LR-N25-0038, License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, Supplement 3
| ML25111A013 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/21/2025 |
| From: | Emily Larson Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N25-0038, LAR-H24-02 | |
| Download: ML25111A013 (1) | |
Text
Eric Larson Hope Creek Generating Station Site Vice President, PSEG Nuclear 2200 Alloway Creek Neck Road PO Box 236 Hancocks Bridge, New Jersey 08038-0221 (856) 339-2414 Eric.Larson@PSEG.com 10 CFR 50.90 LR-N25-0038 LAR H24-02 April 21, 2025 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354
Subject:
License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, Supplement 3
Reference:
- 1.
PSEG letter to NRC, License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, dated May 20, 2024 (ADAMS Accession No. ML24142A407 and ADAMS Package ML24142A428)
- 2.
PSEG letter to NRC, License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, Supplement 1, dated October 17, 2024 (ADAMS Accession Nos.
ML24291A057 and ML24291A059)
- 3.
PSEG letter to NRC, License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, Supplement 2, dated April 4, 2025 (ADAMS Accession No. ML25094A035)
PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) in May 2024 to Renewed Facility Operating License No. NPF-57 for Hope Creek Generating Station (HCGS) to revise Hope Creeks current Technical Specifications (CTS) to the Improved Technical Specifications (ITS) consistent with NUREG-1433, Revision 5, Standard Technical Specifications, General Electric BWR/4 Plants, (ISTS) (Reference 1). Supplement 1 to the ITS Conversion LAR submitted in October 2024 (Reference 2) revised Enclosure 2, Volume 13 -
ITS Section 3.8 Electrical Power Systems, of the ITS Conversion LAR to eliminate an ISTS requirement not applicable to HCGS. Supplement 2 to the ITS Conversion LAR submitted in April 2025 (Reference 3) revised Enclosures 1 and 2 of the ITS Conversion LAR to adopt ISTS generic change TSTF-597, Revision 0, Eliminate LCO 3.0.3 MODE 2 Requirement, and include necessary licensee identified changes.
LR-N25-0038 Page 2 10 CFR 50.90 This supplement proposes to restore the current technical specification action requirement associated with the Reactor Core Isolation Cooling (RCIC) System Reactor Vessel Water Level
- High, Level 8 instrument function in lieu of the more restrictive action specified in the ISTS for the same function. The supplement also includes minor editorial changes to ITS 3.3.5.3 Discussion of Change L03 and ITS 3.3.5.3 Bases. The attachment to this letter provides a summary of changes to Attachment 11, "ITS 3.3.5.3, Reactor Core Isolation Cooling (RCIC)
System Instrumentation," to Enclosure 2 Volume 8 - ITS Section 3.3 Instrumentation, dated May 20, 2024, (ADAMS Accession No. M L24142A436) of the HCGS ITS Conversion LAR (Reference 1). The enclosure to this letter includes only ITS Conversion LAR pages impacted by Supplement 3 and are identified with a revision bar and an S3 designation.
The PSEG Fleet Review Committee reviewed this LAR supplement and determined that operation of Hope Creek in accordance with the proposed changes will not endanger the health and safety of the public.
PSEG has determined that the information provided in this supplement does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted in Reference 1. In addition, the information provided in this supplement does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
In accordance with 1 0 CFR 50.91 (b)(1 ), a copy of this LAR supplement has been sent to the State of New Jersey.
