Text

License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, Supplement 2
	ML25094A035
Person / Time
Site:	Hope Creek
Issue date:	04/04/2025
From:	Emily Larson; Public Service Enterprise Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	LR-N25-0015, LAR H24-02
	Download: ML25094A035 (1)
	v • d • e

Eric Larson Hope Creek Generating Station Site Vice President, PSEG Nuclear 2200 Alloway Creek Neck Road PO Box 236 Hancocks Bridge, New Jersey 08038-0221 (856) 339-2414 Eric.Larson@PSEG.com 10 CFR 50.90 LR-N25-0015 LAR H24-02 April 4, 2025 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:

License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, Supplement 2

Reference:

1.

PSEG letter to NRC, License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, dated May 20, 2024 (ADAMS Accession No. ML24142A407 and ADAMS Package ML24142A428)

2.

PSEG letter to NRC, License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, Supplement 1, dated October 17, 2024 (ADAMS Accession Nos.

ML24291A057 and ML24291A059)

3.

Improved Standard Technical Specification Change Traveler TSTF-597, Eliminate LCO 3.0.3 Mode 2 Requirement, Revision 0, dated March 15, 2024 (ADAMS Accession No. ML24075A080)

4.

NRC Safety Evaluation for Technical Specifications Task Force Traveler TSTF-597, Revision 0, Eliminate LCO 3.0.3 MODE 2 Requirement Using the Consolidated Line Item Improvement Process, dated December 26, 2024 (ADAMS Accession No. ML24358A228)

PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) in May 2024 to Renewed Facility Operating License No. NPF-57 for Hope Creek Generating Station (HCGS) to revise Hope Creeks current Technical Specifications (CTS) to the Improved Technical Specifications (ITS) consistent with NUREG-1433, Revision 5, Standard Technical Specifications, General Electric BWR/4 Plants, (ISTS) (Reference 1). Supplement 1 to the ITS Conversion LAR submitted in October 2024 (Reference 2) revised Enclosure 2, Volume 13 -

ITS Section 3.8 Electrical Power Systems, of the ITS Conversion LAR to eliminate an ISTS requirement not applicable to HCGS.

LR-N25-0015 10 CFR 50.90 Page 2 PSEG proposes to adopt ISTS generic change TSTF-597, Revision 0, Eliminate LCO 3.0.3 MODE 2 Requirement, dated March 15, 2024 (Reference 3) into the HCGS ITS. TSTF-597 was approved for adoption into ISTS, Revision 5 in December 2024 as documented in the NRC Safety Evaluation associated with TSTF-597 (Reference 4).

The Enclosure to this letter provides proposed changes to the HCGS ITS Conversion LAR associated with the adoption of TSTF-597. Attachment 1 to this letter provides a summary of changes as a result of adopting TSTF-597. The Enclosure to this letter also includes necessary licensee identified changes to the HCGS ITS Conversion LAR. A summary description of the licensee identified proposed changes to the ITS Conversion LAR is provided in Attachment 2.

The Enclosure to this letter includes only ITS Conversion LAR pages impacted by Supplement 2 and are identified with a revision bar and an S2 designation. Some pages include proposed changes as a result of PSEG resolution of NRC Requests for Additional Information not included in the original ITS Conversion LAR or Supplement 1. These NRC accepted changes are not specifically identified and will be identified later in a subsequent revision to the ITS Conversion LAR. Proposed Supplement 2 changes affect the following enclosures and volumes of the HCGS ITS Conversion LAR (Reference 1):

- Contents of the Hope Creek Improved Technical Specifications (ITS)

Submittal (ADAMS Accession No. ML24142A429)

Volume 5 - ITS Section 3.0 LCO and SR Applicability, dated May 20, 2024, (ADAMS Accession No. ML24142A433)

Volume 6 - ITS Section 3.1 Reactivity Control Systems, dated May 20, 2024, (ADAMS Accession No. ML24142A434)

Volume 8 - ITS Section 3.3 Instrumentation, dated May 20, 2024, (ADAMS Accession No. ML24142A436)

Volume 10 - ITS Section 3.5, Emergency Core Cooling Systems (ECCS),

RPV Water Inventory Control, And Reactor Core Isolation Cooling (RCIC) System, dated May 20, 2024, (ADAMS Accession No. ML24142A438)

Volume 11 - ITS Section 3.6 Containment Systems, dated May 20, 2024, (ADAMS Accession No. ML24142A439)

Volume 12 - ITS Section 3.7 Plant Systems, dated May 20, 2024, (ADAMS Accession No. ML24142A440)

Volume 13 - ITS Section 3.8 Electrical Power Systems, dated May 20, 2024, (ADAMS Accession No. ML24142A441)

Volume 14 - ITS Section 3.9 Refueling Operations, dated May 20, 2024, (ADAMS Accession No. ML24142A442)

Volume 16 - ITS Chapter 4.0 Design Features, dated May 20, 2024, (ADAMS Accession No. ML24142A444)

LR-N25-0015 Page 3 10 CFR 50.90

Volume 17 - ITS Chapter 5.0 Administrative Controls, dated May 20, 2024, (ADAMS Accession No. ML24142A445)

The PSEG Fleet Review Committee reviewed this LAR supplement and determined that operation of Hope Creek in accordance with the proposed changes will not endanger the health and safety of the public.

PSEG has determined that the information provided in this supplement does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted in Reference 1. In addition, the information provided in this supplement does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

ln accordance with 10 CFR 50.91(b)(1), a copy of this LAR supplement has been sent to the State of New Jersey.

If there are any questions or if additional information is needed, please contact Mr. Brian Thomas at brian.thomas@pseg.com.

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

Executed on L./ / '1 / d c;-*.

(Date)

Respectfully, Eric Larson Site Vice President Hope Creek Generating Station : Summary of Proposed Changes to Hope Creek Generating Station ITS Conversion LAR Adopting TSTF-597 : Summary of Proposed Licensee Identified Changes to Hope Creek Generating Station ITS Conversion LAR

Enclosure:

Proposed Changes to Hope Creek Generating Station Improved Technical Specification Conversion License Amendment Request cc:

Administrator, Region I, NRC NRC Project Manager, Hope Creek NRC Senior Resident Inspector, Hope Creek Manager NJBNE

LR-N25-0015 ATTACHMENT 1

SUMMARY

OF PROPOSED CHANGES TO HOPE CREEK GENERATING STATION ITS CONVERSION LAR ADOPTING TSTF-597 (2 TOTAL PAGES, INCLUDING COVER SHEET)

LR-N25-0015 Summary of Proposed Changes to Hope Creek Generating Station ITS Conversion LAR Adopting TSTF-597 A1-1 Reference Specification Title Summary of Changes HCGS ITS Conversion LAR -

LAR Enclosure 1 HCGS ITS Submittal Contents of the Hope Creek ITS Submittal Page ii: Updated the Table of contents Page E1-1: Changed two to three Page E1-3: Changed two to three Page E1-5: Added Eliminate LCO 3.0.3 MODE 2 Requirement (TSTF-597) heading and description.

Table 1: Added TSTF-597 and details HCGS ITS Conversion LAR -,

Volume 5 3.0 LCO and SR Applicability CTS 3.0.3: Deleted LCO 3.0.3 MODE 2 (Startup) Requirement CTS 3.0.3: Added DOC L02 marker to RH Margin DOC A04: Modified to TSTF-597 changes, and reference new DOC L02 DOC L02: Added new L-DOC for TSTF-597 changes ITS LCO 3.0.3: Modified to TSTF-597 changes ITS 3.0 JFDs: Deleted JFD-3 which addressed the Reviewers Note.

Reviewers Note is deleted by TSTF-597 changes ITS LCO 3.0.3 Bases: Modified to TSTF-597 changes HCGS ITS Conversion LAR -,

Volume 8 3.3.7.1 CREF System Instrumentation DOC M02: Modified as a result of proposed adopting TSTF-597

LR-N25-0015 ATTACHMENT 2

SUMMARY

OF PROPOSED LICENSEE IDENTIFIED CHANGES TO HOPE CREEK GENERATING STATION ITS CONVERSION LAR (5 TOTAL PAGES, INCLUDING COVER SHEET)

LR-N25-0015 Summary of Proposed Licensee Identified Changes to Hope Creek Generating Station ITS Conversion LAR A2-1 Reference ITS Specification Title Summary of Changes HCGS ITS Conversion LAR -,

Volume 6 3.1.1 Shutdown Margin ITS 3.1.1 Required Action D.3 insert: Deleted the comma HCGS ITS Conversion LAR -,

Volume 8 3.3.1.1 RPS Instrumentation CTS Table 4.3.1.1-1: Added SR 3.3.1.1.3 to channel calibration column for Functions 2.b and 2.f. Moved SR 3.3.1.1.3 LH margin reference to footnote (g). Modified SR 3.3.1.1.3 surveillance requirement.

ITS 3.3.1.1 DOCs: Revised DOC A14 to address footnote (g) incorporation into ITS SR 3.3.1.1.3. Revised DOC LA09 to eliminate discussion related to footnote (g).

ITS SR 3.3.1.1.3: Deleted LH margin reference to footnote (e). Modified surveillance requirement. Added RH margin reference to JFD-4. Added JFD-4.

ITS SR 3.3.1.1.10: Changed LH margin reference to DOC M02.

ITS SR 3.3.1.1.3 Bases: Revised Bases to include modified discussion related to SR 3.3.1.1.3. Added RH margin reference to Bases JFD 6.

Added Bases JFD 6.

HCGS ITS Conversion LAR -,

Volume 8 3.3.4.1 EOC-RPT Instrumentation ITS SR 3.3.4.1.5 Bases: Deleted interruption HCGS ITS Conversion LAR -,

Volume 8 3.3.5.1 ECCS Instrumentation ITS Table 3.3.5.1-1 Footnote (a): Replaced acronym EDG with emergency diesel generator ITS Table 3.3.5.1-1, HPCI Water Level - High, Level 8 trip: Deleted SR 3.3.5.1.7, added JFD-4 since the ECCS response time is not applicable to this HPCI trip function.

ITS Table 3.3.5.1-1 Footnote (d): Changed JFD reference to JFD-3 HCGS ITS Conversion LAR -,

Volume 8 3.3.6.1 Primary Containment Isolation Instrumentation ITS 3.3.6.1 Required Action G.1 Completion: Added Functions to the first Completion Time ITS Table 3.3.6.1-1 (Insert 2) Function 3.a.2: Added and to the allowable value parameters ITS Table 3.3.6.1-1 (Insert 3) Function 4.a.2: Added and to the allowable value parameters ITS Table 3.3.6.1-1 (Insert 4) Function 5.a.2: Added and to the allowable value parameters

LR-N25-0015 Summary of Proposed Licensee Identified Changes to Hope Creek Generating Station ITS Conversion LAR A2-2 Reference ITS Specification Title Summary of Changes HCGS ITS Conversion LAR -,

Volume 8 3.3.8.2 RPS Electric Power Monitoring ITS SR 3.3.8.2.2.b: Added symbol for Bus B undervoltage allowable value parameter HCGS ITS Conversion LAR -,

Volume 10 3.5.1 ECCS -

Operating ITS SR 3.5.1.7: Added psig to the insert.

HCGS ITS Conversion LAR -,

Volume 11 3.6.1.3 Primary Containment Isolation Valves ITS SR 3.6.1.3.13 Insert: Deleted the hyphen in long-term consistent with the ISTS Writers Guide guidance.

HCGS ITS Conversion LAR -,

Volume 12 3.7.1 Safety Auxiliaries Cooling System ITS 3.7.1, CTS 4.7.1.1.b: Changed LH margin reference to SR 3.7.1.2, added RH margin reference to DOC L05.

ITS 3.7.1 DOCs: Revised DOC M01 to change the initial Frequency of 36 months to 48 months in anticipation of operation on a 24 month fuel cycle based on currently performing the test during EDG loss of power/LOCA testing. Added DOC L05 to address addition of actuation on an actual signal. Added DOC L06 to address exception for valves that are locked sealed or otherwise secured in position, similar to ITS 3.7.2 DOC L03.

SR 3.7.1.1: Deleted LH margin reference to 4.7.1.1.b.1, changed two RH margin references from JFD-1 to JFD-8 SR 3.7.1.2: Added LH margin reference to 4.7.1.1.b.1, Added DOCs L05 and L06 reference to LH margin, added RH margin reference to JFD-1 HCGS ITS Conversion LAR -,

Volume 12 3.7.2 Station Service Water System and Ultimate Heat Sink ITS 3.7.2, CTS 4.7.1.2.b.1: Added DOC L07 reference to RH margin.

ITS 3.7.2 DOCS: Revised DOC M01 to change the initial Frequency of 36 months to 48 months in anticipation of operation on a 24 month fuel cycle based on currently performing the test during EDG loss of power/LOCA testing. Added DOC L07 to address addition of actuation on an actual signal.

SR 3.7.2.4: Added DOC L07 reference to LH margin.

LR-N25-0015 Summary of Proposed Licensee Identified Changes to Hope Creek Generating Station ITS Conversion LAR A2-3 Reference ITS Specification Title Summary of Changes HCGS ITS Conversion LAR -,

Volume 13 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air ITS 3.8.3, CTS 4.8.1.1.2.a.7: Restored pressure in, added required to air start receiver, deleted s from receivers, added RH margin reference to DOC A06 ITS 3.8.3 DOCS: Added DOC A06 ITS SR 3.8.3.4: Added pressure in, added LH margin reference to DOC A06, added required to air start receiver ITS 3.8.3 JFDs: Added JFD-4.

ITS Bases Background, last paragraph: Added each, to the subsystems insert HCGS ITS Conversion LAR -,

Volume 14 3.9.6 RPV Water Level ITS 3.9.6, CTS 3.9.8, CTS 4.9.8: Restored inches ITS 3.9.6 DOCs: Restored inches ITS 3.9.6, LCO 3.9.6, SR 3.9.6.1: Changed in to inches ITS 3.9.6 Bases: Changed in to inches HCGS ITS Conversion LAR -,

Volume 14 3.9.7 RPV - High Water Level ITS 3.9.7, CTS 3.9.11.1, Applicability: Changed in to inches ITS 3.9.7, Applicability: Changed in to inches ITS 3.9.7 Bases: Changed in to inches HCGS ITS Conversion LAR -,

Volume 14 3.9.8 RHR - Low Water Level ITS 3.9.8, CTS 3.9.11.2: Applicability, changed in to inches ITS 3.9.8, Applicability: Changed in to inches HCGS ITS Conversion LAR -,

Volume 16 4.0 Design Features ITS 4.0, CTS 5.6.2, Changed to inches HCGS ITS Conversion LAR -,

Volume 17 5.2 Organization ITS 5.2, CTS 6.2.2: Changed or to and in 5.2.2.a insert ITS 5.2 DOC A03: Changed or to and ITS 5.2, ITS 5.2.2.a: Changed or to and

LR-N25-0015 Summary of Proposed Licensee Identified Changes to Hope Creek Generating Station ITS Conversion LAR A2-4 Reference ITS Specification Title Summary of Changes HCGS ITS Conversion LAR -,

Volume 17 5.5 Programs and Manuals ITS 5.5, CTS 6.8.4.a: Added and (i.e., sampling and control)

ITS 5.5, CTS 6.8.4.a.2: Added at a frequency to insert ITS 5.5, CTS 6.8.4.e: Added at a frequency to insert ITS 5.5, CTS 6.16.d: Changed train to subsystem ITS 5.5, ITS 5.5.2: Added and (i.e., sampling and control)

ITS 5.5, ITS 5.5.2.b: Added at a frequency to insert ITS 5.5, ITS 5.5.5.a: Restored s in systems ITS 5.5, ITS 5.5.5.e: Changed dissipates to dissipate ITS 5.5, ITS 5.5.7.c: Added at a frequency to insert ITS 5.5, ITS 5.5.11: Changed P in program to lowercase, add RH margin reference to JFD-17 ITS 5.5, ITS 5.5.12.d: Deleted train and restored subsystem ITS 5.5 JFDs: Added JFD-17 HCGS ITS Conversion LAR -,

Volume 17 5.6 Reporting Requirements ITS 5.6 Insert 1: Changed LCO 3.3.4.1 End of Cycle Recirculation Pump Trip acronym to EOC-RPT

LR-N25-0015 Enclosure ENCLOSURE PROPOSED CHANGES TO HOPE CREEK GENERATING STATION IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST (76 TOTAL PAGES, INCLUDING COVER SHEET)

LR-N24-0029 LAR H24-02 ii ENCLOSURE 1 CONTENTS OF THE HOPE CREEK GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS SUBMITTAL Table of Contents Executive Summary...................................................................................................... 1 Risk Informed Initiatives................................................................................................ 1 Surveillance Frequency Control Program (TSTF-425)............................................... 1 Technical Specifications End States (TSTF-423)....................................................... 2 Industry Initiatives Proposing to Adopt.......................................................................... 2 Battery Monitoring and Maintenance Program (TSTF-500)........................................ 2 Proposed NRC Approved Travelers not in NUREG-1433 Revision 5............................ 3 Eliminate Automatic RWCU System Isolation on SLC Initiation (TSTF-584).............. 3 Revise Automatic Depressurization System (ADS) Instrumentation Requirements (TSTF-592)................................................................................................................ 4 Eliminate LCO 3.0.3 MODE 2 Requirement (TSTF-597)............................................ 5 Content of Hope Creek Improved Technical Specifications Submittal, Volumes 1 through 17..................................................................................................................... 6 Volume 1................................................................................................................ 7 Volume 2................................................................................................................ 7 Volumes 3 through 17............................................................................................ 8 CTS Markup and Discussion of Changes (DOCs).................................................. 8 CTS Bases........................................................................................................... 10 Type and Category Descriptions.............................................................................. 10 Type Descriptions................................................................................................ 10 Category Descriptions.......................................................................................... 12 ISTS Markup and Justification for Deviations (JFDs)............................................ 16 ISTS Bases Markup and JFDs............................................................................. 16 Specific No Significant Hazards Consideration (NSHC) Determinations............... 16 Table 1 - Notable TSTF Travelers and Adoption Status at Hope Creek...................... 17 S2

LR-N24-0029 LAR H24-02 E1-1 CONTENTS OF THE HOPE CREEK GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS SUBMITTAL Executive Summary The proposed changes from the Hope Creek Generating Station (Hope Creek) current Technical Specifications (CTS) to the Improved Technical Specifications (ITS) are based on Revision 5.0 of NUREG 1433, Standard Technical Specifications - General Electric BWR/4 Plants. Generic BWR/4 Improved Standard Technical Specification (ISTS) changes (Technical Specification Task Force (TSTF) change travelers) incorporated into NUREG-1433, up to and including Revision 5.0, apply to Hope Creek and have been incorporated into the Hope Creek ITS without deviation, except where noted in this ITS Conversion LAR in the Justification for Deviations. Table 1 of this enclosure lists notable TSTF travelers and status of Hope Creek adoption of these TSTF travelers into the CTS. There are three additional Nuclear Regulatory Commission (NRC) approved TSTF change travelers since approval of NUREG-1433, Revision 5, addressed in this license amendment request. TSTF-GG-13-01, Improved Technical Specifications Conversion Guidance, Revision 0, was used to prepare the content of the license amendment request. Additionally, there are no linked Hope Creek submittals associated with this ITS license amendment request.

