ML20058C606

Rev to Application for Amend to License NPF-57 Proposing Changes to Ts,Per Method Utilized in New STS

ML20058C606
Person / Time
Site:	Hope Creek
Issue date:	11/16/1993
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20058C610	List: ML20058C606 ML20058C634
References
NLR-493161, NUDOCS 9312020506
Download: ML20058C606 (12)

Text

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f a-Pubhc Servo E+ cur, and Gas Company Joseph J. Hagan Public Servoe Electnc and Gas Company P o. Box 230 Hancocks Bridge, NJ 08036 609-3394200 mm.-.m.~' ~~

OV161993 NLR-N93161 Revision te LCR 92-10

-j United States Nuclear Regulatory Commission i

Document Control Desk Washington, DC 20555 Gentlemen:

REVISION TO LICENSE AMENDMENT APPLICATION INSTRUMENTATION REQUIREMENTS FOR SINGLE LOOP OPERATIONS FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 This letter submits a revision to the application for amendment to Appendix A of Facility Operating License NPF-57 for the Hope Creek Generating Station filed in NLR-N92187, dated February 2, 1993 (LCR 92-10).

Specifically, the changes to the Bases for Specification 3.0.2 are being retracted,'and a new Specification 3.0.5 and its associated Bases are being proposed.

The original changes and the revised changes both have the same intent and achieve the same objective; however, the revised changes proposed in this letter are consistent with the method utilized in the new Standard Technical Specifications (NUREG-1433). includes a revised description of and justification for the proposed changes.

The revision does not impact our conclusion that the proposed changes'do not involve a significant hazards consideration, nor does it affect our basis'for drawing i

this conclusion.

Revised marked up Technical Specification pages which reflect the proposed changes are included in Attachment 2. provides a summary of the differences between our revised amendment application and our original amendment i

application.

In accordance with the requirements of 10 CFR 50.91(b) (1), a copy l'

of this submittal has been sent to the State of New Jersey as indicated below.

Upon NRC approval, PSE&G requests that'the j

license amendment be made effective as of the date issuance but that a sixty day implementation period be provided in order to allow sufficient time to complete associated administrative activities.

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9312020506 931116 (k)f PDR ADOCK 05000354-P PDR V

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NOV161993 Document Control Desk 2

NLR-N93161 Should you have any questions or comments on this submittal, please do not hesitate to contact us.

Since ely,

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i Affidavit Attachments (3) 1 C

Mr.

T.

T.

Martin. Administrator - Region I U._S.

Nuclear Regulatory Commission 475 Allendale Road r

King of Prussia, PA 19406 Mr.

S.

Dombek, Licensing Project Manager U.

S.

Nuclear Regulatory Commission j

One White Flint North 11555 Rockville Pike i

Rockville, MD 20852 i

Mr.

C.

S. Marschall (SO9) i USNRC Senior Resident Inspector i

Mr.

K.

Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 i

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REF: NLR-N92161 i

Revision to LCR 92-10 I

STATE OF NEW JERSEY

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SS.

i COUNTY OF SALEM

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J.J.

Hagan, being duly sworn according to law deposes and says:

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I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set l

forth in the above referenced letter, concerning the Hope Creek Generating Station, are true to the best of my knowledge, j

information and' belief.

i Subscribed and Sworn to before me I

thic/[pdb day of /7th1AM/X4,1993 hlin sfAk b@JA G

/lotary Pubfio of New Jersey

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KIMBERLYJD BROWN My Commission expires on-N0JARY PUBilC OF NEW JERSEY my Lummis51Dn Lapile! Aptd D, W35 i.

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ATDCIME2R 1 IYOPOSID 0WGES 'IO 'IHE TDORIICAL SPDCIFICATIOtB 4

REVISIQi 'IO IlG2GE AME2iINDE APPLICATIQi D6HUME271ATIQi REUHREME2iIS FOR SDUIE IDOP OPERATIQB IDPE GEEK CE2TEIMTDU SIATIQi F7CILTIY OIERATDC IJCDEE NPF-57 NIR-N93161 D000210. 50-354 REVISIQi 'IO IIR 92-10 I.

DESGTPIIQi OF 'IME PROPOSED OWEES A.

Simle Inoo Operations Revise Specification 3.4.1.1, "RECIRQHATIGI SYSTD4 - RECIRWIATIQi IDOFS", to delete existing Action "a.1.e" and incorporate the affected requirenents into new Actions "a.2",

"a.3", and "a.4" as modified below:

Action "a.2" will pertain to the Average Power Range Monitor (APRM) scram setpoints and require the applicable setpoints to be rMnmei to those applicable for single recirculation loop operation within four hours of l

entering sirgle loop operations.