If there are any questions or if additional information is needed, please contact Mr. Brian Thomas at brian.thomas@pseg.com.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on Lj - J 1 *,) D 2 s-(Date)
Respectfully, Eric Larson Site Vice President Hope Creek Generating Station
Attachment:
Summary of Proposed Changes to Hope Creek Generating Station ITS Conversion LAR
Enclosure:
Proposed Changes to Hope Creek Generating Station Improved Technical Specification Conversion License Amendment Request
LR-N25-0038 10 CFR 50.90 Page 3 cc:
Administrator, Region I, NRC NRC Project Manager, Hope Creek NRC Senior Resident Inspector, Hope Creek Manager NJBNE
LR-N25-0038 LAR H24-02 ATTACHMENT
SUMMARY
OF PROPOSED CHANGES TO HOPE CREEK GENERATING STATION ITS CONVERSION LAR (2 TOTAL PAGES, INCLUDING COVER SHEET)
LR-N25-0038 Attachment Summary of Proposed Changes to Hope Creek Generating Station ITS Conversion LAR A-1 The proposed change to the Hope Creek Generating Station (HCGS) Improved Technical Specifications (ITS) Conversion License Amendment Request (LAR) restores the current technical specification action requirement associated with the Reactor Core Isolation Cooling (RCIC) System Reactor Vessel Water Level - High, Level 8 instrument function in lieu of the more restrictive action specified in the Improved Standard Technical Specifications (ISTS) for the same function. The proposed change also includes minor editorial changes to ITS 3.3.5.3 Discussion of Change (DOC) L03 and ITS 3.3.5.3 Bases. The following is a summary of the changes:
Reference Specification Summary of Changes HCGS ITS Conversion LAR -,
Volume 8, 1 ITS 3.3.5.3, RCIC System Instrumentation CTS markup:
Changed Condition C to B for Reactor Vessel Water Level - High, Level 8 Trip Function in CTS Table 3.3.5-1.
Added a DOC L02 reference to ACTION 50.a.
Discussion of Changes:
Revised ITS 3.3.5.3 DOC L02 to reflect the change from the ITS 3.3.5.3 ACTION C to ACTION B.
Editorial change made to DOC L03 clarifying the less restrictive change to CTS and removing duplicated text.
ISTS markup:
Added DOC L02 reference in LH column to ITS 3.3.5.3 ACTION B and removed DOC L02 reference in LH column to ACTION C.
Changed Condition C to B for Reactor Vessel Water Level - High, Level 8 Trip Function in ITS Table 3.3.5.3-1 and added a reference to new JFD 4.
ISTS Justification for Deviations:
Added JFD 4.
ISTS Bases markup Editorial change made to ISTS Bases page B 3.3.5.3-6 to reflect wide range water level measurement instrumentation instead of narrow range water level instrumentation consistent with HCGS plant design.
Revised ISTS 3.3.5.3 ACTIONS B and C sections to reflect the changes made to the Specification and added a reference to new Bases JFD 7.
ISTS Bases Justification for Deviations Added Bases JFD 7.
LR-N25-0038 LAR H24-02 ENCLOSURE PROPOSED CHANGES TO HOPE CREEK GENERATING STATION IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST (12 TOTAL PAGES, INCLUDING COVER SHEET)
SURVEILLANCES Note 2 TABLE 3.3.5-1 REACTOR CORE ISOLATION COOLING SYSTEM ACTUATION INSTRUMENTATION TRIP FUNCTION MINIMUM OPERABLE CHANNELS PER TRIP FUNCTION (a)
ACTION
- a.
Reactor Vessel Water Level - Low Low, Level 2 4(b) 50
- b.
Reactor Vessel Water Level - High, Level 8 4(b) 50
- c.
Condensate Storage Tank Water Level - Low(e) 2(c) 51
- d.
Manual Initiation 1(d) 52 (a)
A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required surveillance without placing the trip system in the tripped condition provided all other channels monitoring that parameter are OPERABLE.
(b)
One trip system with one-out-of-two twice logic.
(c)
One trip system with one-out-of-two logic.
(d)
One trip system with one channel.
(e)
Initiates RCIC suction switchover from the condensate storage tank to the torus.
