LR-N04-0260, Response to Request for Additional Information Request for Change to Technical Specifications Reactor Protection System Instrumentation, Control Rod Block Instrumentation, Source Range Monitors and Power Distribution Limit Surveillance.
| ML041890311 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/29/2004 |
| From: | Bakken A Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LCR H03-02, LR-N04-0260 | |
| Download: ML041890311 (8) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 0 PSEG JUN 2 9 2004 NuclearLLC LR-N04-0260 LCR H03-02 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS REACTOR PROTECTION SYSTEM INSTRUMENTATION, CONTROL ROD BLOCK INSTRUMENTATION, SOURCE RANGE MONITORS AND POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354
Reference:
LR-N03-0405, "Request for Change to Technical Specifications: Reactor Protection System Instrumentation, Control Rod Block Instrumentation, Source Range Monitors and Power Distribution Limits Surveillance Requirements," dated October 24, 2003.
By the referenced letter, PSEG Nuclear LLC (PSEG) requested a revision to the Technical Specifications (TS) for the Hope Creek Generating Station to revise the Surveillance Requirements (SRs) for certain Reactor Protection System and Control Rod Block Instrumentation, the source range monitors and power distribution limits. In a communication from Mr. D. Collins on May 7, 2004, and a subsequent telephone conference on May 12, 2004, the NRC requested additional information concerning the proposed change. The requested information is provided in the attachment to this letter. In accordance with 10CFR50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey.
PSEG has determined that the information contained inthis letter and attachment does not alter the conclusions reached in the IOCFR50.92 no significant hazards analysis previously submitted.
95-2168 REV. 7199
Document Control Desk 2- JUN 2 92004 LR-N04-0260 If you have any questions or require additional information, please contact Mr. Paul Duke at (856) 339-1466.
I declare under penalty of perJury that the foregoing is true and correct.
Executed on 6 9-o-a y A. C. _____
(date) C. Bakken III Sr. Vice President - Nuclear Operations Attachment
Document Control Desk JUN 2 9 2004 LR-N04-0260 C: Mr. H. Miller, Administrator- Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Collins, Project Manager - Salem & Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 08C2 Washington, DC 20555 USNRC Senior Resident Inspector- Hope Creek (X24)
Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625 LR-N04-0260 LCR H03-02 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REACTOR PROTECTION SYSTEM INSTRUMENTATION, CONTROL ROD BLOCK INSTRUMENTATION, SOURCE RANGE MONITORS AND POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS By letter dated October 24, 2003, PSEG Nuclear LLC (PSEG) requested a revision to the Technical Specifications for the Hope Creek Generating Station to revise the Surveillance Requirements (SRs) for certain Reactor Protection System and Control Rod Block Instrumentation, the source range monitors and power distribution limits. In a communication from Mr. D. Collins on May 7, 2004, and a subsequent telephone conference on May 12, 2004, the NRC requested additional information concerning the proposed change. PSEG's responses are provided below.
l.a Section 3.A.1 of the application (page 5), states that the requirement to perform the Average Power Range Monitor (APRM) Flow Biased Simulated Thermal Power-Upscale channel functional test and the APRM Fixed Neutron Flux-Upscale channel functional test within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to startup causes the diversion of plant personnel and resources for unnecessary testing. The application states that the quarterly test frequency provides sufficient assurance of proper functioning. Provide quantitative data from the aforementioned channel functional tests, proving sufficiency over recent cycles.
PSEG Response:
Conditions that could affect the ability of the APRMs to perform their required functions are typically self revealing (e.g., by upscale or downscale alarms) or identified during channel calibrations, channel checks, or routine operator monitoring of control room instrumentation.
Plant operating experience demonstrates the periodic test frequencies provide sufficient assurance the APRMs are functioning properly. In October 2001 a loose connector to the Redundant Reactivity Control System (RRCS) was identified during a channel functional test performed before plant startup. The connector was repaired and the test was completed satisfactorily; however, this condition did not represent a failure to satisfy a channel functional test acceptance criterion and would not inhibit the RRCS function. For the APRM Flow Biased Simulated Thermal Power-Upscale and APRM Fixed Neutron Flux-Upscale trip functions, a review of surveillance test results for the last three years identified no case in which a condition discovered during a periodic channel functional test would have prevented the APRMs from performing their required function.
