LR-N04-0454, Request for Change to Technical Specifications to Revise Scram Discharge Volume Vent and Drain Line Requirements Using the Consolidated Line Item Improvement Process

Request for Change to Technical Specifications to Revise Scram Discharge Volume Vent and Drain Line Requirements Using the Consolidated Line Item Improvement Process

ML050670385
Person / Time
Site:	Hope Creek
Issue date:	02/25/2005
From:	Barnes G Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR H04-07, LR-N04-0454, NUREG-1433, Rev 2
Download: ML050670385 (11)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 It FEB 2 5 2005 0 PSEG NuclearLLC LR-N04-0454 LCR H04-07 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS TO REVISE SCRAM DISCHARGE VOLUME VENT AND DRAIN LINE REQUIREMENTS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS HOPE CREEK GENERATING STATION DOCKET NO. 50-354 FACILITY OPERATING LICENSE NO. NPF-57 In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear, LLC (PSEG) hereby transmits a request for amendment of the Technical Specifications (TS) for Hope Creek Generating Station.

The proposed changes would revise the required action within TS 3.1.3.1, "Control Rod Operability," for the condition of having one or more scram discharge volume vent or drain lines with valve(s) inoperable. These changes are based on Technical Specification Task Force (TSTF) change traveler TSTF-404 (Revision 0) that has been approved generically for the BWR (boiling water reactor)/4 Standard Technical Specifications (STS), NUREG-1433, Revision 2.

The availability of this TS improvement was announced in the FederalRegister on February 24, 2003, as part of the consolidated line item improvement process (CLIIP).

Attachment 1 provides a description of the proposed change and confirmation of applicability. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Attachment 3 provides the corresponding TS Bases marked-up pages for information. There are no new regulatory commitments associated with this proposed change.

PSEG does not have specific schedule needs for this proposed change and requests approval of the proposed license amendment in accordance with the normal NRC review schedule for this type of request. PSEG requests implementation within 60 days of receipt of the approved amendment.

Ao 95-2168 REV. 7/99

FEB 2 5 2005 Document Control Desk LR-N04-0454 In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated New Jersey State Official.

Should you have any questions regarding this request, please contact Mr. Robin Ritzman at (856) 339-1445.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 2/X sSincerely, (Date)

George P. Barnes Site Vice President Hope Creek Generating Station Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes

3. Proposed Technical Specification Bases Changes

Document Control Desk FEB 2 5 2005 LR-N04-0454 C Mr. S. Collins, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission Mr. Daniel Collins, Project Manager - Hope Creek Mail Stop 08C2 Washington, DC 20555-0001 USNRC Senior Resident Inspector - Hope Creek (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625

ATTACHMENT 1 LCR H04-07 LR-N04-0454 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed changes would revise the required actions within Hope Creek Generating Station Technical Specification (TS) 3.1.3.1, "Control Rod Operability,"

for the condition of having one or more scram discharge volume vent or drain lines with valve(s) inoperable. The changes are based on Technical Specification Task Force (TSTF) change traveler TSTF-404 (Revision 0) that has been approved generically for the BWR (boiling water reactor)/4 Standard Technical Specifications (STS), NUREG-1433, Revision 2.1 The availability of this TS improvement was announced in the Federal Register on February 24, 2003, as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Anplicability of Published Safety Evaluation PSEG Nuclear, LLC (PSEG) has reviewed the safety evaluation published on February 24, 2003, (68 FR 8637) as part of the CLIIP. This verification included a review of the NRC staff's evaluation as well as the supporting information provided to support TSTF-404. PSEG has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Hope Creek Generating Station and justify this amendment for the incorporation of the changes to the Hope Creek Generating Station TS.

2.2 Optional Changes and Variations PSEG is not proposing any variations or deviations from the TS changes described in TSTF-404 or the NRC staffs model safety evaluation published on February 24, 2003.

1 Hope Creek Generating Station has not adopted Standard Technical Specifications (STS);

therefore, the requirements of STS 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves,' referenced inTSTF-404, are actually addressed by Hope Creek Generating Station TS 3.1.3.1. Regulatory Issue Summary 2000-06, 'CLIIP for Adopting STS Changes for Power Reactors", permits adoption of CLIIP changes for Licensees that have not converted to STS, but have determined that the TSTF isapplicable to their facility.

1

ATTACHMENT 1 LCR H04-07 LR-N04-0454

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Determination PSEG has reviewed the proposed no significant hazards consideration determination published on February 24, 2003, as part of the CLIIP. PSEG has concluded that the proposed determination presented in the notice is applicable to Hope Creek Generating Station and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verification and Commitments There are no new regulatory commitments associated with this proposed change.

4.0 ENVIRONMENTAL EVALUATION PSEG has reviewed the environmental evaluation included in the model safety evaluation published on February 24, 2003, as part of the CLIIP. PSEG has concluded that the NRC staffs findings presented in that evaluation are applicable to Hope Creek Generating Station and the evaluation is hereby incorporated by reference for this application.

2

ATTACHMENT 2 LCR H04-07 LR-N04-0454 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

The following Technical Specifications for Hope Creek Generating Station Facility Operating License NPF-57 are affected by this change request:

Technical Specification Page TS 3.1.3.1.d 3/4 1-4 TS 3.1.3.1.e 3/4 1-4

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION (Continued) (

ACTIO (Continued)

2. If the inoperable control rod(s) is inserted, within one hour disarm the associated directional control valves** either:

a) Electrically, or b) Hydraulically by closing the drive water and exhaust water isolation valves.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

3. The provisions of Specification 3.0.4 are not applicable.

c. With more than 8 control rods inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Recplace _ _

id.k With one scram discharge volume vent valve and/or one scram discharge 1 Z volume drain valve inoperable and open, restore the inoperable fivalvezs) 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 be in at least HOT<

/ SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

e. With any scram discharge volume vent valve(s) and/or any scram) discharge volume drain valve(s) otherwise inoperable, restore the A inoperable valve(s) to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours.

