LR-N05-0030, Request for Change to Technical Specifications Relocation of Overcurrent Protective Devices
| ML052930278 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek |
| Issue date: | 10/11/2005 |
| From: | Barnes G Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LCR H05-04, LR-N05-0030 | |
| Download: ML052930278 (28) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 O0T 1 l2D5
§yPSEG LR-N05-0030 Nuclear LLC LCR H05-04 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS RELOCATION OF OVERCURRENT PROTECTIVE DEVICES HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) hereby transmits a request for amendment of the Technical Specifications (TS) for Hope Creek Generating Station. In accordance with 10 CFR 50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey.
The proposed amendment relocates TS 3/4.8.4.1, "Primary Containment Penetration Conductor Overcurrent Protective Devices," and TS 314.8.4.5, "Class 1E Isolation Breaker Overcurrent Protective Devices," to the Hope Creek Generating Station Updated Final Safety Analysis Report (UFSAR). Relocation of Primary Containment Penetration Conductor Overcurrent Protective Devices and Class 1 E Isolation Breaker Overcurrent Protective Devices from the TS to the UFSAR is consistent with the NRC Final Policy Statement on TS Improvements for Nuclear Power Reactors. In addition, as a result of the proposed changes, subsequent revisions to Primary Containment Penetration Conductor Overcurrent Protective Devices and Class 1 E Isolation Breaker Overcurrent Protective Devices may be processed in accordance with 10 CFR 50.59 as opposed to 10 CFR 50.90, which minimizes resource demands upon PSEG and the NRC. provides a description of the proposed changes. Attachment 2 provides the existing TS pages marked-up to show the proposed changes. For your information, Attachment 3 provides the existing TS Bases pages marked-up to reflect the associated changes to the TS.
PSEG requests implementation within 60 days of receipt of the approved amendment. Approval of this change is requested by April 3, 2006 to support Hope Creek Generating Station refueling outage RF 13.
4 \\
95-2168 REV. 7/99
Document Control Desk LR-N05-0030 OT 11 205 Should you have any questions regarding this request, please contact Mr. Paul Duke at (856) 339-1466.
1 declare under penalty of perjury that the foregoing is true and correct.
Executed on _ /D /1 l 1og (Date)
Sincerely, George P. Barnes Site Vice President Hope Creek Generating Station Attachments (3)
Document Control Desk OCT 1 1 2005 LR-N05-0030 C
Mr. S. Collins, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission Mr. S. Bailey, Project Manager - Hope Creek Mail Stop 08B1 Washington, DC 20555-0001 USNRC Senior Resident Inspector - Hope Creek (X24)
Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P.O. Box 415 Trenton, NJ 08625 LCR H05-04 LR-N05-0030 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 CHANGE TO TECHNICAL SPECIFICATIONS RELOCATION OF PRIMARY CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES Table of Contents
- 1. DESCRIPTION 1
- 2. PROPOSED CHANGE................................................................
1
- 3. BACKGROUND..........................................................................................................1
- 4. TECHNICAL ANALYSIS................................................................
1
- 5. REGULATORY SAFETY ANALYSIS................................................................
7 5.1 No Significant Hazards Consideration........................................................... 7 5.2 Applicable Regulatory Requirements/Criteria................................................ 9
- 6. ENVIRONMENTAL CONSIDERATION...............................................................
10
- 7. REFERENCES...............................................................
10
ATTACHMENT 1 LCR H05-04 LR-N05-0030 CHANGES TO TECHNICAL SPECIFICATIONS
- 1.
DESCRIPTION The proposed amendment relocates Technical Specification (TS) 3/4.8.4.1,
'Primary Containment Penetration Conductor Overcurrent Protective Devices," and TS 3/4.8.4.5, 'Class 1 E Isolation Breaker Overcurrent Protective Devices," to the Hope Creek Generating Station Updated Final Safety Analysis Report (UFSAR).
- 2.
PROPOSED CHANGE The proposed change will relocate Primary Containment Penetration Conductor Overcurrent Protective Devices and Class IE Isolation Breaker Overcurrent Protective Devices from the TS to the UFSAR. The elimination of TS 3/4.8.4.1 and TS 3/4.8.4.5 results in deletion of some information from TS Bases 3/4.8.4, "Electrical Equipment Protective Devices."
- 3.
BACKGROUND Relocation of Primary Containment Penetration Conductor Overcurrent Protective Devices and Class 1E Isolation Breaker Overcurrent Protective Devices from the TS to the UFSAR is consistent with the NRC Final Policy Statement on TS Improvements for Nuclear Power Reactors (58 FR 39132). The Final Policy Statement on TS Improvements for Nuclear Power Reactors establishes a specific set of objective criteria as guidance for determining which regulatory requirements and operating restrictions should be included in TS. It encourages licensees to implement a voluntary program to update TS to be consistent with improved vendor-specific Standard Technical Specifications issued by the NRC.
Additionally, as a result of the proposed change, subsequent revisions to Primary Containment Penetration Conductor Overcurrent Protective Devices and Class 1 E Isolation Breaker Overcurrent Protective Devices may be processed in accordance with 10 CFR 50.59 as opposed to 10 CFR 50.90, which minimizes resource demands upon PSEG Nuclear LLC (PSEG) and the NRC.
The proposed change is consistent with NUREG-1433, "Standard Technical Specifications General Electric Plants, BWRI4," which did not retain limiting conditions for operation, surveillance requirements or a bases for Primary Containment Penetration Conductor Overcurrent Protective Devices or for Class I E Isolation Breaker Overcurrent Protective Devices.
- 4.