Attachment I LR-N04-0260 LCR H03-02 1.b Similarly, provide quantitative data from the Rod Block Monitor (section 3.B.1, page 6), APRM (section 3.B.2, page 6), and Reactor Coolant System Recirculation Flow (section 3.B.2, page 6) channel functional tests proving sufficiency over recent cycles.
PSEG Response:
For the Rod Block Monitor (RBM), a review of surveillance test results for the last three years identified no case in which a condition discovered during a periodic channel functional test would have prevented the RBM from performing its required function. A channel functional test in February 2000, identified a failing multiplexer card which prevented the LPRM count circuit from functioning properly (RBM inop would not reset). The multiplexer card was replaced and the remainder of the functional test was completed satisfactorily. In December 2003, a failing power supply was identified during a channel calibration that was performed to resolve an unexplained difference in local flux levels between RBM channels observed during normal plant operation.
For the APRM control rod block trip functions, a review of surveillance test results for the last three years identified no case in which a condition discovered during a periodic channel functional test would have prevented the APRMs from performing their required function.
In July 2001, a defective test card pushbutton switch was identified during a Reactor Coolant System Recirculation Flow channel functional test. The test card was replaced and the functional test was completed satisfactorily. A review of surveillance test results for the last three years identified no other case in which a condition discovered during a periodic channel functional test could have prevented a Reactor Coolant System Recirculation Flow Unit from performing its required function.
- 2. The proposed amendment would revise TS Table 4.3.1.1-1 to allow performance of the APRM Neutron Flux - Upscale, Setdown channel functional test to be deferred for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Section 3.A.2 of the application (page 6), reviews the limitations concerning APRM Setdown channel functional tests when entering an Operational Condition. The application states: "The current Surveillance Requirement can increase the potential for a plant transient." The staff requires an explanation of this statement, including how the current Surveillance Requirement increases transient potential, and why it must be amended.
Discuss, in quantitative terms, how much the proposed amendment would reduce the potential for plant transients and explain why the proposed changes would not compromise plant safety.
PSEG Response:
The APRM Upscale Setdown trip is enabled when the Reactor Mode Switch is not in the "run" position. In Operational Condition 1,the APRM channel Attachment I LR-N04-0260 LCR H03-02 functional tests require lifting leads and installing test switches in the Power Range Monitor cabinets to permit testing the Upscale Setdown function because Reactor Mode Switch is in the "run" position. In Operational Conditions 2, 3, 4 and 5, the channel functional test can be performed without lifting leads because the Reactor Mode Switch is not in the "run" position.
While procedural controls are maintained for the installation and removal of test switches, and while PSEG employs a variety of techniques aimed at reducing the frequency of human performance related events, each instance of lifting and relanding leads in the Power Range Monitor cabinets still carries some small potential to cause plant transients due to human error.
The proposed 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides a reasonable time in which to complete the functional test under conditions in which the potential for a plant transient is reduced without compromising plant safety, since the most probable result of performing the functional test is the verification of conformance with the TS requirements. A review of surveillance test results for the last three years identified no failures for the weekly channel functional test.
- 3. Section 3.D of the application (page 7), states that SR 4.2.1.b, 4.2.3.b, and 4.2.4.b create confusion as to how often surveillance is required. The proposed solution involves removing the offending requirement. The NRC staff is not reassured that the suggested revision addresses potential thermal power increases of at least 15% of Rated Thermal Power. Justify why requirements 4.2.1 b, 4.2.3.b, and 4.2.4.b should be removed rather than reworded to clarify how often surveillance is required.
PSEG Response:
The proposed change to verify power distribution limits within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of reaching or exceeding 25% of rated thermal power (RTP) will require the surveillances to be performed sooner during plant startup than under the current Surveillance Requirements.
During plant startup, the planned power increase most often is ascent to RTP.