Risk Informed Initiatives Several risk informed initiatives incorporated into the ISTS and associated Bases specified in NUREG-1433, Revision 5.0, have been previously approved and incorporated into the Hope Creek Technical Specifications. Therefore, information related to the NRC reviewer notes provided in the ISTS and ISTS Bases associated with these risk informed initiatives are provided in this ITS Conversion LAR. PSEG is not adopting TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b" at this time. Therefore, the Hope Creek ITS does not include Risk Informed Completion Times in the Specifications or a Risk Informed Completion Time Program in ITS Chapter 5.

Surveillance Frequency Control Program (TSTF-425)

Hope Creek previously adopted a Surveillance Frequency Control Program (SFCP) on February 25, 2011, in License Amendment 187 (NRC ADAMS Accession No. ML103410243). In the NRC safety evaluation accompanying the SFCP amendments, the NRC concluded that the adoption of TSTF-425, Revision 3, and risk-informed methodology of NEI 04-10, " Risk-Informed Method for Control of Surveillance Frequencies," Revision 1, as referenced in the Administrative Controls section of the Technical Specifications, satisfies the key principles of risk-informed decisionmaking applied to the relocated Surveillance frequencies as delineated in Regulatory Guide 1.177, Revision 1, and Regulatory Guide 1.174, Revision 2. Changes to Surveillance frequencies listed in the SFCP are made in accordance with NEI 04-10, Revision 1, as specified in CTS Chapter 6 (ITS Chapter 5).

S2

LR-N24-0029 LAR H24-02 E1-3 gravity monitoring as a reliable and accurate indication of the state-of-charge of the battery and that this will hold true over the life of the battery.

The battery room temperature is routinely monitored such that a room temperature excursion could reasonably expect to be detected and corrected prior to the average battery electrolyte temperature dropping below the minimum electrolyte temperature.

The measurement equipment used to monitor float current has the necessary accuracy and capability to measure electrical currents in the expected range.

The cell resistance limits in CTS 4.8.2.1 are relocated to the Battery Monitoring and Maintenance Program.

The modified performance discharge test completely encompasses the load profile of the battery service test and that it adequately confirms the intent of the service test to verify the battery capacity to supply the design basis load profile.

Commitments associated with TSTF-500 are provided in Enclosure 5. A description of the UFSAR changes associated with TSTF-500 are provided in Enclosure 6.

Commitments and UFSAR revision packages associated with TSTF-500 will be completed prior to implementation of the ITS Amendment.

Proposed NRC Approved Travelers not in NUREG-1433 Revision 5 Three NRC approved TSTF travelers not incorporated into NUREG-1433, Revision 5 are proposed to be adopted. The ISTS markup pages are annotated to show the incorporation of NRC approved TSTF change travelers that are applicable to the Hope Creek ITS Conversion LAR but not included in NUREG-1433, Revision 5. These annotations provide added information on where a change originates when not included in the latest revision of NUREG-1433. Hope Creek specific deviations from the approved TSTF traveler are annotated with JFDs in the ISTS markup, as applicable.

Eliminate Automatic RWCU System Isolation on SLC Initiation (TSTF-584)

For the reduction of risk from an Anticipated Transient Without Scram (ATWS) event for Boiling Water Reactors (BWRs), 10 CFR 50.62(c)(4) states that the Standby Liquid Control (SLC) System initiation must be automatic and must be designed to perform its function in a reliable manner for plants granted a construction permit after July 26, 1984, and for plants granted a construction permit prior to July 26, 1984, that have already been designed and built to include this feature. Hope Creek voluntarily committed to incorporate a Redundant Reactivity Control System (RRCS) to automatically initiate ATWS features in order to bound possible future NRC requirements for ATWS. However, the SLC System alternately can be manually initiated by the operators as directed by plant emergency operating procedures.

Since the Reactor Water Cleanup (RWCU) System isolation signal on SLC System initiation is a fail-close signal for the RWCU system return isolation valves, it complicates plant maintenance evolutions that interrupt power to the signal, resulting in S2

LR-N24-0029 LAR H24-02 E1-5 correct overly restrictive action requirements, and to treat less significant channel inoperabilities consistently.

The NRC staff concluded that the proposed changes to ISTS 3.3.5.1 for BWR/4 and BWR/6 in Traveler TSTF-592 are acceptable because the remedial actions to be taken until the LCO can be met provide protection to the health and safety of the public. The NRC staff also concluded that there is reasonable assurance that plants adopting TSTF-592 will continue to ensure that when LCO 3.3.5.1 is not met, the licensee will shut down or follow any remedial action permitted by the Technical Specifications until the condition can be met.

PSEG has reviewed the NRC safety evaluation associated with TSTF generic traveler TSTF-592 provided in an NRC letter to the TSTF dated January 31, 2024. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-592. PSEG has concluded that the justifications presented in TSTF-592 and the safety evaluation prepared by the NRC staff are applicable to Hope Creek. As such, this NRC approved change to NUREG-1433 is included in the ITS Conversion LAR.

Eliminate LCO 3.0.3 MODE 2 Requirement (TSTF-597)

In NUREG-1433, LCO 3.0.3 requires the unit to be placed into a MODE or other specified condition outside the currently applicable modes when an LCO is not met, and any of the following conditions are true: 1) the associated actions are not met, 2) an associated action is not provided, or 3) LCO 3.0.3 entry is directed by the associated actions. LCO 3.0.3 requires that action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit in MODE 2 (Startup) within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , MODE 3 (Hot Shutdown) within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and MODE 4 (Cold Shutdown) within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Traveler TSTF-597 revises the shutdown requirements in ISTS LCO 3.0.3 by removing the requirement to place the unit in MODE 2 prior to entering MODE 3.

The requirements to be in MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months and MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months remain unchanged.

The NRC staff determined that the proposed changes to the ISTS LCO 3.0.3 and associated Bases continue to meet the Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors and 10 CFR 50.36. Additionally, the NRC staff found the changes to be technically clear and consistent with customary terminology and format in accordance with NUREG-0800 (Standard Review Plan) Chapter 16.0. The NRC staff concluded that the changes are acceptable and continue to provide reasonable assurance of adequate protection of the health and safety of the public.

PSEG has reviewed the NRC safety evaluation associated with TSTF generic traveler TSTF-597 provided in an NRC letter to the TSTF dated December 26, 2024. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-597. PSEG has concluded that the justifications presented in TSTF-597 and the safety evaluation prepared by the NRC staff are applicable to Hope Creek. As such, this NRC approved change to NUREG-1433 is included in the ITS Conversion LAR.

S2

LR-N24-0029 LAR H24-02 Table 1 - Notable TSTF Travelers and Adoption Status at Hope Creek (continued)

(Page 7 of 7)

Traveler No.

Traveler Rev.

Traveler Title HCGS License Amendment No.

HCGS License Amendment Date Proposed in ITS Conversion LAR Plant Specific Deviations Comments 580 1

Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling Yes No TSTF-580 is applicable to HCGS. Propose adoption as specified in NUREG-1433, Rev. 5.

582 0

RPV WIC Enhancements 227 3/12/2021 No 584 0

Eliminate Automatic RWCU System Isolation on SLC Initiation Yes No TSTF-584 is applicable to HCGS. Propose adoption as specified in TSTF-584-A, Revision 0.

587-T 0

Delete LCO 3.5.2 Note Yes No TSTF-587-T is applicable to HCGS. Propose adoption as specified in NUREG-1433, Rev. 5.

592 2

Revise Automatic Depressurization System (ADS)

Instrumentation Requirements Yes No TSTF-592 is applicable to HCGS. Propose adoption as specified in TSTF-592-A, Revision 2.

597 0

Eliminate LCO 3.0.3 MODE 2 Requirement Yes No TSTF-597 is applicable to HCGS. Propose adoption as specified in TSTF-597-A, Rev. 0.

S2

ITS 3.0 ITS A01 3 /4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met, and except as provided in LCO 3.0.8, and LCO 3.0.9.

3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the Action requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in an OPERATIONAL CONDITION in which the Specification does not apply by placing it, as applicable, in:

1.

At least STARTUP within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications.

This Specification is not applicable in OPERATIONAL CONDITIONS 4 or 5.

3.0.4 When an LCO is not met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the OPERATIONAL CONDITION or other specified condition in the Applicability for an unlimited period of time; or b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the OPERATIONAL CONDITION or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

HOPE CREEK 3/4 0-1 Amendment No.228 (LCO)

LCO 3.0.1 LCO 3.0.2 LCO 3.0.3 LCO 3.0.4 LCO 3.0.2 Required Actions of the associated Conditions LCOs shall be met MODES in the Applicability, LCO 3.0.2, LCO 3.0.7, met or is no longer applicable Completion Time(s)

Required Action(s)

, unless otherwise stated an and the associated ACTIONS are not met an is not provided, or if directed by the associated ACTIONS MODE or other specified condition MODE 3 MODE 4 13 37 LCO is not applicable this Specification LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

MODE MODE MODE discovery of a except as provided in LCO 3.0.5 and LCO 3.0.6.

n in accordance with the LCO or S

completion of the actions required by LCO 3.0.3 is not required MODE A05 A02 A02 A06 A07 A03 A04 Compliance with the Limiting Conditions for Operation contained in the succeeding or other conditions specified A02 A02 A02 L02 a

b S2

DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY Hope Creek Page 2 of 7 These changes are acceptable because they result in no change in the intent or application of the Technical Specifications, but merely reflect editorial preferences used in the ITS.

A04 The CTS 3.0.3 phrase, except as provided in the associated ACTION requirements is replaced with and the associated Actions are not met, an associated Action is not provided, or if directed by the associated Actions to cover all potential possibilities that require entry into LCO 3.0.3. Operational Condition is changed to MODE or other specified condition to be consistent with ISTS and this change is applied consistently throughout the ITS.

CTS 3.0.3, in part, states that within one hour action shall be initiated to place the unit in an OPERATIONAL CONDITION in which the Specification does not apply by placing it, as applicable, in: at least STARTUP within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and at least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ISTS LCO 3.0.3 states that action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . This changes the CTS by using the sum of the times (i.e., the ITS Completion Time of 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to enter MODE 4 is the same as the sum of the CTS allowance of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) instead of sequential times (i.e., each time is measured from the completion of the previous step). See Discussion of Change L02 for the adoption of TSTF-597 which deletes the LCO 3.0.3 MODE 2 requirement (i.e.

Mode 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ) from the ISTS. Accordingly, the CTS LCO 3.0.3 MODE 2 requirement (i.e., Mode 2 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ) is deleted. The stated times in CTS 3.0.3 and ISTS 3.0.3 are listed below:

MODE Title CTS Time to Enter MODE ISTS Time to Enter MODE (Current MODE) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to begin action 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to begin action 2

Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 7 hours 3

Hot Shutdown within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 13 hours 4

Cold Shutdown within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 37 hours The purpose of CTS 3.0.3 is to establish the shutdown requirements that must be implemented when an LCO is not met and the condition is not specifically addressed in the associated ACTION requirements. The delineated time limit allows the unit to be placed in a safe shutdown MODE when the plant cannot be maintained within the limits for safe operation. The time limit, specified in CTS 3.0.3 to reach the lower MODES of operation, permits the shutdown to proceed in a controlled manner that is well within the specified maximum cooldown rate.

Furthermore, the time limit is within the cooldown capabilities of the plant assuming only the minimum required equipment is OPERABLE. In the CTS, this is accomplished by allowing a total of 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the plant to be in MODE 4 when a shutdown is required during the MODE of Operation. In the ITS, the time S2 S2 S2

DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY Hope Creek Page 3 of 7 limits for ITS LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a lower mode of operation when an ISTS LCO 3.0.3 shutdown is required, the time limit for reaching the next lower MODE applies (i.e., if the plant is in MODE 2, 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months is allowed to reach MODE 3). ITS 3.0 Bases gives a detailed discussion on the use of applying the allowed outage times when the unit is in a lower MODE when ITS LCO 3.0.3 is entered. This is further explained, with examples, in the discussion of Section 1.3, "Completion Times." This change is acceptable because ISTS and CTS both allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to reach MODE 4 from power operation.

These changes are considered changes to the CTS presentation and are designated as administrative as they apply rules of usage established by ITS without resulting in technical changes to the Technical Specifications.

A05 CTS 3.0.3 states "Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation." ITS LCO 3.0.3 states "Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3."

This change is acceptable because the changes to CTS 3.0.3 are editorial. Both the CTS and ITS state that LCO 3.0.3 can be exited if the LCO which led to the entry into LCO 3.0.3 is met, or if one of the ACTIONS of that LCO is applicable.

The CTS requirement also specifies that the time to complete the ACTIONS in the LCO is based on the initial failure to meet the LCO. Reentering the LCO after exiting LCO 3.0.3 does not reset the ACTION statement time requirements. This information is not explicitly stated in ITS LCO 3.0.3 but is true under the multiple condition entry concept of the ITS.

In addition, CTS 3.0.3 states This specification is not applicable in MODES 4 or

5. ITS LCO 3.0.3 states LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

CTS 3.0.3 and ITS LCO 3.0.3 require the unit to be placed only as low as COLD SHUTDOWN (MODE 4). Once the unit is in MODE 4, there are no further requirements. Thus, CTS 3.0.3 and ITS LCO 3.0.3 are effectively only applicable in MODES 1, 2, and 3, and the addition of the sentence merely reflects editorial preferences used in the ITS.

These changes are designated as administrative because there is no change in the intent or application of the CTS 3.0.3 requirements.

A06 ITS LCO 3.0.6 is added to the CTS. ITS LCO 3.0.6 provides guidance regarding appropriate Actions to be taken when a support system inoperability also results in the inoperability of one or more related supported systems. ITS includes LCO 3.0.6 and a Safety Function Determination Program (Specification 5.5.9) to resolve the application of LCOs to support and supported systems. Since the function of ITS LCO 3.0.6 is to clarify existing ambiguities and to maintain consistency with previous interpretations, this new provision is considered an administrative change with no impact on safety.

S2 S2

DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY Hope Creek Page 6 of 7 REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.0.2 states, "Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval." ITS SR 3.0.2 states, " The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as "once," the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications." This changes the CTS by adding, " If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance." The remaining changes to CTS 4.0.2 are discussed in DOCs A08 and M01.

This change is acceptable because the 25% Frequency extension given to provide scheduling flexibility for Surveillances is equally applicable to Required Actions that must be performed periodically. The initial performance is excluded because the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Completion Time with extension in order to avoid operation in unacceptable conditions. This change is designated as less restrictive because additional time is provided to perform some periodic Required Actions.

