ML20249A810
| ML20249A810 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/12/1998 |
| From: | Keiser H Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20249A811 | List: |
| References | |
| LCR-H98-02, LCR-H98-2, LR-N98274, NUDOCS 9806180273 | |
| Download: ML20249A810 (17) | |
Text
F 1 l 1 Pubhc Service L Electric and Gas ,
Cornpany
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Harold W. Keiser Pubhc Service Electne and Gas Company PO. Box 236. Hancocks Bndge. NJ 08038 609-339-1100 Sc*'e'aI$$e$' ult JINI12 SM LR-N98274 LCR H98-02 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS ULTIMATE HEAT SINK TEMPERATURE LIMITS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57. )
DOCKET NO. 50-354 .
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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 (HC). In accordance with 10CFR50.91(b)(1), a copy of this ,
submittal has been sent to the State of New Jersey.
Implementation of the proposed changes contained in this submittal will: 1) provide increased operational flexibility during periods of elevated river water temperature; 2) '
maintain Ultimate Heat Sink (UHS) operation within design and licensing basis requirements; and 3) reduce the need for required operator actions during periods of elevated river water temperature. Prompt NRC review of the changes contained in this submittal is requested to support plant operation during the upcoming period of elevated river water temperature. In addition, revisions are also being made to the Station Service Water System (SSWS), Safety Auxiliaries Cooling System (SACS) i Action Statements. These proposed changes will provide more explicit direction for i !
plant operation unde: limiting SSWS/ SACS configurations. p j
. 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 significant hazards considerations. The basis for the requested p !
change is provided in Attachment 1 to this letter. A 10CFR50.92 evaluation, with a i determination of no significant hazards consideration, is provided in Attachment 2. The
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jut 41 EN Document Control Desk LR-N98274 marked up Technical Specification pages affected by the proposed changes are provided in Attachment 3. Engineering analyses performed to support the conclusions reached in this submittal are provided in Attachment 4.
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 be pleased to discuss them with you.
Sincer ,
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Affidavit Attachments (4) b5-4933
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Document Control Desk LR-N98274 C. Mr. H. Miller, Administrator- Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 l.
11555 Rockville Pike l Rockville, MD 20852 l
Mr. S. Pindale (X24) i USNRC Senior Resident inspector- HC Mr. K. Tosch, Manager IV l Bureau of Nuclear Engineering L P. O. Box 415 j Trenton, NJ 08625 i
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f; REF: LR-N98274 -
LCR H98-02 STATE OF NEW JERSEY )
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COUNTY OF SALEM - )
H. W. Keiser, being duly sworn according to law deposes and says:
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l am Chief Nuclear Officer and President - Nuclear Business Unit of Public Service l- 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.
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Subscribed and Sw t]n before me this /Mbay o AW 1998 U
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Notary Public of New Jersey My Commission expires on / 3/h db AR N L.P" " '
NOTA'"":EUC r4 e *JP Er
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D cument C:ntrol Deck LR-N98274 i Attachment 1 LCR H98-02
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HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS) l l BASIS FOR REQUESTED CHANGE:
l LCO 3.7.1.3 Changes The changes proposed in this request result from the performance of comprehensive and detailed heat removal analyses of Hope Creek's Station Service Water System (SSWS), Safety Auxiliaries Cooling System (SACS) and Residual Heat Removal System (RHR). In part, these analyses: 1) re-evaluated RHR system heat exchanger performance; 2) justified an increase in the SACS maximum operating temperature from 95'r to 100 F; 3) evaluated the impact of the increased SACS temperatu19 on SACS supported equipment; and 4) determined the scope of optrator actions required to maintain operation of the containment and heat removal systems within their respective design bases.
As a result of these analyses, Hope Creek will avoid unnecessary plant shutdown transients during periods of elevated river water temperature and reduce the need for required operator actions in response to river water conditions.
LCO 3.7.1.1 and 3.7.1.2 Changes The changes associated with the SSWS and SACS TS Action Statements facilitate implementation of plant operator actions required to maintain safe plant operations under degraded SSWS or SACS configurations. Specifically, limitations (which define the bounds of the SSWS/ SACS / UHS design analyses) are being added to SSWS and SACS TS Action Statements to: 1) ensure that a minimum complement of operable SSWS and SACS components is available to l
support continued plant operation during all postulated river 1 water conditions; and 2) maintain the capability of the safety-related heat removal systems to mitigate the consequences of design basis accidents and transients when continued plant operation is permitted by the TS (either indefinitely or as specified in an LCO Action Statement).
