View source for LR-N972466, Provides Info to Supplement Justification Made in Which Requested Rev to Plant UHS Temperature & River Water Level Limits Contained in Encl TS

{{Adams
| number = ML20217Q305
| issue date = 08/25/1997
| title = Provides Info to Supplement Justification Made in Which Requested Rev to Plant UHS Temperature & River Water Level Limits Contained in Encl TS
| author name = Simpson E
| author affiliation = PUBLIC SERVICE ELECTRIC &amp; GAS CO. OF NEW JERSEY
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000354
| license number = 
| contact person = 
| document report number = LCR-H97-02, LCR-H97-2, LR-N972466, NUDOCS 9709020325
| title reference date = 05-19-1997
| package number = ML20217Q307
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 19
}}

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Put*c Service Ntric and Gas empany E. C. Simpoor.                                       Pub!ic Service Electric and Gas Company   P.O. Dox 233. Hancock= Bridge, bu 00038 - 009-339 1700
    ,u.n - .,w         ,r -                                                               AUG 2 51997 LR-N972466 LCR 397-)1 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL-SPECIFICATIONS (SUPPLEMENT)
ULTIMATE ' HEAT SINK TEMPERATURE AND RIVER WATER LEVEL LIMITS HOPE CREEK GENERATING STATION EACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Gentlemen:
On May 19, 1997, via letter-LR-N97261, Public Service Electric &
Gas (PSE&G) Company transmitted License Change Request (LCR) H97-02.to the NRC to request a revision to the Technical Specifications (TS) for the Hope Creek Generating Station.
Specifically, LCR H97-02 requested a revision to the Hope Creek-Ultimate Heat Sink (UHS) temperature and river water level limits contained in the TS.                                 In response to questions raised by the NRC during their review-of LCR H97-02, the information contained in the attachments to this letter is being provided to supplement the justification made in the May 19th submittal.
PSE&G has determined that-the informa                                               n contained in the attachments to this letter does not al.sr the conclusions reached in'the 10CFR50.92 No Significant Hazards analysis previously submitted with LCR H97-02. The revisions to the marked up TS pages contained in Attachment 2 are being made to clarify the intent of the original changes submitted in LCR H97-02 and'
            'likewise do not alter the conclusions reached in the No SignificantLHazards analysis. . In accordance with
           = 10CFR50. 91 (b) (1 ) , a copy of this submittal has been sent to the State ~of New Jersey, NRC approval'of tb'se changes is requested prior to completion of the next refuelins outage (RF07)- to: 1) . provide a suitable Technical Specification Limiting Condition for Operation (LCO) that clarifies the UHS and-supported systems design bases; and 2) permit the elimination of compensatory. measures that have been                                                   -
implemented as a result of issues identified in this LCR to maintain UHS operability.
The additional information being provided to supplement the justification contained in LCR H97-02 is contained in
                                                                                                                                            >'\
Attachment 1 to this letter. The revised marked up Technical
                                                                                                                                             \
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1 AUG 2 51997
}      Document Control Desk                                           LR-N97,466 Specification page affected by the proposed changes is provided in Attachment 2.
Should you have any questions regarding this request, we will be pleased to discuss them with you.
Sincerciy,
                                                                           '~
hr>]sent Affidavit Attachments (2) 95-4933
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ -       a

AUG 2 51937 Document Control Desk                                                                     .LR-N97466 C                Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Cormission 475 Allendale Road King of Prussia, PA                 19406 Mr. D. Jaffe, Licensing Project Manager - HC U. S. Nuclear Regulatory Commission One White Flint North-11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr.                 S. Morris (X24)
USNRC Senior Resident Inspector - HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 s
95 4933

                       '. t REF: LR-N97466
                            ,     .                                     LCR-H97-02 STATE OF NEW JERSEY.)
                                                  ;) SS.
COUNTY OF SALEM         -)
E. C. Simpson, being duly sworn according to law deposes and says:
I am Senior Vice President - Nuclear Engineering of Public Service 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.
(   Jv,@1 Subscribed and Sworn to before me this _a s'       day of b d , 1997 0
W   O      W    LL Notary b blic o [New Jersey EUZAMiTH J. KIDD NOTARY PUSUC 0F NEW JERSEY My_ Commission expires on                               '