L02 (Category 4 - Relaxation of Required Action) CTS 3.0.3 states When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in an OPERATIONAL CONDITION in which the Specification does not apply by placing it, as applicable, in: 1. At least STARTUP within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.0.3 states, When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in: a. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and b. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . This changes the CTS by deleting the requirement to place the unit in at least STARTUP within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The change to ISTS 3.0.3 to delete the LCO 3.0.3 MODE 2 requirement (TSTF-597) is described below.

The purpose of LCO 3.0.3 is to place the unit into a MODE or other specified condition outside the currently applicable modes when an LCO is not met, and any of the following conditions are true: 1) the associated actions are not met, 2) an associated action is not provided, or 3) LCO 3.0.3 entry is directed by the S2

DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY Hope Creek Page 7 of 7 associated actions. This change is acceptable because deleting the requirement to place the unit in MODE 2 (Startup) is consistent with the change to ISTS 3.0.3 which deletes the MODE 2 (Startup) requirement in accordance with TSTF-597, Revision 0, Eliminate LCO 3.0.3 MODE 2 Requirement. This change is designated as less restrictive because less stringent Required Actions requirements are being applied in the ITS than were applied in the CTS.

HCGS proposes to adopt TSTF-597, Revision 0, Eliminate LCO 3.0.3 MODE 2 Requirement, dated December 26, 2024 (ADAMS Accession No. ML24358A224). The NRC staff reviewed TSTF-597, Revision 0, which proposed changes to Standard Technical Specifications (STS) found in NUREG-1433 and 1434 to remove the LCO 3.0.3 MODE 2 requirement. The TSTF was approved for adoption into the ISTS as documented in the NRC Safety Evaluation accompanying TSTF-597 (ADAMS Accession No. to ML24358A228). The NRC staff determined that the proposed changes to the STS continue to meet the Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors and 10 CFR 50.36.

S2

LCO Applicability 3.0 General Electric BWR/4 STS 3.0-1 Rev. 5.0 CTS Hope Creek Amendment XXX 1

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a.

MODE 2 within [7] hours,

b.

MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and

c.

MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

REVIEWER'S NOTE-----------------------------------

The brackets around the time provided to reach MODE 2 allow a plant to extend the time from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to a plant specific time. Before the time can be changed, plant specific data must be provided to support the extended time.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; 3.0.1 3.0.2 3.0.3 3.0.4 DOC L02 a

b TSTF

-597 TSTF

-597 S2 S2

JUSTIFICATION FOR DEVIATIONS ITS 3.0, LCO AND SR APPLICABILITY Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.

S2

LCO Applicability B 3.0 General Electric BWR/4 STS B 3.0-4 Rev. 5.0 Hope Creek Revision XXX 1

BASES LCO 3.0.3 (continued) less time than allowed, however, the total allowable time to enter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 is entered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for entering MODE 3 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for entering MODE 3 is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.8, "Spent Fuel Storage Pool Water Level." LCO 3.7.8 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.8 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.8 of "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry into the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time. Compliance with ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an 7

1 1

1 7

7 7

3 28 4

4 37 9

TSTF

-597 S2

SDM 3.1.1 General Electric BWR/4 STS 3.1.1-2 Rev. 5.0 Hope Creek Amendment XXX CTS 1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.3 Initiate action to restore one standby gas treatment (SGT) subsystem to OPERABLE status.

AND D.4 Initiate action to restore isolation capability in each required [secondary]

containment penetration flow path not isolated.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour E. SDM not within limits in MODE 5.

E.1 Suspend CORE ALTERATIONS except for control rod insertion and fuel assembly removal.

AND E.2 Initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies.

AND Immediately Immediately Action c DOC L01 Action c DOC M01 2

one Filtration Recirculation and Ventilation System (FRVS) ventilation unit 3

DOC L02 Action b DOC A05 DOC M01 Action b DOC A05 DOC M01 S2

HOPE CREEK 3/4 3-7 Amendment No. 206 ITS 3.3.1.1 ITS A01 TABLE 4.3.1.1-1 REACTOR PROTECTION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS FUNCTIONAL UNIT CHANNEL CHECK (m)

CHANNEL FUNCTIONAL TEST (m)

CHANNEL CALIBRATION (a)(m)

OPERATIONAL CONDITIONS FOR WHICH SURVEILLANCE REQUIRED

1. Intermediate Range Monitors:

a. Neutron Flux - High (b) 2 3, 4, 5

b. Inoperative NA NA 2, 3, 4, 5

2. Average Power Range Monitor(f):

a. Neutron Flux - Upscale (Setdown)

(b)

(l)

(n), (o) 2

b. Simulated Thermal Power-Upscale (g)

(e)

(d) (g) (n), (o) 1

c. Neutron Flux - Upscale (d) (n), (o) 1

d. Inoperative NA NA 1, 2

e. 2-Out-Of-4 Voter NA 1, 2

f. OPRM Upscale (e)

(g) 19% RTP

3. Reactor Vessel Steam Dome Pressure - High (k) 1, 2

4. Reactor Vessel Water Level -

Low, Level 3 (k) 1, 2

5. Main Steam Line Isolation Valve - Closure NA 1

6. This item intentionally blank

7. Drywell Pressure - High (k) 1, 2 APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS SR 3.3.1.1.1 SR 3.3.1.1.4 SR 3.3.1.1.5 SR 3.3.1.1.8 L03 (c)

L03 L04 Function 1.a Function 3 Function 2.a Function 6 Function 1.b Function 2.b Function 2.c Function 2.d Function 2.e Function 2.f Function 4 Function 5 (c) 6 A08 LA08 LA08 (a)(b)

(a)(b)

(l)

L10 (a)(b)

(a)(b)

M03 M03 M03 (a)(b)

M03 SR 3.3.1.1.3 SR 3.3.1.1.3 S2 S2

HOPE CREEK 3/4 3-8 Amendment No. 206 ITS 3.3.1.1 ITS A01 TABLE 4.3.1.1-1 (Continued)

REACTOR PROTECTION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS FUNCTIONAL UNIT CHANNEL CHECK (m)

CHANNEL FUNCTIONAL TEST (m)

CHANNEL CALIBRATION (m)

OPERATIONAL CONDITIONS FOR WHICH SURVEILLANCE REQUIRED

8.

Scram Discharge Volume Water Level - High:

a.

Float Switch NA 1, 2, 5(j)

b.

Level Transmitter/ Trip Unit (k) 1, 2, 5(j)

9.

Turbine Stop Valve -

Closure NA 1

10. Turbine Control Valve Fast Closure Valve Trip System Oil Pressure - Low NA 1

11. Reactor Mode Switch Shutdown Position NA NA 1, 2, 3, 4, 5

12. Manual Scram NA NA 1, 2, 3, 4, 5 (a)

Neutron detectors may be excluded from CHANNEL CALIBRATION.

(b)

The IRM and SRM channels shall be determined to overlap for at least 1/2 decades during each startup after entering OPERATIONAL CONDITION 2 and the IRM and APRM channels shall be determined to overlap for at least 1/2 decades during each controlled shutdown, if not performed within the previous 7 days.

(c)

DELETED (d)

This calibration shall consist of the adjustment of the APRM channel to conform to the power values calculated by a heat balance during OPERATIONAL CONDITION 1 when THERMAL POWER 24% of RATED THERMAL POWER. Adjust the APRM channel if the calculated power exceeds the APRM output by greater than 2% of RATED THERMAL POWER.

(e)

The CHANNEL FUNCTIONAL TEST includes the recirculation flow input function, excluding the flow transmitters.

(f)

The LPRMs shall be calibrated in accordance with the Surveillance Frequency Control Program.

(g)

Calibration includes the flow input function.

(h)

Deleted.

(i)

This item intentionally blank (j)

With any control rod withdrawn. Not applicable to control rods removed per Specification 3.9.10.1 or 3.9.10.2.

(k)

Verify the trip setpoint of the trip unit in accordance with the Surveillance Frequency Control Program.

(l)

Not required to be performed when entering OPERATIONAL CONDITION 2 from OPERATIONAL CONDITION 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering OPERATIONAL CONDITION 2.

(m)

Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.

SR 3.3.1.1.3 Note 1 to SR 3.3.1.1.8 Note to SR 3.3.1.1.11 are SR 3.3.1.1.2 and NOTE Compare the average power range monitor (APRM) channels to the calculated power. Adjust the APRM channels if the calculated power exceeds the APRM output by more than 2% RTP while operating at 24% RTP.

NOTE--------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after L09 SR 3.3.1.1.6 Table 3.3.1.1-1 footnote (c)

A13 Table 3.3.1.1-1 footnote (c)

SR 3.3.1.1.4 NOTE L03 L04 For Function 1.a, 1.b, and 2.a, MODE A08 (c)

(c) 7 10 9

8 11 Function 7 Function 8 Function 9 Function 10 Function 11 (c)

L03 L03 (c) from a cell containing one or more fuel assemblies L03 LA08 SR 3.3.1.1.7 APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS A08 (b)

(a)

L10 Add SR 3.3.1.1.8, Note 2 LA09 M03 (a)(b)

S2 Calibrate the flow input function to the APRM Simulated Thermal Power - Upscale and Oscillation Power Range Monitor - Upscale Functions.

S2

A14 S2

DISCUSSION OF CHANGES ITS 3.3.1.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Hope Creek Page 5 of 19 to accommodate the water from a full core scram. This is an acceptable change because the ITS includes this type of allowance in the ITS Section 3.10, Special Operations, LCOs. ITS LCO 3.0.7 adequately prescribes the use of Special Operations LCOs; therefore, cross referencing serves no functional purpose.

This change is designated as administrative because it does not result in a technical change to the CTS.

A14 CTS Table 4.3.1.1-1, Function (g), which applies to the Channel Calibration of Functions 2.b (Simulated Thermal Power - Upscale) and 2f (OPRM Upscale),

states that the calibration includes the flow input function. The ITS presentation presents the calibration of the flow input function as a separate Surveillance (ITS SR 3.3.1.1.3). This changes the CTS by presenting a separate Surveillance Requirement to calibrate the flow input function of the specified RPS Functions instead of modifying the instrument Channel Calibration requirement. Calibration of the flow input function replaced the requirement to adjust the APRM flow biased channel to conform to a calibrated flow signal in License Amendment 206, dated August 4, 2017 (NRC ADAMS Accession No. ML17216A022). The Frequency for ITS SR 3.3.1.1.3, which is consistent with the respective Channel Calibrations of the APRM Simulated Thermal Power - Upscale and Oscillation Power Range Monitor - Upscale Functions, is not changed and will continue to be controlled in accordance with the Surveillance Frequency Control Program.

This change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

A15 CTS Table 4.3.1.1-1, Footnote (o), states, in part, that the methodologies used to determine the as-found and the as-left tolerances are specified in the associated Technical Specification Bases. ITS Table 3.3.1.1-1, Footnote (b), includes a similar requirement but states that the methodologies used to determine the as-found and the as-left tolerances are specified in the Technical Requirements Manual (TRM) and Updated Final Safety Analysis Report (UFSAR), respectively.

This is an administrative change preference to the CTS to be consistent with the ISTS.

Change control for the Technical Specification Bases are pursuant to requirements of 10 CFR 50.59, via the Technical Specification Bases Control Program specified in CTS 6.15 (ITS Section 5.5). Change control for the TRM and UFSAR is also pursuant to requirements of 10 CFR 50.59. Therefore, this change is designated as administrative and is acceptable because it does not result in a technical change to the CTS.

A16 CTS 2.2.1 ACTION specifies actions for RPS instrumentation channels with setpoints not within limits. This Action states, in part, that with a trip setpoint less conservative than the value shown in the Allowable Values column of CTS Table 2.2.1-1, to declare the channel inoperable until the channel is restored to an OPERABLE status. ITS 3.3.1.1 does not contain this statement. This changes the CTS by eliminating a specific condition on the actions required when an instrument's trip setpoint is not within the Allowable Value.

The purpose of the CTS 2.2.1 ACTION is to ensure channels with setpoints outside the Allowable Value are declared inoperable and appropriate Action S2

DISCUSSION OF CHANGES ITS 3.3.1.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Hope Creek Page 12 of 19 methods of surveillance test performance, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to how the Surveillance Requirement is met for individual Functions is being removed from the Technical Specifications.

LA09 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 3.3.1-1, Footnote (e) requires a CHANNEL FUNCTIONAL TEST of the flow input to Average Power Range Monitor (APRM)

Functions 2.b (Simulated Thermal Power - Upscale) and 2.f (OPRM Upscale).

The CHANNEL FUNCTIONAL TEST is also required by ITS SR 3.3.1.1.5; however, the ITS SR does not include the CTS Table 3.3.1-1, Footnote (e) requirement for inclusion of the recirculation flow input. This changes the CTS by moving the detail referencing the recirculation flow input to the Bases.

The purpose of the CHANNEL FUNCTIONAL TEST is to ensure that the entire channel will perform the intended Function. The removal of these details, related to methods of surveillance test performance, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to how the Surveillance Requirement is met for individual Functions is being removed from the Technical Specifications.

LA10 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 2.2.1 requires the RPS instrumentation setpoints to be set consistent with the Trip Setpoint values shown in Table 2.2-1.

However, the CTS 2.2.1 Action is only required to be taken when the setpoint is less conservative than the Allowable Value column of Table 2.2-1. When the setpoint is less conservative than the Allowable Value, the channel is to be declared inoperable and adjusted consistent with the Trip Setpoint value. CTS Table 2.2-1 specifies both the Trip Setpoints and Allowable Values for the RPS Instrumentation Functional Units. ITS 3.3.1 requires the RPS instrumentation for each Function in Table 3.3.1.1-1 to be OPERABLE. ITS Table 3.3.1.1-1 specifies only the Allowable Values for the RPS Instrumentation Functions. The Allowable Values represent the OPERABILITY limit of the channels in ITS. This changes the CTS by moving the Trip Setpoints and requirements to adjust the Trip Setpoints (when necessary) to the TRM.

S2

RPS Instrumentation 3.3.1.1 General Electric BWR/4 STS 3.3.1.1-4 Rev. 5.0 CTS Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.2

NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER 25% RTP.

Compare the average power range monitor (APRM) channels to the calculated power. Adjust the APRM channels if the calculated power exceeds the APRM output by more than 2% RTP while operating at 25% RTP.

[ 7 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.1.1.3 Adjust the channel to conform to a calibrated flow signal.

[ 7 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.1.1.4

NOTE------------------------------

Not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

Perform CHANNEL FUNCTIONAL TEST.

[ 7 days OR In accordance with the Surveillance Frequency Control Program ]

Table 4.3.1.1-1 Footnote (m)

Table 4.3.1.1-1 Footnote (d)

Table 4.3.1.1-1 Footnote (m) 24 24 For Functions 1.a, 1.b, and 2.a, not Table 4.3.1.1-1 Footnote (l)

DOC L10 1

2 2

1 2

2 Table 4.3.1.1-1 Footnote (g)

DOC A14 Table 4.3.1.1-1 Footnote (m) 1 DOC L09 4.3.1.1 Calibrate the flow input function to the APRM Simulated Thermal Power - Upscale and Oscillation Power Range Monitor - Upscale Functions.

S2 4

RPS Instrumentation 3.3.1.1 General Electric BWR/4 STS 3.3.1.1-8 Rev. 5.0 CTS Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.14 Verify Turbine Stop Valve - Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure - Low Functions are not bypassed when THERMAL POWER is [30]% RTP.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.1.1.15

NOTE[S]---------------------------

[1.] Neutron detectors are excluded.

[2. For Function 5 "n" equals 4 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.]

Verify the RPS RESPONSE TIME is within limits.

[ [18] months on a STAGGERED TEST BASIS OR In accordance with the Surveillance Frequency Control Program ]

24 10 11 2

2 1

1 2

2 2

4.3.1.3 Table 3.3.1-1 Notation (j)

DOC M02 1

S2

JUSTIFICATION FOR DEVIATIONS ITS 3.3.1.1, REACTOR PROTECTIONS SYSTEM (RPS) INSTRUMENTATION Hope Creek Page 1 of 1

1.

Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2.

The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.

3.

ISTS SR 3.3.1.1.12, which is applicable to ITS Table 3.3.1.1-1, Function 2.b (Average Power Range Monitor (APRM) Simulated Thermal Power-Upscale),

requires a verification that the APRM Flow Biased Simulated Thermal Power - High time constant is 7 seconds with a Frequency specified in accordance with the Surveillance Frequency Control Program (SFCP). The Hope Creek Generating Station (HCGS) current Technical Specifications (CTS) do not contain this Surveillance as it was removed in Amendment 206 of the CTS (reference NRC letter dated August 4, 2017, "Hope Creek Generating Station - Issuance of Amendment Regarding Digital Power Range Neutron Monitoring System Upgrade (CAC No. MF6768)," ADAMS Accession No. ML17216A022).

Removal of this test requirement was based on NRC-approved General Electric-Hitachi (GEH) Licensing Topical Report (LTR) NEDC-32410P-A, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM)

Retrofit Plus Option III Stability Trip Function," Volumes 1 and 2, including Supplement 1, referred to collectively as the Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) LTR. Subsequently, ISTS SR 3.3.1.1.12 is not included in the HCGS Improved Technical Specifications (ITS).