TECHNICAL ANALYSIS The regulatory requirements related to the content of the TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific 1
ATTACHMENT 1 LCR H05-04 LR-N05-0030 categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.
On February 6, 1987, the NRC published its Interim Policy Statement on TS Improvements for Nuclear Power Plants in the Federal Register (52 FR 3788). In part, the Interim Policy Statement provided the criteria to be utilized in determining which requirements need to be governed by the TS.
In 1987, based on the Interim Policy Statement, the four nuclear steam supply system owners groups submitted proposals identifying requirements in the existing TS that could be relocated from the TS to other licensee controlled documents.
The NRC staff reviewed the owners group submittals and published its conclusion in the report dated May 9,1988, uNRC Staff Review of Nuclear Steam Supply System Vendor Owners Groups' Application of the Commission's Interim Policy Statement Criteria to Standard Technical Specifications," (Split Report). The Split Report identified those TS requirements that must be retained in the new improved TS (having met one or more of the criteria) and those TS requirements that could be relocated (having met none of the criteria.) The Split Report identified Overcurrent Protection Devices Limiting Condition for Operation (LCO) as an item that could be relocated from the TS to other licensee controlled documents.
Supplement I to the Boiling Water Reactor Owners' Group (BWROG) Report NEDO-31466, 'Technical Specification Screening Criteria Application and Risk Assessment," was completed in February 1990. The original report documented the evaluation of the LCOs from the lead plants for the BWROG TS Improvement program (Hatch-2 and Grand Gulf). NEDO-31466, Supplement I documents the application of the TS screening criteria to 70 additional LCOs identified in a review of other plant specific TS and the BWR Standard TS. To ensure consistency of evaluation and to provide a common basis of comparison, the original screening criteria interpretations utilized by the BWROG in the development of the original report were applied in the development of the supplemental report. NEDO-31466, Supplement I identified 49 LCOs to be retained in TS and 21 LCOs that did not meet any of the criteria and could be relocated. Hope Creek Class 1 E Isolation Breaker Overcurrent Protective Devices was identified in NEDO-31466, Supplement 1 as an item that could be relocated from the TS to other licensee controlled documents.
On July 22,1993, the NRC published the Final Policy Statement on TS Improvements for Nuclear Power Reactors (58 FR 39132). The Final Policy Statement reflected public comments on the Interim Policy Statement and experience gained in developing the new improved TS. The Final Policy Statement LCO criteria were subsequently incorporated into 10 CFR 50.36(c)(2)(ii). In accordance with the Final Policy Statement the criteria of 10 2
ATTACHMENT 1 LCR H05-04 LR-N05-0030 CFR 50.36(c)(2)(ii) were applied against Primary Containment Penetration Conductor Overcurrent Protective Devices and Class 1 E Isolation Breaker Overcurrent Protective Devices LCOs and provided the following results:
Primary Containment Penetration Conductor Overcurrent Protective Devices Criterion 1 - Installed instrumentation that is used to detect, and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary.
The purpose of this criterion is to detect excessive reactor coolant pressure boundary leakage. The containment penetration conductor overcurrent protection devices are installed to minimize the damage from a fault in a component inside containment, or in cabling which penetrates containment. Primary Containment Penetration Conductor Overcurrent Protective Devices do not involve installed instrumentation that is used to detect, and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary. Consequently, Primary Containment Penetration Conductor Overcurrent Protective Devices do not meet Criterion 1.
Criterion 2 - A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The purpose of this criterion is to capture those process variables that have initial values assumed in the design basis accident and transient analyses, and which are monitored and controlled during power operation. The containment penetration conductor overcurrent protection devices are installed to minimize the damage from a fault in a component inside containment, or in cabling which penetrates containment. The containment penetration conductor overcurrent protection devices do help preserve the assumptions of the accident analysis by enhancing proper equipment operation. However, Primary Containment Penetration Conductor Overcurrent Protective Devices do not involve a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Consequently, Primary Containment Penetration Conductor Overcurrent Protective Devices do not meet Criterion 2.
Criterion 3 - A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
3
ATTACHMENT 1 LCR H05-04 LR-N05-0030 The purpose of this criterion is to capture only those structures, systems, and components (SSC) that are part of the primary success path of the safety analysis (an examination of the actions required to mitigate the consequences of the design basis accidents and transients). The primary success path of a safety analysis consists of the combinations and sequences of equipment needed to operate, so that the plant response to the design basis accidents and transients limits the consequences of these events to within the appropriate acceptance criteria. Also, captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function, but it does not include backup and diverse equipment. The containment penetration conductor overcurrent protection devices are installed to minimize the damage from a fault in a component inside containment, or in cabling which penetrates containment. Primary Containment Penetration Conductor Overcurrent Protective Devices do not involve a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Consequently, Primary Containment Penetration Conductor Overcurrent Protective Devices do not meet Criterion 3.
Criterion 4 - A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
The purpose of this criterion is to capture only those SSC that operating experience or probabilistic risk assessment has shown to be significant to public health and safety. Requirements proposed for relocation do not contain constraints of prime importance in limiting the likelihood or severity of the accident sequences that are commonly found to dominate risk. NEDO-31466, 'Technical Specification Screening Criteria Application and Risk Assessment," performed a risk assessment to review plant safety risks associated with relocating LCOs from the TS as discussed in sections 3.5, 6.1, 6.2, and 6.8 and summarized in Table 4-1 (item 276). Primary Containment Penetration Conductor Overcurrent Protective Devices were found to be a non-significant contributor to risk.
PSEG has reviewed the NEDO-31466 risk assessment, considers it applicable to Hope Creek, and concurs with its conclusions.