Document Control Dock.                                                   LR-N97466
     -Att:chment.1                                                             LCR H97-02 HOPE CREEK GENERATING STATION
      ,.     .            FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354
         . ULTIMATE HEAT SINK REVISIONS TO THE TECHNICAL SPECIFICATIONS SUPPLEMENTAL INFORMATION Ooncerning the information pertaining-to the PROTO-FLO and PIPE-e
     .FLO computer models, have these models been approved for use by the NRC at other facilities? What QA program was used to develop this model and what were the results when compared against the Hope Creek startup test data?
PSE&G is not aware of either PROTO-FLO or PIPE-FLO computer model being formally approved for use by the NRC at other facilities.
PSE&G has utilized software validation and verification procedures to evaluate and maintain the adequacy of these programs for use at Hope Creek. The PIPE-FLO results for Station Service Water System (SSWS) flows were evaluated against plant data co''ected during the last refueling outage and the plant data co.. firmed the adequacy of the computer models in determining SSWS flow rates.                    To confirm the adequacy of the PROTO-FLO program for determining Safety Auxiliaries Cooling System (SACS) flows, as-built data obtained during plant startup was used to compare the results achieved from the program. Results from this comparison have been acceptable, with additional SACS                               '
benchmarking activities currently taking place.
Concerning the status of Hope Creek's Generic Letter 89-13 program on evaluating heat exchanger performance, what observations on fouling have been made when SSWS piping was replaced and what observations were made when the SACS heat exchangers were opened?
As stated in PSE&G's letter concerning Generic Letter 89-13 implementation (sent via letter LR-N97411, dated 8/1/93), the SACS heat exchanger program was revised to consist-of inspection                     '
and cleaning rather than performance testing. The SACS Heat exchangers have been inspected and eddy current tested every 36 months since 1988.                   The only heat exchanger that was not             i
      ' inspected in 1996 was the B1 heat exchanger, which was inspected in April of 1994.                   Inspections in 1996 showed that the tubes in the heat exchangers were clean and free of tube fouling. These inspection results, along with the heat exchanger performance-between inspection cycles-(i.e., typical delta T's for flow and load conditions), indicate that fouling _has not been an issue at Hope Creek. In addition, there has not been a fouling concern identified for the SSHS piping at Hope Creek. The primary reason for this good condition iu attributed to the chlorination program that has successfully kept biological growth in check.
Page 1 of 10

Document Control D0ck                                                     LR-N97466 Attcchment 1-                                                              LCR H97-02 T,he mQst recent inspection of a SACS-heat exchanger occurred in October, 1996 after 8 months of service since its last cleaning.
This inspection was performed to evaluate the consequences.of a service water strainer failure. The inspection showed minor debris, but the tubes were clean when the tube sheet was cleared of this minor debris. The as found condition was consistent with our expectations and past inspections.
What differential pressure is assumed for the traveling screens and strainers? Provide plant alarm setpoints (do) for clogging of traveling screens and strainers.
The Ultimate Heat Sink (UHS) river water temperature analysis assumed 75% clogged strainers.                  A:75% clogged strainer would result in a strainer high differential pressure alarm (five psid) during normal operations.                  Operability of the SSWS-pump would be assessed when this alarm is received, therefore degracation (increased strainer clogging) was not evaluated in the UHS river                       3 water temperature-limit analysis. The traveling screen high differential pressure alarm is set at approximately six inches of water. This fouling and its resulting level difference was determined to have a minimal impact on SSWS performance.                      Since the effect on the UHS temperature limit would be much less than 0.1 F with a clogged' traveling screen, this-condition was not included in the UHS temperature limit analysis.
Provide additional information on UHS temperature vs. SSWS flow rates. What LOCA heat loads were used in those evaluations?
What were the deviations from the previous analyses?
Table 2 of this attachment provides the heat-loads that were used in the UHS river water temperature limit analyses. Table 3 ot this attachment provides a comparison of UHS river water temperature limits vs. SSWS flowrates for limiting plant configurations.                 The original-UHS temperature limit analysis used nominal design heat loads for each component.                     The revised UHS temperature limit analysis used " actual" heat loads for components for which design calculations support.                    The modified heat loads include the Residual Heat Removal (RHR) heat exchanger, Emergency Diesel Generator (EDG) room coolers and Filtration, Recirculation and Ventilation (FRVS) room coolers.
   -The RHR heat load used was the same as previous analyses.except for the one'SSWS-pump per loop case. In that case the RHR heat exchanger heat load was based upon a suppression pool temperature using two RHR heat exchangers.
Page 2 of 10