4.

ISTS SR 3.3.1.1.3 is revised in ITS SR 3.3.1.1.3 to require calibration of the flow input signal to the APRM Simulated Thermal Power - Upscale and Oscillation Power Range Monitor - Upscale Functions. This change is consistent with the current calibration requirement (Current Technical Specification Table 4.3.1.1-1 Footnote (g)) approved in License Amendment 206, dated August 4, 2017 (NRC ADAMS Accession No. ML17216A022). As described in the safety evaluation associated with License Amendment 206, the analog LPRM signal processing electronics, LPRM averaging, APRM trip electronics, and LPRM detector power supply hardware and recirculation flow signal processing electronics were replaced by an integrated digital NUMAC chassis-based APRM electronics. License Amendment 206 eliminated the requirement to adjust the APRM flow biased channel to conform to a calibrated flow signal and replaced it with the requirement to include the flow input function in the instrument calibration.

S2

RPS Instrumentation B 3.3.1.1 General Electric BWR/4 STS B 3.3.1.1-26 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

A restriction to satisfying this SR when < 25% RTP is provided that requires the SR to be met only at 25% RTP because it is difficult to accurately maintain APRM indication of core THERMAL POWER consistent with a heat balance when < 25% RTP. At low power levels, a high degree of accuracy is unnecessary because of the large, inherent margin to thermal limits (MCPR and APLHGR). At 25% RTP, the Surveillance is required to have been satisfactorily performed in accordance with SR 3.0.2. A Note is provided which allows an increase in THERMAL POWER above 25% if the Frequency is not met per SR 3.0.2. In this event, the SR must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reaching or exceeding 25% RTP. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR.

SR 3.3.1.1.3 The Average Power Range Monitor Flow Biased Simulated Thermal Power - High Function uses the recirculation loop drive flows to vary the trip setpoint. This SR ensures that the total loop drive flow signals from the flow unit used to vary the setpoint are appropriately compared to a calibrated flow signal and, therefore, the APRM Function accurately reflects the required setpoint as a function of flow. Each flow signal from the respective flow unit must be 105% of the calibrated flow signal. If the flow unit signal is not within the limit, the APRMs that receive an input from the inoperable flow unit must be declared inoperable.

[ The Frequency of 7 days is based on engineering judgment, operating experience, and the reliability of this instrumentation.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

24 3

1 2

1 Upscale and OPRM - Upscale s

Recirculation flow signal processing is provided by the integrated digital Nuclear Measurement Analysis and Control (NUMAC) chassis based APRM electronics. This SR ensures the recirculation flow input function is calibrated along with the CHANNEL CALIBRATION for these RPS Functions.

6 S2

JUSTIFICATION FOR DEVIATIONS ITS 3.3.1.1 BASES, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Hope Creek Page 1 of 1

1.

Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2.

The Improved Standard Technical Specifications (ISTS) contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.

3.

The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

4.

RPS parameter assumptions and any sensor diversity, if provided, to initiate a scram are described in the anticipated operating transient analyses and unnecessary to be defined in the ITS Bases to ensure compliance with the Technical Specification requirements. Any changes to the analysis assumptions are evaluated pursuant the criteria specified in 10 CFR 50.59 and other applicable regulatory requirements. Typical diversity summarized in Table B 3.3.1.1-1 are not appropriate for the plant specific ITS Bases and, thus, is deleted.

5.

The Hope Creek Generating Station (HCGS) current Technical Specifications (CTS) exclude the sensors of the Reactor Vessel Steam Dome Pressure - High Functional Unit (Improved Technical Specification (ITS) Table 3.3.1.1-1, Function 3) and the Reactor Vessel Water Level - Low, Level 3 Functional Unit (ITS Table 3.3.1.1-1, Function 4) from response time testing for RPS circuits. These sensor response time testing requirements were eliminated based upon NEDO-32291, "System Analyses for Elimination of Selected Response Time Testing Requirements," as approved by the NRC and documented in letter to R.A. Pinelli from Bruce A. Boger, dated December 28, 1994. Therefore, the related discussion in the Bases for ISTS SR 3.3.1.1.15 (ITS SR 3.3.1.1.11) is not included in the ITS.

6.

ISTS SR 3.3.1.1.3 is revised in ITS SR 3.3.1.1.3 to require calibration of the flow input signal to the APRM Simulated Thermal Power - Upscale and Oscillation Power Range Monitor - Upscale Functions. This change is consistent with the current calibration requirement (Current Technical Specification Table 4.3.1.1-1 Footnote (g)) approved in License Amendment 206, dated August 4, 2017 (NRC ADAMS Accession No. ML17216A022). Bases are provided for ITS SR 3.3.1.1.3 to support the change to the Specification.

S2

EOC-RPT Instrumentation B 3.3.4.1 General Electric BWR/4 STS B 3.3.4.1-15 Rev. 5.0 1

Hope Creek Revision XXX BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.4.1.6 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The EOC-RPT SYSTEM RESPONSE TIME acceptance criteria are included in Reference 7.

A Note to the Surveillance states that breaker interruption time may be assumed from the most recent performance of SR 3.3.4.1.7. This is allowed since the time to open the contacts after energization of the trip coil and the arc suppression time are short and do not appreciably change, due to the design of the breaker opening device and the fact that the breaker is not routinely cycled.

Response times cannot be determined at power because operation of final actuated devices is required. [ Therefore, the 18 month Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components that cause serious response time degradation, but not channel failure, are infrequent occurrences.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.3.4.1.7 This SR ensures that the RPT breaker interruption time (arc suppression time plus time to open the contacts) is provided to the EOC-RPT SYSTEM RESPONSE TIME test. [ The 60 month Frequency of the testing is based on the difficulty of performing the test and the reliability of the circuit breakers.

OR 5

6 1

3 2

1 2

6 1

1 S2

ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-10 Rev. 5.0 Hope Creek Amendment XXX 1

CTS Table 3.3.5.1-1 (page 1 of 8)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

1. Core Spray System

a.

Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3

[4](a)

B SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6 SR 3.3.5.1.7

[-113] inches

b.

Drywell Pressure -

High 1, 2, 3

[4](a)

B SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6 SR 3.3.5.1.7

[1.92] psig

c.

Reactor Steam Dome Pressure - Low (Injection Permissive) 1, 2, 3

[4]

C SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3]

SR 3.3.5.1.5 SR 3.3.5.1.6 SR 3.3.5.1.7

[390] psig and

[500] psig (a)

Also required to initiate the associated [diesel generator (DG) and isolate the associated plant service water (PSW) turbine building (T/B) isolation valves].

(b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

Table 3.3.3-1 Table 3.3.3-2 Table 4.3.3.1-1 Table 3.3.3-1 Table 3.3.3-2 Table 4.3.3.1-1 Function 1.a DOC A10 4.3.3.3 Table 3.3.3-1 Table 3.3.3-2 Table 4.3.3.1-1 Function 1.b DOC A10 4.3.3.3 Table 3.3.3-1 Table 3.3.3-2 Table 4.3.3.1-1 Function 1.c DOC A10 4.3.3.3 8

emergency diesel generator 8

8 Table 3.3.3-1 Footnote (b)

N N

Nominal N

-136 1.88 481 441 4

4 4

the Technical Requirements Manual and Updated Final Safety Analysis Report, respectively DOC M01 DOC M01 1

1 1

2 2

5 5

5 S2

ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-13 Rev. 5.0 Hope Creek Amendment XXX 1

CTS Table 3.3.5.1-1 (page 4 of 8)

Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

2. LPCI System

[ g. Low Pressure Coolant Injection Pump Discharge Flow - Low Bypass) 1, 2, 3

[4]

[1 per pump]

E SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6

[ ] gpm and

[ ] gpm ]

[ h. Manual Initiation 1, 2, 3

[2]

[1 per subsystem]

C SR 3.3.5.1.6 NA ]

3. High Pressure Coolant Injection (HPCI) System

a.

Reactor Vessel Water Level - Low Low, Level 2 1, 2(e), 3(e)

[4]

B SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6 SR 3.3.5.1.7

[ -47] inches

b.

Drywell Pressure -

High 1, 2(e), 3(e)

[4]

B SR 3.3. 5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6 SR 3.3.5.1.7

[1.92] psig

c.

Reactor Vessel Water Level - High, Level 8 1, 2(e), 3(e)

[2]

C SR 3.3.5.1.1 SR 3.3.5.1.2

[SR 3.3.5.1.3](b)(c)

SR 3.3.5.1.5(b)(c)

SR 3.3.5.1.6 SR 3.3.5.1.7

[56.5] inches (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(e)

With reactor steam dome pressure > [150] psig.

Table 3.3.3-1 Table 3.3.3-2 Table 4.3.3.1-1 Function 2.d

(

Table 3.3.3-1 Table 4.3.3.1-1 Function 2.f DOC A09 Table 3.3.3-1 Table 3.3.3-2 Table 4.3.3.1-1 Function 3.a 4.3.3.3 Table 3.3.3-1 Table 3.3.3-2 Table 4.3.3.1-1 Function 3.b 4.3.3.3 Table 3.3.3-1 Table 3.3.3-2 Table 4.3.3.1-1 Function 3.e d

d d

4 d

f e

200 N

N Nominal N

1.88 1100

-45 61 4

3 4

4 4

4 the Technical Requirements Manual and Updated Final Safety Analysis Report, respectively DOC M01 DOC M01 1

1 1

1 2

2 2

2 1

2 4

3 5

5 S2 4

S2

JUSTIFICATION FOR DEVIATIONS 3.3.5.1, EMERGENCY CORE COOLING SYSTEM (ECCS) INSTRUMENTATION Hope Creek Page 1 of 1

1.

Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2.

The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3.

The reactor steam dome pressure in the Applicability for the Automatic Depressurization System instrumentation of ITS 3.3.5.1 is revised to 200 psig to be consistent with Applicability of the High Pressure Coolant Injection (HPCI) System specified in ITS 3.5.1, "ECCS - Operating." This change meets the intent of the ISTS and the HCGS current Technical Specifications and ITS ACTION requirements that the Applicability of HCPI and Reactor Core Isolation Cooling systems be equivalent.

4.

ISTS SR 3.3.5.1.7 (ITS SR 3.3.5.1.5), which requires verifying the ECCS RESPONSE TIME is within limits, is not applicable to the HPCI Reactor Vessel Water Level - High, Level 8 Function (ITS Table 3.3.5.1-1, Function 3.e, ISTS Function 3.c)) consistent with the current HCGS licensing basis as shown in the UFSAR. The HPCI System response time value provided in UFSAR Table 7.3-17 is associated with only HPCI System initiation. This change is acceptable since the ISTS is changed to reflect the current licensing basis.

S2

Primary Containment Isolation Instrumentation 3.3.6.1 General Electric BWR/4 STS 3.3.6.1-2 Rev. 5.0 CTS Hope Creek Amendment XXX 1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more automatic Functions with isolation capability not maintained.

B.1 Restore isolation capability.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C. Required Action and associated Completion Time of Condition A or B not met.

C.1 Enter the Condition referenced in Table 3.3.6.1-1 for the channel.

Immediately D. As required by Required Action C.1 and referenced in Table 3.3.6.1-1.

D.1 Isolate associated main steam line (MSL).

OR D.2.1 Be in MODE 3.

AND D.2.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. As required by Required Action C.1 and referenced in Table 3.3.6.1-1.

E.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months F. As required by Required Action C.1 and referenced in Table 3.3.6.1-1.

F.1 Isolate the affected penetration flow path(s).

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months G. As required by Required Action C.1 and referenced in Table 3.3.6.1-1.

G.1 Isolate the affected penetration flow path(s).

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Table 3.3.2-1 ACTIONS 20 and 21 DOC L04 ACTION b.1.a ACTION c.1 ACTION c.2a.1 ACTION b.2 ACTION c.2.b Table 3.3.2-1 ACTION 22 Table 3.3.2-1 Action 27 and Functional Unit 1.c Action 28 DOC L06 Table 3.3.2-1 ACTIONS 24 and 25 DOC L03 for Functions other than Function 2.d AND 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for Function 2.d 1

S2

Insert Page 3.3.6.1-8 INSERT 1 a.2 Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3 2

H SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4

-136.0 inches INSERT 2 a.2 HPCI Steam Line Flow - High, Timer 1, 2, 3 1

F SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 3.0 secs and 13.0 secs Table 3.3.2-1 Table 4.3.2.1-1 Function 6.b 1

1 Table 3.3.2-1 Table 4.3.2.1-1 Function 1.a.2 CTS ITS 3.3.6.1 S2

Insert Page 3.3.6.1-10 INSERT 3 a.2 RCIC Steam Line Flow - High, Timer 1, 2, 3 1

F SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 3.0 secs and 13.0 secs Table 3.3.2-1 Table 4.3.2.1-1 Function 5.b CTS 1

ITS 3.3.6.1 S2

Insert Page 3.3.6.1-11 INSERT 4 a.2 Differential Flow -

High, Timer 1, 2, 3 1

F SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 45.0 secs and 47.0 secs Table 3.3.2-1 Table 4.3.2.1-1 Function 4.b CTS 1

ITS 3.3.6.1 S2

DISCUSSION OF CHANGES ITS 3.3.7.1, CONTROL ROOM EMERGENCY FILTRATION (CREF) SYSTEM INSTRUMENTATION Hope Creek Page 3 of 10 ITS LCO 3.0.3 requires, when the LCO and the associated ACTIONS are not met, within one hour, place the unit in MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months and MODE 4 with 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . ITS 3.3.7.1, Required Action B.2, ensures affected CREF subsystems are declared inoperable when inoperable actuation instrumentation is not restored within the specified Completion Time and the control room has not (or cannot) be placed in the pressurization mode of operation. ITS 3.3.7.1, Required Action B.2, in turn, would require entry into the applicable Conditions and Required Actions of ITS 3.7.4, "Control Room Emergency Filtration (CREF)

System." With the elimination of the provision that LCO 3.0.3 is not applicable, entry into LCO 3.0.3 will now be required upon failure to meet all applicable ACTIONS of ITS 3.3.7.1. This change is designated as more restrictive because an allowance to consider Specification 3.0.3 as not applicable is removed.

M03 CTS Table 3.3.7.1-1, Action 71.a, requires the control room to be placed in the pressurization mode of operation within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if an inoperable Control Room Air Inlet Radiation - High channel is not restored to an OPERABLE status within 7 days. ITS 3.3.7.1, Required Action B.1, requires the control room to be placed in the pressurization mode of operation within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months if an inoperable Control Room Air Inlet Radiation - High channel is not restored to an OPERABLE status within 7 days. This changes the CTS by reducing the time to place the control room in the pressurization mode of operation from 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The purpose of this portion of CTS 3.3.7.1, Table 3.3.7.1-1, Action 71.a, is to ensure the CREF System is placed in the accident configuration when specific actuation channels are inoperable for an extended period of time. Reducing the time to place the control room in the pressurization mode of operation from 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable since 7 days are provided for restoration of the inoperable channel, providing operators ample time to prepare for the transition to the pressurization mode of operation. This change is designated as more restrictive because the Completion Time for placing the control room in the pressurization mode of operation has been reduced.

RELOCATED SPECIFICATIONS R01 CTS Table 3.3.7.1-1 includes requirements for the New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Monitors (Functions 2.a.1 and 2.a.2). These requirements are relocated to the Technical Requirements Manual (TRM).

New fuel storage vault and spent fuel storage pool area criticality monitors are provided to detect excessive radiation levels as an indication of criticality. There are no automatic functions that are performed by these instruments. The instruments are not used to mitigate a design basis accident (DBA) or transient.

10 CFR 70.24 and 10 CFR 50.68 govern criticality accident requirements.

10 CFR 70.24(d)(1) and 10 CFR 50.68(a) allow for the holder of an operating license to comply with either 10 CFR 70.24(a) through (c) or 10 CFR 50.68(b).

Hope Creek complies with 10 CFR 50.68(b) in lieu of maintaining monitoring systems as described in 10 CFR 70.24. The design of the new fuel storage vault and spent fuel storage pool provide a margin to criticality pursuant to 10 CFR 50.68(b) precluding criticality.

S2 S2

RPS Electric Power Monitoring 3.3.8.2 General Electric BWR/4 STS 3.3.8.2-3 Rev. 5.0 CTS Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.8.2.2 Perform CHANNEL CALIBRATION. The Allowable Values shall be:

a. Overvoltage [132] V.

b. Undervoltage [108] V, with time delay set to

[zero].

c.

Underfrequency [57] Hz, with time delay set to

[zero].

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

SR 3.3.8.2.3 Perform a system functional test.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

4.8.4.4.b 1st part 4.8.4.4.b 2nd part 4.8.4.4.b 1 DOC M01 4.8.4.4.b 2 DOC M01 4.8.4.4.b 3 2

2 112.6 V (Bus A) and 113.7 V (Bus B) 128.7 1

S2

ECCS - Operating 3.5.1 General Electric BWR/4 STS 3.5.1-7 Rev. 5.0 Hope Creek Amendment XXX 1

CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.8

NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with [reactor pressure] [1020] and

[920] psig, the HPCI pump can develop a flow rate

[4250] gpm [against a system head corresponding to reactor pressure].