Additionally, the Final Policy Statement does not list Primary Containment Penetration Conductor Overcurrent Protective Devices among the four LCOs to be retained because operating experience or probabilistic risk assessment has shown them to be significant to public health and safety. Consequently, Primary Containment Penetration Conductor Overcurrent Protective Devices do not meet Criterion 4.
4
ATTACHMENT 1 LCR H05-04 LR-N05-0030 Primary Containment Penetration Conductor Overcurrent Protective Devices LCO does not meet any 10 CFR 50.36(c)(2)(ii) criterion as described above; therefore, it may be relocated to the UFSAR. All changes to the UFSAR are subject to evaluation in accordance with 10 CFR 50.59 provisions. 10 CFR 50.59 provides sufficient regulatory controls to address future changes to these requirements.
Class I E Isolation Breaker Overcurrent Protective Devices Criterion 1 - Installed instrumentation that is used to detect, and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary.
The purpose of this criterion is to detect excessive reactor coolant pressure boundary leakage. The Class I E isolation breaker overcurrent protective devices sense and protect the Class I E buses from overcurrent conditions during all modes. However, failure of an overcurrent protection device during a transient or accident condition would not prevent safety functions from occurring. The Class 1 E onsite AC sources and offsite power sources and their distribution system are of sufficient capacity and capability to supply power to both Class I E and non-Class 1 E loads during all plant conditions. Class 1 E Isolation Breaker Overcurrent Protective Devices do not involve installed instrumentation that is used to detect, and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary. Consequently, Class 1E Isolation Breaker Overcurrent Protective Devices do not meet Criterion 1.
Criterion 2 - A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The purpose of this criterion is to capture those process variables that have initial values assumed in the design basis accident and transient analyses, and which are monitored and controlled during power operation. The Class 1 E isolation breaker overcurrent protective devices sense and protect the Class 1 E buses from overcurrent conditions during all modes. However, failure of an overcurrent protection device during a transient or accident condition would not prevent safety functions from occurring. The Class 1 E onsite AC sources and offsite power sources and their distribution system are of sufficient capacity and capability to supply power to both Class 1 E and non-Class 1 E loads during all plant conditions. Class 1 E Isolation Breaker Overcurrent Protective Devices do not involve a process variable, design feature, or 5
ATTACHMENT 1 LCR H05-04 LR-N05-0030 operating restriction that is an initial condition of a DBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Consequently, Class 1 E Isolation Breaker Overcurrent Protective Devices do not meet Criterion 2.
Criterion 3 - A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The purpose of this criterion is to capture only those structures, systems, and components (SSC) that are part of the primary success path of the safety analysis (an examination of the actions required to mitigate the consequences of the design basis accidents and transients). The primary success path of a safety analysis consists of the combinations and sequences of equipment needed to operate, so that the plant response to the design basis accidents and transients limits the consequences of these events to within the appropriate acceptance criteria. Also, captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function, but it does not include backup and diverse equipment. The Class 1 E isolation breaker overcurrent protective devices sense and protect the Class 1 E buses from overcurrent conditions during all modes. However, failure of an overcurrent protection device during a transient or accident condition would not prevent safety functions from occurring. The Class 1 E onsite AC sources and offsite power sources and their distribution system are of sufficient capacity and capability to supply power to both Class 1 E and non-Class 1 E loads during all plant conditions. Class 1 E Isolation Breaker Overcurrent Protective Devices do not involve a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Consequently, Class I E Isolation Breaker Overcurrent Protective Devices do not meet Criterion 3.
Criterion 4 - A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
The purpose of this criterion is to capture only those SSC that operating experience or probabilistic risk assessment has shown to be significant to public health and safety. Requirements proposed for relocation do not contain constraints of prime importance in limiting the likelihood or severity of the accident sequences that are commonly found to dominate risk. NEDO-31466, Supplement 1 performed a risk assessment to 6
ATTACHMENT 1 LCR H05-04 LR-N05-0030 review plant safety risks associated with relocating LCOs from the TS as discussed in section 6 and summarized in Table 4-1 (item 375). Class 1 E Isolation Breaker Overcurrent Protective Devices were found to be a non-significant contributor to risk. PSEG has reviewed the NEDO-31466, Supplement 1 risk assessment, considers it applicable to Hope Creek, and concurs with its conclusions. Additionally, the Final Policy Statement does not list Class 1 E Isolation Breaker Overcurrent Protective Devices among the four LCOs to be retained because operating experience or probabilistic risk assessment has shown them to be significant to public health and safety. Consequently, Class 1 E Isolation Breaker Overcurrent Protective Devices do not meet Criterion 4.
Class 1 E Isolation Breaker Overcurrent Protective Devices LCO does not meet any 10 CFR 50.36(c)(2)(ii) criterion as described above; therefore, it may be relocated to the UFSAR. All changes to the UFSAR are subject to evaluation in accordance with 10 CFR 50.59 provisions. 10 CFR 50.59 provides sufficient regulatory controls to address future changes to these requirements.
- 5.
REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration PSEG Nuclear LLC (PSEG) has evaluated whether or not a significant hazards consideration is involved with the proposed changes to Technical Specification (TS) 3/4.8.4.1 and TS 3/4.8.4.5 by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendments as discussed below:
- 1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response
No.