SURVEILLANCE REQUIREMENTS 4.1.3.1.1 The scram discharge volume drain and vent valves shall be demonstrated OPERABLE by:

a. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> verifying each valve to be open,* and

b. At least once per 31 days cycling each valve through at least one complete cycle of full travel.

4.1.3.1.2 When above the low power setpoint of the RWM, all withdrawn control rods not required to have their directional control valves disarmed

• These valves may be closed intermittently for testing under administrative controls.

• • May be rearmed intermittently, under administrative control, to permit testing associated with restoring the control rod to OPERABLE status.

• A0Sepormse Arc+toh eh~ry ; aluJ or each 5DV veh nd4 . Ins,

<;nr41 W***An isolof.fec li;eo "lay Le. unsoSlo.+. under a t;;s+IaIsve. conrbei +o oclovt droni'n HOPE K E "f t 3/4 1-4 Amendment No.105

INSERT 2

d. With one or more scram discharge volume (SDV) vent or drain lines***

with one valve inoperable, isolate the associated line within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.****

e. With one or more SDV vent or drain lines*** with both valves inoperable, isolate the associated line within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.****

ATTACHMENT 3 LCR H04-07 LR-N04-0454 PROPOSED CHANGES TO TS BASES PAGES The following Technical Specifications Bases for Hope Creek Generating Station, Facility Operating License No. NPF-57, is affected by this change request:

Technical Specification Page Bases 3/4.1.3 B 3/4 1-2a

REACTIVITY CONTROL SYSTEMS CONTROL RODS (Continued)

The control rod system is designed to bring the reactor subcritical at a rate fast enough to prevent the MCPR from becoming less than the fuel cladding Safety Limit during the limiting power transient analyzed in Section 15.4 of the FSAR. This analysis shows that the negative reactivity rates resulting from the scram with the average response of all the drives as given in the specifications, provide the required protection and MCPR remains greater than the fuel cladding Safety Limit. The occurrence of scram times longer than those specified should be viewed as an indication of a systematic problem with the rod drives and therefore the surveillance interval is reduced in order to prevent operation of the reactor for long periods of time with a potentially serious problem. S The scram discharge volume is required to be OPERABLE so that it will be available when needed to accept discharge water from the control rods during a reactor scram and will isolate the reactor coolant system from the containment when required.

ons7et+l hkeel Control rods with inoperable accumulators are declared inoperable and Specification 3.1.3.1 then applies. This prevents a pattern of inoperable accumulators that would result in less reactivity insertion on a scram than has been analyzed. The OPERABILITY of the control rod scram accumulators is required to ensure that adequate scram insertion capability exists when needed over the entire range of reactor pressures. The OPERABILITY of the scram accumulators is based on maintaining adequate accumulator pressure.

In OPCON 1 and 2, the scram function is required for mitigation of DBAs and transients, and therefore the scram accumulators must be OPERABLE to support the scram function. In OPCON 3 and 4, control rods are only allowed to be withdrawn under limits imposed by the reactor mode switch being in shutdown and by the control rod block being applied. This provides adequate requirements for control rod scram accumulator OPERABILITY during these conditions. In OPCON 5, withdrawn control rods are required to have OPERABLE accumulators.

The actions of Specification 3.1.3.5 are modified by a note in:icating that a separate Condition entry is allowed for each control rod scram accumulator. This is acceptable since the required Actions for each Condition provide appropriate compensatory actions for each affected accumulator.

Complying with the Required Actions may allow for continued operation and subsequent affected accumulators-governed by subsequent Condition entry and application of associated Required Actions.

With two or more control rod scram accumulators inoperable and reactor pressure > 900 psig, adequate pressure ..:ust be supplied to the charging water header. With inadequate charging water pressure, the accumulators could HOPE CREEK B 3/4 1-2a Amendment No. 98 l

Insert 1 When one SDV vent or drain valve is inoperable in one or more lines, the associated line must be isolated to contain the reactor coolant during a scram. The 7 day allowed outage time is reasonable, given the level of redundancy in the lines and the low probability of a scram occurring while the valve(s) are inoperable and the line is not isolated. The SDV is still isolable since the redundant valve in the affected line is OPERABLE. During these periods, the single failure criterion may not be preserved, and a higher risk exists to allow reactor water out of the primary system during a scram.

If both valves in a line are inoperable, the line must be isolated to contain the reactor coolant during a scram. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> allowed outage time to isolate the line is based on the low probability of a scram occurring while the line is not isolated and unlikelihood of significant CRD seal leakage.

Note *** indicates that separate Action entry is allowed for each SDV vent and drain line. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable SDV line. Complying with the Required Actions may allow for continued operation, and subsequent inoperable SDV lines are governed by subsequent entry and application of associated Required Actions.

Note **** indicates that when a line is isolated, the potential for an inadvertent scram due to high SDV level is increased. During these periods, the line may be unisolated under administrative control. This allows any accumulated water in the line to be drained, to preclude a reactor scram on SDV high level. This is acceptable since the administrative controls ensure the valve can be closed quickly, by a dedicated operator, if a scram occurs with the valve open.