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1 Document Csnt'rol Dack 'LR-N98274 Attachment 1 LCR H98-02 REQUESTED CHANGE AND PURPOSE:
LCO 3.7.1.3 Changes As shown in Attachment 3 of this letter, the UHS LCO 3.7.1.3 is being modified to incorporate new plant operation. restrictions and river. water temperature limits where specific ACTIONS are required. These restrictions and actions contained within the proposed LCO 3.7.1.3 are being incorporated to support increased flexibility in continued plant operation. As will be discussed later, these revisions: 1) maximize plant operational l capabilities during periods of elevated river water temperature; and 2) provide specific requirements for system operability such that a continued capability to mitigate the consequences of design basis accidents is ensured.
LCO 3.7.1.1 and 3.7.1.2 Changes As shown in Attachment 3 of this letter, Note *** of the SACS LCO 3.7.1.1, Action Statement a.3.a, is being revised to provide additional restrictions on continued plant operation in the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AOT. During the SACS one pump per loop configuration, all
>- ' SACS heat exchangers must be operable in addition to the two diesel generators and SSWS pumps associated with the operable SACS pumps. Similar restrictions are also being added to LCO 3.7.1.2, Action Statement a.2, for a one SSWS pump per loop configuration. These revisions provide explicit TS guidance that maintains SSWS/ SACS operating configurations within design analysis assumptions.
In addition, LCO 3.7.1.2, Action Statement a.3 is being revised to direct the operator to assess operability of the associated SACS system and to take the actions required by LCO 3.7.1.1, Action Statement a.2 when the SACS safety function can not be supported. This link ensures that appropriate actions are taken to maintain the operability of supported ECCS components and that plant operation is conducted consistent with the Hope Creek licensing basis.
BACKGROUND:
LCO 3.7.1.3 Changes The current UHS river water temperature limit of 85.0 F was incorporated into the TS with the approval of TS Amendment No.
106 on' October 28, 1997. The basis for the 85.0 F river water temperature limit was provided in PSE&G's License Change Request Page 2 of 9 i
Document Csntrol Deck LR-N98274' Attachment 1 LCR H98-02 (LCR) submittal dated May 19, 1997, and'its supplement dated August 25, 1997. That LCR was generated to resolve UHS river water-temperature issues identified in LER 96-022-02, dated j
January 31, 1997.
Although the issuance of TS Amendment No. 106 resolved the Licensing and Design Basis issues associated with Hope Creek's UHS,.PSE&G'has continued to evaluate SSWS/ SACS /RHR/ UHS performance to optimize plant configurations and limits during
' elevated river water temperature conditions'and ensure that these
-systems remain capable of performing their safety functions.
These evaluations were necessary since, based on past history, river water temperatures could exceed 85.0*F and possibly result l
in a TS required plant shutdown during periods of peak electrical demand. As discussed _in the following sections, these evaluations have included: 1) benchmarking analyses of SSWS and SACS flowpaths; 2) equipment qualification and performance analyses using elevated room temperatures; 3) detailed assessments of RHR heat exchanger performance and containment heat removal; 4) a review of required operator actions; and 5)
-refined thermal / hydraulic analyses of SSWS/ SACS /RHR.
These evaluations have resulted in the new UHS river water temperature and level limits contained in this submittal. The UHS-river water temperature limits ensure that the required heat loads can be removed for postulated combinations of external events and plant accidents or transients.
LCO 3.7.1.1 and 3.7.1.2 Changes TS Amendment Nos. 75 and 106 provided a link between the SSWS and SACS LCOs and their support and supported systems where appropriate. These links enabled the operators to assess the ability to continue plant operation. These changes resolved conflicts between support and supported system LCO AOTs similar torthose discussed in Generic Letter 91-18 (Section 6.12 of i Enclosure 2 of Generic Letter 91-18, dated November 7, 1991). 1 Since the issuance of these TS amendments, plant personnel have identified a need for additional TS guidance concerning SSWS/ SACS configurations and SSWS loop inoperability. The changes proposed in this submittal provide a resolution to those identified issues, i
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Document Control Deck LR-N98274
~ Attachment 1 LCR H98-02 JUSTIFICATION OF REQUESTED CHANGES:
LCO 3.7.1.3 Changes Except as described below, the Licensing and Design Basis requirements are the same as those contained in Hope Creek's submittals referenced in the NRC's Safety Evaluation for Technical Specification _ Amendment No. 106.