The proposed changes do not increase the probability of any previously evaluated accident. No safety function has been altered. The proposed changes relocate the Primary Containment Penetration Conductor Overcurrent Protective Devices Limiting Condition for Operation (LCO) and Class I E Isolation Breaker Overcurrent Protective Devices LCO requirements from the TS to the Hope Creek Generating Station Updated Final Safety Analysis Report (UFSAR). Relocation of the Primary Containment Penetration Conductor Overcurrent Protective Devices LCO and Class I E Isolation Breaker Overcurrent Protective Devices LCO requirements is consistent with the NRC Final Policy Statement on TS Improvements and 10 CFR 50.36. In part, the Final Policy Statement 7
ATTACHMENT 1 LCR H05-04 LR-N05-0030 provides screening criteria to evaluate TS requirements for the purpose of relocation to other licensee-controlled documents. LCOs which do not meet any of the Final Policy Statement criteria and any 10 CFR 50.36(c)(2)(ii) criteria may be proposed for relocation. The Primary Containment Penetration Conductor Overcurrent Protective Devices LCO and Class 1 E Isolation Breaker Overcurrent Protective Devices LCO requirements do not satisfy any of the Final Policy Statement screening criteria. The proposed changes do not affect any operational characteristic, function, or reliability of any structure, system, or component (SSC). Thus the consequences of accidents previously analyzed are unchanged between the existing TS requirements and the proposed changes.
Based upon the above, the proposed change will not involve a significant increase in the probability or consequences of an accident previously analyzed.
- 2.
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response
No.
The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated in the UFSAR. No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed changes. Specifically, no new hardware is being added to the plant as part of the proposed change, no existing equipment is being modified, and no significant changes in operations are being introduced.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
- 3.
Does the proposed change involve a significant reduction in a margin of safety?
Response
No.
The proposed changes will not alter any assumptions, initial conditions, or results of any accident analyses. The proposed changes relocate the Primary Containment Penetration Conductor Overcurrent Protective Devices LCO and Class 1 E Isolation Breaker Overcurrent Protective Devices LCO requirements from the TS to the UFSAR consistent with the NRC Final Policy Statement on TS Improvements and 10 CFR 50.36.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
8
ATTACHMENT 1 LCR H05-04 LR-N05-0030 Based on the above, PSEG concludes that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.
5.2 Applicable Regulatory Requirements/Criteria The following regulatory requirements are applicable:
10 CFR 50.36(c)(2)(ii) - A limiting condition for operation must be included in TS for any item meeting one or more of the following four criteria:
- 1. installed instrumentation that is used to detect, and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary;
- 2. a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier;
- 3. a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; and
- 4. a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
Existing TS requirements that fall within or satisfy any of the criteria in 10 CFR 50.36 must be retained in the TS, while those TS requirements that do not fall within or satisfy these criteria may be relocated to other licensee controlled documents. The Primary Containment Penetration Conductor Overcurrent Protective Devices LCO and Class 1 E Isolation Breaker Overcurrent Protective Devices LCO requirements do not meet any of the criteria set out in 10 CFR 50.36 and may therefore be eliminated from TS.
In conclusion, based on the considerations discussed above:
- 1) There is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner,
- 2) Such activities will be conducted in compliance with the Commission's regulations; and 9
ATTACHMENT 1 LCR H05-04 LR-N05-0030
- 3) Issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
- 6.
ENVIRONMENTAL CONSIDERATION PSEG has determined the proposed amendment relates to changes in a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or relates to changes in an inspection or a surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed change is not required.
- 7.
REFERENCES
- 1. The NRC has approved a similar license amendment for Millstone Nuclear Power Station, Unit 3 when it issued Amendment No. 192 on January 19, 2001 (TAC No. MA8747) 10
ATTACHMENT 2 LCR H05-04 LR-N05-0030 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES Hope Creek Affected Page List Index Page xiii Index Page xiv The following Technical Specifications for Hope Creek Generating Station Facility Operating License NPF-57 are affected by this change request:
Technical Specification Page TS 3/4.8.4.1 3/4 8-24 through 3/4 8-29 TS 3/4.8.4.5 3/4 8-41 through 3/4 8-43
INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SEC-ION PAGE 3/4.7.3 FLOOD PROTECTION......................................
3/4 7-9 Table 3.7.3-1 Perimeter Flood Doors.................
3/4 7-10 3/4.7.4 REACTOR CORE ISOLATION COOLING SYSTEM................. 3/4 7-11 3/4.7.5 SNUBBERS..............................................
3/4 7-13 Table 4.7.
- Snubber Visual Inspection Interval 3/4 7-17a Figure 4.7.:-1 Sample Plan 2) for Snubber Functional Test.3/4 7-18
.3/4.7.6 SEALED SOURCE CONTAMINATION...........................
3/4 7-19 3/4.7.7 MAIN TURBINE BYPASS SYSTEM............................
3/4 7-21 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES A.C. Sources-Operating.3/4 8-1 Table 4.8.1.1.2-1 Diesel Generator Test Schedule...
3/4 8-10 A.C. Sources-Shutdow.3/4 8-11 3/4.8.2 D.C. SOURCES D.C. Sources-Operating.3/4 8-12 Table 4.8.2.1-1 Battery Surveillance Requirements 3/4 8-15 D.C. Sources-Shutdown.3/4 8-17 3/4.8.3 ONSITE POWER DISTRIBUTION SYSTEMS Distribution -
Operating.3/4 8-18 Distribution -
Shutdown.3/4 8-21 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES Primary Containment Penetration Conductor Overcurrent Protective Devices( Iet4)......................
Table 3.8.4.1-1 Primary Containment Penetration Conductor Overcurrent Protective Devices.....
3/4 8-26 Motor Operated Valve Thermal Overload Protection (Bypassed)..........................................