If the setpoints associated with one I

trip system are not reduced within four hours, the affected trip system l

must be placed in the tripped condition and, within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the remaining setpoints must be reduced.

Action "a.3" will pertain to the Average Power Range Monitor (APRM) rod block setpoints and require the applicable setpoints to be reduced to those applicable for single recirculation loop operation within four i

hours of enterirg sirgle loop operations. If the setpoints associated l

with one trip function are not reduced within four hours, at least one of the affected channels must be placed in the tripped condition and, within the follwing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the remainiry setpoints must be reduced.

Action "a.4" will pertain to the Rod Block Monitor (RH4) trip setpoints and require the applicable setpoints to be reduced to those applicable for single recirculation loop operation within four hours of enterirg i

single loop operations. If the setpoints associated with one trip function are not reduced within four hours, at least one affected channel must be placed in the tripped cordition and, within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the runainirg setpoints must be reduced.

B.

Power Ascension Prot 7ran Data l

Revise the followirg specifications to change the value of delta-w for single loop operation from "To be detemined at a later date" to 9%:

Specification 2.2.1, "PIACIOR PROTDCTIQi SYSTD4 DETRLME2iTATIQi SETPODTIS", Table 2.2.1-1 Specification 3.2.2, "APRM SLTPODTIS" Page 1 of 9

' Attachment 1 Revision'to LCR 92-10 Instrumentation Requirements for SLO NIR-N93161 i

P Pavise the follwirq specifications to change the value of minuum thermi poser corresponding to corditions in which no tenperature stratification occurs from 530% to 538% and delete the associated footnote (the 50% value for rcx:irculation flow in the operating loop has l

been established as the correct final value):

Specification 3.4.1.1, "RDCIRCUIATIQi SYSTD4 - RECIRCULATIQi i

IDOFS", Action "a.1.g" and Surveillance 4.4.1.1.2 Bases Section 3/4.4.1, "Rf: CIRCULATION SYSTDi" Revise the following specifications to charge the value of core flow with j

both Rocirculation Pumps at minimum speed from 39% to 40% ard delete the associated footnote:

4 Specification 3.4.1.I, "RECIRCUIATIGT SYSTD1 - RECIRCUIATIQi 1001G", Actions "c" ard "d" and Surveillance 4.4.1.1.1.

C.

Srecification 3.0.5 Add limiting Cordition for Operation (ILO) 3.0.5 of NUREG-1433 to the Hope Creek 'ISs.

We new 100 3.0.5 would state the following:

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" Equipment removed from service or declared inoperable to comply.with ACTIGE may be returned to servloe urder administrative control solely l

to perform testing required to dau= Late its OPERABIIZTY or the OPERABIIJTY of other equipment. his is an exception to ILO 3.0.2 for the system returned to service urder administrative control to perform the testirg required to duuusixote OPERABIllTY."

Incorporate Ihses for IID 3.0.5 which are similar to the NURD3-1433 2

Bases. W e new Bases would state the following:

"SpecifLcation 3.0.5 establishes the allowance for restorirg equignent to service urder administrative controls when.it has been removed fram service or declared inoperable to comply with ACTIOtE. 'Ihe sole l

purpose of this Specification is to provide an exception to If0 3.0.2 (e.g., to not comply with the applicable Required Action (s)) to allow the perforrance of testirg required to restore ard duuerobate:

i a.

% e OPERABILITY of the equipment being returned to service; i

or b.

W e OPERABIllTY of other equipment.

i n e administrative controls ensure the tine the equipment is returned

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to service in conflict with the requirements.of the ACTIGE is limited 1

to the time absolutely r-mq to perform the testirg required to.

restore and demonstrate the OPERABILITY of the equipwnt. This Specification does not provide time to perform any other preventive or j

corrective maintenance.

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' Attachment 1 Revision to LCR 92-10

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Instrumentation Requirements for SLO NLR-N93161 An exarple of demonstrating the OPERABIIIIY of the equipment being returnxl to serviors is reopening a containnent isolation valve that has been closM to comply with Rogainxi Actions ard must be reopened to perform the testire required to restore and denobate OPERABILITY.