[ 92 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.5.1.9

NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with [reactor pressure] [165] psig, the HPCI pump can develop a flow rate [4250] gpm [against a system head corresponding to reactor pressure].

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

In accordance with the INSERVICE TESTING PROGRAM 4.5.1.b.3 Footnote **

DOC L06 4.5.1.b.3 4.5.1.c.2.a 5600 5600 2

1 2

6 7

4.5.1.c.2.a Footnote **

DOC L06 7

7 of 1000 psig of psig HPCI turbine inlet a

HPCI turbine inlet 215 a

S2

PCIVs 3.6.1.3 General Electric BWR/4 STS 3.6.1.3-12 Rev. 5.0 Hope Creek Amendment XXX 1

CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.12 Verify the combined leakage rate for all secondary containment bypass leakage paths is [ ] La when pressurized to [ ] psig.

In accordance with the Primary Containment Leakage Rate Testing Program ]

SR 3.6.1.3.13 Verify leakage rate through each MSIV is

[11.5] scfh when tested at [28.8] psig.

[In accordance with the Primary Containment Leakage Rate Testing Program]

SR 3.6.1.3.14 Verify combined leakage rate through hydrostatically tested lines that penetrate the primary containment is within limits.

In accordance with the Primary Containment Leakage Rate Testing Program SR 3.6.1.3.15 Verify each [ ] inch primary containment purge valve is blocked to restrict the valve from opening

> [50]%.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]

3.6.1.2.c 4.6.1.2.f 5

150 scfh DQG 250 scfh combined through all four main steam lines main steam line SR 3.6.1.3.13 Verify combined leakage rate through containment isolation valves which form the boundary for the long term seal of the feedwater lines is within limits.

In accordance with the Primary Containment Leakage Rate Testing Program 3.6.1.2.e 4.6.1.2.h 3.6.1.2.d 4.6.1.2.g 11 12 7

7 1

9 4

1 1

2 6

S2

ITS 3.7.1 ITS A01 PLANT SYSTEMS LIMITING CONDITION FOR OPERATION (continued)

ACTION: (Continued)

c.

In OPERATIONAL CONDITION 4 or 5 with the SACS subsystem, which is associated with safety related equipment required OPERABLE by Specification 3.5.2, having two SACS pumps or one heat exchanger inoperable, declare the associated safety related equipment inoperable and take the ACTION required by Specification 3.5.2.

d.

In OPERATIONAL CONDITION 5 with the SACS subsystem, which is associated with an RHR loop required OPERABLE by Specification 3.9.11.1 or 3.9.11.2, having two SACS pumps or one heat exchanger inoperable, declare the associated RHR system inoperable and take the ACTION required by Specification 3.9.11.1 or 3.9.11.2, as applicable.

e.

In OPERATIONAL CONDITION 4, 5, or **, with one SACS subsystem, which is associated with safety related equipment required OPERABLE by Specification 3.8.1.2, inoperable, realign the associated diesel generators within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to the OPERABLE SACS subsystem, or declare the associated diesel generators inoperable and take the ACTION required by Specification 3.8.1.2. The provisions of Specification 3.0.3 are not applicable.

f.

In OPERATIONAL CONDITION 4, 5, or **, with only one SACS pump and heat exchanger and its associated flowpath OPERABLE, restore at least two pumps and two heat exchangers and associated flowpaths to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or, declare the associated safety related equipment inoperable and take the associated ACTION requirements.

SURVEILLANCE REQUIREMENTS 4.7.1.1 At least the above required safety auxiliaries cooling system subsystems shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve in the flow path that is not locked, sealed or otherwise secured in position, is in its correct position.

b.

In accordance with the Surveillance Frequency Control Program by verifying that:

1) Each automatic valve servicing safety-related equipment actuates to its correct position on the appropriate test signal(s), and 2) Each pump starts automatically when its associated diesel generator automatically starts.

HOPE CREEK 3/4 7-2 Amendment No. 187 SR 3.7.1.1 SR 3.7.1.2 SR 3.7.1.3 LA02 Verify each SACS EDG SACS manual, power operated, and automatic valve A01 SACS subsystem A01 M01

NOTE---------------

Isolation of flow to individual components does not render SACS inoperable.

A07 SR 3.7.1.1 Note L05 S2 e

an actual or simulated initiation

, except for valves that are locked, sealed, or otherwise secured in the actuated position L06 V

DISCUSSION OF CHANGES ITS 3.7.1, SAFETY AUXILIARIES COOLING SYSTEM (SACS)

Hope Creek Page 4 of 9 MORE RESTRICTIVE CHANGES M01 CTS 4.7.1.1 provides Surveillance Requirements for the SACS subsystems but does not include a specific Surveillance to verify the SACS pumps automatically start on an Emergency Core Cooling System (ECCS) initiation signal.

ITS SR 3.7.1.2 requires verifying each SACS subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position at a periodic Frequency in accordance with the Surveillance Frequency Program. This changes the CTS to include a specific automatic actuation test of each SACS subsystem.

The purpose of the Surveillance is to ensure the SACS subsystems actuate automatically on an actuation signal to perform the associated design functions.

The CTS definition of a LOGIC SYSTEM FUNCTIONAL TEST (CTS 1.22) includes the actuated device to verify OPERABILITY. In the ITS presentation, the ITS definition for LOGIC SYSTEM FUNCTIONAL TEST specified in ITS Section 1.1 does not include the actuated device, but rather, each applicable Specification provides a Surveillance Requirement verifying the required components automatically actuate on an actual or simulated initiation signal. Therefore, verification of subsystem actuation is specified in ITS 3.7.1 and includes verifying the SACS pumps start on an actual or simulated ECCS initiation signal. The addition of ITS SR 3.7.1.2 is appropriate and will ensure necessary testing is performed. HCGS controls periodic Frequencies for Surveillances in accordance with the Surveillance Frequency Control Program per CTS 6.8.4.j (ITS 5.5.13).

Currently, automatic start of the SACS pumps on an actual or simulated ECCS initiation signal is performed during EDG loss of power/LOCA testing. Therefore, ITS SR 3.7.1.2 will be performed at a Frequency in accordance with the Surveillance Frequency Control Program with an initial Frequency of 48 months, in anticipation of operation on a 24 month fuel cycle, and consistent with the Frequency of EDG loss of offsite power/LOCA testing. This change is designated as more restrictive because additional testing is included in the ITS than required in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.1.1 LCO contains a listing of components which comprise a SACS subsystem. ITS LCO 3.7.1 does not contain this detail. This changes the CTS by relocating the SACS subsystem design detail to the ITS Bases.

The purpose of the component listing in CTS LCO 3.7.1.1 is to describe the makeup of a SACS subsystem. The removal of this detail, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the S2

DISCUSSION OF CHANGES ITS 3.7.1, SAFETY AUXILIARIES COOLING SYSTEM (SACS)

Hope Creek Page 8 of 9 within the Technical Specifications to "immediately" initiate preparations for the shutdown, as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months provides ample time for such preparations, including sufficient time to perform a safe, controlled shutdown of the unit. Therefore, it is unnecessary to include the subject phrase in the ITS. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L05 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS 4.7.1.1.b.1 states, in part, actuates to its correct position on the appropriate test signal(s). ITS SR 3.7.1.2 states, in part, verify each SACS subsystem actuates on an actual or simulated initiation signal. This changes the CTS by allowing satisfactory actual automatic SACS subsystem initiation to be used to fulfill the SACS system functional surveillance requirement. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the tests.

The purpose of CTS 4.7.1.1.b.1 is to ensure each SACS subsystem actuates on a simulated automatic initiation signal. This change is acceptable because it has been determined that the current Surveillance Requirement acceptance criteria are not the only method that can be used for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L06 (Category 5 - Deletion of Surveillance Requirement) CTS 4.7.1.1.b requires verification that each SACS automatic valve servicing safety related equipment actuates to its correct position. ITS SR 3.7.1.2, in part, also requires verifying each SACS automatic valve servicing safety related systems actuates on an initiation signal except for components that are not locked, sealed, or otherwise secured in position. This changes the CTS by excluding those valves that are locked, sealed, or otherwise secured in position from the verification.

The purpose of the CTS Surveillance is to provide assurance that if an event occurred requiring SACS valves servicing safety related components to be in the correct position, then those requiring automatic actuation would actuate to the necessary isolated position. This change is acceptable because it is not necessary to verify each SACS valve can actuate to its correct position if the valve is already secured in the correct position. Automatic valves that are locked, sealed, or otherwise secured in position are not required to actuate on an actual or simulated initiation signal in order to perform the safety function because the valves are already in the required position. Testing such valves would not provide any additional assurance of OPERABILITY. Valves that are required to actuate will continue to be tested. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to provide confidence that the SACS can perform its assumed safety function. Surveillance testing associated with the SACS continues to be adequate to assure, pursuant S2 S2

DISCUSSION OF CHANGES ITS 3.7.1, SAFETY AUXILIARIES COOLING SYSTEM (SACS)

Hope Creek Page 9 of 9 to the requirements of 10 CFR 50.36(c)(3), that the necessary quality of the SACS is maintained, that facility operation will be within safety limits, and that the SACS LCO will be met. This change is designated as less restrictive because less stringent SR requirements are being applied in the ITS than were applied in the CTS.

S2

RHRSW System 3.7.1 General Electric BWR/4 STS 3.7.1-3 Rev. 5.0 SACS 1

CTS Hope Creek Amendment XXX 1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Both RHRSW subsystems inoperable for reasons other than Condition B.

E.1

NOTE--------------

Enter applicable Conditions and Required Actions of LCO 3.4.8 for [RHR shutdown cooling] made inoperable by RHRSW System.

Restore one RHRSW subsystem to OPERABLE status.

[8] hours F. Required Action and associated Completion Time of Condition E not met.

F.1 Be in MODE 3.

AND F.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

1 7

2 8

1 8

SACS SACS Action a.1.b Action a.2 Action 3.b Action a.4 4.7.1.1.a E

E 6

6 Action a.3.b Action a.4 SR 3.7.1.2 Verify each SACS subsystem actuates on an actual or simulated In accordance with the initiation signal, except for valves that are locked, sealed, or otherwise Surveillance Frequency secured in the actuated position.

Control Program SR 3.7.1.3 Verify each SACS pump starts automatically when associated In accordance with the EDG starts.

Surveillance Frequency Control Program 4.7.1.1.b.2 9

4.7.1.1.b.1 DOCM01 DOC L05 DOC L06

NOTE---------------

Isolation of flow to individual components does not render SACS inoperable.

servicing safety related systems or components DOC A07 D

OR One SACS subsystem inoperable for reasons other than Condition A or D.

OR E

S2

S2 S2

ITS 3.7.2 ITS A01 PLANT SYSTEMS LIMITING CONDITION FOR OPERATION (continued)

ACTION: (Continued)

b.

In OPERATIONAL CONDITION 4 or 5:

With only one station service water pump and its associated flowpath OPERABLE, restore at least two pumps with at least one flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or declare the associated SACS subsystem inoperable and take the ACTION required by Specification 3.7.1.1.

c.

In OPERATIONAL CONDITION *:

With only one station service water pump and its associated flowpath OPERABLE, restore at least two pumps with at least one flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or declare the associated SACS subsystem inoperable and take the ACTION required by Specification 3.7.1.1. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.7.1.2 At least the above required station service water system loops shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power operated or automatic), servicing safety related equipment that is not locked, sealed or otherwise secured in position, is in its correct position.

b.

In accordance with the Surveillance Frequency Control Program, by verifying that:

1.

Each automatic valve servicing non-safety related equipment actuates to its isolation position on an isolation test signal.

2.

Each pump starts automatically when its associated diesel generator automatically starts.

When handling recently irradiated fuel in the secondary containment.

HOPE CREEK 3/4 7-4 Amendment No. 187 SR 3.7.2.3 SR 3.7.2.5 A01 LA02 actual or simulated initiation EDG SR 3.7.2.4 Insert Note to SR Frequency of SR 3.7.2.4 and SR 3.7.2.5 LA02 SSWS subsystem L03 SSWS systems or components, in the flow paths

, and SSWS subsystem A01 A08

, except for valves that are locked, sealed, or otherwise secured in the actuated position L07 S2 M01

DISCUSSION OF CHANGES ITS 3.7.2, STATION SERVICE WATER SYSTEM (SSWS) AND ULTIMATE HEAT SINK (UHS)

Hope Creek Page 5 of 14 valves on an actual or simulated initiation signal. The addition of ITS SR 3.7.2.4 is appropriate and will ensure necessary testing is performed. HCGS controls periodic Frequencies for Surveillances in accordance with the Surveillance Frequency Control Program per CTS 6.8.4.j (ITS 5.5.13). Currently, automatic start of the SSWS pumps and automatic actuation of valves on an actual or simulated ECCS initiation signal is performed during EDG loss of power/LOCA testing. Therefore, ITS SR 3.7.2.4 will be performed at a Frequency in accordance with the Surveillance Frequency Control Program with an initial Frequency of 48 months, in anticipation of operation on a 24 month fuel cycle, consistent with the Frequency of EDG loss of offsite power/LOCA testing. This change is designated as more restrictive because additional components are required to be verified to actuate than required in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.1.2 LCO contains a listing of components which comprise a SSWS subsystem. ITS LCO 3.7.2 does not contain this detail. This changes the CTS by relocating the SSWS subsystem design detail to the ITS Bases.

The purpose of the component listing in CTS LCO 3.7.1.2 is to describe the makeup of a SSWS subsystem. The removal of this detail, which is related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to maintain two OPERABLE SSWS subsystems and, therefore, continues to include lowest functional capability or performance levels of equipment required for safe operation of the facility pursuant to the requirements of 10 CFR 50.36(c)(2). This change is also acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, UFSAR, ODCM, NQAP, CLRT Program, IST Program, or ISI Program) CTS LCO 3.7.1.2 and its Applicability, CTS 3.7.1.3 Applicability, along with Footnote *, and Actions b and c of both Specifications, require, in part, that the SSWS and UHS be OPERABLE in OPERATIONAL CONDITIONS 4, 5, and when handling recently irradiated fuel in the secondary containment. ITS 3.7.2 does not contain requirements for these OPERATIONAL CONDITIONS (MODES or other specified S2

DISCUSSION OF CHANGES ITS 3.7.2, STATION SERVICE WATER SYSTEM (SSWS) AND ULTIMATE HEAT SINK (UHS)

Hope Creek Page 13 of 14 SACS pump are powered from the same electrical power distribution subsystem).

This change is acceptable because LCO 3.0.6, ITS 5.5.9 (SFDP), and the Technical Specification ACTIONS of the supported systems ensure a plant shutdown will be required when warranted. LCO 3.0.6 allows the ACTIONS of the supported system LCOs to not be entered provided an evaluation of safety function is performed in accordance with the SFDP. When a SSWS pump and a SACS pump are inoperable concurrently, and LCO 3.0.6 is applied, ITS 5.5.9 requires, in part, cross division checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected. If a loss of safety function is determined to exist by the SFDP (e.g.,

inadequate cooling to three of six Filtration Recirculation Ventilation System recirculation units or inadequate cooling to both RHR suppression pool cooling subsystems), action will be required in the associated Technical Specification(s) where the loss of safety function exists (e.g., ITS 3.6.4.3, ACTION F or ITS 3.6.2.3 ACTION C) and a plant shutdown will be required, if applicable.

Therefore, LCO 3.0.6 and ITS 5.5.9 provide adequate controls to ensure appropriate action is performed when one SSWS pump and one SACS pump are inoperable concurrently with elevated UHS temperature.

Additionally, this change is offset by avoiding an unnecessary plant transient under extreme weather conditions when unit operation is needed to support grid stability. It is overly restrictive to require a plant shutdown with one inoperable SSWS pump concurrent with an inoperable SACS pump when UHS temperature is elevated if the associated cooling safety function can still be accomplished with the remaining SSWS/SACS components. Requiring a plant shutdown for this condition results in an unnecessary plant transient with no additional safety benefit.

ITS 3.7.1 and 3.7.2 ACTIONS, along with LCO 3.0.6, the SFDP, and the supported systems Technical Specification ACTIONS continue to provide appropriate remedial actions for an inoperable SSWS and SACS pump pursuant to the requirements of 10 CFR 50.36(c)(2)(i). This change is considered acceptable based on the considerations provided herein and it is not necessary to require a plant shutdown for an inoperable SACS and SSWS pump based on elevated UHS temperature in ITS 3.7.2 ACTIONS. This change is less restrictive because the plant shutdown requirement when an SSWS pump and a SACS pump are inoperable with UHS water temperature elevated has been deleted.