Since plant startup and ascension to RTP typically take more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, deleting the requirements to verify power distribution limits within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after completion of a thermal power increase of at least 15% of RTP will have a negligible effect on the frequency of performing the surveillances during plant startup.
During normal plant operation, return to RTP following a downpower maneuver of at least 15% of RTP is typically accomplished over several hours, so the effect of the proposed change on the frequency of performing the surveillances would again be expected to be negligible.
LR-N04-0260 LCR H03-02
- 4. The proposed amendment would revise TS Table 4.3.6-1, to allow performance of the Reactor Mode Switch Shutdown Position channel functional test to be deferred until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the Reactor Mode Switch is inthe shutdown position.
The application states that it is necessary to use jumpers or lifted leads to perform the functional test prior to a planned shutdown. Provide justification in terms of the reactor safety to defer this functional test until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the Reactor Mode Switch is in the shutdown position.
PSEG Response:
Under the current TS requirements, a planned entry into Operational Condition 3 from Operational Condition 1 or 2 would be prohibited if the functional test had not been performed within the required interval. Performance of the Reactor Mode Switch Shutdown Position control rod withdrawal block functional test in Operational Condition 1 or 2 would require extensive use of temporary jumpers or lifted leads with the attendant small potential for plant transients due to human error.
The proposed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allowance provides a reasonable time in which to complete the functional test under conditions in which the potential for a plant transient is reduced without compromising plant safety, since the most probable result of performing the functional test is the verification of conformance with the TS requirements. A review of surveillance test results for the last three years identified no failures for the Reactor Mode Switch Shutdown Position channel functional test.
- 5. The proposed amendment would revise SR 4.3.7.6.b by deleting the requirement to perform the source range monitor channel functional test prior to moving the Reactor Mode Switch from the Shutdown position. SR 4.9.2.b would be revised by deleting the requirement to perform the source range monitor channel functional test prior to the start of core alterations. The application states that these tests are unnecessary. Provide justification these tests to be unnecessary.
PSEG Response:
The surveillance requirements proposed to be deleted are unnecessary because they are conditioned on events that do not affect the ability of the SRMs to perform their required function and because the remaining SRs continue to provide adequate assurance of operability.
Neither starting core alterations nor moving the Reactor Mode Switch from the "Shutdown" position affects the ability of the SRMs to provide the operator with information on the status of the neutron level in the core. The SRM indication function is unaffected by the position of the Reactor Mode Switch. SRM alarms and interlocks are bypassed when the Reactor Mode Switch is in the "Run" position. In Operational Conditions 3 and 4, the Reactor Mode Switch would typically be moved from the "Shutdown" position to the "Startup" position (to Attachment I LR-N04-0260 LCR H03-02 enter Operational Condition 2) or to the "Refuel" position (to withdraw or recouple a single control rod as allowed in TS Table 1.2).
The proposed change does not affect the periodic test frequency for SR 4.3.7.6 or SR 4.9.2.b. SR 4.0.4 continues to require the Surveillance Requirement(s) associated with each Limiting Condition for Operation to be performed within the applicable surveillance interval before entry into an Operational Condition or other specified applicable condition.
Plant operating experience demonstrates the periodic test frequencies provide sufficient assurance the SRMs are functioning properly. Conditions that could affect the ability of the SRMs to perform their required functions are typically self revealing (e.g., by upscale, downscale or period alarms) or identified during channel checks, or routine operator monitoring of control room instrumentation.
In March 2003, a failing period alarm relay was identified when a period status lamp would not reset during a channel calibration performed before plant shutdown. The relay was replaced and the test was completed satisfactorily; however, this condition did not represent a failure to satisfy a channel functional test acceptance criterion. One SRM channel was observed to be downscale during a monthly channel functional test in March 2003. The SRM discriminator was recalibrated to restore the channel to operable status; however, this condition did not represent a failure to satisfy a channel functional test acceptance criterion.
A review of surveillance test results for the last three years identified no case in which a condition discovered during a periodic channel functional test would have prevented the SRMs from performing their required function.