LR-N19-0060, Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program

Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program

ML19170A070
Person / Time
Site:	Hope Creek
Issue date:	06/18/2019
From:	Carr E Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR H19-03, LR-N19-0060
Download: ML19170A070 (11)

Text

PSEG Nuclear U.C P. 0. Box 236, Hancocks Bridge, New Jersey 08038-0236 OPSEG

\'t td ear LLC 10 CFR 50.90 LR-N19-0060 LAR H19-03 JUN 1 8 2019 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:

Application to Revise Technical Specifications to Adopt TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program" In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for an amendment to the Technical Specifications (TS) for Hope Creek Generating Station (Hope Creek).

PSEG requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program." TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test, which currently permit performance by means of any series of sequential, overlapping, or total channel steps, to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. provides a description and assessment of the proposed changes. provides the existing TS pages marked to show the proposed changes. provides revised (clean) TS pages.

Approval of the proposed amendment is requested within one year of submittal acceptance. Once approved, the amendment shall be implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application is being provided to the designated State of New Jersey Official.

There are no regulatory commitments contained in this letter.

J 1 8 LR-N19-0060 10 CFR 50.90 Page 2 If you have any questions or require additional information, please contact Mr. Lee Marabella at 856-339-1208.

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

Executed on ----

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Respectfully,

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C Eric Carr Site Vice President Hope Creek Generating Station : Description and Assessment : Proposed Technical Specification Changes (Mark-Up) : Revised Technical Specification Pages cc: Administrator, Region I, NRC NRC Project Manager, Hope Creek NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE PSEG Corporate Commitment Tracking Coordinator Hope Creek Commitment Tracking Coordinator

LR-N19-0060 LAR H19-03 Attachment 1 Description and Assessment Page 1

LR-N19-0060 LAR H19-03

1.0 DESCRIPTION

PSEG Nuclear LLC (PSEG) requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program. " TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test, which currently permit performance by means of any series of sequential, overlapping, or total channel steps, to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.

2. 0 ASSESSMENT

2. 1 Applicability of Safety Evaluation PSEG has reviewed the safety evaluation for TSTF-563 provided to the Technical Specifications Task Force in a letter dated December 4, 2018. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-563.

As described herein, PSEG has concluded that the justifications presented in TSTF-563 and the safety evaluation prepared by the NRC staff are applicable to Hope Creek and justify this amendment for the incorporation of the changes to the Hope Creek TS.

A Surveillance Frequency Control Program was incorporated into the Hope Creek TS in a license amendment dated February 25, 2011 (NRC Agency Documents Access and Management System (ADAMS) Accession No. ML103410243) as corrected in a license amendment supplement dated April 19, 2011 (ADAMS Accession No. ML110980151).

2. 2 Optional Changes and Variations PSEG is proposing the following variations from the TS changes described in the TSTF-563 or the applicable parts of the NRC staff's safety evaluation.

a) The Hope Creek TS utilize different numbering than the Standard Technical Specifications (STS) on which TSTF-563 was based. Specifically, definitions in the Hope Creek TS are in Section 1 vice Section 1. 1 and the definitions are numbered.

These differences are administrative and do not affect the applicability of TSTF-563 to the Hope Creek TS.

b) The Hope Creek TS are different from Revision 4 of the General Electric BWR/4 STS (NUREG-1433) on which TSTF-563 is based. The definition of Channel Calibration has wording differences from the STS definition that do not change the intent. The Hope Creek TS Channel Calibration definition states, "The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated. " The STS states, "The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps. " Elimination of the phrase "so that the entire channel is calibrated" in the proposed change has no effect because the definition previously states that the Channel Calibration must encompass the entire channel; therefore, the proposed change aligns the wording with that of the STS and Page 2

LR-N19-0060 LAR H19-03 is addressed in the technical justification of TSTF-563 which states in Section 3. 0 Technical Evaluation, "The proposed change to permit changing the surveillance frequency of channel component(s) does not affect the test method or evaluation method. The requirement to perform a channel calibration, channel functional test . . .

o n the entire channel i s not changed".