L07 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS 4.7.1.2.b.1 states, in part, actuates to its isolation position on an isolation test signal. ITS SR 3.7.2.4 states, in part, verify each SSWS subsystem actuates on an actual or simulated initiation signal. This changes the CTS by allowing satisfactory actual automatic SSWS subsystem initiation to be used to fulfill the SSWS system functional surveillance requirement. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the tests.

S2

DISCUSSION OF CHANGES ITS 3.7.2, STATION SERVICE WATER SYSTEM (SSWS) AND ULTIMATE HEAT SINK (UHS)

Hope Creek Page 14 of 14 The purpose of the CTS surveillance test is to ensure each SSWS subsystem actuates on an initiation signal. This change is acceptable because it has been determined that the current Surveillance Requirement acceptance criteria are not the only method that can be used for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

S2

[PSW] System and [UHS]

3.7.2 General Electric BWR/4 STS 3.7.2-6 Rev. 5.0 SSWS Hope Creek Amendment XXX 1

1 2

CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.2.5

NOTE------------------------------

Isolation of flow to individual components does not render [PSW] System inoperable.

Verify each [PSW] subsystem manual, power operated, and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.7.2.6 Verify each [PSW] subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

[ [18] months OR In accordance with the Surveillance Frequency Control Program ]

3 4

SSWS SSWS 4.7.1.2.a 4.7.1.2.b.1 DOC M01 DOC L03 DOC L07 SR 3.7.2.5 Verify each SSWS pump starts automatically when associated In accordance with the EDG starts.

Surveillance Frequency Control Program 5

4.7.1.2.b.2 1

1 2

1 S2

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

6.

Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.

7.

Verifying the pressure in all diesel generator air start receivers to be greater than or equal to 325 psig.

8.

Verifying the lube oil pressure, temperature and differential pressure across the lube oil filters to be within manufacturer's specifications.

b.

In accordance with the Surveillance Frequency Control Program by visually examining a sample of lube oil from the diesel engine to verify absence of water.

c.

In accordance with the Surveillance Frequency Control Program and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months by checking for and removing accumulated water from the fuel oil day tank.

d.

In accordance with the Surveillance Frequency Control Program by removing accumulated water from the fuel oil storage tanks.

e.

In accordance with the Surveillance Frequency Control Program by performing a functional test on the emergency load sequencer to verify operability.

f.

In accordance with the surveillance interval specified in the Diesel Fuel Oil Testing Program and prior to the addition of new fuel oil to the storage tank, samples shall be taken to verify fuel oil quality. Sampling and testing of new and stored fuel oil shall be in accordance with the Diesel Fuel Oil Testing Program contained in Specification 6.8.4.e.

HOPE CREEK 3/4 8-5 Amendment No. 187 See ITS 3.8.1 See ITS 3.8.1 SR 3.8.3.4 each required EDG is check for and remove each SR 3.8.3.5 properties are tested

, and maintained within the limits of, SR 3.8.3.3 A05 L03 L04 ITS A01 ITS 3.8.3 A05 A06 62

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 2 of 8 A04 CTS 3.8.1.1 and 3.8.1.2 Actions, in part, provide requirements to be taken for each inoperable EDG. ITS 3.8.3 ACTIONS include an explicit Note that states, "Separate Condition entry is allowed for each EDG." This Note provides instructions for the proper application of the ACTIONS for ITS compliance. This changes the CTS by providing explicit direction for using the ITS 3.8.3 ACTIONS when stored diesel fuel oil, diesel lube oil, and starting air subsystem parameters for an EDG are not within limits.

This change is acceptable because the addition of the Note reflects the CTS allowance to take appropriate Actions for each EDG. This change is designated as administrative since it does not result in a technical change to the CTS.

A05 CTS 4.8.1.1.2.f states, in part, in accordance with the Diesel Fuel Oil Testing Program contained in Specification 6.8.4.e, and prior to the addition of new fuel oil to the storage tank, samples shall be taken ITS SR 3.8.3.3 states, Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program. This changes the CTS by removing the text identifying where the Diesel Fuel Oil Testing Program is addressed in Technical Specifications and removing redundant frequency information (i.e., prior to the addition of new fuel oil to the storage tank) that is already stated in the administrative controls section (CTS 6.8.4.e) of the Technical Specifications.

This change is acceptable because the Diesel Fuel Oil Testing Program requirements remain unchanged and is a presentation preference consistent with the ISTS. This change is designated as administrative because it represents a presentation preference and does not represent a technical change to the CTS.

A06 CTS 4.8.1.1.2.a.7 requires verifying the pressure in all diesel generator air start receivers to be greater than or equal to 325 psig. ITS SR 3.8.3.4 requires verifying pressure in each required EDG air start receiver is 325 psig. This change clarifies the intent of the CTS Surveillance that, for all diesel generators, the pressure in the required air start receivers is within the limit.

At HCGS, the Air Starting System for each EDG consists of two independent air starting subsystems, each with adequate capacity for five (5) successive start attempts without recharging the air start receivers. This change is acceptable because it simply clarifies the intent of the existing requirement; only one air start subsystem is needed to support 5 successive EDG start attempts. This change is designated as administrative because it provides clarification to the existing requirement and does not represent a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 The CTS does not provide inventory requirements for EDG lube oil. ITS LCO 3.8.3, in part, requires lube oil to be within limits for each required EDG with associated Required Actions and Completion Times when outside these limits.

ITS Surveillance Requirement (SR) 3.8.3.2 requires verification that the lube oil inventory is a 7-day supply for each EDG. ITS 3.8.3 ACTIONS B and F provide Required Actions if the required EDG lube oil inventory is not within limits. This changes the CTS by adding limits for lube oil inventory in which Surveillance S2

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 General Electric BWR/4 STS 3.8.3-3 Rev. 5.0 CTS Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.2 Verify lube oil inventory is a [7] day supply.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.

In accordance with the Diesel Fuel Oil Testing Program SR 3.8.3.4 Verify each DG air start receiver pressure is

[225] psig.

[ 31 days OR In accordance with the Surveillance Frequency Control Program ]

SR 3.8.3.5 Check for and remove accumulated water from each fuel oil storage tank.

[ [31] days OR In accordance with the Surveillance Frequency Control Program ]

4.8.1.1.2.f 4.8.1.1.2.a.7 DOC A06 4.8.1.1.2.d 325 E

2 DOC M01 2

2 4

pressure in required 62

JUSTIFICATION FOR DEVIATIONS ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.

3. Hope Creek Generating Station (HCGS) was granted a deviation from the guidance in Regulatory Guide 1.137, Fuel-Oil Systems for Standby Diesel Generators, and Standard Review Plan Section 9.5.4, Paragraph I.1.d, as stated in UFSAR Section 1.8.1.137 and approved by License Amendments 59 (ADAMS Accession No. ML011770048) and 96 (ADAMS Accession No. ML011760565). ISTS SR 3.8.3.1 is revised in the ITS establishing a fuel oil inventory for each emergency diesel generator (EDG) consistent with the current technical specifications and adding a total combined onsite fuel oil storage inventory requirement to support continuous operation of at least three EDGs for 7 days in MODES 1, 2, and 3 and a 7 day supply for the required EDGs when not in MODE 1, 2, or 3. ISTS ACTION A is revised in the ITS to reflect the intent of the ISTS to allow operation of the EDGs with a reduced fuel oil inventory equivalent to approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to allow time to restore the required fuel oil inventory in the associated EDG following a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months EDG load run and circumstances caused by events such as:

a. Full load operation required for an inadvertent start while at minimum required level; or

b. Feed and bleed operations that may be necessitated by increased particulate levels or any number of other oil quality degradations.

4. As described in HCGS UFSAR Section 9.5.6.2, the Air Start System for each EDG consists of two independent air starting subsystems, each with adequate capacity for five (5) successive start attempts without recharging the air start receivers. Because only one air starting subsystem is needed to support five successive EDG start attempts, ISTS SR 3.8.3.4 is modified in ITS SR 3.8.3.4 to clarify that the air start pressure verification is for the required air start receiver for each EDG.

S1 S2

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 General Electric BWR/4 STS B 3.8.3-1 Rev. 5.0 Hope Creek Revision XXX 1

B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air BASES BACKGROUND Each diesel generator (DG) is provided with a storage tank having a fuel oil capacity sufficient to operate that DG for a period of [7] days while the DG is supplying maximum post loss of coolant accident (LOCA) load demand discussed in FSAR, Section [9.5.2] (Ref. 1) [and Regulatory Guide 1.137 (Ref. 2)]. The maximum load demand is calculated using the assumption that at least two DGs are available. This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.

Fuel oil is transferred from storage tank to day tank by either of two transfer pumps associated with each storage tank. Redundancy of pumps and piping precludes the failure of one pump, or the rupture of any pipe, valve, or tank to result in the loss of more than one DG. All outside tanks, pumps, and piping are located underground.

For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (Ref. 3). The fuel oil properties governed by these SRs are the water and sediment content, the kinematic viscosity, specific gravity (or API gravity),

and impurity level.

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions.

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. Each engine oil sump contains an inventory capable of supporting a minimum of [7] days of operation. [The onsite storage in addition to the engine oil sump is sufficient to ensure [7] days' continuous operation.] This supply is sufficient to allow the operator to replenish lube oil from outside sources.

Each DG has an air start system with adequate capacity for five successive start attempts on the DG without recharging the air start receiver(s).

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in FSAR, Chapter [6] (Ref. 4), and Chapter [15] (Ref. 5),

ANALYSES assume Engineered Safety Feature (ESF) systems are OPERABLE. The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF E

either U

4 three E

The emergency diesel generator (EDG) fuel oil storage and transfer system provides onsite storage for a period of at least 7 days of continuous operation for three of four EDGs Each EDG is provided with two separate storage tanks.

a tanks, the Each independent EDG fuel oil storage transfer system is completely enclosed in concrete, missile protected cells that are isolated from the other systems, except for the underground portion of the common supply line and the diesel fuel oil fill barge and truck connection. System components are in a Seismic Category I building.

E E

E Each EDG and its makeup tank contains an adequate supply of lube oil for the EDG to operate for a minimum of 7 days at maximum rated load.

two independent subsystems, each U

E E

1 2

2 2

In the event of a failure of an EDG fuel oil transfer pump, fuel oil can be transferred from either storage tank to the associated day tank by a single transfer pump provided both storage tanks are aligned to the single transfer pump.

its associated S2

REFUELING OPERATIONS 3/4.9.8 WATER LEVEL - REACTOR VESSEL LIMITING CONDITION FOR OPERATION 3.9.8 At least 22 feet 2 inches of water shall be maintained over the top of the reactor pressure vessel flange.

APPLICABILITY: During handling of fuel assemblies or control rods within the reactor pressure vessel while in OPERATIONAL CONDITION 5 when the fuel assemblies being handled are irradiated or the fuel assemblies seated within the reactor vessel are irradiated.

ACTION:

With the requirements of the above specification not satisfied, suspend all operations involving handling of fuel assemblies or control rods within the reactor pressure vessel after placing all fuel assemblies and control rods in a safe condition.

SURVEILLANCE REQUIREMENTS 4.9.8 The reactor vessel water level shall be determined to be at least at its minimum required depth within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to the start of and in accordance with the Surveillance Frequency Control Program during handling of fuel assemblies or control rods within the reactor pressure vessel.

HOPE CREEK 3/4 9-11 Amendment No. 193 3.9 3.9.6 Reactor Pressure Vessel (RPV) Water Level LCO 3.9.6 Applicability ACTION A SR 3.9.6.1 RPV level RPV movement irradiated fuel assemblies within the RPV, During movement of new handling of

RPV, RPV are A02 RPV water level not within limit.

movement and handling of RPV A01 ITS 3.9.6 ITS Verify RPV water level is 22 ft 2 inches above the top of the RPV flange.

L01 A01 above LA01 S2 S2

DISCUSSION OF CHANGES ITS 3.9.6, REACTOR PRESSURE VESSEL (RPV) WATER LEVEL Hope Creek Page 3 of 3 The purpose of the surveillance frequencies is to ensure the LCO requirement is met prior to and during performance of the specified activities. This change is acceptable because the requirement that RPV water level is 22 ft 2 inches above the top of the RPV flange throughout the applicable conditions is unchanged. Elimination of the requirement to perform this verification within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to the activity is not significant because the normal periodic Surveillance Frequency is established in the SFCP to provide adequate assurance that requirements are being met. If the Surveillance has been performed within the normal specified interval, reliance on the results is allowed since ITS SR 3.0.4 (CTS 4.0.4) requires only that a Surveillance be performed within the required Frequency prior to entering the applicable MODE or specified condition. The Frequency specified in the SFCP provides adequate assurance that the LCO requirements are satisfied. If any Surveillance has not been performed within this interval, handling of fuel assemblies or control rods within the reactor pressure vessel must be immediately suspended. This change is consistent with the ISTS and considered adequate, pursuant to the requirements of 10 CFR 50.36(c)(3), to ensure RPV water level is acceptable prior to and during movement of irradiated fuel assemblies or; during movement of new fuel assemblies or handling of control rods within the RPV when irradiated fuel assemblies are seated within the RPV. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

S2

[RPV] Water Level -[Irradiated Fuel]

3.9.6 General Electric BWR/4 STS 3.9.6-1 Rev. 5.0 Hope Creek Amendment XXX 1

2 3.9 REFUELING OPERATIONS 3.9.6

[Reactor Pressure Vessel (RPV)] Water Level - [Irradiated Fuel]

LCO 3.9.6

[RPV] water level shall be [23] ft above the top of the [RPV flange].

APPLICABILITY:

During movement of irradiated fuel assemblies within the [RPV],

[ During movement of new fuel assemblies or handling of control rods within the [RPV], when irradiated fuel assemblies are seated within the [RPV]. ]

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. [RPV] water level not within limit.

A.1 Suspend movement of fuel assemblies [and handling of control rods] within the

[RPV].

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify [RPV] water level is [23] ft above the top of the [RPV flange].

[ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Surveillance Frequency Control Program ]

CTS 2

22 ft 2 inches 22 ft 2 inches 2

2 2

2 3.9.8 3/4.9.8 Applicability Action 4.9.8 DOC L01 S2 S2

[RPV] Water Level - Irradiated Fuel B 3.9.6 General Electric BWR/4 STS B 3.9.6-2 Rev. 5.0 Hope Creek Revision XXX 1

2 BASES LCO A minimum water level of [23] ft above the top of the [RPV] flange is required to ensure that the radiological consequences of a postulated fuel handling accident are within acceptable limits, as provided by the guidance of Reference 3.

APPLICABILITY LCO 3.9.6 is applicable when moving [irradiated] fuel assemblies [or handling control rods (i.e., movement with other than the normal control rod drive)] within the [RPV]. The LCO minimizes the possibility of a fuel handling accident in containment that is beyond the assumptions of the safety analysis. [If irradiated fuel is not present within the [RPV], there can be no significant radioactivity release as a result of a postulated fuel handling accident.] Requirements for handling of new fuel assemblies or control rods (where water depth to the [RPV] flange is not of concern) are covered by LCO 3.9.7, "[RPV] Water Level - New Fuel or Control Rods."

Requirements for fuel handling accidents in the spent fuel storage pool are covered by LCO 3.7.8, "Spent Fuel Storage Pool Water Level."

REVIEWERS NOTE-----------------------------------

LCO 3.9.6 is written to cover new fuel and control rods as well as irradiated fuel. If a plant adopts LCO 3.9.7, however, the second bracketed portion of this Applicability is adopted in lieu of the first bracketed portion, and the LCO name and Required Action A.1 modified appropriately.

ACTIONS A.1 If the water level is < [23] ft above the top of the [RPV] flange, all operations involving movement of [irradiated] fuel assemblies [and handling of control rods] within the [RPV] shall be suspended immediately to ensure that a fuel handling accident cannot occur. The suspension of

[irradiated] fuel movement [and control rod handling] shall not preclude completion of movement of a component to a safe position.

SURVEILLANCE SR 3.9.6.1 REQUIREMENTS Verification of a minimum water level of [23] ft above the top of the [RPV]

flange ensures that the design basis for the postulated fuel handling accident analysis during refueling operations is met. Water at the required level limits the consequences of damaged fuel rods, which are postulated to result from a fuel handling accident in containment (Ref. 2).

[ The Frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is based on engineering judgment and is considered adequate in view of the large volume of water and the normal procedural controls on valve positions, which make significant unplanned level changes unlikely.

22 ft 2 inches 22 ft 2 inches 22 ft 2 inches 2

5 2

2 2

2 1

7 5

5 5

when moving new fuel assemblies or with irradiated fuel assemblies seated within the RPV 1

S2 S2 S2

REFUELING OPERATIONS 3/4.9.11 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.1 At least one shutdown cooling mode loop of the residual heat removal (RHR) system shall be OPERABLE and in operation* with:

a.

One OPERABLE RHR pump, and

b.

One OPERABLE RHR heat exchanger.

APPLICABILITY: OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is greater than or equal to 22 feet 2 inches above the top of the reactor pressure vessel flange and heat losses to ambient** are not sufficient to maintain OPERATIONAL CONDITION 5.

