ML20117K123

Application for Amend to License NPF-57,changing FSAR Decoupling SSE from LOCA

ML20117K123
Person / Time
Site:	Hope Creek
Issue date:	08/30/1996
From:	Eric Simpson Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LR-N96234, NUDOCS 9609110138
Download: ML20117K123 (13)

Text

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Pubhc Sennce Electre and Gas Company E. C. Simpson Public Service Electnc and Gr: Ocmoany P.O. Box 236. Hancocks Bridge, NJ 08038 604339-1700 mue .m.,w-~

AUG 'l 01996 LR-N96234 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

UNREVIEWED SAFETY QUESTION AND NO SIGNIFICANT HAEARDS CONSIDERATION FOR A CHANGE TO THE HOPE CREEK UFSAR FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 During the 10CFR50.59 review of a proposed Updated Final Safety Analysis Report (UFSAR) change, Public Service Electric and Gas Company (PSE&G) determined that an Unreviewed Safety Question (USQ) was involved. Pursuant to the provisions of 10CFR50.59(c),

PSE&G is submitting the proposed amendment to the Hope Creek license in accordance with 10CFR50.90.

The details of the proposed change, the USQ evaluation and the No Significant Hazards Analysis are provided as Attachments to this letter. The proposed changes have been evaluated in accordance with 10CFR50.91(a) (1) , using the criteria in 10CFR50.92 (c) , and PSE&G has concluded that this request involves no significant hazards considerations.

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Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities. ,

I Should you have any questions concerning this submittal, please feel free to contact us.

Sincerely,

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\\ J 9609110138 960830 PDR ADOCK 05000354 p PDR Pnnted on w Recycled Paper

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4 AUG 3 01996 l D'ocument Control Desk LR-I96234 l

Affidavit Attachments (4)

C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Jaffe, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission  !

One White Flint North l 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. R. Summers USNRC Senior Resident Inspector (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 l

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REF: LR-N96234 STATE OF NEW JERSEY )

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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, are true to the best of my knowledge, information and belief.

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Subscribed and Sworn before me l this M b day of 1 M , 1996 0

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ATTACHNENT 1 l EOPE CREEK GENERATING STATION l FACILITY OPERATING LICENSE NPF-57

DOCKET NO. 50-354 j CHANGE TO THE UFSAR l DECOUPLING SSE FRON LOCA i

i REQUESTED CHANGE AND PURPOSE l

} This proposal revises Hope Creek Updated Final Safety Analysis i Report (UFSAR) Section 9.2.5, Ultimate Heat Sink (UHS). As i

indicated in Attachment 3, this revision clarifies the UHS temperature limit bases concerning coincident LOCA and Safe j Shutdown Earthquake (SSE) scenarios.

The purpose of these changes is to provide appropriate descriptions of regulatory criteria in the Hope Creek UFSAR.

Currently, the information contained in the UFSAR Sections 3.6.1, 6.2.1 and 15.6.5 is being used not only to evaluate the structural integrity of reactor coolant pressure retaining components, but to determine the most limiting scenario for Station Service Water System (SSWS) heat removal capability as well. Specifically, the current UHS administrative temperature limit (see LER 96-015-00 for information on the non-conservative Technical Specification UHS limit) has been calculated using SSWS heat removal capability under a coincident SSE, LOCA, loss-of-offsite-power and a single active failure. Approval of this proposed change will enable the use of a new, more appropriate, limiting scenario, which: 1) is consistent with the regulatory requirements; and 2) would permit a higher UHS temperature limit to be established using the normal SSWS discharge path to the cooling tower.

BACKGROUND As discussed in the following paragraphs, PSE&G believes that application of coincident design basis events (SSE and LOCA) for SSWS heat removal analysis is in excess of NRC design basis requirements (e.g., General Design Criteria, the Standard Review  ;

Plant, USNRC Regulatory Guides). However, the information

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currently in the UFSAR has been used to analyze SSWS and UHS heat removal capability under a coincident SSE, LOCA, loss-of-offsite-power and single. active failure. With this scenario being the basis for the UHS temperature limit, the proposed changes would invol~ev an'Unreviewed safety Question since the margin of safety as defined in the licensing basis for those systems (capability of the SSWS and UHS to mitigate the effects of the above Page 1 of 4

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scenario) would be reduced. Therefore, these proposed changes were determined to require NRC approval prior to implementation.

