in AOT for an inoperable primary contairiment isolation valve position indication instrument from wither 7 or 30 days to an unlimited time does not decrease the margin of safety since a more restrictive '

compensating measure is in effect, namely the subject penetration is in the safe configuration with regard to containment isolation provisions - closed. Therefore, the margin of safety remains the same as that permitted by Technical Specification 3.6.3, ACTION a.2 or a.3. With the penetration in an isolated position and the assurances available that such a position will be maintained, the maximum margin of safety has been achieved, i.e. the penetration has been placed in the post accident configuration.

The length of time that either or both position indication instrumentation channels for either or both containment isolation valves remain inoperable has no bearing on the position of the valves in tha subject penetration.

Realizing that the information provided by the position indication instrumentation is simply indication only, i.e.

no automatic isolation or actuation function results from loss of or change in position indication, further substantiates the proposed change.

Therefore, it can be concluded that the proposed change does not involve a significant reduction in a margin of safety.

v. Conclusion In conclusion, PSE&G has demonstrated that the proposed change does not involve a significant hazards consideration based upon the discussion of the af fects of the change '

contained in Section III and the analysis of the change contained in Section IV. The proposed change does not: (i)

I involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) )

create the possibility of a new or different kind of accident from any accident previously evaluated, nor (iii) involve a significant reduction in a margin of safety.

Furthermore, PSE&G has reviewed Federal Register Volume 51, i Number 44 dated March 6, 1986 and concludes that the l i;

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proposed change most closely conforms to Example (vi) of Amendments That Are Considered Not Likely To Involve Significant Hazards consideration (page 7751). This conclusion is based upon a review of Standard Review Plan (SRP) Section 6.2.4. Although the SRP specifies that provisions must be available in the control room which provide position indication for power operated isolation valves,Section II.f does recognize the use of deactivated power operated isolation valves, closed manual valves and blind flanges as sealed closed barriers and permits the use of administrative controls to assure that those valves which are isolated cannot be inadvertently opened. With the containment penetration in the isolated position the consequences of an accident are not increased. Clearly, the administrative controls in place and the requirements of Technical Specification Surveillance Requirement 4.6.1.1 for such situations justify the proposed change.

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