c) The Hope Creek definition of Channel Functional Test has wording differences from the STS definition that do not change the intent. The Hope Creek TS Channel Calibration definition states, "The CHANNEL FUNCTIONAL TEST may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is tested." The STS states, "The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps." Elimination of the phrase "such that the entire channel is tested" in the proposed change aligns the wording with that of the STS and is addressed in the technical justification of TSTF-563 which states in Section 3.0 Technical Evaluation, "The proposed change to permit changing the surveillance frequency of channel component(s) does not affect the test method or evaluation method. The requirement to perform a channel calibration, channel functional test . . . on the entire channel is not changed. "

3. 0 REGULATORY ANALYSIS

3. 1 No Significant Hazards Consideration Analysis PSEG Nuclear LLC (PSEG) requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program." TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test which currently permit performance by means of any series of sequential, overlapping, or total channel steps. Both definitions are revised to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.

PSEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment, " as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. All components in the channel continue to be calibrated and tested. The frequency at which a channel is tested or calibrated is not an initiator of any accident previously evaluated, so the probability of an accident is not affected by the proposed change. The channels surveilled in Page 3

LR-N19-0060 LAR H19-03 accordance with the affected definitions continue to be required to be operable and the acceptance criteria of the surveillances are unchanged. As a result, any mitigating functions assumed in the accident analysis will continue to be performed.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. All components in the channel continue to be calibrated and tested. The design function or operation of the components involved are not affected and there is no physical alteration of the plant (i. e., no new or different type of equipment will be installed). No credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases are introduced. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. All components in the channel continue to be calibrated and tested. The Surveillance Frequency Control Program assures sufficient safety margins are maintained, and that design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing basis. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by method of determining surveillance test intervals under an NRC-approved licensee-controlled program.

Page 4

LR-N19-0060 LAR H19-03 Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, PSEG concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3. 2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4. 0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR

51. 22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

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LR-N19-0060 LAR H19-03 Enclosure 1 Proposed Technical Specification Changes (Mark-Up)

1.0 DEFINITIONS The following terms are defined so that uniform interpretation of these specifications may be achieved. The defined terms appear in capitalized type and shall be applicable throughout these Technical Specifications.

ACTION 1.1 ACTION shall be that part of a Specification which prescribes remedial measures required under designated conditions.

1.2 DELETED AVERAGE PLANAR LINEAR HEAT GENERATION RATE 1.3 The AVERAGE PLANAR LINEAR HEAT GENERATION RATE (A PLHGR} shall be applicable to a specific planar height and is equal to the sum of the LINEAR HEAT GENERATION RATES for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at that height.

CHANNEL CALIBRATION 1.4 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors.

The CHA NNEL C ALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD} or thermocouple sensors may consist of an inplace qualitative assessmemt of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

The CHANNEL C ALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps eo that the entire ehannel is ealihrated , and each step must be performed within the Frequency in the Surveillance Frequenc Control Pro ram for the devices included in the step.

CHANNE E 1.5 A GHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

CHANNEL FUNCTIONAL TEST 1.6 A CHANNEL FUNCTIONA L TEST shall be:

a. Analog channels - the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip function:3 and channel failure trips.

b. Bistable channels - the injection of a simulated signal into the sensor to veify OPERABILITY including alarm and/or trip functions.

The CHANNEL FUNCTIONAL TEST may be performed by any series of sequential, overlapping or total channel steps sae that the entire ehannel is tested., and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

HOPE CREEK 1-1 Amendment No.

LR-N19-0060 LAR H19-03 Enclosure 2 Revised Technical Specification Pages

1.0 DEFINITIONS The following terms are defined so that uniform interpretation of these specifications may be achieved.

The defined terms appear in capitalized type and shall be applicable throughout these Technical Specifications.

ACTION 1.1 ACTION shall be that part of a Specification which prescribes remedial measures required under designated conditions.

1.2 DELETED AVERAGE PLANAR LINEAR HEAT GENERATION RATE 1.3 The AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) shall be applicable to a specific planar height and is equal to the sum of the LINEAR HEAT GENERATION RATES for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at that height.

CHANNEL CALIBRATION 1.4 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CHANNEL CHECK 1.5 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

CHANNEL FUNCTIONAL TEST 1.6 A CHANNEL FUNCTIONAL TEST shall be:

a. Analog channels - the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions and channel failure trips.

b. Bistable channels - the injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions.

The CHANNEL FUNCTIONAL TEST may be performed by any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

HOPE CREEK 1-1 Amendment No.xxx