Docunant Control D sk                                                                        LR-N97466 Attochment 1                                                                                 LCR H97-02
     -What is the effect-of-the new SSWS pumps?                                       What IST program 1imits are going to be established for the.new pumps?
The new SSWS pumps have resulted in improved SSWS flowrates.                                        The SSWS pump Inservice Testing (IST) limit was based upon the new pump curve operating at 95% of its original design curve.
However, this IST limit may be changed as system modifications or additional-UHS river water temperature analyses are performed.                                          l Provide additional information on the historical river levels and temperatures for the Hope Creek UHS.
The following data on river water level was extracted from UF3AR                           _
Table 9.2-2. This table specifies the current licensing basis for various tide levels at Hope Creek:
Tide Level (ft)
High-High Tide                                                   97.5 High Tide                                                        92.2 Mean Tide                                                        89.3 Low Tide                                                         86.4 Low-Low Tide                                                     76.0 Proposed Low Tide Limit                                          80.0 The lowest recorded tide for Hope Creek was 81-feet on 12/31/62 as stated in Section 2.4.1.2.1 of the UFSAR. This data was-verified against recorded tide levels for the Salem Generating Station due to their recent Service Water System pump NPSH concerns.
A review of recent river water temperatures (as measured by the temperature elements in the SSWS intake bay) for 1994-1997, the average daily river water temperature- exceeded 85.0 F for 11 days in July, 1994, and for one day in August, 1995. The average daily river water temperature remained below 87.0 F during these years.
During periods of elevated river water temperature, Hope Creek monitors river water temperature (at the-SSWS pump discharge) _and will take the appropriate actions in accordance with the UHS
(
Technical Specification Action Statements whenever the UHS river water temperature limits are exceeded.
Provide the basis for the UHS temperature limitations in the proposed Technical Specification changes. What is the result of component _ failures with river water temperatures above 85.0 F, but below 87.0 F?
For the cases analyzed in support of the LCR submittal, adequate cooling to safety related loads can be provided for the design basis and' limiting failure conditions considered with a SACS header Page 3 of 10 l
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Document Control Dock                                                                        LR-N97466 Attechmont 1                                                                                 LCR H97-02 temperature of 95 F.                                     The UHS temperature limit for DBA scenarios (including loss-of-coolant-accident [LOCA] / loss of instrument air (LIA]/ Safe Shutdown Earthquake [SSE] / loss-of-of f site power [ LOP]),
assuming a single active failure, is 85.0*F.                                      This failure mode consists of an emergency overboard discharge (EOB) valve, 1EA-HV23 56A (B) , failare which would restrict SSWS flow.                                   However, this
,     failure mode can be eliminated by manually opening the EOB valve under administrative controls (and reflected in the proposed Technical Specification Action Statement).                                      Specifically, the breaker (10B212 MCC No. 131 and 10B222 MCC No. 131) would be opened (prior to the river water exceeding 85.0"F) to prevent the spurious e
actuation of the valve. Completion of these actions would allow plant operation to continue indefinitely with river water temperatures in excess of 85.0 F subject to the provisions listed in the following paragraphs.
The UHS river water temperature limit for conditions resulting from combinations of design basis events (LOCA/LIA/SSE/ LOP) concurrent with equipment outages permitted by Technical Specification Action Statements is bounded by the one (1) SSWS pump per loop case (UHS river water temperature limit would be 64.6 F) .                                     This limit can be raised to 85.0 F (85.0 F as stated in LCR H97-02) assuming two operator actions.                                      The first assumed operator action is to un-isolate SSWS flow to one (1) SACS heat exchanger in one loop.                                        The second operator action is to un-isolate SSWS flow to a second SACS heat exchanger in the other loop. These actions will enable a                                            ,
total of four SACS heat exchangers to be used (this scenario also assumes that two RHR heat exchangers are used in suppression pool cooling post-LOCA) to mitigate the consequences of DBAs.
The UHS river water temperature limit for either a SSWS/ SACS loop outage with only one (1) emergency diesel generator (EDG) cross-tied (for a total of three (3) on one operable SSPS/ SACS loop) during the limiting accident scenario (LOP /SSE) ir. 87.0 F.                                     The UHS river temperature limit for a SSWS/ SACS loop outage with two (2)
EDGs cross-tied (four (4) total) to the operable SACS loop in these same conditions is 86.1 F.
The result of not isolating the spent fu'l pool heat exchanger for the limiting design basis conditions is a reduction in UHS river water temperature limit by up to 0.2 F. Therefore, the existing compensatory action to isolate the spent fuel pool heat exchangers is of marginal benefit.                                     The UHS river water temperature limit of 87.3 F for a normal configuration was based on the assumption that the fuel pool heat exchanger is isolated.                                     Failure to take these compensatory measures would result in the UHS river water temperature limit being reduced to 87.1 F.
The Technical Specifications are being revised to reflect these UHS temperature limits, which reflect the above compensatory operator actions. In summary, there is no single failure or UHS /SSWS/ SACS Technical Specification permitted condition that would result in a UHS river water temperature limit being below 85.0 F. Continued operation on an indefinite basis beyond 85.0 F (provided that the Page 4 of 10

