ML20127J096

Forwards Status of Tech Spec Issues Identified in SER Section 16.Resolutions to Listed Tech Spec Issues Considered Incomplete Also Encl for Review & Approval

ML20127J096
Person / Time
Site:	Hope Creek
Issue date:	06/21/1985
From:	Mittl R Public Service Enterprise Group
To:	Butler W Office of Nuclear Reactor Regulation
References
NUDOCS 8506260448
Download: ML20127J096 (17)

Text

Pubkc Service Ilectnc and Gas Company 80 Park Plaza, Newark, NJ 07101/ 201430-8217 MAILING ADDRESS / P.O. Box 570, Newark, NJ 07101 Robert L. Mitti General Manager Nuclear Assurance and Regulation June 21, 1985 Director of Nuclear Reactor Regulation U.S.

Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Attention:

Mr. Walter Butler, Chief Licensing Branch 2 Division of Licensing Gentlemen:

SAFETY EVALUATION REPORT TECHNICAL SPECIFICATION ISSUES HOPE CREEK GENERATING STATION DOCKET NO. 50-354 is a current list which provides a status of the Technical Specification Issues identified in Section 16 of the Safety Evaluation Report (SER).

Items identified as "completa" are those for which PSE&G has provided responses and no confirmation of status has been received from the staff.

We will consider these items closed unless notified otherwise.

In order to permit timely resolution of items identified as " complete" which may not be resolved to the staff's satisfaction, please provide a specific description of the issue which remains to be resolved.

Enclosed for your review and approval (see Attachment 3) are the resolutions to the SER Technical Specification Issues listed in Attachment 2.

Should you have any questions or require any additional information on these items, please contact us.

Very truly yours, 8506260448 850621 PDR ADOCK 05000354 E

PDR 1

Attachmonts MP85 81 02 1-vw I

The Energy People 954912 (3Y) 444

Director of-Nuclear Reactor Regulation

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H. Wagner USNRC Licensing Project Manager (w/ attach.)

A. R..Blough-USNRC* Senior Resident Inspector (w/ attach.)

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SER TECHNICAL SER R. L. MITTL TO SPECIFICATION SECTION A. SCHWENCER

' ISSUE NUMBER SUBJECT STATUS LETIER DATED 1

2.4.11.2 Service water intake temperature Cmplete 4/10/85 2

2.4.14 Closing of doors and hatches Cmplete 4/10/85 3

3.9.6 Pressure isolation valves Complete 6/21/85 4

4.4.4 Thermal-hydraulic instability Cmplete 4/10/85 5

4.4.4 Single-loop operation Cmplete 4/10/85 6

4.4.5 Crud effects Cmplete 4/10/85 7

4.4.6 Imse parts monitoring systm Complete 4/10/85 channel operability 8

5.2.2 Safety / relief valve (SRV) test Cmplete 5/13/85 program 9

5.2.5 Reactor coolant pressure boundary Cmplete 4/10/85 leakage rates 10 5.4.6 Reactor core isolation cooling pump Cm plete 4/10/85 testing 11 5.4.7 Residual heat removal system pump Cmplete 4/10/85 operability 12 6.2.1.6 Torus /drywell vaceftbreaker and Cmplete 6/21/85 vent systs testing 13 6.2.1.6 Vacuum breaker position indication Cmplete 5/13/85 accuracy 14 6.2.3 Testing of inleakage rate and draw-Caplete 4/10/85 down time 15 6.2.4.1 Leakage testing for valves with Cmplete 6/21/85 resilient seals 16 6.2.6 Containment isolation valve leakage Cmplete 6/21/85 MP85 81 02 3-vw Page 1 of 4

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.SER TECHNICAL SER R. L. MITIL 'IO

SPECIFICATION SECTION A. SCHWENCER ISSUE NUMBER SUBJECT STATUS IEITER DATED 17 6.2.6, 6.7, Main stem isolation valve leak rate Cmplete 6/21/85 15.6.5.2 testing 18 6.2.6 Various valve leak rates Cmplete 6/21/85 19 6.3.4.2

_ Emergency core cooling system Cmplete 5/13/85 (ECCS) subsyste flow rates 20 6.3.4.2 ECCS subsystem operating sequence Cmplete 5/13/85 21

.6.5.1.3 Water seal bucket drain tap Conplete 4/10/85 surveillance 22 7.2.2.3 Testability of plant protection Complete 5/13/85 system at power 23 7.2.2.8, Anticipated transients without Cmplete 6/10/85 7.6.2.2 scre mitigation 24 7.2.2.9 Reactor mode switch Cmplete 5/13/85 25 7.3.2.3 Freeze protection of water-filled Ccmplete 6/10/85 lines g.