An exarple of demonstratiry the OPERABILITY of other equipment is takirg an !noperable channel or trip system out of the tripped condition to prevent the trip function from ocwrrirg during the performance of testing required to restore OPERABIIIIY on another chanrel in the other trip system. A similar example of darsuttating the OPERABILITY of other equiptrent is taking an im%1e channel or trip system out of the tripped condition to permit the logic to function ard indicate the appropriate response during the perfomance of testing required to restore ard decbLrate OPERABILITY on another channel in the same trip system."

Iro 3.0.5 is applicable to all Technical Specifications; however, the intent of IID 3.0.5 is not to supemede more specific guidance containcd within any individual specification.

II.

RPRXN IUR 'IHE PROIOGED OWC _F3 b.

Simle 1000 Operations Specification 3.4.1.1, Action "a.1.e" currently requires the APRM Scram ard Rob Block setpoints and RTM setpoints be rMocM to those applicable for sirgle locp operations within four hours of entering sirgle loop operations. Due to the anount of time required to actually perfom these actions and complete the associated surveillance testirg, this time limit becanes overly restrictive when sirgle loop operations is entered due to an unanticipated trip of a Recirculation Pump

'Ihe changes that are proposed in this submittal provide conservatius alternative actions that would provide additional time to reduce the subject setpoints and perfom associated surveillance tests.

B.

Power Ascension Pnmum Data

'Ibe values prncently provided in Technical Specifications for delta-w for l

sirgle loop operation, mininum thermal power couespcu.liry to corditions in which no tenperature stratification occurs, and core flat with both Recimulation Pumps at minimum speed are initial values that wem established prior to startup testirg. Final values have now been detemined and this ancrdment ruquest therefore seeks to incorporate those values.

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Sngelfication 3.0.5 PSE&G believes that it is not the intent of IID 3.0.2 that conformance to the action requirenents for equipvent renoved from service or declared inoperable preclude the perfornmce of surveillance testing to denonstrate the operability of that or other equipment. 'Iherefore, the new IfD 3.0.5 and its associated Bases are being proposed.

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.-Attachment 1 Revision to LCR 93-10 i

Instrumentation Requiremcats for SLO NLR-N93161

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m. JUSTJFIOTIOi ICR YHE IBOIMID 0%2S A.

Sirgie I000 Operations l

Specification 3.4.1.1, Action "a.1.e" currently requires the APRM Scram and Rod Block setpoints ard RH4 setpoints to be reduced to those applicable for sirgle loop operations wiUtin four hours of errsirg s.4rgle loop operations. The affected setpoints are associated with the flow-biased simulated thermal pcuer upschle functions of the subject instrumentation. After the setpoints are reduced, associated surveillance tests must be canpleted to verify operability of the instruments with the reduced setpoints in order to comply with this action statement.

Due to the amount of time requirud to actually perform these actions ard complete the associated surveillance testirn, the four hour time limit becones overly restrictive when single loop operations is entered due to an unanticipated trip of a recirculation pump.

If these actions cannot be conpleted within four hours, Specification 3.4.1.1, Action 3 requires the plant to be placcd in at least hot shutdcun within the next twelve hours. The charges that are proposed in 3is submittal would provide a conservative alternate course of action that would provide additional time to reduce the subject setpoints and perform associated surveillance tests.

In accordance with the proposed charges, the requirement to reduce the subject setpoints within four hours of enterirg siIgle loop operations would still exist. However, provisions would be added such that, with the setpoints of a single trip systcyfunction associated with each of the three instrumentation groups (i.e., APRM Scram a-d Rod Block and RH4) not ITduced within fcur hours, that trip systeyfunct m would be placed in the tripped cordition. The setpoints of that insta unentation would then be required to be reduced to the applicable values within the following six b s.

propocod actions, upon unanticipated entry into In accordance w.

4 sirgle loop operat us, attenpts would be made to reduce the setpoints of all specified instlunentation within four hours. As a minimum, the setpoints of at least one trip systeyfunction associated with each of _

the three instrumentation groups (i.e., APRM Scram and Rod Block ard RB4) would be reduced and surveillance tects completed. The remainiry trip systcW5tnction(s) would be placed in the tripped condition. They would.

remain in the tripped cordition txcept as required to be taken out of the tripped condition durirg perfornmce of the associated surveillance tests.

By conservatively requiring the setpoints of at least one trip systeyfunction per instrunentation group to be reduced to those applicable for single loop operations ard the other trip systeyfunction to be placed in the tripped condition, thert. is nrance that a scram and/or rod block would be initiated by the APRris ard/or RH4 if the reducrd setpoints arn reached. This condition could exist for up to six hours at which time n,

remainiry setpoints would be required to be reduced.