HOPE CREEK 3/4 3-52 Amendment No. 62 A01 ITS 3.3.5.3 ITS REQUIRED CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 Table 3.3.5.3-1 Function 1 Table 3.3.5.3-1 Function 2 Table 3.3.5.3-1 Function 3 Table 3.3.5.3-1 Function 4 B
B D
C LA02 When a is solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows (a) the associated Function maintains RCIC initiation capability Functions 2 and 4; and (b) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 1 and 3 1
2 3
4 LA02 A06 L02 L03 S3
ACTION E TABLE 3.3.5-1 (Continued)
REACTOR CORE ISOLATION COOLING SYSTEM ACTUATION INSTRUMENTATION ACTION 50 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement:
- a.
With one channel inoperable, place the inoperable channel in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or declare the RCIC system inoperable.
- b.
With more than one channel inoperable, declare the RCIC system inoperable.
ACTION 51 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, place at least one inoperable channel in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or declare the RCIC system inoperable.
ACTION 52 - With the number of OPERABLE channels one less than required by the Minimum OPERABLE Channels per Trip Function requirement, restore the inoperable channel to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or declare the RCIC system inoperable.
HOPE CREEK 3/4 3-53 Amendment No. 62 A01 ITS 3.3.5.3 ITS ACTION A As required by Required Action A.1 and referenced in Table 3.3.5.3-1.
ACTION D RA B.2 ACTION C 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of RCIC initiation capability RA B.1 RA D.2.1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of RCIC initiation capability Add Required Action D.1 Note and Required Action D.2.2 L04 RA C.1 ACTION E RA D.1 L03 or more channels L02 ACTION B and L03 S3
DISCUSSION OF CHANGES 3.3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM INSTRUMENTATION Hope Creek Page 7 of 9 System (ECCS) injection/spray subsystems are assumed to begin injection at pressures higher than 200 psig (286 psid for LPCI and 289 psid for core spray).
Therefore, requiring the RCIC System to be OPERABLE between 150 psig and 200 psig serves no safety significant purpose. NEDC-33172P (ADAMS Accession No. ML053250469; not publicly available) was reviewed by the NRC and ECCS performance was determined acceptable for the HCGS extended power uprate as documented in the NRC safety evaluation associated with License Amendment 174, dated May 14, 2008 (NRC ADAMS Accession No. ML081230540).
This change is acceptable because the loss of coolant accident analyses indicate that low pressure ECCS injection/spray subsystems will begin to inject at pressures greater than 200 psig and the low pressure ECCS is fully capable of restoring and maintaining RPV water level during any accident or transient initiated below 200 psig. As such, there is minimal safety impact associated with the proposed change. The change is designated less restrictive because less stringent Applicability requirements are being applied in the ITS than were applied in the CTS.
L02 (Category 4 - Relaxation of Required Action) CTS Table 3.3.5-1, ACTIONs 50.a and 50.b, applies, in part, to Trip Function b (Reactor Vessel Water Level - High, Level 8). CTS Table 3.3.5-1, ACTION 50.a, requires with one channel inoperable, placing the inoperable channel in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or declaring the RCIC System inoperable. CTS Table 3.3.5-1, ACTION 50.b, requires with more than one channel inoperable, declare the RCIC system inoperable. ITS 3.3.5.3, Required Action B.1, applies to Function 2 (Reactor Vessel Water Level - High, Level 8) and requires, with one or more channels inoperable, declare RCIC System inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of RCIC initiation capability and placing the channel(s) in trip. This changes the CTS by allowing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to place multiple inoperable channels in the tripped condition provided RCIC initiation capability is maintained.