To justify _the changes to increase the UH3 temperature
' limit, Hope Creek has performed extensive analyses of system performance as. described below.
In an effort to accurately predict the SSWS/ SACS system flow rates, hydraulic models have been developed and benchmarked using SACS data obtained in the last refueling outage, (RFO7), against actual plant _ configurations for the SSWS and SACS systems. After the models were generated and benchmarked, both were used to I
simulate worst-case accident alignments so that accurate system '
flow rates could be calculated. The hydraulic analyses for SSWS assumed the maximum allowable degradation of the SSWS pumps, strainers, and SSWS/ SACS heat exchangers so that the flow rates and heat transferred are minimized. The SSWS minimum flow design conditions for design basis accident scenarios are defined as follows: 1) a minimum river water level of 80'; 2) flow is through the emergency overboard discharge pathway; 3) all SSWS pumps are operating at their minimum IST performance; 4) the SSWS strainers are 75% clogged; and 5) the SSWS/ SACS heat exchangers are fouled in accordance with design basis conditions.
The thermal / hydraulic analyses for the SACS system maximized heat loads and system flow rates, both of which are conservative with respect to maintaining the SACS system at an increased maximum i design temperature of 100 F. The SSWS/ SACS thermal / hydraulic analyses evaluated the performance of the SSWS/ SACS relative to UHS temperature limit for the worst case TS permitted operating configurations. 'For each case, the SACS header temperature was held constant 'at the increased design limit of 100 F and the required UHS temperature was determined for the SSWS flow rates l from the SSWS' hydraulic analysis. Since UHS temperature is the l parameter of concern,-the sensitivity of UHS temperature due to !
variations in each uncertainty parameter (i.e., flow, temperature and heat loads) was established. Consistent with PSE&G submittals associated with TS Amendment No. 106, the impacts of variation'of each uncertainty parameter are combined using the square-root-sum-of-the-squares (SRSS) method to arrive at the overall UHS temperature _ limit uncertainty. This uncertainty, calculated at approximately 1.3 degrees was applied (subtracted from the '
_ calculated' UHS temperature limits, resulting in the limits Page 4 of 9
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Document C ntrol Deck LR-N98274 Atta:hment 1 LCR H98-02 specified in the LCO) to the final UHS limits contained in this submittal.
For the increase in the SACS temperature design limit, PSE&G has:
- 1) evaluated the environmental qualification of equipment cooled by SACS or located in rooms cooled by SACS; 2) evaluated that effect on piping stresses resulting from the five degree temperature increase; and 3) assessed the capability of components and systems to perform their post-accident safety related functions under worst case design basis condition. As indicated in the Engineering analyses contained in Attachment 4 of this submittal, Hope Creek has concluded that the five degree increase in the maximum SACS operating temperature would have no detrimental impact on the performance of any safety functions.
Attachment 4 of this submittal contains the Engineering evaluation of the UHS temperature increase. Details on the assessments, other evaluations and analyses performed to support the UHS temperature limit are included in Attachment 4.
In order to maintain the capability of UHS to mitigate the consequences of design basis accidents and transients, Hope Creek will continue to implement the plant configuration restrictions imposed by TS Amendment No. 106 on LCO 3.7.1.3. However, the river temperature limits, which require these restrictions, will be increased and/or modified to reflect the new limits supported by the Engineering analyses. At a UHS temperatures above 85 F, certain operating configuration restrictions still need to be retained. Specifically, opening of the emergency overboard discharge valves and ensuring the availability of the emergency discharge pathways is still required prior to exceeding 85 F in river water temperature. These actions include: 1) opening valves EA-HV-2356A&B in the emergency overboard discharge lines and opening their respective breakers (to prevent inadvertent closure of the associated motor operated valves); 2) ensuring that the SSWS header outlet isolation valves EA-HV-2357A&B are open and opening their respective breakers (to prevent inadvertent closure of the associated motor operated valves); and 3) ensuring that the SSWS outlet header manual isolation valves EA-V612 and EA-V624 (see UFSAR Figure 9.2-3) are open. By taking these actions, a seismically qualified flowpath is ensured for all postulated design basis scenarios.
