ML20198T013

Application for Amend to License NPF-57,proposing Rev to Flood Protection TS LCO & Associated Action Statements

ML20198T013
Person / Time
Site:	Hope Creek
Issue date:	12/30/1998
From:	Eric Simpson Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198T022	List: ML20198T013 ML20198T028
References
LCR-H98-08, LCR-H98-8, LR-N98521, NUDOCS 9901120096
Download: ML20198T013 (10)

Text

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, j Pubhc Service Electnc and Gas I

• , Cornpany E. c. Gmpson Public Service Electric and Gas Company Po. Box 236, Hancocks Bridge, NJ 08038 609-339-1700

.Senics %ce Weedent . Nuclear Engnennng 1

DEC 3 0 1998  :

LR-N98521 LCR H98-08 United States Nuclear Regulatory Commission j Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS l FLOOD PROTECTION REQUIREMENTS l

HOPE CREEK GENERATING STATION l FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Gentlemen:

In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company hereby requests a revision to the Technical Specifications (TS) for the Hope Creek Generating Station (HC). In accordance with 10CFR50.91(b)(1), a copy of this  !

submittal has been sent to the State of New Jersey. The changes proposed in this i

submittal consist of revisions to the Flood Protection TS Limiting Condition for Operation (LCO) and its associated Action Statements. Implementation of the proposed changes will enable Hope Creek to avoid unnecessary plant shutdown transients, and reduce challenges to plant operators during periods of elevated river /

water temperature.

The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1),

using the criteria in 10CFR50.92(c), and a determination has been made that this request involves no significant hazards considerations. The basis for the requested change is provided in Attachment 1 to this letter. A 10CFR50.92 evaluation, with a g

determination of no significant hazards consideration, is provided in Attachment 2. The marked up Technical Specification pages affected by the proposed changes are provided in Attachment 3.

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.

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9901120096 981230 PDR ADOCK 05000354E P , PDR i

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4 DEC 3 0 1998 i Document Control Desk t l1 ,LR-N98521 .

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~~Should you have any questions regarding this ;oquest, please contact James Priest at  !

609-339-5434. ,

t l Sincerely, '

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Affidavit i Attachments (3). l C Mr. H. Miller, Administrator - Region i i U. S. Nuclear Regulatory Commission  !

475 Allendale Road l King of Prussia, PA 19406 Mr. R. Ennis  ;

Licensing Project Manager - Hope Creek ' '

l U. S. Nuclear Regulatory Commission

! One White Flint North Mail Stop 14E21 11555 Rockville Pike '

Rockville, MD 20852 ,

Mr. S. Pindale (X24) i USNRC Senior Resident inspector- HC l

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

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95 4933

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' Document Control Desk DEC 3 01998

~ LR-N98521 JPP- I l

BC- Senior Vice President - Nucl$ar Operations (X04)

Senior Vice President - Nuclear Engineering (N19)-  ;

General Manager - Hope Creek Operations (HO7)

Director - QA/NT/EP (X01)-  !

Director . Licensing / Regulation and Fuels (N21) l Director- Design Engineering l Manager - Financial Control & Co-Owner Affairs (N07) i Program Manager - Nuclear Review Board (N38)  !

Manager - Hope Creek. Operations (H01)

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Manager - System Engineering - Hope Creek (H18)

Manager- Hope Creek Licensing (N21)

J. Keenan, Esq. (N21)

! , NBU RM (N64) i L

Microfilm Copy . .

l Files Nos.1.2.1 (Hope Creek),2.3 (LCR H98-08) l 1

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COUNT ( OF SALEM )

E. C. Simpson, being duly sworn according to law deposes and says:

' I am Senior Vice President - Nuclear Engineering of P'ublic Service Electric and Gas '

Company, and as such, I find the matters set forth in the above refere ,ed letter, conceming Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief.

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! 1 I I L ' Sut, scribed and Sw rn to before me i this M O day of mbu,1998 r LM\ N N __

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1 My Commission expires on O mu~

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• Docum:nt C:ntral De k LR-N98521 l Attachm:nt 1 LCR H98-08 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 i REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS)

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l BASIS FOR REQUESTED CHANGE:

The requirements for Hope Creek's flood protection actions are currently contained in I

! TS Limiting Condition for Operation (LCO) 3.7.3. LCO 3.7.3 contains specific actions and time limits for closure of watertight perimeter flood doors, which are based upon weather conditions and river water levels. The requirements are applicable at Hope 1 Creek at all times. The proposed changes to these flood protection TS address  ;

conditions where the LCO and the associated Action Statements can not be met.  !

l Currently, these circumstances would require entry into TS 3.0.3; however, the changes contained in this submittal would provide more specific guidance for continued plant i l

operation and shutdown requirements, as well as reduce operational burden while maintaining effective flood protection measures.