These issues were identified while attempting to determine the most limiting scenario for SSWS heat removal capability.

JUSTIFICATION OF REQUESTED CHANGE 8 Nuclear power plants must be designed to accommodate a spectrum of design basis initiating events within the licensing and design basis of the plant. An initiating event includes a single event and its consequential effects that place the plant or some portion of the plant in an off-normal condition. An initiating event can be an equipment failure, a human error, a natural phenomenon, or a man-made hazard. The licensing and design basis of the plant includes accepted rules for treating the availability of offsite power, the availability of mitigative equipment, the environmental and seismic qualification required of such equipment, and assumptions regarding the most limiting single active or passive component failure for any particular event.

The regulatory requirements for the design of the Hope Creek UHS and SSWS are specified in the General Design Criteria (GDC).

Guidance for an appropriate application of these GDC requirements for Hope Creek systems is contained in NUREG-0800, USNRC Standard Review Plan (SRP). As stated in the Hope Creek Safety Evaluation Report (SER), the SSWS was reviewed in accordance with SRP Section 9.2.1 and the UHS was reviewed in accordance with SRP Section 9.2.5. These SRP sections state that the systems must be capable of: 1) withstanding the effects of natural phenomena such as earthquakes; 2) transferring heat loads from safety-related structures, systems and components to a heat sink under normal operating and accident conditions; and 3) perform its safety function assuming a single active failure coincident with a loss-of-offsite-power.

The referenced USNRC Regulatory Guides in the SRP further elaborate on the design requirements for these systems. In accordance with USNRC Regulatory Guide 1.29, Rev. 3, the design of the plant's cooling water and component cooling systems (or portions of those systems that are required for emergency core '

cooling, post-accident containment heat removal, residual heat removal from the reactor or cooling the spent fuel storage pool) should be designed to withstand the effects of an SSE and remain functional. USNRC Regulatory Guide 1.27 states that the UHS safety functions must be ensured: 1) following the most severe natural phenomena postulated for the site (e.g., the SSE, design basis tornado, hurricane, flood or drought); 2) during other applicablo site-related events that may be caused by natural Page 2 of 4

phenomena; and 3) during reasonable combinations of less severe natural and accidental phenomena or conditions needed for a consistent level of conservatism (i.e., the probability of their existing at the same time and having significant consequences is comparable to that associated with the most severe phenomena).

The Hope Creek SER concluded that the SSWS and the UHS satisfied the applicable acceptance criteria of SRP Sections 9.2.1 and 9.2.5. There is no discussion, regulatory requirement or commitment to sustain a design basis accident coincident with an SSE for SSWS/ UHS heat removal capability. However, PSE&G has conservatively imposed such requirements in light of the current text of UFSAR Sections 3.6.1, 6.2.1 and 15.6.5.

The proposed UFSAR changes identified in Attachment 3 will continue to satisfy the requirements for the design of reactor coolant pressure retaining components (since no changes are proposed to UFSAR Sections 3.6.1, 6.2.1 and 15.6.5) and meet the aforementioned design requirements for the SSWS and UHS.

Although the SSE and LOCA would be decoupled for the purposes of determining SSWS heat removal capability, PSE&G concludes that the clarification to the SSWS/ UHS design requirements are justified since: 1) the SSWS/ UHS will remain capable of achieving and maintaining a safe shutdown following an SSE (and the attendant effects, such as a loss-of-offsite-power) and a single active failure; and 2) the SSWS/ UHS will remain capable of achieving and maintaining a safe shutdown following a design basis LOCA with a loss-of-offsite power and a single active failure.

In addition, PSE&G believes that the coincident LOCA and SSE scenario is not a credible design basis raquirement for analyzing SSWS/ UHS heat removal capability due to the extremely low probability of this occurrence. This position is consistent with statements made in the following various regulatory documents.

For example, USNRC Regulatory Guide 1.27 states that the evaluation of UHS design basis requirements is determined using l the probability of concurrent phenomena. Furthermore, Part 9900 l of the USNRC Inspection and Enforcement Manual concerning Standard Technical Specifications states,

" Design basis events are analyzed to demonstrate that a plant can be operated without undue risk to public health and safety (and) other than as specified by a regulatory requirement, each design basis event is taken as an individual case and not in combination with other design basis events. Safety-related structures, systems and 1 components are designed to (1) remain functional during a Safe Shutdown Earthquake (SSE), (2) ensure the integrity of the reactor coolant pressure boundary, and (3) to have the Page 3 of 4

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capability to shutdown the reactor and maintain it in a safe shutdown condition or the capability to mitigate the consequences of accidents. However, as a design basis event, the SSE is not assumed to occur simultaneously with postulated accidents."