The assessments of SACS performance could not support a configuration with closed emergency overboard discharge Page 5 of 9 e_- __
Document C ntr:1 Deck LR-N98274 Attachment 1 LCR H98-02 valves at elevated river water temperature conditions (above 85"F) under the required worst case design basis conditions. Therefore, Hope Creek will continue to control emergency overboard valve configuration consistent with TS Amendment No. 106 licensing bases, with the Action Statement for LCO 3.7.1.3 reflecting this restriction concerning emergency overboard discharge valves above 85 F.
At 88 F, additional actions to maintain continued plant operation would be required. These actions are contained in the proposed UHS LCO ACTION Statement and are also referenced by LCOs 3.7.1.1, 3.7.1.2 and 3.8.1.1.
Specifically, indefinite plant operation with any EDG, SSWS or SACS pump inoperable is not permitted with river water temperatures in excess of this 88 F temperature limit and a Technical Specification shutdown ACTION Statement will be entered. In this configuration, adequate heat removal is assured under design basis conditions (including postulated single failures in accordance with the licensing basis) with river water temperatures up to 89*F. Except as noted in the TS and as discussed in the previous paragraph, there are no restrictions on SSWS/ SACS or EDG allowed outage 7
times (AOTs) below 88*F.
The Hope Creek SSWS/ SACS was designed in compliance with !
the requirements of 10CFR50, Appendix A, Criterion 44. This General Design Criterion requires these systems to transfer heat from structures, systems and components important to safety to an ultimate heat sink. The systems' safety function shall be to transfer the total heat load of these components under both normal operating and emergency conditions. Suitable redundancy in components and features shall be provided to assure that the systems' safety l 1
function can be accomplished assuming a single failure.
The design basis of SSWS/ SACS satisfies this criterion; however, as described in submittals referenced in the NRC's Safety Evaluation for TS Amendment No. 106, limited operator actions are taken to maintain SSWS/ SACS capability to mitigate design basis accidents or to support continued plant operation during periods of elevated river water temperature. As a result of the Engineering analyses of SSWS/ SACS /RHR, the proposed UHS temperature limits actually require less operator actions than those limits contained in TS Amendment No. 106.
l Specifically, in cases where SSWS/uhCS temperatures can not be maintained and a LOP and/or LOCA occurs, the current SSWS abnormal operating procedure will direct that Page 6 of 9 l
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l Document'Cantrol Deck' LR-N98274 Attachment 1 LCR H98-02 operators isolate SACS' flow to the fuel pool heat exchangers-for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, isolate SSWS flow to one.
Reactor Auxiliaries Cooling System (RACS) (see UFSAR Figure 9.2-3) heat exchanger and throttle SSWS flow to.the remaining RACS heat exchanger. However, isolating / throttling of.RACS flow under LOP conditions will' no longer be required. The revised SSWS/ SACS /UH,'analy'ses has supported the' removal of this post-transient operator action. The actions associated with isolating / throttling SSWS flow to the RACS heat exchangers are not necessary
.under LOCA conditions since the SSWS flow to'those componcnts'is automatically isolated.
The SSWS abnormal operating procedure also addresses a condition where a LOP and/or LOCA occurs coincident with:
- 1) an event which results in. blockage.of the normal flow path-to the cooling tower; 2) the emergency overboard discharge valves are open.(as discussed in the previous section); and 3) SACS heat exchanger outlet temperatures can not be maintained below 95 F. In this situation, the procedure directs the operators to: 1) isolate the SSWS outlet from one of the SSWS/ SACS heat exchangers in the SSWS/ SACS loop not servicing residual heat removal (RHR) decay heat loads if all four-SSWS pumps are running; or 2)
~ when only two SSWS pumps'are operating in one loop and one SSWS pump is operating in the other, ensure that the SSWS outlet from one of the SSWS/ SACS heat exchangers in the
-loop with only one SSWS pump in service not servicing RHR decay heat loads is closed. These actions are also no longer-necessary under these conditions, since the SSWS/ SACS / UHS analyses have ensured that sufficient-flow to the SSWS/ SACS heat exchangers will be available such that heat removal requirements are satisfied for the proposed UHS river water temperature limits.
LCO 3.7.1.1 and 3'.7.1.2 Changes The current SSWS and SACS TS LCOs and Action' Statements were established such that the capability of these systems to mitigate the consequences of design basis accidents and transients is maintained when continued plant operation is permitted. Hope Creek TS Amendment No. 75 implemented changes.to the SSWS and I SACS AOTs which require (via notations in the LCO Action Statements) operators.to assess the operability of specified
-support and supported' components (SSWS pumps, SACS pumps.and diesel generators) when an A0T was entered for an inoperable 1SSWS/ SACS' pump or pumps. The purpose of those changes was to
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Document C;ntr:1 Deck LR-N98274 LCR H98-02 limit SSWS/ SACS configurations that would result in less than adequate post-accident heat removal capability.
