ML20059E530

Application for Amend to License NPF-57,eliminating APRM Downscale Trip Requirements.Ge Rept Encl

ML20059E530
Person / Time
Site:	Hope Creek
Issue date:	09/04/1990
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059E534	List: ML20059E530 ML20059E535 ML20059E540
References
LCR-90-03, LCR-90-3, NLR-N90059, NUDOCS 9009100225
Download: ML20059E530 (8)

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Public Service Electric and Gas =

Company StCntey LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge NJ 08038 609-339-4800 vce me,et meiear overaws SEP 0 41M0 NLR-N90059 LCR 90-03 i

United States Nuclear Regulatory Commission l

Document control-Desk Washington,'DC 20555 I

Gentlement LICENSE AMENDNENT APPLICATION i ELIMINATION OF APRM DOWNSCALE TRIP REQUIREMENTS j FACILJTY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354

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This letter submits an application for amendment-to .ppendix A of '

Facility Operating License NPF-57 for the Hope Creek Generating' Station and is being filed in accordance with the provisions of l10 CFR 50.90. This amendment request proposes elimination of the APRM downscale trip requirements. Attachment 1-includes a detailed description of the change and provides sufficient justification to demonstrate that the proposed change does not involve a significant hazards consideration pursuant to_10 CFR 50.92. The proposed marked up Technical. Specification pages.are contained in Attachment 2. Additionally, the General. Electric report justifying this change for the Hope Creek Generating Station is contained in Attachment 3.

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In accordance with 10 CFR 50.91(b) (1), a copy of this request has been sent to the State of New Jersey as indicated below. Upon NRC approval, please issui a License Amendment which will be effective upon issuance and shall be-implemented within150 days of issuance. This latitude permits appropriate procedural modifications necessary to implement the proposed changes.:

Should you have any questions or comment on this transmittal, do not hesitate to contact us.

Sincerely,

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Affidavit i Attachmants (3) 1(

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g hDR ADOCK 05000354 PDC i

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NLR-N90059 l

C Mr. C. Y. Shiraki Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. T. T. Martin, 2dministrator Region-I Mr. Kent Tosch, chief New. Jersey Department of Environmental Protection Division of Envirennental Quality Bureau of. Nuclear Engineering-CN 415 Trenton,'NJ 08625 Y

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1 Ref: 'NLR-N90059

'LCR 90 ~]

STATE'OF NEW JERSEY -)

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COUNTY OF SALEM )

S. LaBruna, being duly sworn according'to law deposes and says:

I an'Vice President - Nuclear Operations of Public' Service

- Electric and Gas Company,:and,as such',.I find-the matters set forth- on our' letter dated september 4, .1990 _ , , concerning the-Hope Creek Generating. Station, are true to=the best of my knowledge, information and belief.

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[-V t-l Subscr d and Sworn to before me

!% this , day of8cAprdah , 1990 h A.A)

_ Notary Public of .New JerseyVANITA M. MARSHALL l NOTARY PUBLIC 0F NEW JER8EY -

my consission Empires mer s, ises My Commission expires on n, . q'

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ATTACHMENT 1

. ' LICENSE'AMENDNENT APPLICATION FOR APRM DOWNSCALE ELIMINATIONi LICENSE ' AMENDNENT APPLICATION FACILITY OPERATING - LICENSE NPF-57 HOPE' CREEK GENERATING STATION. NLR-N90059-DOCKET No. 50-354 BC LCR'90-03 I. t==crintion of Pro m M chanoe This amendment. application proposes to eliminate the Average Power Range Monitor (APRM) downscale RPS scram Technical 3.3.1-1, Specification requirements (Item-2e in Tables 2.2.1-1, 3.3.1-2, and 4.3.1.1-1).

II. n.= mon for Pronosed chanae The surveillance' tests for the APRM downscale trip function, required by Technical Specifications,. require the plant to-be.

placed in a " half scram" condition, thus= increasing the -

probability of a spurious trip or ESF actuation. ; Additionally,

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maintenance and surveillance testing-for the APRM downscale trip place a significant. burden on the plant staff. Since the downscale~ trip is not judged to be performing a function with a value-commensurate with its associated risk-or burden, we!are proposing elimination of its Technical Specification requirements.

The'APRM downscale scram was-not included in the-later.BWR designs (BWR/5 and BWR/6 plants) and its elimination has been justified for several BWR/3 and BWR/4-plants. General Electric has completed an evaluation and determined that-elimination.of the APRM downscale trip is also justified for. the Hope Creek Generating Station; this is documented in General Electric Report EDE-06-290 and is contained in Attachment 3'of this submittal.

III. Justification for Pronosed Change The Intermediate Range Monitor (IRM) upscale scram functions-(IRM "high high" and inoperable trips) are' automatically bypassed when the Reactor Mode switch is placed'in the-Run position. The'APRM downscale scram was-designed to reactivate the IRM upscale scram

-functions when the associated APRM channel'is downscale and the Reactor Mode switch is in the Run position (Figure l'provides a diagram of the APRM/IRM scram channel). The only plant conditions under which this could occur are:

1. If the Reactor Mode switch is placed in the Run position before reactor power has increased to the indicating range of the APRMs during'a plant startup, or-Page 1 of 5 l

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JAtstachment11 - ,- l NLR-C90059

. -Elimination of APRN Downscale' Trip LCR 90-03 j i

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2. If the Reactor Mode switch remainz in the=Run-position :l after reactor;powerc hasLdecreased below the indicating range of=the APRMs during'a plant shutdown. ,

Under thGse conditions, both of which are induced by operator error, the accidents of concern with respect to the APRM downscale scram are the Rod Drop-Accident'(RDA) and the low pn!ar-Rod-Withdrawal-Error-(RWE).- i l

Normally,' proper Reactor Mode switch positioning is  !

administratively ensured by compliance with the integrated operating procedures for plant startup and shutdown. Considering j the amount of attention normally given by operators to the neutron monitoring system and integrated operating' procedures -!

during startup and shutdown,11t is unlikely that the Reactor Mode- [

switch would be improperly positioned.