The purpose of the Reactor Vessel Water Level - High, Level 8 Function is to close the RCIC steam supply and cooling water supply valves to prevent overflow into the main steam lines. The Reactor Vessel Water Level - High, Level 8 logic is arranged in a one-out-of-two taken twice logic. This instrumentation logic arrangement precludes the loss of or initiation of the RCIC System trip function on reactor vessel high water level due to the inoperability of a single instrument channel. Therefore, ITS 3.3.5.3 Required Action B.2 is an acceptable action. If two Reactor Vessel Water Level - High, Level 8 channels are inoperable and tripped, one in each trip system, RCIC System automatic initiation capability is precluded since the RCIC turbine is isolated. As a result, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of Required Action B.2 is not appropriate, and the RCIC System must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of RCIC initiation capability in accordance with ITS 3.3.5.3 Required Action B.1. This change is acceptable because of the redundancy of sensors available to provide initiation signals to isolate the RCIC steam supply and cooling water supply prior to overflow in the main steam lines and the Required Actions compensate for the inoperability allowing operation to continue provided automatic initiation of the S3 S3 S3
DISCUSSION OF CHANGES 3.3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM INSTRUMENTATION Hope Creek Page 8 of 9 RCIC System is not prevented. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
L03 (Category 3 - Relaxation of Completion Time) CTS Table 3.3.5-1, ACTIONs 50.a and 50.b, apply, in part, to Trip Function a (Reactor Vessel Water Level - Low Low, Level 2). CTS Table 3.3.5-1, ACTION 50.a, requires with one channel inoperable, placing the inoperable channel in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or declaring the RCIC System inoperable. CTS Table 3.3.5-1, ACTION 50.b, requires with more than one channel inoperable, declare the RCIC system inoperable. ITS 3.3.5.3, Required Action B.1, applies to Function 1 (Reactor Vessel Water Level - Low Low, Level 2) and requires, with one or more channels inoperable, declare RCIC System inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of RCIC initiation capability and placing the channel in trip. This changes the CTS by allowing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to place multiple inoperable channels in the tripped condition provided RCIC initiation capability is maintained.
The purpose of the CTS ACTIONS for Trip Functions a and b, is to place instrumentation channels in a condition that performs the related safety function or declare the RCIC System inoperable upon discovery of loss of RCIC initiation capability. Because of the redundancy of sensors available to provide initiation signals and the fact that the HPCI System and ADS in conjunction with the low pressure ECCS are fully capable of mitigating any accident or transient, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable to permit restoration of any inoperable channel to OPERABLE status. Alternately, the inoperable channels may be placed in trip (ITS 3.3.5.3, Required Action B.2),
since this would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue. In the situation where inoperable channels result in a loss of automatic initiation capability, the RCIC System must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This change is consistent with the ISTS and designated as less restrictive because less stringent Completion Time requirements are being applied in the ITS than were applied in the CTS and providing the option to place affected channels in trip when more than one channel is inoperable.
L04 (Category 1 - Relaxation of LCO Requirements) CTS Table 3.3.5-1, ACTION 51, applies to Trip Function c (CST Level - Low) and requires with number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, place at least one inoperable channel in the tripped condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or declare the RCIC system inoperable. ITS 3.3.5.3, ACTION D, applies to Function 3 (CST Level - Low) and requires with one or more channel inoperable, declare RCIC System inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of RCIC initiation capability (Required Action D.1) and place channel in trip within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (ITS 3.3.5.3, Required Action D.2.1). Alternately, the RCIC pump suction may be aligned to the suppression pool (ITS 3.3.5.3, Required Action D.2.2). If the RCIC pump suction is aligned to the suppression pool then ITS 3.3.5.3, Required Action D.1, is not applicable (ITS 3.3.5.3, Required Action D.1 Note) since the CST Level - Low Function is satisfied when the RCIC pump suction is aligned to the suppression pool. This changes the CTS S3 S3 S3
RCIC System Instrumentation 3.3.5.3 General Electric BWR/4 STS 3.3.5.3-1 Rev. 5.0 Hope Creek Amendment XXX 1
3.3 INSTRUMENTATION 3.3.5.3 Reactor Core Isolation Cooling (RCIC) System Instrumentation LCO 3.3.5.3 The RCIC System instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.
APPLICABILITY:
MODE 1, MODES 2 and 3 with reactor steam dome pressure > [150] psig.
ACTIONS
NOTE-----------------------------------------------------------
Separate Condition entry is allowed for each channel.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels inoperable.