The proposed changes to TS LCO Action Statements 3.7.1.1.a.3.a and 3.7.1.2.a.2 do not alter any of the conclusions contained in the NRC SER for TS Amendment No. 75. Instead, restrictions in the existing SSWS and SACS pump AOTs will be revised to include requirements for operability of the passive SACS heat exchangers in limiting SSWS/ SACS configurations. A failure to meet the requirements that permit continued plant operation while in these AOTs will still require the operators to take action to place the plant in safe condition (as specified by LCO Action Statement 3.7.1.1.a.4 for SACS or TS 3.0.3 for SSWS). Implementat ton of these changes would: 1) provide clear guidance in the TS which maintains SSWS/ SACS operation within the bounds of the established design basis analyses; and 2) minimize operator assessments of acceptable SSWS/ SACS configurations that perm.t continued plant operation.
Hope Creek TS Amendment No. 106 provided additional requirements in the TS for operator actions to mitigate a loss of function in one SACS loop. Prior to implementation of TS Amendment No. 106, operators were required to assess operability of all SACS supported loads in response to an inoperable SACS loop. From this assessment, plant operation would be limited by the most restrictive A0T of i SACS supported system (which could be as limiting as TS 3.0.3). TS Amendment No. 106 established an appropriately conservative six hour period to realign SACS cooling to affected loads that were needed to support plant operation for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (the length of the SACS loop A0T).
The purpose of that change, in part, was to address the conflict between the SACS loop AOT and the AOT of SACS supported systems (similar to that discussed in Generic Letter 91-18).
The proposed changes to TS LCO Action Statement 3.7.1.2.a.3 do not alter any of the conclusions contained in the NRC ;
SER for TS Amendment No. 106. Under the proposed TS, l operators will be required to assess the operability of a SACS loop when its associated SSWS loop is declared inoperable. These proposed changes implement TS actions which: 1) recognize the operability link between SSWS and it supported SACS loop; and 2) ensure consistency with the provisions outlined in Generic Letter 91-18. The proposed change will continue to ensure that operability of the safety-related, SACS supported components and systems is Page 8 of 9
LR-N98274
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' Document Csntrol' Desk
' Attachment 1 LCR M98-02
-maintained 'i n accordance with-. Hope Creek's existing licensing basis when a SSWS loop is declared-inoperable.
' CONCLUSIONS:
The-changes proposed in this request are.being made~to: '1) implement--a morez appropriate LCO for Hope Creek's UHS; and 2).
provide explicit direction for plant operation under limiting
'SSWS/ SACS configurations. PSE&G concludes'that these proposed.
changes are adequately justified and result'in No Significant:
Hazards Consideration as' described in Attachment 2.of this-letter, j
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D:cument C ntrol Desk LR-N98274 Attachment 2 LCR H98-02 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 PJ!: VISIONS TO THE TECHNICAL SPECIFICATIONS (TS) 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to'the Hope Creek Generating Station (HC)
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 provided below.
' REQUESTED CHANGE The proposed changes affect sectione 3.7.1.1, 3.7.1.2 and 3.7.1.3 of the Hope Creek TS. Specifically, the proposed changes-implement more appropriate Ultimate Heat Sink (UHS) limits for river water temperature, which increase operational flexibility.
In addition, the Station Service Water System (SSWS) and Safety Auxiliaries Cooling System (SACS) TS Action Statements are being revised te provide additional restrictions on continued plant operation. Toese revisions provide explicit TS guidance, which maintains SSWS/ SACS operating configurations within design analysis assumptions.
BASIS
- 1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
LCO 3.7.1.3 Changes The proposed TS revisions related to UHS involve no hardware changes and no changes to existing structures, systems or components. The UHS and supported system temperature and configuration limits ensure that the UHS can remove required heat loads during design basis accidents and transients with the proposed UHS river water temperature limits. The proposed UHS TS ACTION Statements ensure that the plant is directed to enter a safe shutdown condition whenever the capability to mitigate design basis accidents and transients is lost. The existing UHS TS surveillance requirements.to increase monitoring of the river water temperature at 82"F adequately ensures that the actions required at elevated river water temperature Page 1 of 4 i
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Document Crntrol Deck LR-N98274
. Attachment 2 LCR H98-02 conditions are taken as appropriate. Since the UHS will
-still' remain capable of meeting all applicable' design basis
-requirements and retaining the capability to mitigate the consequences of. accidents described in the HC UFSAR, the proposed changes were determined to be-justified. As a
-result, these-changes.will not increase the probability of an accident-previously evaluated nor significantly increase the consequences of an accident previously evaluated.
