ML20073A425
| ML20073A425 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/09/1994 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-94-02, GL-94-2, NLR-N94140, NUDOCS 9409200258 | |
| Download: ML20073A425 (8) | |
Text
%;
a Pubhc Gervice Electric and Gas Company
' StCven E. Mittenberger Pubhc Service Electric and Gas Company P.O. Box 236. Hancocks Bridge, NJ 08038 609 339-1100
. vice prescent ano cmet Nucwar officer SEP 0 91994 NLR-N94140 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO GENERIC LETTER 94-02 BWR THERMAL HYDRAULIC INSTABILITIES
. FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 This letter responds to Generic Letter 94-02 for the Hope Creek Generating Station and is being submitted in accordance with the reporting requirements of the generic letter.
Specifically, Reporting Requirement 1 specifies that the NRC be notified of the plans and status with respect to the generic letter's requested actions within 60 days of its date.
Information concerning our actions and plans relative to the requested actions of the generic letter is provided in the attachment to this' letter.
Specifically, the attachment includes information concerning procedure and training' enhancements for
)
preventing or responding to thermal hydraulic instabilities as well.as information relative to our plans and schedule for implementing a long term solution.
Reporting Requirement 2 specifies that written correspondence be provided to verify implementation of actions within 30 days of their completion.
Appropriate correspondence will be prepared and transmitted to the NRC in accordance with this requirement.
when both'the procedure and training enhancements are completed and when the long term solution is fully implemented.
1 4
f 00 i
9409200258 940909 I}
PDR ADOCK 05000354
_. R-PDR
. ;i.
e SEP 0 91994 Document Control Desk 2
NLR-N94140 Should there be any questions or comments with regard to this submittal, please do not hesitate to contact us.
Sincerely, A$
"(
Attachment Affidavit C
Mr. T.
T.
Martin, Administrator - Region I U.
S.
Nuclear Regulatory Commission 475 Allendale Road l
King of Prussia, PA 19406 l
Mr.
D. Moran, Licensing Project Manager U.
S.
Nuclear Regulatory Commission l
One White Flint North 1
11555 Rockville Pike Rockville, MD 20852 Mr.
R.
Summers (SO9)
USNRC Senior Resident Inspector Mr.
K. Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 I
i, i
i I
l 1
I i
4 REF: NLR-N94140 STATE OF NEW JERSEY
)
)
SS.
COUNTY OF SALEM
)
S. E. Miltenberger, being duly sworn according to law deposes and says:
I am Vice President and Chief Nuclear Officer of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.
l
~
f
/
Subscr bcd and Sworn to before me bb day o i a77,m llM,. 1994 this I V L4m b14[.
l.
ClWt dotaryPublicbfNewJersey KIMBERLY Jo agogy My Commission expires on r ca n is r,nr[Ng8SEY
~,,,uu l
l j
~
ATI?c MENT INFWMATICE IN RESKNSE '10 GENERIC IEf1TR 94-02 RESKNSE 'ID GENERIC IEI'ITR 94-02 IMR 'IHERRL HYIEAULIC IN59RTT.TTIES FACILITY OEYRATING LIONSE NPF-57 IOPE CREEK GENERATING STATICN DOO EP NO. 50-354 I.
INIMXIXTIQ(
'1his attachment provides information for the Hope Creek Generating Station in response to Generic letter 94-02 and satisfies the provisions of Reporting Requirement 1 of the generic letter.
Reporting Requiremnt 1 of Generic Intter 94-02 specifies that the NRC be notified of the plans ard status with respect to the generic letter's requested actions within 60 days of its date. The generic letter contains two requested actions. Information concerning each of the two requested actions is provided below.
II.
RESKNSE 'IO REQUESITD ACTION 1 A.
NRC Reauest Requested Action 1 states the followirg:
"All licensees of BWRs, except for Big Rock Point which does not have the capability for operation under variable flow conditions, are requested to review their current procedures aM trainirg p1wtaas and modify them as appropriate to slawfdien the administrative provisions intended to avoid power oscillations or to detect and suppress them if they occur prior to implementation of the long-term solutions. 'Ihe experience gained at WP-2 should be a primary guide in this review. In doing this, each licensee of a EMR (except for Big Rock Point) should:
a.
Ensure that procedural requirements exist for initiation of a manual scram under all operating conditions when all recirculation punps trip (or there are no punps operatirg) with the reactor in the RUN mode, and ensum that operators are aware of the potential for very large power oscillations and the potential for exceeding cxare thermal safety limits before autcnatic protection systems function followirg the trip of all recirculation punps (the procedural manual scram is not remry after long-term solutions are approved and implemented for individual plants); and Page 1 of 5
1 Attachment NLR-N94140 Information in Response to GL 94-02 b.
Ensure that factors inportant to core stability characteristics (e.g., radial and axial peakim, feedwater tatperature, and thermal hydraulic c&patibility of mixed fuel types) are controlled within i
appropriate limits consistent with the core design, power / flow exclusion boundaries, and core monitoring capabilities of the reactor in question, and that these factors are controlled through procedures governing charges in reactor power, including startup and shutdown, particularly at low-ficw operating carditions. Each licensee should review its procedures and determine if instability can be avoided by these pucuiures ard if the procedures can be carried out using existing instnment information.