REQUESTED CHANGE, PURPOSE AND BACKGROUND:

l As shown in Attachment 3 of this letter, LCO 3.7.3, Action Statement a.1, would be l revised to direct the operator to either comply with the existing provisions of LCO 3.7.3 i or declare the affected Station Service Water System (SSWS) pumps inoperable and continue pisri operation in accordance with the requirements imposed by the SSWS LCO 3.7.1.2. In addition, LCO 3.7.3, Action Statement a., will now contain a 12-hour shutdown action requirement to provide specific guidance (in lieu of TS 3.0.3) when the other provisions of the LCO 3.7.3 Action Statements can not be satisfied. These changes will implement controls over continued plant operation that provide a level of protection equivalent to that provided by the current TS. Additionally, as described below, these changes provide greater operational flexibility sirce continued plant operation would be permitted during periods where TS flood protection measures are required as long as SSWS operability (either one or two loops) can be maintained.

Furthermore, a plant shutdown would currently be required by TS 3.0.3 when the TS actions associated with LCO 3.7.3 can not be met, even when a failure to close the SSWS intcke structure doors has no impact on the operation of any safety-related system (i.e., a failure to close a watertight door for an abandoned Unit 2 SSWS pump bay). Therefore, the proposed changes to TS Table 3.7.3-1 to eliminate the watertight j- doors associated with the Unit 2 SSWS bays, are being made to eliminate the

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D:cumsnt Contrsi D:ck LR-N98521 Attachm nt 1 LCR H98-08 i

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' possibility of a TS required shutdown plant transient (under TS 3.0.3) for failure to close l the watertight doors associated with these abandoned SSWS bays. I In addition, Hope. Creek has transmitted Licensee Event Reports that document i occurrences where the required flood protection actions were not implemented in accordance with the requirements of TS LCO 3.7.3. Although there was no safety significance associated with these events, a report was required under the provisions of j 10CFR50.73(a)(2)(i)(B) since no LCO Action Statement (other than TS 3.0.3) l addressed the resulting condition when the watertight doors were not closed within the 1 required timeframe. The proposed changes, which include the addition of an LCO 3.7.3 Action Statement requiring entry into Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, provide clear guidance consistent with the provisions already imposed by TS 3.0.3 and reduce the required regulatory reporting burden.

I JUSTIFICATION OF REQUESTED CHANGES:

The proposed revisions to the flood protection TS are requested to address two issues. The first issue addressed by the proposed changes involves the elimination of unnecessary TS shutdown requirements. Specifically, the current TS require entry into a shutdown action statement (imposed by TS 3.0.3) if a i SSWS intake structure door (or doors) was not closed and river water level was in excess of 95 feet. These shutdown actions would be required regardless of the actual impact on safety related components when the SSWS intake structure doors are not closed or are otherwise inoperable. A failure to close a SSWS intake structure door would have no impact on safety-related SSWS components for watertight doors associated with empty Unit 2 SSWS bays, or would only impact one loop of SSWS if a door associated with an active bay

could not be closed. In these cases, either unrestricted continued plant operation or a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period of continu-ed operation (consistent with the SSWS l LCO 3.7.1.2 for one inoperable SSWS loop) should be permitted.

( Second, a reduction in the regulatory reporting burden will be realized with the

( addition of a TS action requiring entry into Hot Shutdown conditions within 12 l hours if the provisions of the LCO Action Statement can not be met. Since no appropriate TS Action Statement exists within LCO 3.7.3 for occurrences where '

river water level is in excess of 95 feet and specified watertight perimeter doors are not closed, the provisions of TS 3.0.3 are implemented to control continued plant operation. The required entry into TS 3.0.3, for any duration, regardless of safety significance, requires a submittal of an LER in accordance with the i

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D33um::nt Centr:I D2;k LR-N98521 Attachm:nt 1 LCR H98-08 l

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l ' provisions of 10CFR50.73. Implementation of the proposed changes which require entry into Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Cold Shutdown within the