A.1 Enter the Condition referenced in Table 3.3.5.3-1 for the channel.
Immediately B. As required by Required Action A.1 and referenced in Table 3.3.5.3-1.
B.1 Declare RCIC System inoperable.
AND B.2 Place channel in trip.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of RCIC initiation capability 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
[OR In accordance with the Risk Informed Completion Time Program]
C. As required by Required Action A.1 and referenced in Table 3.3.5.3-1.
C.1 Restore channel to OPERABLE status.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LCO 3.5.3 Table 3.3.5-1 Applicability DOC A03 Table 3.3.5-1 Actions b Table 3.3.5-1 Action 50.b DOC L02 DOC L03 Table 3.3.5-1 Action 50.a DOC L02 DOC L03 Table 3.3.5-1 Action 52 2
2 DOC L01 200 3
S3 S3 S3
RCIC System Instrumentation 3.3.5.3 General Electric BWR/4 STS 3.3.5.3-5 Rev. 5.0 Hope Creek Amendment XXX 1
Table 3.3.5.3-1 (page 1 of 1)
Reactor Core Isolation Cooling System Instrumentation FUNCTION REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE
- 1. Reactor Vessel Water Level - Low Low, Level 2
[4]
B SR 3.3.5.3.1 SR 3.3.5.3.2
[SR 3.3.5.3.3](a)(b)
SR 3.3.5.3.5(a)(b)
[-47] inches
- 2. Reactor Vessel Water Level - High, Level 8
[2]
C SR 3.3.5.3.1 SR 3.3.5.3.2
[SR 3.3.5.3.3](a)(b)
SR 3.3.5.3.5(a)(b)
[56.5] inches
- 3. Condensate Storage Tank Level -
Low
[2]
D
[SR 3.3.5.3.1]
[SR 3.3.5.3.3](a)(b)
[SR 3.3.5.3.4](a)(b)
[0] inches
[ 4. Suppression Pool Water Level -
High
[2]
D
[SR 3.3.5.3.1]
[SR 3.3.5.3.3](a)(b)
SR 3.3.5.3.5(a)(b)
[151] inches ]
[
- 5. Manual Initiation
[1]
C SR 3.3.5.3.6 NA ]
(a) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(b) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.
Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].
Table 3.3.5-2 Functional Unit a (Allowable Value)
Table 3.3.5-1 Trip Function a Table 3.3.5-1 Trip Function b Table 3.3.5-1 Trip Function c Table 3.3.5-1 Trip Function d
-45 61 64,291 gallons Table 3.3.5-2 Functional Unit b (Allowable Value)
Table 3.3.5-2 Functional Unit c (Allowable Value) 4 4
4 4
4 Nominal N
N N
4 2
2 2
1 1
1 1
1 2
2 2
1 the Technical Requirements Manual and Updated Final Safety Analysis Report, respectively DOC M01 1
1 1
2 4
B S3
JUSTIFICATION FOR DEVIATIONS 3.3.5.3, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM INSTRUMENTATION Hope Creek Page 1 of 1
- 1.
Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2.
The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
- 3.
The reactor steam dome pressure in the Applicability for ITS 3.3.5.3 is revised to 200 psig to be consistent with Applicability of the High Pressure Coolant Injection (HPCI) System specified in ITS 3.5.1, "ECCS - Operating." This change meets the intent of the ISTS and the Hope Creek Generating Station (HCGS) current Technical Specifications (CTS) and ITS ACTION requirements that the Applicability of HPCI and Reactor Core Isolation Cooling (RCIC) systems be equivalent.
- 4.