3/4 8-30 HOPE CREEK xi.ii Amendment No. 123
INDEX LIMITING CONDITTONS T:R _?PERA-TN AND SURVEILLANICE REQUIREMENTS SECTIN P.:GE Mz tor ^perated Valve Thermal ^verlcad Protecticn IN:: Bypassed) 3,/4 6-38 Table 3.6.4. -1
^:^tr Operated Valves-Thermal Overload Protection (Not Bypassed).............
3;4 3-39 Reactor Protecticn System Electric Power Monitoring.....
3/4 8-40 Class lE Isol ti Breaker Overcurrent Protection Devices (rbni r:
M F' L
-rA g
3/4 8-41 38..51 lass lE Isolation Breaker Overcurrent
\\
Pr-t~cive Devices (Breaker Tripped by a Power Range Neutron Monitcring System Electric Power Mcnitoring..................
3/4 8-44 3/4.9 REFUELING OPE.AT'-CNS 3/4.9.1 REACTOR MODE SWITCH.....................
3/4 9-1 3/4.9.2 INSTRUMENTATIN.
3;4 9-3 3!4.9.3 CONTROL RCD P
_S:
-_.N 3/4 9-5 3,/4.9.4 DELETED.
3,4 9-6 3'4.9.-
3 4 9-7
,4.3.
0 DELE-TED.................................................
3/4 9-8 3i4.9.7
- ELETED.
3/4 9-10 3:4.9.8 *.ATER LEVEL -
REACTCR VESSEL............................
3/4 9-11 3/4.9.9 WATER LEVEL -
SPENT FSE:
STORASE-POOL....
3/4 9-12 3/4.9.10 CONTROL ROD REMOGAL Single Control Rod Removal..............................
3/4 9-13 Multiple Control Rcd Removal............................
3/4 9-15 HOPE CREEK
- x. v Amendment NC.137
( Pores3/4 8-25 tkrouq[
ELECTRICAL POWER SYSTEMS 3/4 8-2q he. beef, dJfe 3/4. 8,4. 1 DELETED RRIMARY CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES L\\IMTING CONDITION FOR OPERATION 3.8'.4. ll primary containment penetration conductor overcurrent pr zetiv devices own in Table 3.8.4.1-1 shall be OPERABLE.
/
APPLICABILI OPERATIONAL CONDITIONS 1, 2 and 3.
ACTION:\\_/
- a. With one or more of the primary containment penetration condu or overcurrent protective devi s shown in Table 3.8.4.1-1 inoperable, dec re the affected system or compone t inoperable and apply the appropriate ACION statement for the affected syste and l.For 4.16 kV circuit reakers, de-energize the 4.16 circuit(s) by tripping the associa d redundant circuit breaker ) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and verify the redundant c rcuit breaker to be tripp at least once per 7 days thereafter.
2.For 480 volt circuit break s, remove the i perable circuit breaker(s) from service by disconnecting the breaker ithin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and verify the inoperable breaker(s) to be di connected t least once per 7 days thereafter.
Otherwise, be in at least HOT SHUT X within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 ho s.
- b.
The provisions of Specification
.0.4 a e not applicable to overcurrent devices in 4.16 kV circuits whch have t ir redundant circuit breakers tripped or to 480 volt circuis which have the inoperable circuit breaker disconnected.*
SURVEILLANCE REQUIREMENTS 4.8.4.1 Each of the prima containment penetration co uctor overcurrent protective devices shown in Table 3.8.4.1-1 shall be dem strated OPERABLE:
- a.
At least onc per 18 months:
- 1.
By v ifying that each of the medium voltage 4.1 kV circuit bre ers are OPERABLE by performing:
A CHANNEL CALIBRATION of the associated protecti
/ relays, and\\
b) An integrated system functional test which includes lmulated automatic actuation of the system and verifying that each relay and associated circuit breakers and overcurrent c trol circuits function as designed.
A er being disconnected, these breakers shall be maintained disconnected nder administrative control.
HOPE CREEK 3/4 8 -24
ELsTIA POWER SYSTEMS/
SURVEL E REQUIREMENTS (Continued)/
- 2.
selecting and functionally testing a representat e sample of at east 10% of each type of lower voltage circui breakers.
Circu't breakers selected for functional testi shall be selected on a ro ting basis.
Testing of these circu& breakers shall consist o injecting a current with a valu between 150% and 300% of the ickup of the long time del trip element and verifying that he circuit breaker op ates within the time delay bandwidth r that current sp ified by the manufacturer.
The instantaneous ement shall b tested by injecting a current in excess of 120% the ickup v e of the element and verifying that the circuit breake tri instantaneously with no inten-tional time delay.
Molde ase circuit breaker testing shall also follow this procedu cept that generally no more than two trip elements, ti delay d instantaneous, will be involved.
Circuit it eakers foun inoperable during functional testing shall be stored to OPERA E status prior to resuming operation.
For ach circuit breaker ound inoperable during these functi al tests, an additional r resentative sample of at least 1 of all the circuit breakers the inoperable type shall al be functionally tested until no re failures are found all circuit breakers of that type ha been fun Tonally tested.
- b. At 1 st once per 60 months by subjecting each circuit br ker to an ection and preventive maintenance in accordance with pro dures repared in conjunction with its manufacturer's recommendation HOPE CREEK 3/4 8-25
PRIMARY CONT, OVERCUR
- 1.
416 VOLT CIRCUIT BREAKERS TABLE 3.8.4.1-1 AINMENT PENETRATION CONDUCTOR RENT PROTECTIVE DEVICES CIRCUIT SYSTEMS OR BREAKER NO.
LOCATION EQUIPMENT POWERED IAN205 1AN205 Reactor Recir lation Pump 1AP201 IBN205 IBN205 Reactor Rec ulation Pump 1BP201 1CN205 1CN205 Reactor Re rculation Pump IAP201 IDN205 IDN205 Reactor R circulation Pump IBP201
- 2.