If the Reactor Mode switch is improperly 1 positioned during a startup or shutdc en, it is unlikely that a RDA or RWE would occur prior to completion of corrective action du.s to the " Infrequent" i frequency classificatio'n of both of these accidents. -j i

If the Reactor Mode switch is improperly positioned, as a result' of procedural non-compliance, and a RDA or RWE occurc prior tc completion of corrective action,. plant protection is' ensured byL automatic system response,-completely independent ~of the APRM 3 downscale scram, as follows.

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1. If a RDA occurs-while the Reactor Mode-switch is in Run and the APRMs are downscale, reactor power will-increase due to positive reactivit j transient will be terminated when'y. addition.

the -The an RPS initiates APRM neutron-flux upscale scram.

2. With the Reactor Mode switch in Run and'the APRMs--

downscale, further control rod withdrawal is prohibited by the APRM Downscale Rod Block, thereby-preventing a i RWE. l In summary, procedural' compliance normally ensures proper Reactor Mode switch positioning. If improper' Reactor Mode switch. 5 positioning occurs, the probability of an accident in: transient occurring prior to completion of corrective action is low. If ar.

accident or transient.does occur prior to completion-of-corrective actien, the Aeutron Monitoring System would provide automatic plant protection independent of the APhM/IRM companion scram.

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.- Attachment 1 NLR-N90059 Elimination of APRM Downscale Trip ICR 90-03 l

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i It is therefore concluded that the requested change would not result in a significantly degraded APRM safety function. Lastly, it is noted that the requested change results in a reduction in the potential for spurious plant trips; and ESF actuations; this reduction has a positive impact on safety.

IV. Sionificant Hazards Consideration. Evaluation Operation of the Hope Creek Generating Station in accordance with the proposed Technical Specification change will not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated, f The accidents of concern with respect to the APRM/IRM I companion scram, caused by an APRM downscale concurrent with i

either an.IRM "high high" or inoperable trip, are the rod I

drop accident (RDA) and the low power rod withdrawal error (RW2). The FSAR and Teload safety analyses do not credit this scram function in the terminntion of either of these accidents. Since this scram function is not credited in the termination of these accidents, the elimination of this scram function has no adverse effect on previously evaluated accidents.

! 2. Create the possibility of a new or different accident from any accident previously evaluated.

The limiting accidents in the operating region of transition between the startup and run modcs are well understood and are evaluated in the FSAR and/or reload safety analyses.

Elimination of the APRM downscale/IRM "high high" or inoperable caused scram does not introduce any new accident scenario since it is not credited in the termination of 1 l these evants (i.e., RDA and RWE). Less limiting events in I this region such as control rod initicted fast period events j I either due to operator error or CRD malfunction are subsets

! of the low power RWE event and are bounded-by both it and l the design basis RDA. In addition, General Electric has t indicated that for reactivity insertion events occurring l with an inappropriate mode-switch position, the only effect of the deletion of the APRM downscale scram would be that

! the initial power level could be a few percent lower. The generic General Electric analyses have been performed at a spectrum of power levels that would bound any possible event at Hope Creek with this proposed change.

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' Attachment 1 WLR-N90059

-Elimination:of APRM Downscale Trip. LCR 90 ,

3. Involve a , ticant reduction in aLaargin of safety.- .j The APRM downucale/IRM "high high" or' inoperable: caused scram-is not credited in the termination of any transient which-could challenge a safety limit. As such, the elimination of this scram function has no effect on any '

Technical Specification defined: safety _ limit. 'l V. conclusion As discussed in Item IV above, PSE&G has-concluded that.the-proposed: changes _to the Technical' Specifications do not involve a sign.ificant hazards consideration'since the changes (1) do not involve a significant' increase in the probability or consequences ^

of an accident previously evaluated, (ii) do.not create the possibility:of a new or difforent kind of accident fron'any accident previously evaluated, and (iii) do not involve a l significsnt_ reduction in a margin of safety.

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,' /Att$chment-1, .NLR-N90059

Elimination; of APRM' Downscale Trip -

LCR'90-03.

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-f 1 0 PENS ON IRM INOP-Lo gI M gEgASS ON ' *

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9. MODE SWITCH

-APENS ONALE- IN 'RUN' y-IRM UPSC . . . .

e TRIP CLOSED ON APRM BYPASS "1 "

-- OPENS ON

"" APRM OOWNSCALE ALAGM N "d _

-OPENS DN APRM UPSC AL" "4 "

'-- CLOSED ON NEUTRON TRIP 1 "" APRM BYP ASS OPENS ON- - 4 APRM -UPSC ALE /-

THERMAL TRIP J

TRIP RELAY O

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FIGURE 1 DIAGRAM OF APRM/IRM SCRAM CHANNEL (TYPICAL OF 8)

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