ISTS 3.3.5.3 Condition C referenced for RCIC System Instrumentation Function 2, Reactor Vessel Water Level - High, Level 8 specified in Table 3.3.5.3-1 is revised in ITS Table 3.3.5.3-1 to Condition B. This ISTS deviation maintains the HCGS CTS action requirement, which allows placing a Reactor Vessel Water Level - High, Level 8 instrument channel in the trip condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The ISTS 3.3.5.3 ACTION C is based on a RCIC System Reactor Vessel Water Level - High, Level 8 instrument logic design that consists of two channels arranged in a two-out-of-two logic. Failure of one of two channels to trip will result in a loss of the RCIC System trip function on reactor vessel high water level. The HCGS RCIC System Reactor Vessel Water Level - High, Level 8 instrument logic consists of four channels arranged in a one-out-of-two taken twice logic. This more reliable instrumentation logic arrangement precludes the loss of or initiation of the RCIC System trip function on reactor vessel high water level due to the inoperability of a single instrument channel. Therefore, ITS 3.3.5.3 Required Action B.2 is an acceptable action.
ITS 3.3.5.3 Required Action B.1 will preclude placing multiple RCIC System Reactor Vessel Water Level - High, Level 8 channels in the trip condition such that RCIC System initiation capability is lost due to an isolated RCIC System turbine.
S3
RCIC System Instrumentation B 3.3.5.3 General Electric BWR/4 STS B 3.3.5.3-6 Rev. 5.0 Hope Creek Revision XXX 1
BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.
- 1. Reactor Vessel Water Level - Low Low, Level 2 Low reactor pressure vessel (RPV) water level indicates that normal feedwater flow is insufficient to maintain reactor vessel water level and that the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, the RCIC System is initiated at Level 2 to assist in maintaining water level above the top of the active fuel.
Reactor Vessel Water Level - Low Low, Level 2 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.
The Reactor Vessel Water Level - Low Low, Level 2 Allowable Value is set high enough such that for complete loss of feedwater flow, the RCIC System flow with high pressure coolant injection assumed to fail will be sufficient to avoid initiation of low pressure ECCS at Level 1.
Four channels of Reactor Vessel Water Level - Low Low, Level 2 Function are available and are required to be OPERABLE when RCIC is required to be OPERABLE to ensure that no single instrument failure can preclude RCIC initiation. Refer to LCO 3.5.3 for RCIC Applicability Bases.
- 2. Reactor Vessel Water Level - High, Level 8 High RPV water level indicates that sufficient cooling water inventory exists in the reactor vessel such that there is no danger to the fuel.
Therefore, the Level 8 signal is used to close the RCIC steam supply, steam supply bypass, and cooling water supply valves to prevent overflow into the main steam lines (MSLs). (The injection valve also closes due to the closure of the steam supply valve.)
Reactor Vessel Water Level - High, Level 8 signals for RCIC are initiated from two level transmitters from the narrow range water level measurement instrumentation, which sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.
1 four 1
1 1
assuming nominal conditions. For loss of feedwater flow analysis cases assuming worst case conditions, the Allowable Value is sufficient to ensure RPV water level does not reach the top of active fuel.
wide S3
RCIC System Instrumentation B 3.3.5.3 General Electric BWR/4 STS B 3.3.5.3-9 Rev. 5.0 Hope Creek Revision XXX 1
BASES ACTIONS (continued)
A Note has been provided to modify the ACTIONS related to RCIC System instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RCIC System instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable RCIC System instrumentation channel.
A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.3-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered to be inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.
B.1 and B.2 Required Action B.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in a complete loss of automatic initiation capability for the RCIC System. In this case, automatic initiation capability is lost if two Function 1 channels in the same trip system are inoperable and untripped. In this situation (loss of automatic initiation capability), the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of Required Action B.2 is not appropriate, and the RCIC System must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of RCIC initiation capability.
The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action B.1, the Completion Time only begins upon discovery that the RCIC System cannot be automatically initiated due to two inoperable, untripped Reactor Vessel Water Level - Low Low, Level 2 channels in the same trip system. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.