26 7.4.2.3 Remote shutdown system operability Open 27 7.6.2.1 Iow pressure /high pressure systes Open interlocks 28 7.6.2.3 Average power range monitor Cmplete 5/13/85 electrical protection assemblies

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.29 7.7.2.2 Nonsafety-related equipnent Ccmplete 5/13/85

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operability 30

-8.3.1.3 Diesel generator connected loads Cmplete 4/10/85 31 8.3.1.7 Load sequencer logic Complete 4/10/85 132-8.3.2.7 DC syste ronitoring Cmplete 4/10/85 4

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SER TEDINICAL SER R. L. MITIL 'IO SPECIFICATION SECTION A. SCHWENCER ISSUE NtMBER SUBJECT STA'IUS LETTER DATED 4

33 8.3.3.3.5 Testing of breaker time-overcurrent Ccmplete 5/13/85 trip characteristics

-34 8.3.3.4.1 Periodic system testing Ccaplete 4/10/85 35 8.3.3.4.2 Load sequencer testing Complete 4/10/85 36 8.3.3.5.4 Testing of fuses Complete 4/10/85 37 9.1.3 Fuel pool cooling system pumps Open 38 9.2.1 Station service water pump testing Ccmplete 4/10/85 39 9.2.2 Safety auxiliaries cooling system Cmplete 4/10/85 and reactor auxiliaries cooling system ptmp availability 40 '

9.2.2 Safety auxiliaries operability to Open ensure diesel generator cooling 41 9.2.7 Control area chilled water system Open availability 42 9.3.1, Air quality testing Ccuplete 5/13/85 9.3.6 43 9.3.2 Core damage estimate procedure This is a confirmatory item.

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'9.5.1.5 Fire watch Cmplete 4/10/85 45 10.2 Turbine steam valve inspection Ccmplete 4/10/85 46 10.4.4 Turbine bypass valve surveillance Ccmplete 4/10/85 47 15.2 Turbine bypass system and level Cmplete 5/13/85 8 high-water trip performance 48 15.4.9 Scram speed Complete 5/13/85 49 15.6.4 Primary. coolant activity Complete 5/13/85 MP85 81 02 5-vw' Page 3 of 4 m

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SER TECHNICAL SER R. L. MITIL TO

-SPECIFICATION SECTION A. SCHWENCER

-ISSUE NUMBER SUBJECT STATUS IfITER IRTED 50 15.6,4 Main stean isolation valve closure Cmplete 4/10/85 time 51 15.9.3 SRV failure reporting Cmplete 4/10/85 52~

15.9.3 Automatic depressurization systen Cmplete 5/13/85 logic f

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ATTACHMENT 2 SER TECHNICAL SPECIFICATION-SER ISSUE SECTION SUBJECT 3

3.9.6 Pressure isolation valves 12 6.2.1.6 Torus /drywell vacuum breaker and vent system testing

'15 6.2.4.1 Leakage testing for valves with resilient seals 16 16.2.6 Containment isolation valve leakage 17 6.2.6, 6.7, Main steam isolation valve leak 15.6.5~.2 rate testing 18 6.2.6 Various valve leak rates DFD:az 5/20/85-

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ATTACHMENT 3 MP85 96/07 02 l

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SER Technical Specification Issue No. 3 (SER Section 3.9.6)

Pressure isolation valves By letter dated September 12, 1984, the applicant committed to meet the staff's stated leak test rate requirements as well as the staff's stated requirements for intervals between tests of pressure isolation valves (PIVs).

Also, the applicant submitted a list of PIVs, which was reviewed by the staff and found acceptable.

The following items remain to be confirmed b'y the staff when the Technical Specifications and inservice test program are reviewed:

(1)

The applicant must demonstrate that the test nethod that will be used for inservice testing of PIVs will accurately or conservatively indicate water leak-rates at reactor operating temperature and pressure.

Response

This item will be addressed in the response to SER Con-firmatory Item No. 3 which is scheduled to be provided by July 15, 1985.

(2)

Limiting conditions for operation indicating those events and time schedules that will initiate the requirements to leak test PIVs, in accordance with staff requirements, must be stated in the Tech-nical Specifications and reflected in the inserv-ice test program.