ACTION:

a.

With no RHR shutdown cooling mode loop OPERABLE, within one hour and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, demonstrate the operability of at least one alternate method capable of decay heat removal. Otherwise, suspend all operations involving an increase in the reactor decay heat load and establish SECONDARY CONTAINMENT INTEGRITY within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

b.

With no RHR shutdown cooling mode loop in operation, within one hour establish reactor coolant circulation by an alternate method and monitor reactor coolant temperature at least once per hour.

SURVEILLANCE REQUIREMENTS 4.9.11.1 At least one shutdown cooling mode loop of the residual heat removal system or alternate method shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

The shutdown cooling pump may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8-hour period.

Ambient losses must be such that no increase in reactor vessel water temperature will occur (even though REFUELING conditions are being maintained).

HOPE CREEK 3/4 9-17 Amendment No. 187 A01 ITS 3.9.7 ITS 3.9 3.9.7 Residual Heat Removal (RHR) - High Water Level LCO 3.9.7 RHR subsystem LA01 MODE with reactor pressure vessel (RPV)

RPV LCO 3.9.7 NOTE subsystem required RHR Applicability A03 LA02 Required subsystem inoperable ACTION A Add proposed Required Action B.2, B.3, B.4 A04 subsystem Verify an is available loading irradiated fuel assemblies into the RPV Required Action B.1 Required Action B.2, B.3, B.4 Condition C Required Action C.1, C.2 from discovery of no reactor coolant circulation Verify 1

Immediately Verify RHR subsystem is SR 3.9.7.1 A02 immediately 1

A04 M01 Insert Applicability NOTE Applicability Note S2

RHR - High Water Level 3.9.8 General Electric BWR/4 STS 3.9.8-1 Rev. 5.0 7

Hope Creek Amendment XXX 1

3 7

3 CTS 3.9 REFUELING OPERATIONS 3.9.8 Residual Heat Removal (RHR) - High Water Level LCO 3.9.8 One RHR shutdown cooling subsystem shall be OPERABLE and in operation.

NOTE--------------------------------------------

The required RHR shutdown cooling subsystem may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

APPLICABILITY:

MODE 5 with irradiated fuel in the reactor pressure vessel (RPV) and the water level [23] ft above the top of the [RPV flange].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required RHR shutdown cooling subsystem inoperable.

A.1 Verify an alternate method of decay heat removal is available.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter B. Required Action and associated Completion Time of Condition A not met.

B.1 Suspend loading irradiated fuel assemblies into the RPV.

AND B.2 Initiate action to restore

[secondary] containment to OPERABLE status.

AND Immediately Immediately 7

7 22 ft 2 inches 3

3 3.9.11.1 3/4.9.11 Applicability Action a 3.9.11.1 Footnote

Action a DOC M01 2

5

NOTE----------------------------------------------

Not applicable when Reactor Coolant System temperature can be maintained with no RHR shutdown cooling subsystem in operation.

4 establish boundary S2

RHR - High Water Level B 3.9.8 General Electric BWR/4 STS B 3.9.8-1 Rev. 5.0 7

3 Hope Creek Revision XXX 1

7 3

B 3.9 REFUELING OPERATIONS B 3.9.8 Residual Heat Removal (RHR) - High Water Level BASES BACKGROUND The purpose of the RHR System in MODE 5 is to remove decay heat and sensible heat from the reactor coolant, as required by GDC 34. Each of the two shutdown cooling loops of the RHR System can provide the required decay heat removal. Each loop consists of two motor driven pumps, a heat exchanger, and associated piping and valves. Both loops have a common suction from the same recirculation loop. Each pump discharges the reactor coolant, after it has been cooled by circulation through the respective heat exchangers, to the reactor via the associated recirculation loop or to the reactor via the low pressure coolant injection path. The RHR heat exchangers transfer heat to the RHR Service Water System. The RHR shutdown cooling mode is manually controlled.

In addition to the RHR subsystems, the volume of water above the reactor pressure vessel (RPV) flange provides a heat sink for decay heat removal.

APPLICABLE With the unit in MODE 5, the RHR System is not required to mitigate any SAFETY events or accidents evaluated in the safety analyses. The RHR System ANALYSES is required for removing decay heat to maintain the temperature of the reactor coolant.

The RHR System satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO Only one RHR shutdown cooling subsystem is required to be OPERABLE and in operation in MODE 5 with irradiated fuel in the RPV and the water OHYHO [23] ft above the RPV flange. Only one subsystem is required because the volume of water above the RPV flange provides backup decay heat removal capability.

An OPERABLE RHR shutdown cooling subsystem consists of an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path. In MODE 5, the RHR cross tie valve is not required to be closed; thus, the valve may be opened to allow pumps in one loop to discharge through the opposite loop's heat exchanger to make a complete subsystem. Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required. However, to ensure adequate 7

3 22 ft 2 inches 2

The RHR System consists of four separate subsystems, each with one RHR pump. RHR subsystems C and D are dedicated to low pressure coolant injection (LPCI) mode of operation. RHR subsystems A and B are also used for LPCI and can be aligned for shutdown cooling. Each shutdown cooling subsystem consists of one motor driven pump, a heat exchanger, and associated piping and valves. Both loops have a common suction from recirculation loop B.

The RHR heat exchangers transfer heat to the Safety Auxiliaries Cooling System.

RHR cross tie valves allow the C and D RHR pumps to be used as a means for alternate decay heat removal via their respective RHR loop heat exchanger if the normal shutdown cooling RHR pump (A or B) for that loop is inoperable.

1 1

4 S2

RHR - High Water Level B 3.9.8 General Electric BWR/4 STS B 3.9.8-2 Rev. 5.0 7

3 Hope Creek Revision XXX 1

7 3

BASES LCO (continued) core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. A Note is provided to allow a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months exception for the operating subsystem to be removed from operation every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

APPLICABILITY One RHR shutdown cooling subsystem must be OPERABLE and in operation in MODE 5, with irradiated fuel in the reactor pressure vessel DQGZLWKWKHZDWHUOHYHO [23] feet above the top of the RPV flange, to provide decay heat removal. RHR System requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS);

Section 3.5, Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System; and Section 3.6, Containment Systems. RHR Shutdown Cooling System requirements in MODE 5 with irradiated fuel in the reactor pressure vessel and with the water level

< [23] ft above the RPV flange are given in LCO 3.9.9.

ACTIONS A.1 With no RHR shutdown cooling subsystem OPERABLE, an alternate method of decay heat removal must be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In this condition, the volume of water above the RPV flange provides adequate capability to remove decay heat from the reactor core. However, the overall reliability is reduced because loss of water level could result in reduced decay heat removal capability. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will ensure continued heat removal capability.

Alternate decay heat removal methods are available to the operators for review and preplanning in the unit's Operating Procedures. The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods that can be used include (but are not limited to) the Spent Fuel Pool Cooling System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem. The method used to remove the decay heat should be the most prudent choice based on unit conditions.

22 ft 2 inches 22 ft 2 inches 8, "Residual Heat Removal (RHR) - Low Water Level."

3 2

2 A Note provides exception when decay heat is low enough such that losses to ambient are sufficient to ensure no increase in Reactor Coolant System (RCS) temperature will occur with RHR shutdown cooling subsystems not in operation. In this condition, a method of reactor coolant circulation must be maintained to provide assurance of continued RCS temperature monitoring capability.

5 S2 S2

REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.2 Two shutdown cooling mode loops of the residual heat removal (RHR) system shall be OPERABLE and at least one loop shall be in operation,* with each loop consisting of:

a.

One OPERABLE RHR pump, and

b.

One OPERABLE RHR heat exchanger.

APPLICABILITY: OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is less than 22 feet 2 inches above the top of the reactor pressure vessel flange and heat losses to ambient** are not sufficient to maintain OPERATIONAL CONDITION 5.

ACTION:

a.

With less than the above required shutdown cooling mode loops of the RHR system OPERABLE, within one hour and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, demonstrate the OPERABILITY of at least one alternate method capable of decay heat removal for each inoperable RHR shutdown cooling mode loop.

b.

With no RHR shutdown cooling mode loop in operation, within one hour establish reactor coolant circulation by an alternate method and monitor reactor coolant temperature at least once per hour.

SURVEILLANCE REQUIREMENTS 4.9.11.2 At least one shutdown cooling mode loop of the residual heat removal system or alternate method shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

The shutdown cooling pump may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8-hour period.

Ambient losses must be such that no increase in reactor vessel water temperature will occur (even though REFUELING conditions are being maintained).

HOPE CREEK 3/4 9-18 Amendment No. 187 A01 ITS 3.9.8 ITS 3.9 3.9.8 Residual Heat Removal (RHR) - Low Water Level RHR subsystems RHR shutdown cooling subsystem MODE with reactor pressure vessel (RPV)

RPV LA01 A03 One or two required subsystems inoperable 1

Verify an is available required subsystem ACTION A ACTION C Add proposed ACTION B M01 subsystem 1

from discovery of no reactor coolant circulation Verify SR 3.9.8.1 Verify RHR subsystem is LCO 3.9.8 NOTE subsystem required operating RHR LA02 A02 LCO 3.9.8 Applicability Insert Applicability NOTE Applicability Note S2

RHR - Low Water Level 3.9.9 General Electric BWR/4 STS 3.9.9-1 Rev. 5.0 8

Hope Creek Amendment XXX 1

3 8

3 CTS 3.9 REFUELING OPERATIONS 3.9.9 Residual Heat Removal (RHR) - Low Water Level LCO 3.9.9 Two RHR shutdown cooling subsystems shall be OPERABLE, and one RHR shutdown cooling subsystem shall be in operation.

NOTE--------------------------------------------

The required operating shutdown cooling subsystem may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

APPLICABILITY:

MODE 5 with irradiated fuel in the reactor pressure vessel (RPV) and the water level < [23] ft above the top of the [RPV flange].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required RHR shutdown cooling subsystems inoperable.

A.1 Verify an alternate method of decay heat removal is available for each inoperable required RHR shutdown cooling subsystem.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter B. Required Action and associated Completion Time of Condition A not met.

B.1 Initiate action to restore

[secondary] containment to OPERABLE status.

AND B.2 Initiate action to restore one standby gas treatment subsystem to OPERABLE status.

AND Immediately Immediately 8

8 22 ft 2 inches 3

3 3.9.11.2 Applicability 3.9.11.1 Footnote

Action a DOC M01 Filtration Recirculation and Ventilation System ventilation unit 5

5 DOC M01 2

4 boundary establish

NOTE----------------------------------------------

Not applicable when Reactor Coolant System temperature can be maintained with no RHR shutdown cooling subsystem in operation.

S2

ITS A01 ITS 4.0 DESIGN FEATURES 5.4 REACTOR COOLANT SYSTEM (continued)

VOLUME 5.4.2 The total water and steam volume of the reactor vessel and recirculation system is approximately 21,970 cubic feet at a nominal steam dome saturation temperature of 547°F.

5.5 DELETED 5.6 FUEL STORAGE CRITICALITY 5.6.1 The spent fuel storage racks are designed and shall be maintained with:

a.

A keff equivalent to less than or equal to 0.95 when flooded with unborated water, including all calculational uncertainties and biases as described in Section 9.1.2 of the FSAR.

b.

A nominal 6.308 inch center-to-center distance between fuel assemblies placed in the storage racks.

5.6.1.2 The keff for new fuel for the first core loading stored dry in the spent fuel storage racks shall not exceed 0.98 when aqueous foam moderation is assumed.

DRAINAGE 5.6.2 The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 199' 4".

CAPACITY 5.6.3 The spent fuel storage pool shall be limited to a storage capacity of no more than 4006 fuel assemblies.

5.7 COMPONENT CYCLIC OR TRANSIENT LIMIT 5.7.1 The components identified in Table 5.7.1-1 are designed and shall be maintained within the cyclic or transient limits of Table 5.7.1-1.

HOPE CREEK 5-5 Amendment No. 234 See ITS 5.5 LA01 4.3.1 4.3 4.3.1.1.b 4.3.1.1.c 4.3.1.1 4.3.1.2.b is designed and shall be maintained with ft inches 4.3.2 4.3.3 A02 A01 A01 A01 Add proposed ITS 4.3.1.1.a M01 Add proposed ITS 4.3.1.2.a and c M01 under optimum conditions, which includes allowances for uncertainties as described in Section 9.1 of the UFSAR A03 S2

ADMINISTRATIVE CONTROLS UNIT STAFF (Continued)

b.

At least one licensed Reactor Operator shall be in the control room when fuel is in the reactor. In addition, while the unit is in OPERATIONAL CONDITION 1, 2 or 3, at least one licensed Senior Reactor Operator shall be in the control room;

c.

ALL CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or licensed Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.

HOPE CREEK 6-2 Amendment No. 177 ITS A01 ITS 5.2 L03

a.

A non-licensed operator shall be assigned to the unit when the reactor contains fuel and an additional non-licensed operator shall be assigned to the unit when the reactor is operating in MODES 1, 2, and 3.

A03 L02 S2

DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION Hope Creek Page 2 of 8 consistent with the ISTS allowing for either location to be chosen for documentation because both locations provide similar change control processes and require NRC notification of changes pursuant to 10 CFR 50.71(e). This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS Table 6.2.2-1 provides requirements, in part, for the number of Equipment Operators (EOs) required during Operational Conditions (ITS MODES) 1, 2, 3, 4, or 5. At HCGS the equipment operator is a non-licensed operator. During Operational Condition 1, 2, or 3, two EOs are required as part of the minimum shift crew composition with one EO required during Operational Condition 4 or 5.

ITS 5.2.2.a provides a similar requirement stating that a non-licensed operator shall be assigned when the reactor contains fuel and an additional non-licensed operator shall be assigned when the reactor is operating in MODES 1, 2, and 3.

This changes the CTS by presenting the non-licensed operator requirements in paragraph format rather than table format.

The purpose of the CTS Table 6.2.2-1 is to provide minimum shift crew composition requirements to ensure operations can be performed safety. This change is acceptable because the change is in presentation only, changing the minimum non-licensed operator requirements from a tabular format to a paragraph format, and has no impact on the minimum shift crew composition necessary to ensure operations can be performed safety. This change is designated as administrative because it does not result in technical changes to the CTS.

A04 CTS 6.2 uses the term OPERATIONAL CONDITION(S). ITS 5.2 uses the term MODE(S). This changes the CTS by incorporating the ITS MODE definition.

The purpose of CTS 5.1 is to establish the Operational Condition (i.e., ITS MODE) in which the specification is required. This change is acceptable because the CTS definition of an Operational Condition, any one inclusive combination of mode switch position and average reactor coolant temperature as specified in Table 1.2, and the ITS definition of MODE, corresponds to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel, define similar conditions. This change is designated as an administrative change and is acceptable because it does not result in a technical change to the CTS.

A05 CTS Table 6.2.2-1, Table Notation, states, in part, that except for the Senior Nuclear Shift Supervisor, the shift crew composition may be one less than the minimum requirements of Table 6.2.2-1 to accommodate unexpected absence of on-duty shift crew members. ITS 5.2.2 provides the same allowance but does not explicitly make exception to the Senior Nuclear Shift Supervisor. This changes the CTS by not explicitly stating the Senior Nuclear Shift Supervisor is an exception to the unexpected absence allowance.

The purpose of the Table Notation specification associated with shift crew composition absences is to accommodate for unexpected conditions requiring an absence of an on-duty shift crew member. CTS makes an exception for the S2

Organization 5.2 General Electric BWR/4 STS 5.2-1 Rev. 5.0 Hope Creek Amendment XXX 1

CTS 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.

a.

Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the [FSAR/QA Plan].

b.

The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.

c.

A specified corporate officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

d.

The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

5.2.2 Unit Staff The unit staff organization shall include the following:

a.

A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, or 3.

REVIEWER'S NOTE----------------------------------------

Two unit sites with both units shutdown or defueled require a total of three non-licensed operators for the two units.

6.2 6.0 6.2.1 6.2.1.a 6.2.1.b.

6.2.1.c 6.2.1.d Quality Assurance Topical Report Table 6.2.2-1 EO 3

5 the unit when the s

to the unit when the 4

generic 2

and S2

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued) 6.8.4 The following programs shall be established, implemented, and maintained:

a.

Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the HPCI, CS, RHR, RCIC, Containment Hydrogen Recombiner, H2/02 analyzer, Post-Accident Sampling, Control Rod Drive Hydraulic (Scram Discharge portion) systems. The program shall include the following:

1.

Preventive maintenance and periodic visual inspection requirements, and

2.

A service pressure leak test for each system at refueling cycle intervals or less.

b.

In-Plant Radiation Monitoring A program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shall include the following:

1.

Training of personnel,

2.

Procedures for monitoring, and 3.

Provisions for maintenance of sampling and analysis equipment.

c.

Deleted HOPE CREEK 6-16 Amendment No.149 ITS A01 ITS 5.5 and Manuals 5.5 5.5.2 5.5.2 This program provides controls to minimize practicable at a frequency in accordance with the Surveillance Frequency Control Program Integrated leak requirements a

b The provisions of SR 3.0.2 are applicable.