If it is concluded that a near-term upgrade of core monitoring capability is called for to ease the burden on operators, determine the need to incorporate on-line stability monitoring or monitors for stability sensitive parameters and inform the IEC of the schedule and technical evaluation for such upgrades found to be r - ary.
('Ihese procedural operation controls will no larger be remyy for licensees which implement fully autcmatic long-term solutions, such as Options III or IIIa of Reference 2.
Licensees should propose for plant-specific review the administrative controls to be retained in conjunction with other long-term solutions.)."
B.
PSE&G Response to Requested Action 1 Our response to Requested Action 1 is as follows:
Hope Creek has implemented the interim corrective actions (ICAs) specified in NRC Bulletin 88-07, Supplement 1, aM, in addition, has supported the BWROG effort to develop improved guidelines for the ICAs to better address startup and 1cw power maneuvering conditions. A copy of the inproved BWR Owners' Group Guidelines for stability interim corrective action was provided to the NRC in Refereme 1 (see Section IV below for the list of references). It is our urderstanding that, based on a review of an advanced copy of these guidelines (Reference 2), the NRC will accept the improved BWROG guidelines as an adequate response to Requested Actions 1.a ard 1.b of Generic Istter 94-02.
It should be noted that the BWR Owners' Group Guidelines (Reference 1) are consistent with, but more restrictive than, the ICAs which were previously implcmented as a result of the lac Bulletin 88-07, Supplement 1 requirements. 'Ihe original regions defined in the 1988 BWROG ICAs and included in the NRC Bulletin 88-07, Supplement 1, were bascd on stability tests ard events known at the tirm. Subsequent work identified a sensitivity to reactor power shape and/or feedwater temperature conditions. Because of this, the Reference 1 guidelines incorporate an exparded instability region and power distribution control definition to strurgthen the oscillation prevention feature. 'Ihis, in conjunction with the detection ard suppression provisions of the guidelines, provides a higher degree of protection against unacceptable power oscillations.
i Page 2 of 5 l
Attcchm:nt NLR-N94140 Information in Response to GL 94-02 Although Hope Creek's current procedures ard operator training meet the intent of the requested actions in Generic letter 94-02, Hope Creek plans to modify its procedures and operator training, whem r-mry, such that they are consistent with, or more conservative than, the BWROG guidelines in Reference 1.
Implementation involves development of changes, u-ad, incorporation (if I-vry), rh'mont distribution, and training of all licensed operators (both classroom and sinulator during the normal operator requalification cycle). These activities will be acrpleted by May 30, 1995. The Reference 1 Controlled Entry Region will be treated as part of the Exit Region and power distribution controls will not be implemented. Hope Creek is not licensed to operate at exterded load lines above 108% ard will not include the Reference 1 Exit Region above the 108% rod line in the Exit Region.
Because the guidelines are intended for use until replaced by a stability long-term solution, nodification of the Hope Creek Technical Specifications for the interim period is not appropriate. The Reference 1 guidelines and resulting plant operating procedure and operator training modifications are intended for use only until the stability long-term solution is implemented. Beyond this, all appropriate procedures and training will be specified by the long term solution inplemented at Hope Creek.
III. RIEFCtEE TO RIIUESTED NJfION 2 A.
NN' Reouest Requested Action 2 states the following:
"All licensees of BGS, except for Big Rock Point, are requested to develop and subnit to the NRC a plan for long-term stability corrective actions, including design specifications for any hardware nodifications or additions to facilitate manual or automatic protective response needed to ensure that the plant is in compliance with Gereral Design Criteria 10 and 12.
An acceptable plan could provide for 11rplementing one of the long-tern stability solution options proposed by the BNROG and approved by the NRC in Reference 3 or in subsequent documentation. The plan should include a description of the action proposed and a schedule of any submittal requiring plant-specific design review and approval by the NRC ard an installation schedule (if applicable). The plan should also address the need for near-term and long-term tedinical specification modifications. Generic BWROG documents or planned subnittal may be
)
referenced in the plan."
l B.
PSE&G Response to Reauested Action 2 In recponse to the Roquested Action 2 of NRC Generic letter 94-02, ikpe Creek's plans for inplementing a long-tern solution to the reactor coupled neutronic/ thermal-hydraulic stability issue are provided below.