Page 4 of 9

-Attachment 1 Revision to LCR 92-10

' Instrumentation Requirements for SLO NLR-N93161 3

'Ihese proposed charges would provide a rore reasonable amount of tire to take the required actions than the current action requirements while presenting no negative impact on plant safety.

B.

Rraer Ascension Prociram Data Delta-w for sirnle 1000 operation The method used to calculate delta-w, in general, correspords with the guidelines pmvided in General Electric document 24A1715, Single Recirullation Pump Operation (PNO-A22-4370-0007(1)) ard is outlined below:

1.

Develop the two loop relationships for Core Flow versus Core Plate differential pressure and Core Flow versus percent of Rated Recirculation Drive Flow.

a.

Collect data during two loop operation.

b.

Calculate second order regression-fits for Core Flow as a function of Core Plate differential pressure and percent of Rated Recirullation Drive Flow.

c.

Determine the value of Rated Recirullation Drive Flow.

2.

Collect Single loop Operation data for Core Power, Recirculation Drive Flow and Core Plate differential pressure. This is done over a rarge of Recirculation Pump speed up to the maximum allowed by Technical Specifications (90% rated).

3.

Cbnvert Single loop Operations Core Plate differential pressure to Cbre Flow using the tuo loop relationships determined in step 1.

(Core Flow versus Core Plate differential pressure is independent of two loop or single lexp operation).

4.

Convert Recirculation Drive Flows to percent of Rated using the value determimd in step 1.

5.

Comparn Core Flow in Sirgle Icop Operation to Core Flow in Two Icop Operation for the same permnt Recirculation Drive Flow.

6.

Calculate delta-w by determining the maximum _ difference between Le two drive flow rates (two loop and single loop drive-flows)' for the same core Flow.

7hc results of the calculations outlined above are as follows:

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• Attachment 1-Revision to LCR 92-10

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Inst u 4ntation Requirements for SLO NLR-N93161

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1 Icop A in service Icop B in service Cycle Delta-w Delta-w 1

8.56%

7.82%

2 S.45%

8.50%

I 3

8.30%

8.70%

l Based upon the above results, PSE&G is hereby proposirq to

'f incorporate a conservative value of 9% for delta-w.

Mininum themal power corresmndim to conditions in which no teroerature stratification occurs

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'Ihe core power and flw values corresponding to conditions in which no temperature stratification occurs were detemined during power ascension testing. Rather than determining actual minimum power ard f1w values, the test verified that for certain set corxlitions, no tagmture stratification occurred. 'Ihe corditions of the test were as follows:

Reactor Power Active Icop Flw i

Test Date

(% Rated)

(% Rated) f 11/01/86 37 no active loop i

38 no steady-state SIO data l

11/01/86 53 90 (loop A) 11/08/86 38 no active loop All test conditions shwed no temperature stratification occurred.

Insofar as single loop data is available only for relatively high l

flw conditions, PSE&G is conservatively proposirq to retain the value of 50% core f1w and incorporate the value of 38% _themal j

pomr. A test to detemine the actual Itinirum values would necessitate single loop operations for approxi2rately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.

7 PSE&G does not feel that this is nemry since the conservative t

values that are being progre3 will have insignificant operational-

-i impacts.

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Page 6 of 9 l

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' Attachment 1 Revision to'LCR 92-10 l

Instrumentation Requirements for SLO NLR-N93161 l

. gore flow with both Recirculation Punos at minimtmt somxi i

Specification 3.4.1.1, Action "d",

requires that with total core flow less than this value and themal power greater than the limit specified in Figure 3.4.1.1-1 (this figure coduspords to the 80%

Rod Pattern line), actions am initiated to reduce thermal power belw the limit specified in Figure 3.4.1.1-1 or increase core flow to greater than 45% rated. These actions are similar to those specified in NRC Ikilletin 88-07, Supplement 1,. " Power Oscillations in Dolling Wster Reactors" which states the core flow value to be 40%. PSE&G is proposity to' incorporate the conservative value of 40% in ortier to retain consistency with the requirements of Bulletin l

88-07 rather than incorporate an additional value that would represent core ficw with both Recirculation Pumps at minimum speed.

C.

Spegifigation 3.0.5 FSE&G believes that adopting the proposed IID 3.0.5 and the associated Bases maintains conpliance with the intent of IID 3.0.2.

IV.