Document Control Dock                                         LR-N97466 Attochment 1                                                  LCR H97-02 provisions in the proposed UHS Technical Specification Action S,tatement are_ met) is also justified with river water temperatures up to 87.0 F since no' single f ailure (active short-term or passive long-term) under these_ conditions would prevent the plant from mitigating design basis events.
In the Operator Action section of the LCR, there is significant discussion of valve manipulation. Would the action occur locally at the valve or in the control room or a combination of each location?
Table 1 of this attachment indicates the operator actions that are assumed to occur in the UHS analyses.        The type of action required is indicated on the table.       For the new actions assumed in the analyses, the post-accident actions are control room actione only.       The new action of opening the EOBs (or Yard Spray valves as referred to in the SSWS abnormal procedure) occurs during normal plant operation (not post-accident) prior to the river water temperature exceeding 85.0*F in order to permit continued plant operation.
Once action (s) is/are required, how long do the operators have to diagnose the situation and respond? Is-the travel time of operator to open breakers taken into account? How does Eope c    Creek know that the operators can perform each of the required actions in the time that is available for successful performance of each task? Is the river water surveillance interval taken into account?      How is the river water temperature displayed and the SACS temperature displayed?
For the new actions (non-post accident), the operators will.have adequate time to diagnose the situation and respond.        This conclusion is based upon:      1) expected river water temperature response characteristics; 2) the ready availability of_ river water temperature indications-in the control room; 3) the relatively basic operator actions involved in dealing with elevated river water temperature; and 4) observations of operating crew performance during simulated testing with elevated river water temperature concitions.
River water temperatures at Hope Creek generally do not rise or fall rapidly, but change gradually as the-tide changes. River water temperature at the SSWS intake structure is continuously indicated and recorded on a strip chart recorder in the control room. In addition, control room alarms annunciate when ESWS pump discharge temperature reaches 80 F and will alarm again a" two degree intervals above 80 F. This computer data point for SSWS pump discharge temperature provides direct indication (no detailed operator analysis is required) of UHS temperatures, which is used tn determine compliance'with the TS LCO and Action Statements.
Page 5 of 10

l Document Control Desk                                                                                 LR-H97466 Attachmont 1                                                                                          LCR H97-02 Upon receipt of these control room alarmo, operators woul.d ensure (hat appropriate actions are taken to comply with the TS requirements.      To allow continued plant operation with river water temperature above 85.0 F, operators will be required to open the2 E0Bs and their respective breakers; otherwise, the plant will be required to enter Hot Shutdown conditions within the next 12 hours to comply with TS. These ope ator actions are prescribed in the                                                  l l
SSWS abnormal procecure and consist of remotely opening the two Eons and locally opening breakers for four valves.                                              The 12 hours to reach Hot Shutdown anticipating  river water                                     (plus  any additional temperatures      time rising   provided above  85.0by F) will provide sufficient time (including anticipated travel time) for equipment operators to complete the local action of opening the four breakers.                  These operator actions and use of the abnormal procedure have been observed during training of the operating crews, with successful results.                                             The ready availability of river water temperature information in the control room and operat'-
awareness of TS cequirements will ensure that either the                                                  .ons required to justify continued plant operation with rivet 4ater temperature above 85.0 F are completed or the actions required to place the plant in a safe shutdown condition are taken.
For the new post accident operator actions involving remote                                                       I manipulation of SSWS/ SACS heat exchanger valves, these actionc                                                    j are required in the unlikely event that the SACS tempet'ture                                                       '
cannot be maintained belcw 95.0'F in post-accident , r design                                                      '
basis event scenarios.                                              In these scenarios, operators monitor SACS temperatures (which is provided in both direct analog and digital format in the control room) and are trained (and directed by plant procedures) to limit heat loads when SACS temperature cannot be maintained and to ensure the SACS loop is in an optimuu configuration to support post accident heat removal.                                                These actions are required to be taken after the RHR heat exchanger is placed in service (assumed to be t=10 minutes) during coincident warst case design basis conditions resulting in temperatures exceeding 95.0 F in SACS.
What would be the most likely error (s) an operator could commit while performing the action (s)? How difficult would it be to recover from the error (s)? What are the consequences of the orror(s) if they are not recovered?
For the new non-post accident operator actions (opening of the                                                      ,
EOBs and breakers), compliance with the TS LCO and Action Statements was assumed in the Engineering analyses. A failure to open the E0B (operator error) would require that the plant be placed in a safe 'hutdown condition if river water temperatures were in excess of 85.0 F.                                             However, recovery from a failure to perform this action is possible if: 1) a failure of the EOB to open does not occur (which would be considered to be second failure in the accident analysis since the operator error was the first single failure) and UHS river water temperatures remain below 87.0 F; or 2) the co ding tower discharge pathway is Page 6 of 10 L                   _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -

Document Control Dock                                       LR-N97466 Attochment 1                                                LCR H97-02 available to support plant shutdown (which is assumed to b3 the c, ace in the event of a normal plant shutdown). In either case, reliance on the operators following TS Action statements is required (and is e basic assumption in the Engineering analyses, i.e.,   plant operation beyond the proposed 87.0'F UHS river water temperature limit to not postulated) in order to maintain plant operation and configuration within the conditions assumed in the engineering analyses of UHS performance.       For these actions failure of the operator to maintain plant configuration within the limits permitted by the TS LCO or Action Statements (opening the EOB) is considered to be a single failure.       Operator error concurrent with a failure of plant equipment (EOB failure) is not postulated in the UHS temperature limit analyses.
In summary, assuming that the cooling tower discharge pathway fails (probability of 1), the plant can be brought to a safe shutdown condition (with UHS river water temperatures up to 0 7 . 0'F) while accommodating a single failure (either operator error or equipment failure, but not both).
For the new post-accident operator action to close the SSWS/ SACS heat exchanger valve, a failure to place the plant in a proper configuration (by remote operator action in the control room to close one valve) would result in an increase in SACS temperature of at most 0.4'F. Failure to recover from this error is not expected to significantly challenge the SACS system or its supported loads from performing their safety related functions.
A failure to take the new post-accident operator action to open the SSWS/ SACS heat exchanger valves in one SSWS pump per loop conditions has a greater impact on maintaining SACS temperature, but is likewise not e challenge to recover from since only remote control room operator action (push button 'peration for at most two valves) is required.
Would operators need additional, specific training to carry out the actions?    If so, what training?    Have they boen given the training?
Training has been provided on the above actions for the operating crews. This training consisted of simulator testing with high UHS river water temperature conditions with a minimum shift crew complement (including 4 equipment operators) . This testing 4
evaluated operator response to elevated river water temperature conditions, including the crew response to the SSNS and SACS abnormal procedure guidance.      In all cases, the shift crews were able to complete the required actions (i.e., opening ECBs and breakers) specified in the abnormal procedures for the simulated plant conditions. One crew did experience problems in satisfying the TS Action Statement time limits when UHS river watar temperature limits were exceeded due to the current TS LCO allowance of a six hour " grace" period before a plant shutdown is required. The problem resulted from the new SSWS and SACS Page 7 of 10
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Document Control D sk                                                                                                                                                    LR-N97466 Attechment 1                                                                                                                                                             LCR H97-02 abnormal operating procedures referencing the "old" TS LCO for UHS, which is being changed with LCR H97-02.                In this case, and after all other shift crew testing, table top discussions were held to review the operator response to the simulated plant conditions.      No difficulties with the abnormal procedures were identified and no additional modifications were required to
  -improve operator response to elevated river water temperature conditions.
Since:      1) the operator action to open the EOBs and breakers occurs prior to exceeded 85.0'F river water temperature (and not during post DBA scenarios); and 2) the new post-accident operator actions are remote control room actions, consideration of adverse environmental conditions and normal operator travel routes were not a factor in the simulator testing.
Would operators need additional support personnel or equipment to carry out the action (s)?_ If so, what personnel and what action (s) would be reqaired of these personnel?
No additional support is expected to be required for the new operator actions.      The simulator testing described above was successfully completed using a minimum shift-crew complement.
Equipment operators.(a minimum of four per shift crew) would be used to perform the local operator actions of opening the breakers.
What indications will the operator have to show that the required actions were successful?
In all cases, a SACS temperature remaining below 95.0*F following design bases events or accidents would provide an indication that the operator actions have been successful. As stated previously, operators monitor SACS temperatures (which is provided in both direct analog and digital format in the control room) and are trained (and directed by' plant procedures) to limit heat loads when SACS temperature cannct be. maintained and to ensure the SACS loop.is in an optimum configuration to support post accident heat removal.
If-the valve manipulatione are loeml:
Are there any potentially harsh /hasardous environments the operators would encounter on route txe, or while performing the required actions?
As indicated in Table 1, the new post-accident operator actions are not local actions. The local actica of opening the breakers occurs during normal plant operation and not during post-accident Page 8 of 10-                                                                                                                                -  -