Page 3 of 5
I Attachm nt NLR-N94140 Information in Response to GL 94-02 The IEC requirement for stability long-term corrective actions to ensure cupliance with General Design Criteria 10 and 12 of 10CFR50 was originally presented in NRC Bulletin 88-07, Supplement 1 (na m 4 r 30, 1988). me Bulletin acknowledged that the NRC was working with the BWR Owners' Group (BWROG) to develop generic approaches to resolve this issue. Se resultig DWROG efforts have led to the solution mm.xp^w and supportirg methodology described in NEDO-31960 and NEDO-31960, Supplement 1, "WR Owners' Group long-Term Stability Solutions Licensiry Methodology." NRC acceptance of the WROG developed solution m mxpt.s and supportirg methodology is indicated in Reference 3; plans have been formulated for implementing a stability long-tem solution.
Based on the technical progress that has been made in the BWROG stability program and the degree of Imc acceptance indicated in Reference 3, plans have been fomulated for implementing a stability long-tem solution.
Hope Creek has elected to proceed with a solution which introduces new plant hardware / software to provide early detection of oscillations and to initiate an appropriate mitigating action. This "Inng-Tem Solution Stability System" (LTSSS) features the Option III (OPRM) con pt description in NEID-31960 ard NEDO-31960, Supplement 1.
To ccxtplete this activity, Hope Creek is participating with other utilities under a DEBOG program and has contracted with ABB Ocznbustion Engineering to develop the hardware / software design and deliver the final product. R m --a dations for Technical Specification changes will be provided as part of the program. These will be irmporated at Hope Creek as appropriate.
Implementation of the stability lory-term solution plan is contingent upon NRC acceptance of the planned BWROG submittal on methodology and the BWROG/ABB Cottbustion Engineering submittal on hardware and software.
The current milestone schedule for completion of the joint design and licensing activities is provided in Section III.C below. % e LTSSS hardware is scheduled to be available in Fall 1995. The plan, as discussed at the July 21, 1994 Option III Owners' meetirg with the NRC, is for the first installation of the LTSSS to be in the fourth quarter of 1996. This schedule allows appropriate time for the ezgineering preparation for system installation. The Owners' Group rm - wdation is for plants to operate with the new RFS trip function disabled for at least six months to evaluate the system performance and its potential for spurious trip signals and to become familiar with the system operation.
The present interim corrective actions (ICAs) will be used during the period when the RPS trip is disabled. Durirg this period, the alarm ard trip functions will be nonitored. The near tem plan is to use the existirq Technical Specification without any nodification for the interim
]
period operation. Upon successful empletion of the evaluation period, the RPS trip function will be enabled and the system declared operational. The present ICAs will be replaced by appropriate operational pm.ulures for lorg-tem operation.
The Hope Creek Technical Specifications will be modified to reflect the installation of LTSSS as a new Reactor Protection System.
Page 4 of 5
~
Attechm^.nt NLR-N94140 In' formation in Response to GL 94-02 s
8 Assumirg that the joint develognent and NRC acceptan is completed as scheduled (see Section III.C below), it is PSE&G's objective to have the LTSSS installed at Hope Creek prior to startup fmn Refueling Outage 7, currently scheduled for the Spring of 1997, and to have it operational following ccrtpletion of the acceptance testing and expiration of the interim evaluation / familiarization period (at least six months following startup fmn the outage).
I C.
Desian ard Licensim Activities (ABB G Option III) 20/94 Initiated design work (ABB G) 30/94 Met with NRC on hardware / software develvpud. process (July 21) l 40/94 Submittal of Option III hardware / software topical report to NRC l
(ABB) 1Q/95 Detect and suppress topical report subnittal (first thne application and reload review) l 30/95 NRC approval of Option III licensing topical and generic Technical Specification 30/95 Start Option III initial plant installation engineering preparation 4Q/95 Completion of system design and development i
40/96 Outage start for intallation of Option III at first plant RFD 7 Plan to install Option III at Hope Creek l
l l
IV.
EDT:RENC'ES 1.
Ietter, L. A. Dyland to M. J. Virgilio, "BWR Owners' Group Guidelines for Stability Interim Corrective Action", June 6, 1994 2.
Ietter, L. A. England to M. J. Virgilio, "IMR Owners' Group Inproved l
Guidelines for Stability Interim Corrective Actions", April 4,1994 3.
Ietter, A. 'Ihadani (NRC) to L. A. England (BWROG), " Acceptance for Referencing of Topical Reports NEDO-31960 and IEDO-31960, Supplement 1,
'DWR Owners' Group long-Tenn Stability Solutions Licensing Methodology 8",
i dated July 12, 1993.
Page 5 of 5
- - ___-___- ___-___-____________ ___.