LR-N17-0060, Application to Revise Technical Specifications to Adopt TSTF-535, Revise Shutdown Margin Definition to Address Advanced Fuel Designs.

Application to Revise Technical Specifications to Adopt TSTF-535, Revise Shutdown Margin Definition to Address Advanced Fuel Designs.

ML17086A071
Person / Time
Site:	Hope Creek
Issue date:	03/27/2017
From:	Carr E Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR H17-04, LR-N17-0060
Download: ML17086A071 (11)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 CPSEG NuclearLLC 10 CFR 50.90 LR-N17-0060 LAR H17-04 MAR 2 7* 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 HOPE CREEK GENERATING STATION RENEWED FACILITY OPERATING LICENSE NO. NPF-57 NRC DOCKET NO. 50-354

Subject:

APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-535, "REVISE SHUTDOWN MARGIN DEFINITION TO ADDRESS ADVANCED FUEL DESIGNS" Pursuant to 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for an amendment to the Technical Specifications (TS) for Renewed Facility Operating License No.

NPF-57 for Hope Creek Generating Station.

The proposed amendment modifies the TS definition of "Shutdown Margin" (SDM) to require calculation of the SDM at a reactor moderator temperature of 68°F or a higher temperature that represents the most reactive state throughout the operating cycle. This change is needed to address new Boiling Water Reactor (BWR) fuel designs that may be more reactive at shutdown temperatures above 68°F. provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked up to show the proposed changes. These proposed changes have been reviewed and approved by the Hope Creek Plant Operations Review Committee.

PSEG requests NRC approval of the proposed License Amendment within one year of submittal to be implemented within 60 days of issuance.

There are no regulatory commitments contained in this letter.

MAR 27-2017 10 CFR 50.90 Page 2 LR-N 17-0060 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), PSEG is notifying the State of New Jersey of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Mr. Lee Marabella at (856) 339-1208.

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

Executed on ---'3'--/ d--- '__7+-/"-J-o"-"-

(Date)

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Respectfully, c.__----"L------*

Eric Carr Site Vice President Hope Creek Generating Station Attachments:

1. Request for Changes to Technical Specifications

2. Technical Specification Page with Proposed Changes cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. MacEwen, Hope Creek Commitment Tracking Coordinator

LR-N17-0060 Attachment 1 Request for Changes to Technical Specifications

LR-N17-0060 LAR H17-04 HOPE CREEK GENERATING STATION RENEWED FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 License Amendment Request to Revise Technical Specifications to Adopt TSTF-535, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs" Table of Contents

1.0 DESCRIPTION

............... ....... ............. .. .... ...... . ........... ....... . .......... ... ........ .. 2 2.0 ASSESSMENT. ... ...... . . ....... . ...... ......... .... . ..... . . ............... ............... . ......... ... 2

2. 1 Applicability of Published Safety Evaluation............. ...... ................... . ....... 2 2.2 Optional Changes and Variations......... ....... ...... ....... . ..... .......................... 2

3.0 REGULATORY ANALYSIS

....... ............................ ....... ..... ..... ............ .......... 3 3.1 No Significant Hazards Consideration Determination....... ... ........................... 3 3.2 Conclusions.. ................. . ...... ........ . .... ..... .......... .. ... ... . ... .. .... . . . . ... . ..... ...... 4

4.0 ENVIRONMENTAL CONSIDERATION

. . ........... ........ ................ . ...... ......... ....... 4

5.0 REFERENCES

..... .......... ........ ...... ........ .... . .............. ...... ..... ........... ... ........ .. 4 Page 1

LR-N17-0060 LAR H17-04 1 .0 DESCRIPTION The proposed amendment modifies the Technical Specifications (TS) definition of "Shutdown Margin" (SDM) to require calculation of the SDM at a reactor moderator temperature of 68°F or a higher temperature that represents the most reactive state throughout the operating cycle.

This change is needed to address new Boiling Water Reactor (BWR) fuel designs that may be more reactive at shutdown temperatures above 68°F.

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation PSEG Nuclear LLC (PSEG) has reviewed the model safety evaluation dated February 19, 2013 (Reference 5.2), as part of the Federal Register Notice of Availability. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-535 (Reference 5.1) As described in the subsequent paragraphs, PSEG has concluded that the justifications presented in the TSTF-535 proposal and the model safety evaluation prepared by the NRC are applicable to Hope Creek Generating Station and justify this amendment for the incorporation of the changes to the plant TS.

2. 2 Optional Changes and Variations PSEG is not proposing any significant variations or deviations from the TS changes described in TSTF-535, Revision 0, or the applicable parts of the NRC's model safety evaluation dated February 19, 2013.

The Hope Creek TS definition of SDM is being updated to correspond with the wording and format proposed in TSTF-535, Revision 0. Hope Creek's TS are based on NUREG-0123, Standard Technical Specifications for General Electric Boiling Water Reactors, and, therefore, the wording and format varies slightly from NUREG-1433, Standard Technical Specifications General Electric BWR/4 Plants, shown in TSTF-535, Revision 0, and the applicable parts of the NRC's model safety evaluation.