480-VOLT MOLDED CAS CIRCUIT BREAKERS Primary and backup breaker have the same device umbers and are located in the same Motor Contr.ol Cente cubicle.
STEMS OR UIPMENT POWERED 52-411065 10B411 I\\N TM 52-451061 10B451 M
52-212021 10B212 IM VTM 52-212101 10B212 IM TM 52-212181 10B2 IM TM 52-212183 1 212 IM TM 52-232061 10B232 IM TM 52-232103 10B232 IM TM 52-232104 10B232 IM TM 52-232 1 10B232 IM TM 52-2182 10B232 IM TM 2-232183 10B232 IM Ii,
'B150 B150 RHR Head Spray Valve IBC-HV-F022 RHR Shutdown Cooling Suction Inboard Valve 1BC-HV-F009 HFB150 HFB150 HFB150 HFB150 HFB150 HFB150 HFB150 HFB150 HFB150 HFB150 HFB150 HFB15O HFB150 HFB150 HFB150 HFB150 HFB150 HFB15C RWCU Suction Isolation Inboard Valve 1BG-HV-FOO1 PCIGS Drywell Supply Header A solation Valve 1KL-HV-5152A M n Steam Line Drain Inboard Vale 1AB-HV-F016 PCIGS rywell Suction Inboar Valve IKL-HV-5148 Drywell ply Header A Isolation lye IKL-HV-5124A Drywell Equi Drain Sump Isolation Val IHB-HV-F019 HPCI Warmup Bypa s Line Isolation Valve 1 -HV-F100 Chilled Water Loop Supply Isolation Valve 1GB- -9531B1 Chilled Water Loop A Re urn
)
Isolation Valve lGB-HV-9 1B2 p
Chilled Water Loop B Suppl I
Isolation Valve IGB-HV-9531B I r HOPE CREEK 33/4 8-26
TABLE 3.8.4.1-1 (Continued)
PRIMARY CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES
- 2.
80-VOLT MOLDED CASE CIRCUIT BREAKERS (Continued)
CIRCUIT SYSTEMS OR BREAKER NO.
LOCATION TYPES EQUIPMENT POWERF/
52-232193 10B232 IM HFB150 Chilled Wate Loop B Return TM HFB150 Isolation lve 1GB-HV-9531B4 52-232203 10B232 IM HFB150 HPCI Tur ne Steam Supply TM HFB150 Isolat n Valve 1FD-HV-F002 52-242021 1 242 IM HFB150 Dryw 1 Floor Drain Sump TM HFB150 Iso ation Valve 1HB-HV-F003 52-242061 10B2 IM HFB150 ywell Supply Header B TM HFB150 solation Valve IKL-HV-5124B 52-242101 10B242 IM HFB150 PCIGS Drywell Supply Header B TM HFB150 Isolation Valve IKL-HV-5152B 52-242102 10B242 IM HFB15 RCIC Turbine Steam Supply TM HFB 0 Isolation Valve lFC-HV-F007 52-242103 10B242 H 150 RCIC Warmup Bypass Line TM FB150 Isolation Valve IFC-HV-F076 52-242172 10B242 H 150 Reactor Recirc Pumps Cooling TM HFB 0 Supply Isolation 1ED-HV-2554 52-242173 10B242 IM HFB1S Reactor Recirc Pumps Cooling TM HFB150 Return Isolation IED-HV-2556 52-252021 10B252 IM HFB150 Drywell Cooler A Fan 1A1V212 TM HFB150 52-252022 10B 2 IM HFB150 ell Cooler B Fan 1B1V212 TM HFB150 52-252031
.OB252 IM HFB150 Dryw 1 Cooler C Fan 1C1V212 TM HFB150 52-252032 10B252 IM HFB150 Drywell oler.D Fan lDlV212 TM HFB150 52-252041 10B252 IM HFB150 Drywell Coo r E Fan 1ElV212 TM HFB150 52-2520 10B252 IM HFB150 Drywell Cooler Fan 1FlV212 TM HFB150 52-2051 10B252 IM HFB150 Drywell Cooler G Fa lGIV212 TM HFB150 2-252052 10B252 IM HFB15O Drywell Cooler H Fan 1 V212 TM HFB150 HOPE CREEK 3/4 8-27
TABLE 3.8.4.1-1 (Continued)
PRIMARY CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE-DEVICES
- 2. 4 -VOLT MOLDED CASE CIRCUIT BREAKERS (Continued)
CIRCUIT SYSTEMS OR BREAKER NO.
LOCATION TYPES EQUIPMENT POWE 52-252063 10B252 IM HFB150 Drywell Equ Drain Sump Pump TM HFB150 IAP267 52-252064 B252 IM HFB150 Drywell loor Drain Sump Pump TM HFB150 1CP267 52-252073 108 2 IM HFB150 Feed ter Inlet A Shutoff TM HFB150 lA HV-FO11A 52-262021
.1OB262 IM-HFB150 ywell Cooler A Fan 1A2V212 TM HFB15O 52-262022 10B262 IM HFB150 Drywell Cooler B Fan 1B2V212 TM HFB150 52-262031 10B262 M HFB1 Drywell Cooler C Fan 1C2V212 T HFBj50 52-262032 10B262 IM B 50 Drywell Cooler D Fan 1D2V212 TM 50 52-262041 10B262 HF81 Drywell Cooler E Fan 1E2V212
/TM HFB15 52-262042 10B262 IM HFB150 Drywell Cooler F Fan 1F2V212 TM HFB150 52-262051 10B262 IM HFB150 rywell Cooler G Fan IG2V212 TM HFB150 52-262052 10B 2 IM HFB150 Dr 11 Cooler H Fan lH2V212 TM HFB150 52-262063 08262 IM HFB150 Drywell quip Drain Sump Pump TM HFB150 IBP267 52-262064 10B262 IM HFB150 Drywell Flo Drain Sump Pump TM HFB150 lDP267 52-253012*
10B253 IM HFB150 Recirc Pump Mot r Hoist IAH201 TM HFB150 Disconnect Switc 1AS204 52-2530 10B253 IM HFB150 Recirc Pump IBP201 uction TM HFB15O Valve IBB-HV-F023B 52-3031 10B253 IM HFB150 Recirc Pump IBP201 Dis arge TM HFB150 Valve IBB-HV-FO31B 2-253053 10B253 IM HFB150 Reactor Vessel Head Vent.