Document Control Dock                                                     LR-N97466 Attochment 1                                                              LCR H97-02 conditions, therefore, harsh environments are not a-factor for this action.
Are there limitations.or preferences on the route an operator would use to get to the valves (ingress / egress)?
As indicated in Table 1, the new post-accident operator actions are not local.        The local action of opening the breakers occurs during normal plant operation and not during post-accident conditions. No limitations on operator routes would be expected during those plant conditions. .As stated previously, there is adequate time for the operators to perform this action.
What was-the previous design basis and what is different?
Table 1 provides the description of the operator actions credited in.-previous UHS river water temperature limit analyses and those that are being added to support the current UHS river water temperature limit analyses.         In summary, the.new operator actions being credited in.the UHS river temperature analyses are:                     1) opening of the EOBs to allow plant operation with river water-
    -temperatures greater. than 85.0*F; and 2) closure of the SSWS/ SACS heat exchanger outlet valve on the SEWS / SACS loop not servicing RHR when either four or three SSWS pumps are operating and SACS temperature cannot be maintained below 95.0'F.                  The previous (and current) design basis for the UHS river water temperature limit relied upon:      1) isolation of the spent fuel pool heat exchangers;
: 2) opening of SSWS/ SACS heat exchanger valves in oneJpump per loop scenarios; and 3) cross-connecting SACS loads on loss of a SACS loop. Additional operator actione are contained in the SSWS/ SACS abnormal procedures, but they are not credited in the UHS river-water temperature limit analyses.
The SSWS abnormal procedure instructs- the operator (in Section 4.3) to enter the SACS abnormal procedure. In which section do you enter the procedere and how do you return to the SSWS malfunction procedure?-
For-the abnormal procedures, operators enter at the beginning of each procedure and take the specified actions which are appropriate-to the plant conditions experienced.                   This pa'rticular step in the SSWS procedure references the SACS: procedure since
    -loss of a SSWS loop would render a SACS-loop inoperable and the reference ensures that actions required for loss of a SACS loop are taken. The operator would enter the SACS' procedure at the beginning take the actions required for that plant' condition (loss of the SACS loop). Since'the SSWS abnormal procedure is not exited by the simultaneous. entry into the SACS procedure, there is no " return" contained'in the SACS procedure to the SSWS procedure. The SSWS procedure would be exited upon restoration of the SSWS. loop.
  =   _      _                       -Page 9 of 10

Document Control D00k                                                                      LR-N97466 Attochment 1                                                                               LCR H97-02 Has the effect of adding the new operator actions to the previous operator actions required by the procedures been considered, i.e., has operator work load been effected in a way which now requires operators to perform activities concurrently, possible causing additional burden and confusion?
As previously stated, the new post-accident operator actions consist of remote control room push button operation of at most two valves. The other new operator actions (EOB and breaker opening) occur during normal plant operation and have been satisfactorily demonstrated by shift crews in simulator testing.
Therefore, PSE&G concludes that the new actions do not cause additional operator burden or confusion, with no significant impact on operator work load.
1 Page 10 of 10

TABLE 1                                                                     .

==SUMMARY==
OF OPERATION ACTIONS ASSUMED IN THE UBS ANALYSES                                       ,
OPERATOR                          WHEN REQUIRED                              TYPE OF ACTION        EFFECT OF               N O It.S            ,
ACTION                                                                        REQUIRED             OPERATOR ACrlON
                 'I. Opening the                     Prior to exceeding 85.0*F UHS temperature. Local action in the  Ensures that the plant  NEW ACTION IN TECH emergency                                                                     ReactorBldg Valves   can sustain DBA         SPEC BASES SACS overboard                                                                     are opened remotely, beyond 85.0*E           taugderelimit exceeded discharge valves                                                              but power supply     Actions are required    by approximately 2.0'Fif breakers are opened  by TS prior to          operator action is not taken (EOBs).
(therefore, shutdown TS locally.             exceeding 85.0*E Actions would appiv).
: 2. Closure of the -               a. When all SSWS pumps are operating and    Remote action from   Ensures that enough     NEW ACTION IN TECH SSWS/ SACS heat                   SACS temp cannot be maintained below        the control room. flowis provided to the SPEC BASES. SACS exchanger outlet                  95.0'F.                                     Would be required    SACS loop senicing      tuumeure excee.fing valve on loop not                                                             onlyafter the RHR    the RHR heat            95.0*F(therefore requirmg servicing RHR.                    -or-                                        heat exchanger is    exchanger. Ifactions    operator action) would be placed in senice at  are not taken, then the needed only for the unlikely
: b. When two SSWS pumps are operating        t>10 min.            UHS limit would be      occurrence ofcoincident on one loop and one on the other and SACS                        lowered by 0.4'F for    design basis conditions temp cannot be maintained below 95.0*E                           case a. and by O.I'F    (high river temp, low river for case b.             level, LOCA. loss of               j cooling tower pathw2y, LOP and worst case pump and heat exchanger performance 1 Page 1 of 2 W
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TABLE 1                                                                       .-