LCO 3.7.1.1 and 3.7.1.2 Changes The proposed TS revisions related to SSWS/ SACS operating configuration restrictions involve no hardware changes and no changes to existing structures, systems or components.
The additional restrictions requiring: 1) SACS heat
. exchanger operability in one SSWS/ SACS pump per loop scenarios; and.2) assessments of SACS loop operability when a SSWS loop is declared inoperable; ensure that the SSWS/ SACS can remove required heat loads during design basis accidents and transients with the proposed UHS river water temperature limits contained in this submittal. The proposed SSWS/ SACS TS ACTION Statements ensure that the plant is directed to enter a safe shutdown condition whenever the capability to mitigate design basis accidents and transients is lost. Since SSWS/ SACS will still remain capable of meeting all applic able design basis requirements and retaining the capability to mitigate the consequences of accidents described in the HC UFSAR, the proposed changes were determined to be justified. As a result, these changes will not increase the probability of an accident previously evaluated nor significantly increase 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.
LCO 3.7.1.3 Changes The prop > sed changes to the UHS TS contained in this
, submittal will not adversely impact the operation of any safety related component or equipment. Since the proposed !
changes involve.no hardware changes and no changes to existing structures, systems or components, there can be no
. impact on the potential occurrence of any accident due to new equipment failure modes. The system configuration limits imposed.by the UHS LCO ensure that supported systems ;
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Document Crntral Desk- LR-N98274 Attachment 2 LCR H98-02 can remove required heat loads during design basis accidents and transients with the proposed UHS river water temperature limits. Furthermore, there is no change in plant. testing proposed in this change request that 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.
LCO 3.7.1.1 and 3.7.1.2 Changes
'The proposed changes to the SSWS/ SACS TS contained in this
. submittal will not adversely impact the operation of any safety related component or equipment. Since the proposed changes involve no. hardware changes and no changes to l existing structures, systems or components, there can be no l impact on the potential occurrence of any accident due to new equipment failure modes. The system. configuration limits imposed by the SSWS/ SACS LCOs ensure that systems can remove required heat loads during design basis
! accidents and transients with the proposed UHS river water temperature limits. Furthermore, there is no change in plant testing proposed in this change request that 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.
LCO 3.7.1.3 Changes The proposed changes for the TS related to the UHS ensure continued capability of the UHS to mitigate the consequences of design basis accidents and transients. The UHS supported systems' configuration limits and changes to the operating. limits of the UHS ensure that the UHS can remove required heat loads during design basis accidents and transients with the proposed river water temperature limits. The proposed UHS TS ACTION Statements ensure that the plant is directed to: 1) enter a safe shutdown condition whenever the capability to mitigate design basis accidents and transients is lost; or 2) enter a conservatively short period of continued operation when
. supported system redundancy is reduced. Since the UHS will still remain capable of meeting all applicable design basis- !
requirements and retaining the capability to mitigate the consequences of accidents described in the HC UFSAR, the .
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Document'C ntral Deck: LR-N98274 LCR H98-02 proposed changes contained were determined to not result in a1significant. reduction in a margin of safety.
LCO 3.7.1.1 and 3.7.1.2 Changes The proposed changes for the TS related to the SSWS/ SACS ensure continued capability of these systems to mitigate the consequences of design basis accidents and transients.
The proposed configuration limits ensure that the safety-related heat removal systems can perform their safety functions-during design basis accidents and transients with the proposed river water' temperature limits. The SSWS/ SACS TS ACTION Statements ensure that the plant is directed to:
- 1) enter a safe shutdown condition whenever.the capability to mitigate design basis accidents.and transients is lost; or 2) enter a conservatively short period of continued
. operation when 'ipported system redundancy is reduced..
Since the SSWS/ ACS will still remain capable of meeting all applicable ssign basis requirements and retaining the capability to mitigate the consequences of accidents described in.the HC UFSAR, the proposed changes contained were determined to not-result in a significant reduction in a margin of sefety.
CONCLUSION Based on'the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.
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