TM HFB150 Inboard Isolation 1BB-HV-FO HOPE CREEK 3/4 8-28
TABLE 3.8.4.1-1 (Continued)
PRIMARY CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES
- 2. 8 0-VOLT MOLDED CASE CIRCUIT BREAKERS (Continued)
CIRCU' SYSTEMS OR EQUIPMENT POWERED TYPES 52-253064 1OB253 IM HFB150 TM HFB150 52-263011 1 O263 IM HFB150 TM HFB150 Reactor Vessel Hea Vent to Steam Line 1BB-HV 005 Reactor Vessel ead Vent Outboard Isol ion 1BB-HV-F002 Recirc Pum Motor Hoist IBH201 Disconnec Switch IBS204 Main S am Relief Valve Hoist 10H20 Disconnect Switch 10S20, 52-263012*
10B26:
IM HFB150 TM HFB150 52-263042*
1OB263 HFB150 HFB150 7
52-263054 10B263 IM TM Suction from Recirc A lBG-HV-F100 52-263081 10B263 IM TM RWCU Suction from RPV Drain Valve lBG-HV-FlOl RWCU Suction Valve lBG-HV-F102 52-263082 10B263 IH TM 52-263083 1OB263 IM Suction from Recirc Loop Lve 1BG-HV-F106 52-264053 1OB264 4K HFB150 TM HFB150 52-264062 IM HFB150 TM HFBI50 52-264071 IH HFB150 TM HFB150 Reci Pump A Discharge Valve 1BB-F03lA Feedwate Inlet B Shutoff Valve 0E-
-F11B Reactor Reci Pump lAP201 Space Heater S220 Reactor Recirc P p lBP201 Space Heater 1BS2 Recirc Pump A Suctio Valve lBB-HV-F023A 52-264072 1OB264 IM HFB150 TM HFB150 1OB264 IM HFB150 TM HFB1so shall be administratively maintained open OPERATIONAL CONDITIONS 1, 2 and 3 and are not required to tested.
HOPE CREEK 3/4 B -29 Amendment No. 66
e Pows 3/4 8-42 Am oSy
/ 4 ~
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P 8-46hQ ech cle~lzeS
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ELECTRICAL POWER SYSTEMS 3/4 8.4.5 6
LE-TE.D IrkAS9 1E ISOLATION BREAKER OVERCURRENT PROTECTIVE DEVICESI/
L\\IK TING CONDITION FOR OPERATION//
3.8j45 All Class 1E isolation breaker (tripped by a LOCA siq>l overc fent protec ve devices shown in Table 3.8.4.5-1 shall be OPERAB APPLICAB ITY: OPERATIONAL CONDITIONS 1, 2 and 3.
ACTION:\\/
- a. Wit one or more of the overcurrent protective devices own in Table 3.8. 5-1 inoperable, declare the affected isolation b aker inoper-able a d remove the inoperable circuit breaker(s) fro service within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and verify the inoperable breaker(s) to be isconnected at least on per 7 days thereafter.
- b. The provisi ns of Specification 3.0.4 are not ap icable to over-current devi es in 480 volt circuits which have he inoperable cir-cuit breaker.sconnected.
SURVEILLANCE REQUIREMENTS 4.8.4.5 Each of the Class 1 isolation breaker ove urrent protective devices shown in Table 3.8.4.5-1 shall e demonstrated OPE ABLE:
- a. At least once per 18 m ths:
By selecting and functio ily testin a representative sample of at least 10% of each type of ower vol age circuit breakers.
Circuit breakers selected for funct nal sting shall be selected on a rotating basis.
Testing of t es circuit breakers shall consist of injecting a current with a val between 150% and 300% of the pickup of the long time delay trip el nt and a value between 150% and 250% of the pickup of the sh t tpe delay, and verifying that the circuit breaker operates wi in th time delay band width for that current specified by the m nufacture.
The instantaneous element shall be tested by injec ng a curren in excess of 120% of the pick-up value of the element nd verifying at the circuit breaker trips instantaneously with n intentional time delay.
Molded case circuit breaker testing shall also follow this pr edure except that gener-ally no more than t trip elements, time lay and instantaneous, will be involved.
or circuit breakers equi ed with solid state trip devices, the func-tional testing may be rformed with use of portable instru nts de-signed to verify the ti e-current character-istics and pic p calibra-tion of the trip eleme s. Circuit breakers found inopera e during functional testing shall restored to OPERABLE st us prior to resuming operation.
For e ch circuit breaker fo d inoperable during these functional tes, an additional represent ive sample of at least 10% of all the circut breakers of the mop rable type shall also be functionally tested u til no more failur are found or all circuit breakers of that type ye been funct nally tested.