==SUMMARY==
OF OPERATION ACTIONS ASSUMED IN THE UHS'JNALYSES                                              ,
                                                                                                                                                     ^
OPERATOR '        WHEN REQUIRED                                 TYPE OF ACTION         EFFECT OF               NOILS ACTION                                                           REQUIRED              OPERATOR ACTION
: 3. Isolation of   LOCA/ LOP scenarios with UHS temp >           Remote action from     Ensures that enough     OLD ACTION credited in the control room       flow is provided to the the TS A,Tcni, Twit No. 68 fuel pool heat    85 0 F and only one SSWS/ SACS loop .
exchangers_       available.                                    would be required     SACS loop sersicing      analyses. This analysis prior to placing the  the RHR heat             assumed no fuel pool .
RHR heat exchanger    exchanger. Ifactions     cooling flow (for up to 24 in service.           are not taken then the hours) for the c 3A UHS limit isimpacted conditions anaryr.ed.
by 0.2*F.
: 4. Opening of      LOCA or LOP scenarios when SACS temp         Remote action from     Ensures that enough      OLD ACTION creditedin SSWS/ SACS heat   cannot be maintained below 95.0"F.            the control room       flowis provided to the   the  A,Tc.iircit No. 75 exchanger valves                                                would be required      SACSloop sersicing       analym,wiiich relied upon in'one pump per                                                 prior to placing the   the RHR heat             limited operator action in loop scenarios.                                                 RHR heat exchanger     exchanger.               this scenario.
m service.
: 5. Cross-         Any time the SACS loop is inoperable.         Local operator actions Actions are required to  OLD ACTIONin terms of connecting SACS   SACS loop failure post accident is a passive  to realign SACS        enable the plant to      passist failure assumptions.
loads on loss ofa failure IAW single failure criteria. Second   supply to affected     mitigate accidents as    Assumptions concerning SACS loop.        failure ofa SACS pump not assumed to          components.            described in the         additional active failures is        l occur after accident. Second failure of a                            UFSAR (i.e., three       consistent with Amendment SACS pump during operation would result                              LPCI pumps for the       No. 75 in entryinto TS shutdown ACTION                                      first ten minutes).
statement until loads are realigned ani operability of supported equipment is restored l
rage 2 of 2 1,

Tcble 2
       .                     D: sign B: sis Accid:nt H:at Loads (MBlu/hr) . Sorted by Loop LOCA/LIA              LOP /SSE LOCA/LIA B Loop LOP /SSE D Loop X Nominal    X Tied     Nominal      Tied LOCA >10 LOCA>10 LOP >30 LOP >30 Component Description          Loop      Hx Tag #        min      min          min       min RHR Hx                      A           1AE205         121.7     121.7       132.5      132.5 RHR Pmp Seal Clr            A           1 AP2021      0,1167    0.1167      0.1167    0.1167 RHR Pmp Mtr Brn0            A           1 AP202 2     0.0833    0.0833      0.0833    0.0833 CHR Pmp Seal Clr            A           1CP2021       0.1167    0.1167      0.1167     0.1167 RHR Pri.p Mir Brn0          A           1CP202 2      0.0833    0.0833      0.0833     0.0833 EDG Lube Oil Clr             A          1AE404          1.353    1.353        1.353     1.353 EDG Lube Oil Ctr             A          1CE404          1.353    1.353        1.353     1.353 EDG Jacket Water Clr_ A                 1AE405         5.412     5412        5412       5 412 EDG Jacket Water Cir A                  1CE405          5 412    5.412        5.412     5.412 EDG inter Clr Hx             A          1AE408          3.118    3.118        3.118     3.118 EDG Inter Clr Hx             A          1CE408          3.118    3.118        3.118     3.118 EDG Rm Cir                   A          1 AVE 412     0.7345      1.469      0.7345     1.469 EDG Rm Clr                   A          1CVE412        0.7345     1.469      0.7345     1.469 EDG Rm Ctr                   A          1 EVE 412      0.7345   (Note 2)     0.7345   (Note 2)
EDG Rm Clr                   A          1GVE412        0.7345   (Note 2)     0.7345   (Note 2)
Fuel Pool Hx                 A          1AE202        Isolated  isolated    Isolated  Isolated RCIC Rm Cir                  A          1AVH208          0.06     0.12         0.06      0.12 RCIC Rm Clr                  A          1BVH208          0.06   (Note 2)       0.06   (Note 2)
RHR Pmp Rm Clr               A           1AVH210       0.2243    0.4485      0.2243    0.4485 RHR Pmp Rm Clr               A           1GVH210       0.2243    0.4485      0.2243    0.4485 RHR Pmp Rm Clr               A           1EVH210       0.2243   (Note 2)     0.2243   (Note 2)
RHR Pmp Rm Clr               A           1GVH210       0.2243   (Note 2)     0.2243   (Note 2)
Core Spray Rm Clr            A           1 AVH211       0.135      0.27 Core Spray Rm Cir            A           1CVH211        0.135      0.27 Core Spray Rm Clr            A           1EVH211        0.135   (Note 2)
Core Spray Rm Cir            A           1GVH211        0.135   (Note 2)
Contmt Gas Comp             A           1AK202        0.0264    0.0264 FRVS Cooler                 A           1 AVH213        1.09      1.09 FRVS Cooler                 A           1CVH213         1.09      1.09 FRVS Cooler                 A           1EVH213         1.09      1.09 Post LOCA Sampling          A           1AE328          0.11      0.11 Control Rm Chiller          A           1AK400        6.3726    6.3726      6.3726     6.3726 1E Panel CNiler            A           1AK403        2.1750    2.1756      2.1756     2.1756 TOTAL        168.3158 158.3156 165.1694 165.1692 Note 1 Component not cross-tied following B loop outage (inoperable)
Note 2 B Component cross-tied however, redundant cooler isolated Note 3 For both a LOCA and LOP /SSE scenario, a loss of instrument air is assumed.
If both primary and standby (redundant) room coolers receive flow, heat load is divided between both coolers. For minimum flow requirements to an individual cooler, the total heat load is applied to primary cooler.
Page 1 of 2