These regulatory documents define an acceptable regulatory approach to satisfying GDC 2 in order to ensure that the design basis for systems, structures and components can accommodate the effects of appropriate combinations of the normal and accident j conditions with the effects of natural phenomena. 1 i

In addition, a Probabilistic Safety Assessment analysis for Hope Creek indicates that the frequency of a small break LOCA (most probable) and an SSE occurring in the same 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period is approximately 2.8E-9 per year. Based on this assessment, the l coincident SSE and LOCA scenario is not a credible event for  !

analyzing SSWS/ UHS heat removal capability. Using this approach, '

PSE&G has concluded that for the purposes of analyzing SSWS heat ,

removal capability: 1) a LOCA is not postulated to occur after l an SSE since the reactor coolant pressure boundary components are ,

designed to withstand the effects of the SSE (per design '

requirements); and 2) an SSE occurring within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />  ;

of a LOCA is not postulated since the probability of these two events is extremely remote.

CONCLUSIONS The UFSAR changes described in Attachment 3 would enable the SSWS/ UHS heat removal capability to be analyzed without considering the coincident LOCA and SSE scenario. Although this would result in a small reduction in a margin of safety described in the UFSAR, the changes would continue to satisfy the regulatory requirements for the SSWS and UHS design and provide a virtually equivalent level of safety.

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ATTACHMENT 2 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSES NPF-57 DOCKET NO. 50-354 CHANGE TO THE UFSAR DECOUPLING SSE AND LOCA 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Hope Creek Generating Station Updated Final Safety Analysis Report (UFSAR) do not involve a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below.

REQUESTED CHANGE This proposal revises Hope Creek UFSAR Sections 9.2.5, Ultimate Heat Sink (UHS). It clarifies the UHS temperature limit bases concerning coincident LOCA and Safe Shutdown Earthquake (SSE) scenarios. The purpose of these changes is to provide appropriate descriptions of regulatory criteria in the Hope Creek UFSAR in order to determine the most limiting scenario for Station Service Water System (SSWS)/ Ultimate Heat Sink (UHS) heat removal capability.

BASIS

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

The proposed changes decouple the SSE and LOCA for the purposes of determining SSWS/ UHS heat removal capability.

These changes do not significantly increase the probability or consequences of an accident previously evaluated since:

1) the reactor coolant pressure boundary components are designed to withstand the effects of an SSE and not result in a LOCA; and 2) the probability of an SSE occurring within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a LOCA is extremely low and is not considered to be a credible scenario for SSWS heat removal analysis.

Therefore, SSWS/ UHS heat removal capability will continue to catisfy the regulatory requirements applicable to Hope Creek under normal operating and accident conditions.

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

The proposed changes to the UFSAR clarify Hope Creek Generating Station's compliance with applicable regulatory requirements that affect SSWS/ UHS heat removal capability analysis. These changes will permit a new UHS temperature limit to be established for Hope Creek. No other changes to plant operation or configuration are part of this change and therefore no new or different kinds of accidents are created from those previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety.

The proposed changes decouple the SSE and LOCA for the purposes of determining SSWS/ UHS heat removal capability.

Although the current UHS temperature limit has been determined assuming a coincident LOCA, SSE, loss-of-offsite-power and single active failure, the proposed changes to eliminate the coincident LOCA and SSE do not significantly reduce a margin of safety. The probability of an SSE occurring within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a LOCA is extremely low and is not considered to be a credible scenario for SSWS heat removal analysis. In addition, the reactor coolant pressure boundary components will continue to be designed to withstand the effects of an SSE and not result in a LOCA.

Therefore, SSWS/ UHS heat removal capability will continue to satisfy the regulatory requirements applicable to Hope Creek under normal operating and accident conditions and will not result in a significant reduction in a margin of safety.

CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

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ATTACHNENT 3 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSES NPF-57 DOCKET NO. 50-354 CHANGE TO UPDATED FINAL SAFETY ANALYSIS REPORT DECOUPLING LOCA AND SSE UFSAR PAGES WITH PROPOSED CHANGES The following UFSAR pages for Facility Operating License No. NPF-57 are affected by this change request:

UFSAR Section Page 9.2.5.1.2 9.2-34 I

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2. To withstand the most severe natural phenomena or site related event, including a safe shutdown earthquake (SSE), hurricane, tornado, missile, flood, freezing, or transportation accident, and reasonably probable combinations of less severe phenomena and/or events.

3. To perform during periods of adverse meteorological conditions, resulting in maximum water consumption and minimum cooling capability.

Although related equipment, such as the intake structure, Station Service Water System (SSWS), and Safety Auxiliaries Cooling System (SACS), are safety-related, the UHS does not have any e uipment that must meet those -_

safeguard requirements. B4 v3% OfG M bete'eah 34.\,G."I.\cN 15'. L . 6 Jinun c.;a c'id e a & LocA .h SS E

' " ^ *r i o 's j 4ks %g3 o f .5be QA5 9.2.5.2 System Descriotion w ger ,gyn g;, g ,. g 4 l ,, +( %

+jo ja M Cag ea t e s.

The UHS is the Delaware River, which provides the source of cooling water to the SACS heat exchangers through the SSWS, as -

shown on Figure 9.2-1. The SACS, in turn, provides demineralized cooling water in a closed loop to the ESF components. The water from the SSWS is discharged into the CWS to provide makeup for that system. I Details of the safety-related and nonsafety-related systems and heat load dissipation are discussed in the following sections:

1. SSWS and intake structure - Section 9.2.1

2. Circulating water and cooling tower - Section 10.4.5

3. SACS - Section 9.2.2.

A discussion of Delaware River water temperatures is provided in the Hope Creek Generating Station Operating License Stage -

Environmental Report.

9.2-34 HCGS-UFSAR Revision 0 April 11, 1988

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HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSES NPF-57 DOCKET NO. 50-354 CHANGE TO THE UFSAR DECOUPLING SSE AND LOCA UNREVIEWED SAFETY QUESTION EVALUATION DOES THE PROPOSED CHANGE INCREASE THE PROBABILITY OF OCCURRENCE OR THE CONSEQUENCES OF AN ACCIDENT OR MALFUNCTION OF EQUIPMENT IMPORTANT TO SAFETY DESCRIBED IN THE UFSAR:

The proposed changes decouple the SSE and LOCA for the purposes of determining SSWS/ UHS heat removal capability.

These changes do not affect the probability or consequences of an accident previously evaluated since: 1) the reactor coolant pressure boundary components are designed to withstand the effects of an SSE and not result in a LOCA; and 2) the probability of an SSE occurring within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a LOCA is extremely low and is not considered to be a credible scenario for SSWS heat removal analysis. The SSWS/ UHS heat removal capability will continue to satisfy the regulatory requirements applicable to Hope Creek under normal operating and accident conditions.

The proposed changes neither modify any system or component, nor cause any system or component to be operated outside its design or testing limits. The proposed changes do not affect the assumptions made in the UFSAR chapter 15 accident analysis. As such, this proposal does not increase the probability or consequences of an accident or malfunction of equipment previously evaluated in the SAR.

DOES THE PROPOSED CHANGE CREATE THE POSSIBILITY OF AN ACCIDENT OR MALFUNCTION OF A DIFFERENT TYPE THAN ANY EVALUATED PREVIOUSLY IN THE UFSAR:

1 The proposed changes to the UFSAR clarify the regulatory requirements that affect SSWS/ UHS heat removal capability analysis only. These changes will permit a new UHS temperature limit to be established for Hope Creek. No other changes to plant operation or configuration are part i of this change. This proposal does not modify any system or  :

component, nor cause any system or component to be operated outside its design or testing limits. Therefore, no new or different kinds of accidents or malfunctions of a different type are created from those previously evaluated.

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DOES THE PROPOSED CHANGE REDUCE THE MARGIN OF SAFETY AS DEFINED IN THE BASES FOR ANY TECHNICAL SPECIFICATIONS The proposed changes decouple the SSE and LOCA for the j purposes of determining SSWS/ UHS heat removal capability.

Although the current UHS temperature limit has been determined assuming a coincident LOCA, SSE, loss-of-offsite- 1 power and single active failure, the proposed changes would I I

reduce the capability of the SSWS/ UHS to accommodate these combined design basis events and would result in a reduction of the margin of safety for the Technical Specification UHS  ;

temperature limit. I I

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