Current staff requirements are outlined in staff Request for Additional Informa-i tion (RAI) Item 210.56, which is in an attachment to a' letter to the applicant dated March 19, 1984.

-Response HCGS Draft Technical Specification Sections 3.4.8, 4.4.8.1, and 4.4.8.2 specify the events and time schedules that will initiate the requirements to leak test PIVs.

(3)

Limitin2 conditions for operation indicating allowabin leak rates for PIVs, in accordance with staff requirements, must be stated in the Tech-nical Specifications and reflected in the inserv-ice test program.

The current staff requirement M P85 27/13 1-srd

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I outlined in staff RAI Item 210.56 is that PIVs shall be limited to a maximum water leak rate of 1 gpm at reactor operating temperature and pressure.

Response

HCGS Draft Technical Specification Sections 3.4.8.e & f provide the limiting conditions for operation indicating the allowable leak rates for PIVs.

M P85 27/13 2-srd

I SER Technical Specification Issue No. 12 (SER Section 6.2.1.6) Tours /drywell vacuum breaker and vent system testing To minimize the potential for steam bypass, the staff will l

require the applicant to commit to (1)

Perform operational testing of the torus-to-drywell vacuum breakers once each month and (2)

Perform a low-pressure leakage test of the drywell-to-torus vent system at the end of each refueling outage at a pressure slightly less than that corresponding to vent submergence.

The staff will include a requirement for these periodic tests in the Technical Specifications.

The applicant has committed to perform these periodic tests.

Response

HCGS Draft Technical Specification Sections 4.6.4.1.b and 4.6.2.1.f provide the surveillance requirements (1) and (2) above, respectively.

M P85 27/13 9-srd

SER Technical Specification Issue No. 15 (SER Section 6.2.4.1) Leakage testing for valves with resilient seals The applicant has committed to add the following provisions to the Technical Specifications for the leak testing of purge / vent line isolation valves:

Leakage integrity tests shall be performed on the con-tainment isolation valves with resilient material seals in (a) active purge / vent systems (i.e.,

those which may be operated during plant operating Modes 1 through 4) at least once every three months and (b) passive purge system (i.e.,-those which must be administrative 1y con-trolled closed during reactor operating Modes 1 through

4) at least once every six months.

Response

HCGS Draft Technical Specification Surveillance Requirements 4.6.1.8.2 requires each drywell and suppression chamber purge supply and exhaust isolation valve with resilient material seals to be leak rate tested at least once per six months on a staggered test basis, and Surveillance Requirement 4.6.1.8.3 requires each operated drywell and suppression chamber purge supply and exhaust isolation valve with resilient material seals to be leak rate tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after each closing of the valve except when being used for multiple cycles then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The measured leakage rate for any penetration boundary shall be less than or equal to 0.05 La when pressurized to Pa (48.1) psig.

These technical specification surveillance requirements meet the intent of this SER technical specification issue.

M P85 27/13 3-srd

SER Technical Specification Issue No. 16 (SER Section 6.2.6)

Leak testing of containment isolation valves tested with water The combined leakage from all these valves will satisfy the requirements of 10 CFR 100 regarding the site radiological safety analysis and will be included in the plant Technical Specifications..This. leakage will be excluded when deter-mining the combined leakage rate for all penetrations and valves as specified in Section III.C.3 of Appendix J.

. Response HCGS Draft Technical Specification Sections 3.6.1.2.f and 4.6.1.2.g provide the appropriate limiting conditions for operation and leak test surveillance requirements for those valves hydrostatically tested.

M P85 27/13 4-srd

SER Technical Specification Issue No. 17 (SER Section 6.2.6, 6.7, 15.6.5.2) Main steam isolation valve leak rate testing 6.2.6 Testing of the two MSIV's simultaneously, between the valves, at 1.10 Pa would lift the disk at the inboard valve and would result in a meaningless test.

The proposed test calls for a test pressure of approxi-mately 20 psig to avoid lif ting the disk at the inboard valve.

The total observed leakage through both the outboard MSIV and the MSSV would then be conservatively assigned to the penetration and speci-fled separately in the Technical Specifications.

The staff concludes that this procedure is acceptable.

See Section 6.7 of this report for more information on the MSIVSS.

6.7 The staff's conclusions are based on the Standard Technical Specifications MSIV leakage rate of 11.5 scfh per valve.

The applicant has not committed to use this leakage rate limit; however, the staff will require that the Hope Creek Technical Specification conform to this limit unless a different valve is proposed by the applicant.