Tc ble 2
            .                       Design Basis Accid:nt Helt Loads (MBlu/ht) Sorted by Loop LOCA/LIA                                     LOP /SSE LOCA/LIA B Loop LOP /SSE B Loop X Nominal                  X Tied                  Nominal         Tied LOCA >10 LOCA>10 LOP >30 LOP >30 Component Description             Loop   Hx Tag #         min                          min                 min          min RHR Hx                       B           1BE205          121.7                 (Note 1)                   132.5     (Note 1)
RHR Pmp Seal Cir             B           1BP2021        0 1107                 (Note 1)                  0.1161      (Note 1)
RHR Pmp Mtr Brno             B           1BP202 2       0.0833                 (Note 1)                  0 0833      (Note 1)
RHR Pmp Seal Clr             B           1DP2021        0.1167                 (Note 1)                  0.1167      (Note 1)
RHR Pmp Mtr Brn0             0           1DP202 2       0.0833                 (Note 1)                  0.0B33      (Note 1)
EDG Luhe Oil Ctr              B          1BE404          1.353                 (Note 1)                    1.353     (Note 1)
EDG Lube Oil Clr              B          1DE404          1.353                      1.353                  1.353        1.353 EDG Jacket Water Clr B                   1BE405          5412                  (Note 1)                    5412      (Note 1)
EDG Jacket Water Clr B                   1DE405          5.412                      5.412                  5.412       5.412 EDG inter Clr Hx              B          1BE408          3 118                 (Note 1)                   3.118    TNTte 1)
EDG inter Clr Hx              B          1DE408          3.118                      3.118                  3.118        3.118 EDG Rm Clr                    B          1BVE412        0.7345                 (Note 1)                  0.7345      (Note 1)
EDG Rm Clr                    B          1DVE412        0.7345                       1.469                0.7345        1.409 EDG Rm Clr                    B          1FVE412         0.7345                 (Note 1)                  0.7345     (Note 1)
EDG Rm Ctr                    B          1HVE412         0.7345                 (Note 2)                  0.7345      (Note 2)
Fuel Pool Hx                  B          1BE202         Isolated                isolated                 Isolated     Isolated HPCI Rm Clr                   B          1AVH209          0.135                         0.27               0.135         0.27 _
HPCI Rm Cir                   B          1BVH209          0.135                 (Note 2)                   0.135      (Note 2)
RHR Pmp Rm Clr               B          1BVH210         0.2243                  0.4485                   0.2243       0.4405 RHR Pmp Rm Clr               B          1DVH210         0.2243                   0.4485                  0.2243       0.4485 RHR Pmp Rm Clr               B          1FVH210         0.2243                 (Note 2)                  0.2243      (Note 2)
RHR Pmp Rm Clr               B          1HVH210         0.2243                 (Note 2)                  0.2243      (Note 2)
Core Spray Rm Clr            B          1BVH211          0.135                 (Note 2)
Core Spray Rm Clr            B          1DVH211          0.135                 (Note 2)
Core Spray Rm Clr            B           1FVH211         0.135                 (Note 2)
Core Spray Rm Clr            B           1HVH211         0.135                 (Note 2)
Contml Gas Comp              B           1BK202           0.0264                           0.0264 FRVS Cooler                 B           1BVH213             1.09 (Note 1)
FRVS Cooler                 B           1DVH213             1.09                                 1.09 FRVS Cooler                  B          1FVH213             1.09 (Note 1)
Post LOCA SamplinD           B          1BE328 _            0.11                                 0.11 Control Rm Chiller           B          1BK400           6.3720 (Note 1)                                   6.3726 (Note 1) 1E Panel Chiller             B          1BK403           2.1756 (Note 1)                                   2.1756 (Note L TOTAL         158.4658                       13.7454 165.3194                   12.519 Total X tied                                 172.061                         177.6882 Note 1 Component not cross-tied following B loop outage (inoperable)
Note 2 B Component cross-tied however, redundant cooler isolated Note 3 For both a LOCA and LOP /SSE scenario, a loss of instrument air is assumed.
If both primary and standby (redundant) room coolers receive flow, heat load is divided between both coolers. For minimum flow requirements to an individual cooler, the total heat load is applied to primary cooler.
Page 2 of 2

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