ElgETICANT IIAZARTE RNSIIERATIQi IFATIIATIO4 IEE&G has, pursuant to 10 CFR 50.92, reviewed the proposed ag :rsluunt to determine whether our request involves a significant hazards consideration. We have determined that operation of the Hope Creek Generating Station in accordance with the proposed chnges:

1.

Will not involve a significant increase in the probability or consequences of an accident previously evaluated.

A.

Sirnie I000 Operations t

Appendix 15C of the Hope Creek UIEAR conmins the sirgle loop analysis that was completed for PSE&G by General Electric. Section 15.C.3.2 evaluates a rod withdrawal error event while in single loop operations and states:

"The rod withdrawal error at rated power is given in the FEIG.

'1hese analyses are performed to demonstrate, even if the operator ignores all instrument indications and the alarn which could occur during the course of.the transient, the rod block system will stop rod withdrawal at a minimum critical power ratio (tKIR) which is higher than the fuel cladding integrity safety limit. Modification of the rod block equation (below) and Icwer power assures the MCTR l

safety limit is not violated."

l Relative to the APRMs, Section 15.C.3.2 concludes:

"The APRM trip settires are flow biased in the same nanner as the rod block monitor trip settings. Therefore, the APRM lod block ard scram settings are subject to the same procedural changes as the Itxi block monitor trip settirgs dimmvi above."

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^ Attachment 1 Revision to LCR 92-10

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' Instrumentation Requirements for SLO NLR-N93161 l

f The charges propcsod in this submittal would require an APfM and/or i

REN channel to be placed in the tripped cordition if its setpoints l

have not been reduced within four hours of entering single loop j

operations. This would ensure that if thermal power reached the setpoint of the channel that has been reduced, the trip function would occur.at the setpoint applicable to single loop operation.

Based on these conservative actions, it is concluded that the proposed changes will not involve a significant increase in the probability or consequences of an ao:ident previously evaluated.

j B.

Power Ascension Finuam Data The proposed changes incorporate plant values which have been conservatively determined from power ascension tests as dLawmi in i

Section III.B of this submittal. In two cases, the proposed values are more limiting than those presently contained in the affected specifications ard in the third case, the value has not been specifird until now. Therefore, the propcad changes will not involve a significant increase in the probability or consequences of an accident previously evaluated.

l C.

Specification 3.0.5

_l The proposed changes merely clarify the intent of Specification 3.0.2 and are therefore viewcd as administrative in nature. -

i 2.

Will not create the possibility of a new or different kird of accident from any accident previously evaluated.

e A.

Sirnie Inoo Onerations The coratraints imposed by the propcsod changes will ensure that, whi.le in single loop cperations, the subject trip functions will still occur at the setpoints applicable to single loop operations s

under the sam time limits as the present specification (i.e.,

within four hours of entering single loop operations).

Additionally, the pwpcc,ed charges will not involve any physical changes to the plant.

D.

Power Ascension Program Data 7he proposed changes will not involve any physical changes to the plant ard have ben conservatively detaTained as discussed in t

Section III.B of this submittal.

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I-Revision to LCR 92-10

• Attachment 1 y

Instrumentation Requirements for SLO

.NLR-N93161 i

C.

Specification 3.0.5 l'

' Ibe proposcd changes merely clarify the intent of Specification 3.0.2 'and are therefore viewod as administrative in nature.

i.

3.

Will not involve a significant reduction in a margin of safety.

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A.

Simle Iron operat;jp_DG 1

h propx.ed changes will provide a mor reasonable period of.

tine to reduce the setpoints of the 1: we and Rai by requiring concervative actions to be taken. 'Ihu actions will ensure that

+

l the applicable trip functions will still occur at the setpoints a3plicable to single loop operations within the same time period as currently specified (i.e., four hours). These changes, therefore, will not involve a reduction in a man 3 n of safety.

1 p.

Power Ascension PnxTram Data Insofar as each of the proposed core values that would be incorporated by this submittal were conservatively detennined as.

derr:ribed in Section III.B of this submittal, it can be concluded that there will be no reduction in margin of safety.

C.

Specification 3.O.5 l

'Ihe proposed charges merely clarify the intent of SpecificaMon 3.0.2 and aru therefore viewed as administrative in nature.

V.

(DtK'IIRI_qi I

Based on the preceding discussion, FSE&G has concluded that the proposed change to the 'Ibchnical Specifications does not involve a significant hazanis consideration insofar as the change: (1) does not involve a significant increase in the probability or consequerces of an accident previously evaluated, (ii) does not create the possibility of a new or different kird of accident from any accident previously evaluated,' and (iii) does not involve a significant reduction in a margin of safety.

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