Response

HCGS Draft Technical Specification Section 3.6.1.2d and 4.6.1.2.f provide appropriate limiting conditions for opera-tion and surveillance requirements for leak testing the main steam isolation valves to demonstrate their operability.

The MSIV sealing system is designed to maintain the seal gas pressure to 5 psi above the reactor vessel pressure.

The system will not operate when the main steam line pressure is above 20 psig.

Testing is performed when the reactor vessel is depressurized, therefore, the leak test pressure will be 5 psig.

FSAR Sections 5.4.5.4 and 6.2.4.4 will be revised in the next amendment to clarify the description of this test method.

HCGS Draft Technical Specification Section 3.6.1.2.d speci-fies an allowable leakage rate of less than or equal to 11.5 scfh for each main steam isolation valve, when tested at 5

_psig (seal system A P).

M P85 27/13 5-srd

SER Technical' Specification Issue No. 18 (SER Section 6.2.6)

Various-valve leak rates (1)

Main' Steam Isolation Valve Sealing System'(MSIVSS)

Testing of the two MSIVs simultaneously,-between the valves, at 1.10 Pa would lift the disk at the inboard valve and would-result in a meaningless test.

The proposed test calls for a test pressure of approximately 20 psig to avoid lif ting the disk at the inboard valve.

The total observed leakage through both the outboard MSIV and the MSSV would then be conservatively assigned to the penetration and specified_ separately in the Technical Specifi-cations.

The staff concludes that this procedure is acceptable.

See Section 6.7 of this report for more information on the MSIVSS.

The_ staff concludes that leak testing the MSIVs in the manner described above is an acceptable alter-native to the requirements of Appendix J.

Response

See response to SER Technical Specification Issue No. 17.

(3)

Hydrostatic Testing of Containment Isolation ValvesSection III.C.2 of. Appendix J to 10 CFR 50 requires ~that' valves, unless pressurized with fluid from a seal system, shall be pressurized with air or nitrogen for leak testing purposes.

There are a number of liquid-filled systems, how-ever, that are specifically designed to remain intact following a LOCA and thus provide a water seal for the system isolation valves or ensure that only liquid leakage from the containment will occur.

Because of this, the applicant proposes.to perform hydrostatic testing to ' determine the leak-tightness of the following isolation valves:

(a) pump suction valves for residual heat removal, high pressure core injection, core spray, and reactor core isolation systems l

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(b) turbine exhaust valves for high pressure core injection and reactor core isolation cooling systems (c) test and minimum flow valves for high pres-sure core injection, residual heat removal, reactor core isolation cooling, and core spray systems (d) torus water cleanup supply valves For the isolation valves in these system lines, the applicant has shown that (a) the flow paths associated with these lines terminate below the low water level in the suppression pool, (b) a water seal is ensured during normal plant opera-tion and for more than 30 days following an acci-dent requiring containment isolation, and (c) it is not credible that these isolation valves will be exposed to the containment atmosphere at any time following the accident.

The combined leakage from all these valves will satisfy the requirements of 10 CFR 100 regarding the site radiological safety analysis and will be included in the plant Technical Specifications.

This leakage will be excluded when determining the combined leakage rate for all penetrations and valves as specified in Section III.C.3 of Appendix J.

Response

See response to SER Technical Specification Issue No. 16.

(5)

Traversing Incore Probe (TIP) System Testing To ensure that the shear valve will perform its intended function, the staff asked the apnlicant to do the following, and the applicant has agreed:

l (a)

Verify the continuity of the explosive charge at least once every 31 days.

M P85 27/13 7-srd

(b)

Initiate one of the explosive squib charges at least once every 18 months.

The replace-ment charge for the explosive valve shall be from the same manufactured batch as the one of that batch successfully fired.

(c)

All charges.should be replaced according to the manufacture's recommended lift time.

Response

(a)

HCGS Draft Technical Specification Section 4.6.3.5 provides the surveillance requirement to verify continuity of the explosive charge at least once per 31 days.

(b)

These valves are ASME IWV Category D valves and are tested in accordance with Technical Specification Section 4.0.5.

This valve testing, pursuant to ASME, requires 20 percent of the charges to be removed, fixed, and replaced every two years with charges from a fresh batch.

This technical specification requirement meets the intent of this SER technical specification issue.

FSAR Section 6.2.4.4(h) will be revised in the next amendment to clarify this test description.

(c)

This item is addressed in HCGS Maintenance Department Procedure MD-CM.SE - 005 (O).

M P85 27/13 8-srd

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