A02 LA01 5.5.2.a 5.5.2.b LA02 A01 and S2 S2

ADMINISTRATIVE CONTROLS

d.

Explosive Gas Monitoring This program provides controls for potentially explosive gas mixtures contained in the Main Condenser Offgas Treatment System. The program shall include the limit for hydrogen concentration in the Main Condenser Offgas Treatment System and a surveillance program to ensure the limit is maintained. This limit shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion).

The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Explosive Gas Monitoring Program surveillance frequencies.

e.

Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

a.

Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:

1.

an API gravity or absolute specific gravity within limits for ASTM 2D fuel oil,

2.

a flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and

3.

bulk water and sediment within limits for ASTM 2D fuel oil;

b.

Other properties for new ASTM 2D fuel oil are within limits within 31 days following sampling and addition to storage tanks; and c.

7RWDOSDUWLFXODWHFRQFHQWUDWLRQRIWKHVWRUHGIXHORLOLVPJOZKHQ

tested every 92 days in accordance with ASTM D-2276, modified as follows: The 0.8 micron membrane filters specified in ASTM D-2276 may be replace with membrane filters up to 3.0 microns.

HOPE CREEK 6-16a Amendment No. 100 at a frequency in accordance with the Surveillance Frequency Control Program LA01 5.5.6 Program 5.5.6 5.5.7 5.5.7 oil The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program test frequencies.

A clear and bright appearance with proper color or a of the new fuel verify that the content LA03 LA03 L01 SR 3 A03 5.5.7.a 5.5.7.a.1 5.5.7.a.2 5.5.7.a.3 5.5.7.b 5.5.7.c LA04 and Storage Tank Radioactivity 5.5.6.a A01 See CTS 3.11.1.4 for storage tank markups.

ITS A01 ITS 5.5

, other than those addressed in a., above, S2

ADMINISTRATIVE CONTROLS 6.16 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM (Continued)

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the Control Room Emergency Filtration System, operating at the flow rate required by Surveillance Requirement 4.7.2.1.c.1, at a Frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 36 month assessment of the CRE boundary.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of Specification 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

HOPE CREEK 6-27 Amendment No.173 LA01 in accordance with the Surveillance Frequency Control Program the VFTP SR 3 5.5.12.d 5.5.12.e 5.5.12.f LA01 ITS A01 ITS 5.5 subsystem S2

A01

Programs and Manuals 5.5 General Electric BWR/4 STS 5.5-2 Rev. 5.0 Hope Creek Amendment XXX CTS 2

5.5 Programs and Manuals 5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include

[the Low Pressure Core Spray, High Pressure Coolant Injection, Residual Heat Removal, Reactor Core Isolation Cooling, hydrogen recombiner, process sampling, and Standby Gas Treatment]. The program shall include the following:

a.

Preventive maintenance and periodic visual inspection requirements and

b.

Integrated leak test requirements for each system at least once per

[18] months.

The provisions of SR 3.0.2 are applicable.

[ 5.5.3 Post Accident Sampling

REVIEWERS NOTE ------------------------------------------

This program may be eliminated based on the implementation of NEDO-32991, Revision 0, Regulatory Relaxation For BWR Post Accident Sampling Stations (PASS), and the associated NRC Safety Evaluation dated June 12, 2001, and implementation of the following commitments:

1. [Licensee] has developed contingency plans for obtaining and analyzing highly radioactive samples from the reactor coolant system, suppression pool, and containment atmosphere. The contingency plans will be contained in emergency plan implementing procedures and implemented with the implementation of the License amendment. Establishment of contingency plans is considered a regulatory commitment.

2. The capability for classifying fuel damage events at the Alert level threshold has been established for [Plant] at radioactivity levels of 300 mCi/cc dose equivalent iodine. This capability may use a normal sampling system or correlations of radiation readings to coolant concentrations. This capability will be described in emergency plan implementing procedures and implemented with the implementation of the License amendment. The capability for classifying fuel damage events is considered a regulatory commitment.

3. [Licensee] has established the capability to monitor radioactive iodines that have been released to offsite environs. This capability is described in our emergency plan implementing procedures. The capability to monitor radioactive iodines is considered a regulatory commitment.

This program provides controls that ensure the capability to obtain and analyze reactor coolant, radioactive gases, and particulates in plant gaseous effluents and containment atmosphere samples under accident conditions. The program 6.8.4.a 6.8 Core Spray containment H2/02 analyzer, post-accident sampling and control rod drive hydraulic (scram discharge portion) at a frequency in accordance with the Surveillance Frequency Control Program 4

1 3

DOC LA01 6.8.4.a.1 6.8.4.a.2 S2 S2

Programs and Manuals 5.5 General Electric BWR/4 STS 5.5-5 Rev. 5.0 Hope Creek Amendment XXX CTS 2

5.5 Programs and Manuals 5.5.6 Pre-Stressed Concrete Containment Tendon Surveillance Program (continued)

The provisions of SR 3.0.3 are applicable to the Tendon Surveillance Program inspection frequencies. ]

5.5.7 Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide ], and in accordance with [Regulatory Guide 1.52, Revision 2, ASME N510-1989, and AG-1].

a.

Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below

[+/- 10%].

ESF Ventilation System Flowrate

[ ]

b.

Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%].

ESF Ventilation System Flowrate

[ ]

c.

Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in [Regulatory Guide 1.52, Revision 2], shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30qC (86qF) and the relative humidity specified below.

ESF Ventilation System Penetration RH Face Velocity (fps)

[ ]

[See Reviewer's

[See

[See Reviewer's Note]

Reviewer's Note]

Note]

5 Control Room Emergency Filtration (CREF) System Filtration Recirculation and Ventilation System (FRVS) - ventilation units FRVS - recirculation units 4000 cfm 9000 cfm 30,000 cfm 4.6.5.3.1.c.1 4.6.5.3.1.f 4.6.5.3.2.c.1 4.6.5.3.2.f 4.7.2.1.1.c.1 4.7.2.1.1.f 4.6.5.3.1.g 4.7.2.1.1.g CREF System FRVS - ventilation units 4000 cfm 9000 cfm CREF System FRVS - ventilation units 4.6.5.3.1.c.2 4.6.5.3.1.d 4.7.2.1.1.c.2 4.7.2.1.1.d 4.7.2.1.1.e.4 0.5%

5%

70%

95%

5 6

1 6

6 6

5 1

1 1

Insert 1 S2

Programs and Manuals 5.5 General Electric BWR/4 STS 5.5-6 Rev. 5.0 Hope Creek Amendment XXX CTS 2

5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (continued)

REVIEWER'S NOTE----------------------------------------

The use of any standard other than ASTM D3803-1989 to test the charcoal sample may result in an overestimation of the capability of the charcoal to adsorb radioiodine. As a result, the ability of the charcoal filters to perform in a manner consistent with the licensing basis for the facility is indeterminate.

ASTM D 3803-1989 is a more stringent testing standard because it does not differentiate between used and new charcoal, it has a longer equilibration period performed at a temperature of 30qC (86qF) and a relative humidity (RH) of 95%

(or 70% RH with humidity control), and it has more stringent tolerances that improve repeatability of the test.

Allowable Penetration = [(100% - Methyl Iodide Efficiently

for Charcoal Credited in Licensee's Accident Analysis) / Safety Factor]

When ASTM D3803-1989 is used with 30qC (86qF) and 95% RH (or 70% RH with humidity control) is used, the staff will accept the following:

Safety factor 2 for systems with or without humidity control.

Humidity control can be provided by heaters or an NRC-approved analysis that demonstrates that the air entering the charcoal will be maintained less than or equal to 70 percent RH under worst-case design-basis conditions.

If the system has a face velocity greater than 110 percent of 0.203 m/s (40 ft/min), the face velocity should be specified.

This value should be the efficiency that was incorporated in the licensee's accident analysis which was reviewed and approved by the staff in a safety evaluation.

d.

Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%].

ESF Ventilation System Delta P Flowrate

[ ]

[ e.

Demonstrate that the heaters for each of the ESF systems dissipate the value specified below [+/- 10%] when tested in accordance with

[ASME N510-1989].

5 4000 cfm 9000 cfm 30,000 cfm CREF System FRVS - ventilation units FRVS - recirculation units 0

7.5 in. w.g.

5 in. w.g.

8 in. w.g.

4.6.5.3.1.e.1 4.6.5.3.2.e.1 4.7.2.1.1.e.1 or the exhaust duct of the FRVS recirculation units 7

4.7.2.1.1.e.4 6

6 1

2 1

1 1

5 ASME N510-1980 the CREF System dissipate 13 kW 4.6.5.3.2.c.2 4.7.2.1.1.c.3 S2

Programs and Manuals 5.5 General Electric BWR/4 STS 5.5-8 Rev. 5.0 Hope Creek Amendment XXX CTS 2

5.5 Programs and Manuals 5.5.9 Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

a.

Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:

1.

An API gravity or an absolute specific gravity within limits,

2.

A flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and

3.

A clear and bright appearance with proper color or a water and sediment content within limits,

b.

Within 31 days following addition of the new fuel oil to storage tanks, verify that the properties of the new fuel oil, other than those addressed in a.,

above, are within limits for ASTM 2D fuel oil, and

c.

Total particulate concentration of the fuel oil is 10 mg/l when tested every 31 days.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program test frequencies.

5.5.10 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a.

Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b.

Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1.

A change in the TS incorporated in the license or

2.

A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c.

The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

7 8

at a frequency in accordance with the Surveillance Frequency Control Program 6.15 6.15.a 6.15.b 6.15.b.1 6.15.b.2 6.15.e 6.8.4.e 6.8.4.e.a 6.8.4.e.a.1 6.8.4.e.a.2 6.8.4.e.a.3 DOC L01 6.8.4.e.b 6.8.4.e.c DOC LA01 5

3 5

U U

2 2

S2

Programs and Manuals 5.5 General Electric BWR/4 STS 5.5-13 Rev. 5.0 Hope Creek Amendment XXX CTS 2

5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued) b)

For each door, leakage rate is [0.01 La] when pressurized to

[10] psig.

e.

The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

f.

Nothing in these Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J.

5.5.13 Battery Monitoring and Maintenance Program

REVIEWERS NOTE------------------------------------------

This program and the corresponding requirements in LCO 3.8.4, LCO 3.8.5, and LCO 3.8.6 require providing the information and verifications requested in the Notice of Availability for TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360," (76FR54510).

This Program provides controls for battery restoration and maintenance. The program shall be in accordance with IEEE Standard (Std) 450-2002, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," as endorsed by Regulatory Guide 1.129, Revision 2 (RG), with RG exceptions and program provisions as identified below:

a.

The program allows the following RG 1.129, Revision 2 exceptions:

1.

Battery temperature correction may be performed before or after conducting discharge tests.

2.

RG 1.129, Regulatory Position 1, Subsection 2, "References," is not applicable to this program.

3.

In lieu of RG 1.129, Regulatory Position 2, Subsection 5.2, "Inspections," the following shall be used: "Where reference is made to the pilot cell, pilot cell selection shall be based on the lowest voltage cell in the battery."

4 In Regulatory Guide 1.129, Regulatory Position 3, Subsection 5.4.1, "State of Charge Indicator," the following statements in paragraph (d) may be omitted: "When it has been recorded that the charging current has stabilized at the charging voltage for three consecutive hourly measurements, the battery is near full charge. These measurements shall be made after the initially high charging current decreases sharply and the battery voltage rises to approach the charger output voltage."

11 3

2010 9

10 11 11 5

DOC M02 p

S2 17

Programs and Manuals 5.5 General Electric BWR/4 STS 5.5-15 Rev. 5.0 Hope Creek Amendment XXX CTS 2

5.5 Programs and Manuals 5.5.14 Control Room Envelope (CRE) Habitability Program (continued)

Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

[The following are exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:

1. ;and]

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the [MCREC] System, operating at the flow rate required by the VFTP, at a Frequency of [18] months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the [18] month assessment of the CRE boundary.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

[ 5.5.15 Setpoint Control Program

REVIEWER'S NOTE----------------------------------------

Adoption of a Setpoint Control Program requires changes to other technical specifications. See TSTF-493, Revision 4, "Clarify Application of Setpoint Methodology for LSSS Functions," Option B, for guidance (Agencywide Documents Access and Management System (ADAMS) Accession Number ML101160026).

This program shall establish the requirements for ensuring that setpoints for automatic protective devices are initially within and remain within the assumptions of the applicable safety analyses, provides a means for processing changes to instrumentation setpoints, and identifies setpoint methodologies to ensure instrumentation will function as required. The program shall ensure that 12 Control Room Emergency Filtration in accordance with the Surveillance Frequency Control Program 6.16.d DOC LA01 6.16.e 6.16.f 1

5 3

1 2

3 12 6.16 S2

JUSTIFICATION FOR DEVIATIONS ITS 5.5, PROGRAMS AND MANUALS Hope Creek Page 3 of 3 ML23234A192). Subsequent ISTS 5.5.13 (ITS 5.5.11) requirements are renumbered, as necessary, to support this deviation

12. HCGS does not require, and CTS do not include a Setpoint Control Program, Risk Informed Completion Time Program, or a Spent Fuel Storage Rack Neutron Absorber Monitoring Program. Therefore, these ISTS programs (ISTS 5.5.15, ISTS 5.5.17, and ISTS 5.5.18) are not included in the ITS. Subsequent Specifications are renumbered, as necessary, to support this deviation.

13. ISTS 5.5.4.k places limitations on venting and purging of the Mark II containment.

The HCGS containment is of the General Electric Mark I design consisting of a drywell and a torus. Specifying the specific type of containment design is unnecessary when describing the limitations on venting and purging and, therefore, is not included in ITS 5.5.3.k consistent with the CTS. Also, the statement in ISTS 5.5.12.b specifying the containment design pressure is not included in ITS 5.5.10 consistent with the CTS. The primary containment internal design pressure is specified in UFSAR Sections 3.8.2 and 6.2 and it unnecessary to duplicate this design requirement in the Technical Specifications.

14. ISTS 5.5.4.b is revised in ITS 5.5.3.b to reflect that Appendix B is to 10 CFR 20, not specific sections of 10 CFR 20, consistent with CTS and the regulation.

15. The reactor cyclic and transient occurrences are currently addressed in CTS Table 5.7.1-1. This table is proposed to be relocated to the UFSAR. Therefore, ISTS 5.5.5 is revised in ITS 5.5.4 to specify that the Component Cyclic or Transient Limit program provides controls to track reactor cyclic and transient occurrences specified in UFSAR Table 5.3-1 consistent with CTS 5.7.1, considering the relocation to the UFSAR.

16. As described in the NRC safety evaluation (SE) accompanying Operating License Amendment 121, dated September 8, 1999 (NRC ADAMS Accession No. ML20211N544 (Package) and ML20211N553 (SE)), PSEG has retained, in the current Technical Specifications, the level of effluent control pursuant to 10 CFR 20 requirements in effect prior to January 1, 1994 and, pursuant to 10 CFR 20.1008(c),

these requirements were determined to be equivalent to or more restrictive than the applicable requirements specified in 10 CFR 20.1001-20.2402. Therefore, ISTS 5.5.4.b, 5.5.4.c, and 5.5.4.g (ITS 5.5.3.b, 5.5.3.c, and 5.5.3.g) are revised, as necessary, in the ITS consistent with current Technical Specifications requirements referencing 10 CFR 20 regulations in effect prior to January 1, 1994.

17. Text revised, inserted, or deleted in ITS to correct a typographical or grammatical error.

S2

Hope Creek Insert Page 5.6-2 INSERT 1 LCO 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR),

LCO 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR),

LCO 3.2.3 LINEAR HEAT GENERATION RATE (LHGR),

LCO 3.3.1.1 Reactor Protection System (RPS) Instrumentation, LCO 3.3.2.1 Control Rod Block Instrumentation, LCO 3.3.4.1 End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation, and LCO 3.4.1 Recirculation Loops Operating.

INSERT 2 NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR-II).

The COLR will contain the complete identification for the referenced topical report used to prepare the COLR (i.e., report number, title, revision, date, and any supplements).

3 3

4 ITS 5.6 S2

v t e Letter Sequence Supplement
EPID:L-2024-LLI-0000, (Open)
Initiation Request, Request, Request Acceptance Administration Questions Answers Results Approval, Approval, Approval Other: ML25182A205, NUREG-1433, Change in Estimated Review Schedule (August 22, 2025) for Amendment Request Concerning Technical Specification Conversion to NUREG-1433, Revision 5
MONTHYEAR2025-01-07 [Table View]

LR-N25-0015, License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, Supplement 2

Text

Subject:

Reference:

Enclosure:

SUMMARY

SUMMARY

Navigation menu

LR-N25-0015, License Amendment Request (LAR) - Hope Creek Technical Specification Conversion to NUREG-1433, Revision 5, Supplement 2

Text

Subject:

Reference:

Enclosure:

SUMMARY

SUMMARY

Navigation menu

Search