The Hope Creek TS utilize different numbering than the Standard Technical Specifications on which TSTF-535 was based. Specifically, definitions in the Hope Creek TS are in Section 1 vice Section 1.1 and the definitions are numbered.

The Standard Technical Specifications format and definition, as modified by TSTF-535, are proposed to be adopted into the Hope Creek TS. The NUREG-1433 definition of SDM includes the sentence, "With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM." This is not explicitly stated in the current Hope Creek TS SDM definition, but is addressed in Hope Creek TS SURVEILLANCE REQUIREMENT 4.1.1.c which requires Shutdown Margin to be verified acceptable with an increased allowance for the withdrawn worth of an immovable or untrippable control rod.

The minor variations are administrative and do not affect the applicability of TSTF-535 to the Hope Creek TS.

Page 2

LR-N17-0060 LAR H17-04

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination PSEG Nuclear LLC (PSEG) requests adoption of TSTF-535, Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs," which is an approved change to the Standrd Technical Specifications (STS), into the Hope Creek Technical Specifications (TS).

The proposed amendment modifies the TS definition of "Shutdown Margin" (SDM) to require calculation of the SDM at a reactor moderator temperature of 68°F or a higher temperature that represents the most reactive state throughout the operating cycle.

PSEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," 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 change revises the definition of SDM. SDM is not an initiator of any accident previously evaluated. Accordingly, the proposed change to the definition of SDM has no effect on the probability of any accident previously evaluated. SDM is an assumption in the analysis of some previously evaluated accidents and inadequate SDM could lead to an increase in consequences of those accidents. However, the proposed change revises the SDM definition to ensure that the correct SDM is determined for all fuel types at all times during the fuel cycle. As a result, the proposed change does not adversely affect the consequences of any accident previously evaluated.

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

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 change revises the definition of SDM. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operations. The change does not alter assumptions made in the safety analysis regarding SDM.

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

Page 3

LR-N 17-0060 LAR H17-04

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change revises the definition of SDM. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The proposed change ensures that the SDM assumed in determining safety limits, limiting safety system settings or limiting conditions for operation is correct for all BWR fuel types at all times during the fuel cycle.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, PSEG concludes that the proposed change presents 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.

3.2 Conclusions 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 (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change 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 change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

5.0 REFERENCES

5. 1 TSTF-535-A, Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs," dated August 8, 2011 5.2 Notice of Availability of the "Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-535, Revision 0, 'Revise Shutdown Margin Definition to Address Advanced Fuel Designs,' Using the Consolidated Line Item Improvement Process," dated February 26, 2013 Page 4

LR-N17-0060 Attachment 2 Technical Specification Page with Proposed Changes

LR-N17-0060 LAR H17-04 TECHNICAL SPECIFICATION PAGE WITH PROPOSED CHANGES The following Technical Specification for Renewed Facility Operating License NPF-57 is affected by this change request:

Technical Specification Definition

1. 40 1-7

OEF'IN!TIONS

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• I SECONDARY

-.:a:. v CONTAINMENT INTEGRITY '

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1.39 SECONDARY CONTAINMENT !HEGITY shall exist when:

a. All secondary containment penetrations required to be clo$ed during accident conditions ara either:'

1.

• Capable of b.eing closed by an OPERABLE secondary containment automatic tsalatlon system, or*

2. Closed by at least one manual valve, blind flange, or deactiv.;tect automatic valve ar damper, as applicable secured in its closed position, except as provid$d in Tab1e 3.6.5.2*1 of

• Specification 3.6.!.2.

b. All secondary containment hatches and blowa1t p.aoe*ls are closed and sealed.

c. The filtration, reeircu1ation and yentil ation system Is in compliance with the requirements of Specification 3.6.5.3.

d. For doub 1e door arrangements, at least one door in each access to the secondary containment is closed .

• e. For single door arrangements, the door in each acc:ess to the secondar*y containment is closed, excep-t for normal entry and exit.

f. Th sealing mechanism usoeiated with each secondary cantainment penetration, e.g., welds, b11aws or orings, is OPERABLE. .

g. The prassure within the secondary containment is less than or equal td the value required by Specification 4.6.5.l.a.

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1.40TD.WN Gt y by w subcri al or wou 4'be subcri 1't'Ca1. usumj,!'l'Q a11 con ol rods are ul1y l ed except or the sin a contro r6d of high t reac:tivt worth

. h is ass . d to be f y withdr fl and the r ctor is in he shutdoy,f'(

d tionj old, i.e. F; and on free.

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SITE BOUNDARY 1.41 The SITE BOUNDARY shall be that line beyond which the land is neither owned, nor leased, nor otherwise contro11ed, by the licensee .

HOPe CREEK Amendment No.34

LR-N 17-0060 LAR H17-04 Insert 1 SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon free;

b. The moderator temperature is :::: 68°F, corresponding to the most reactive state; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

I

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