- b. At ast once per 60 months by subjecting each circuit break r to an in ection and preventive maintenance in accordance with proceures p epared in conjunction with its manufacturer's recommendation HOPE CREEK 3/4 8-41
TABLE 3.8.4.5-1 CLASS 1E ISOLATION BREAKER OVERCURRENT PROTECTIVE DEVICES (BREAKER TRIPPED BY A LOCA SIGNAL) 480 VAC POW CIRCUIT BREAKERS/
- 1. TYPE AKR-5 0/
Class 1E Circuit ass 1E Breaker No.
us Non-Class.E Load Descri tio 52-41011 10B4 Reactor Auxiliaries Cooli
\\ System Pump 1AP209
/
52-41014 10B410 Radwaste and Service ea C 10B313/
52-41024 10B410 Reaotar Building pply Air Hand *ng Unit 1 H300 52-42011 10B420 Reactor uxilaries Cooling System Pu BP209 52-42014 10B420 Radwaste n Service Area 52-42024 10B420 Reac r Building Exhaust Fan 52-43024 10B430 actor Building Sup ly Air
/Hndling Unit ICVH300 52-43014 10B430 Control Rod Drive Pump 207 52-44014 10B 4 Control Rod Drive Pump 1BP2 52-44024 B440 Reactor Building Supply Air Handling Unit IAVH300 52-44034 10B440 Radwaste Area Supply Fan OBV316 52-4501 10B450 Reactor Area MCC 10B252 52-4 14 10B450 Radwaste Area Exhaust Fan OAV305
-45024 10B450 Emergency Instrument Air Compressor 10K100 HOPE CREEK 3/4 8-42
TABLE 3.8.4.5-1 (Continued)
OVAC POWER CIRCUIT BREAKERS
- 1. \\Tpe AKR-5A-30 (Continued)
CS ss 1E.
Cir it Class 1E/
Brea r No.
Bus Non-Class 1E Load Description 52-4503 10B450 Reactor Building Exhaust Fan 1CV 01 52-46011 108460 Reactor Area MCC 10B262 52-46014 1OB460 Radwaste Area Exhaust Fan 0 305 52-47011 1 470 Reactor Area MCC 108272 52-47014 10B4 Radwaste Area Exhaust an OCV305 52-47024 10B470 Radwaste Area Suppi Fan OAV316 52-47031.
108470 chnical Suppor Center MCC 008474 52-48011 108480 Rea or Area H 10B282 52-48024 10B480 React u
ing Exhaust Fan 1AV301 480 VAC MOLDED CASE CIRCUIT BREAKER
- 1. Type HFB150 Class 1E Circuit Class 1E Breaker No.
Bus on-Class 1E Load scription 52-441043 10B441 NSSS Computer Inverte 100485 52-451023 10B4.
Public Address System In rter 10D496 52-471023 1 471 Security System Inverter OA 495 PE CREEK 3/4 8-43
ATTACHMENT 3 LR-N05-0030 LCR H05-04 PROPOSED CHANGES TO TS BASES PAGES The following Technical Specifications Bases for Hope Creek Generating Station, Facility Operating License No. NPF-57, is affected by this change request:
Technical Specification Page Bases 3/4.8.4 B 3/4 8-3
TEL:
Sep 16'97 15:06 No.010 P.10 ELgCTRICAL POWER SYSTEM BASES A.C. SOURCES, D.C. SOURCES andONS= pOWER DISTRIBT Em (Continued)
Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8.2.1-1 is permitted for up to 31 days.
During this 31 day period:
(1) the allowable values for electrolyte level ensures no physical damage to the plates with an adequate electron transfer capability; (2) the allowable value for the average specific gravity of all the cells, not more than.020 below the manufacturer's recommended full charge specific gravity ensures that the decrease in rating will be less than the safety margin provided in sizing; (3) the allowable value for an individual cell's specific gravity, ensures that an individual cell's specific gravity will not be more than.040 below the manufacturer's full charge specific gravity and that the overall capability of the battery will be maintained within an acceptable limit; (4) the allowable value for an individual cell's float voltage, greater than 2.07 volts, ennures the battery's capability to perform its design function; (5) the TABLE 4.8.2.1-1 NOTATION 31 day ACTION time was derived taking into consideration that while battery capacity is degraded, sufficient capacity exists to perform the intended function while providing a time period adequate to permit full restoration of the battery cell parameters to normal limits.
3/4.a.4 ELECTRICAL EWIPMENT PROTECTIVE DEVICES Primary containment electrical penetrations and penetration conduct are p rxpted by demionstrating the OPERABILITY of primary and beck overcurrent ion circuit breakers by periodic surveill The surveill a
rements applicable otge circuit breakers provides assurance o aker relV t ty by testing one representative sample of each menu rs brand of circuit breaker.
Each manufacturer's molded case and a
case it breakers are grouped into representative samples w are than tested on ating basiE to ensure that all breakers sted.
If a wide variety ex.st in any manufacture rand of circuit breakers, it is necessary to that manu rer's breakers into groups and treat each group as a separ of aker for surveillance purposes.
-The OPERABILITY or bypassing of the motor operated valves thermal overload protection continuously or during accident conditions by integral bypass devices ensures that the thermal overload protection during accident conditions will not prevent safety related valves from performing their function.
The Surveillance Requirements for demonstrating the OPERABILITY or bypassing of the thermal overload protection continuously or during accident conditions are in accordance with Regulatory Guide 1.106 "Thermal Overload Protection for Electric Motors on Motor Operated Valves," Revision 1. March 1977.
The list of MOVa required to have thermal overload bypass circuitry is contained in UFSAR Table 8.3-11.
1 ROPE CREEK B 3/4 8-3 Amendment No. 103