, following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, ensures that the plant is placed in a safe shutdown condition consistent with the direction currently provided by TS 3.0.3 for the same conditions (i.e., Cold Shutdown is achieved in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in the proposed l TS as opposed to 37 hoen under the TS 3.0.3 provisions). Therefore, this i proposed TS change and its resultant reduction in regulatory reporting burden will not resuli in a significant change in the manner in which the plant is l currently operated under the existing TS.

l l The TS Action Statement proposed by PSE&G in the flood protection LCO 3.7.3 would require the operator to assess the impact on SSWS operation when a SSWS intake structure watertight door is not closed or is otherwise inoperable. The assessment of SSWS operability would result in the operator taking actions that are already prescribed in TS LCO 3.7.1.2. PSE&G believes that: 1) the actions required by LCO 3.7.1.2 already properly address a failure l to close a SSWS intake structure watertight door (s) under elevated river water

level conditions; and 2) the proposed TS actions result in an operator response that is consistent with actions currently taken to address other support system l failures that would adversely impact the SSWS. In addition, implementation of

! the proposed changes would avoid unnecessary plant shutdown transients in situations where the ability of SSWS to perform its design basis safety related functions is maintained and the SSWS TS LCO would permit continued operation.

j CONCLUSIONS:

i The changes proposed in this request are being made to establish appropriate guidance for continued plant operation with elevated river water levels. PSE&G concludes that these proposed changes are adequately justified and result in no l Significant Hazards Consideration as described in Attachment 2 of this letter.

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• LR-N98521 l Attachm:nt 2 LCR H98-08  ;

HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS) 10CFR50.92. EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to i the hope Creek Generating Station (HC) Technical Specifications 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.

1 REQUESTED CHANGE ,

The proposed changes affect section 3.7.3 of the Hope Creek TS. Specifically, the 1 flood protection TS Action Statements are being revised to provide the operator with the option of declaring affected SSWS pumps inoperable and establish specific guidance (in lieu of TS 3.0.3) when the other provisions of the action statement can not be satisfied. These changes will reduce reporting requirements by avoiding entry into TS  !

3.0.3, while implementing controls over continued plant operation that provide an equivalent level of safeiy permitted in the current TS.

BASIS 7

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

The proposed TS revisions related to flood protection TS Action Statements

, involve no hardware changes and no changes to existing structures, systems or j components. The proposed changes to the flood protection TS Action

!. Statements ensure that the supported systems can perform their required safety functions under worst case design basis conditions, consistent with limitations imposed by other TS. The proposed flood protection TS ACTION Statements ensure that the plant is directed to enter a safe shutdown condition

_ whenever the capability to withstand worst case design basis conditions is l

affected. Since the flood protection changes will still ensure that the plant remains capable of me9 ting applicable design basis requirements and retains the capability to mitigau the consequences of accidents described in the HC UFSAR, the proposed cbnges were determined to be acceptable. As a result, these changes will neither increase the probability of an accident previously

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• DocumInt Central De:k LR-N98521 - ,

AttachmInt 2 - LCR H98-08

'evaluited nor increase the radiological dose consequences of an accident

previously evaluated.

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

The proposed changes to the flood protection TS contained in this submittal will not adversely impact the operation of any safety related component or equipment. Since the proposed changes involve no hardware changes and no j changes to existing structures, systems or components, there can be no impact .

E on the potential occurrence of any accident due to new equipment failure .

modes. The resulting operational limits imposed by the flood protection LCO ensure that the plant can either perform its design basis safety functions or an appropriately conservative shutdown action statement is entered.- Furthermore, there is no change in plant testing proposed in this change request that could initiate an event. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. l l

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

The proposed changes for the flood protection TS retain the plant's continued

" capability to withstand worst case design basis conditions. The proposed flood protection TS ACTION Statements ensure that the plant is directed to: 1) enter a safe shutdown condition whenever the capability to withstand worst case l design basis conditions is lost; or 2) enter a conservatively short period of  !

continued operation when supported system redundancy is reduced. Since the plant will still remain capable of meeting all applicable design basis i requirements and retaining the capability to withstand worst case design basis  !

l events described in the HC UFSAR, the proposed changes were determined to not result in a significant reduction in a margin of safety.  !

CONCLUSION i

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

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D cumInt Centrsi D:ck LR-N98521 Attachm:nt 3 LCR H98-08 i

HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS) l

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TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES l

l The following Technical Specifications for Facility Operating License No. NPF-57 are l affected by this change request:

Technical Specification Page 3.7.3 3/4 7-9 i

, i l Table 3.7.3-1 3/4 7-10 l

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