1 In addition, if two Function 2 channels are inoperable and tripped, one in each trip system, RCIC System automatic initiation capability is precluded since steam is isolated to the RCIC turbine. In these situations 7
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RCIC System Instrumentation B 3.3.5.3 General Electric BWR/4 STS B 3.3.5.3-10 Rev. 5.0 Hope Creek Revision XXX 1
BASES ACTIONS (continued)
Because of the redundancy of sensors available to provide initiation signals and the fact that the RCIC System is not assumed in any accident or transient analysis, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 2) to permit restoration of any inoperable channel to OPERABLE status. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action B.2. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue. Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the inoperable channel in trip would result in an initiation), Condition E must be entered and its Required Action taken.
C.1 A risk based analysis was performed and determined that an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Ref. 2) is acceptable to permit restoration of any inoperable channel to OPERABLE status (Required Action C.1). A Required Action (similar to Required Action B.1) limiting the allowable out of service time, if a loss of automatic RCIC initiation capability exists, is not required. This Condition applies to the Reactor Vessel Water Level -
High, Level 8 Function whose logic is arranged such that any inoperable channel will result in a loss of automatic RCIC initiation capability. As stated above, this loss of automatic RCIC initiation capability was analyzed and determined to be acceptable. This Condition also applies to the Manual Initiation Function. Since this Function is not assumed in any accident or transient analysis, a total loss of manual initiation capability (Required Action C.1) for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed. The Required Action does not allow placing a channel in trip since this action would not necessarily result in a safe state for the channel in all events.
D.1, D.2.1, and D.2.2 Required Action D.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in automatic component initiation capability being lost for the feature(s). For Required Action D.1, the RCIC System is the only associated feature. In this case, automatic initiation capability is lost if two Function 3 channels or two Function 4 channels are inoperable and 2
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1 HPCI System and the ADS in conjunction with the low pressure ECCS are fully capable of mitigating 1
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7 an inoperable Reactor Vessel Water Level - Low Low, Level 2 or placing an inoperable Reactor Vessel Water Level - High, Level 8 channel in trip would result in closing the RCIC steam supply valve 7
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JUSTIFICATION FOR DEVIATIONS 3.3.5.3 BASES, REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM INSTRUMENTATION Hope Creek Page 1 of 1
- 1.
Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2.
The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
- 3.
The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
- 4.
The reactor steam dome pressure in the Applicability for the Reactor Core Isolation Cooling (RCIC) System instrumentation of ITS 3.3.5.3 is revised to 200 psig to be consistent with Applicability of the High Pressure Coolant Injection (HPCI) System specified in ITS 3.5.1, "ECCS - Operating."
- 5.
The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal. The plant specific ITS 3.3.5.3 ACTION Completion Times are consistent with HGCS current technical specifications. Surveillance Frequencies are controlled in the plant specific Surveillance Frequency Control Program consistent with current technical specifications. Therefore, there is no need for further justification of the ACTION Completion Times or Surveillance Frequencies.
- 6.
The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal. ISTS Table 3.3.5.3-1 Notes a and b (ITS Table 3.3.5.3-1 Notes a and b) are applied to the applicable Functions in the ITS with no exclusions.
- 7.
ISTS 3.3.5.3 Condition C referenced for RCIC System Instrumentation Function 2, Reactor Vessel Water Level - High, Level 8 specified in Table 3.3.5.3-1 is revised in ITS Table 3.3.5.3-1 to Condition B. This ISTS deviation maintains the HCGS CTS action requirement, which allows placing a Reactor Vessel Water Level - High, Level 8 instrument channel in the trip condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If two Function 2 channels are inoperable and tripped, one in each trip system, RCIC System automatic initiation capability is precluded since the RCIC turbine is isolated. In this situation, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of ITS 3.3.5.3 Required Action B.2 is not appropriate, and the RCIC System must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of RCIC initiation capability per the requirements of ITS 3.3.5.3 Required Action B.1. Changes are made to ITS 3.3.5.3 Bases to reflect the change to the Specification.
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