ML20077C498
| ML20077C498 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/28/1994 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20077C502 | List: |
| References | |
| NLR-N94029, NUDOCS 9412050148 | |
| Download: ML20077C498 (17) | |
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Pubhc Service l
j Decinc and Gas Company l
Stanley LaBruna Pubhc Service Electnc and Gas Company P.O. Box 236. Hancocks Bndge, NJ 08038 609-339-1700 ve. -~. - me tns>neng NOV 2 81994 NLR-N94029 LCR 94-02 LCR 94-27 LCR 94-28 i
United States Nuclear Regulatory Commission !
Document Control Desk j Washington, DC 20555 l Gentlemen:
REQUEST FOR LICENSE AMENDMENT !
APRM RBM AND RCS SETPOINT AND !
ALLOWABLE VALUE REVISIONS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 l DOCKET NO. 50-35/
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This letter submits an application for amendment to Appendix A of '
Facility Operating License NPF-57 for the Hope Creek Generating Station and is being filed in accordance with 10CFR50.90.
Pursuant to the requirements of 10CFR50.91(b) (1) , a copy of the ;
amendment request has been sent to the State of New Jersey j The proposed changes are associated with the Average Power Range Monitor (APRM), Rod Block Monitor (RBM) and Reactor Coolant i l System (RCS) recirculation flow upscale trip setpoint and ;
i allowable value. Specifically, the setpoints and allowable i values for the APRM flow-biased upscale scram / control rod block would be modified to improve operating margin in the Extended Load Line Limit Analysis (ELLLA) region. The proposed changes to l the RBM trip function would transfer control of the setpoint and l allowable value for the RBM - upscale rod block to the Core j Operating Limits Report (COLR). For the RCS recirculation flow l upscale trip function, the proposed changes would revise the trip ,
l l setpoint and allowable value to reflect 105% of rated core flow. !
L Attachment 1 contains a detailed description of and justification !
for the proposed changes. Based upon the justification provided, '
Public Service Electric & Gas believes that the proposed changes l do not involve a significant hazards consideration pursuant to l 10CFR50.92. Attachment 2 contains marked up Technical i Specification pages which reflect the proposed changes. To j
, facilitate review of the proposed changes, NEDC-31487, the l original analyses to support operation in the ELLLA region and the Reload 5/ Cycle 6 analyses are provided as Attachments 3 and 4, respectively.
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DGnnon
' 9412050148 DR 941128 ADOCK 05000354 PDR i i I i
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NOV 2 81994 l I
l Document Control Desk 2 l
NLR-N94029 l
Upon NRC approval, please issue a license amendment which will be effective upon issuance and shall be implemented within 60 days of issuance. This latitude permits appropriate procedural modifications necessary to implement the proposed changes.
l Should you have any questions or comments on this submittal, l
please do not hesitate to contact us.
Sincerely, h M' l
Affidavit Attachments (4)
C Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Moran, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. R. Summers (SOS)
USNRC Senior Resident Inspector l Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection
! Division of Environmental Quality l Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 l
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96-4933
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a l REF: NLR-N94029 LCR 94-02 LCR 94-27 I l
LCR 94-28 j l
STATE OF NEW JERSEY )
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) SS. !
COUNTY OF SALEM ) !
l S. LaBruna, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Engineering of Public Service Electric and Gas Cor.pany, 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. )
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w ist t fdM-r Subscribed and Sworn to before me this, dW hday ofMRaen /3R451994
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m but , -
l hotaryPublicohNwJersey KIMBERLY JD BROWN NOT ARY PilDLIC Of NEW JERSEY My Commission Erpires April 21,1998 My Commission expires on l
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, i ATTACKMENT 1 .
PROPOSED CKANGES TO THE TECHNICAL BPECIFICATIONS l 1
LICENSE AMENDMENT APPLICATION APRM RBM AND RCS SETPOINT AND ALLOWABLE VALUE REVISIONS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 NLR-N94029 DOCKET NO. 50-354 LCR 94-02, 94-27 AND 94-28 9
I. DESCRIPTION OF THE PROPOSED CHANGES LCR 94-02 A. Chances to APRM Flow-Biased Scram / Control Rod Block l
This license amendment application proposes changes !
associated with the Average Power Range Monitor (APRM).
l Specifically, the setpoints and allowable values for l
the APRM flow-biased upscale scram / control rod block ,
would be modified to improve operating margin in the i Extended Load Line Limit Analysis (ELLLA) region. A 1 description of the proposed changes is as follows: '
- 1. Chances to Table 2.2.1-1 on Pace 2-4 ;
The proposed changes would modify the APRM flow-i biased upscale scram trip setpoint from s 0.66 (w
- delta w) + 51%** to s 0.58 (w - delta w)
+ 59%** and the APRM flow-biased upscale scram trip allowable value from s 0.66 (w - delta w)
+ 54%** to s 0.58(w - delta w) + 62%**. The .
current maximum trip setpoint of 113.5% and l allowable value of 115.5% would be maintained. !
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- 2. Chances to Specification 3.2.2 on Pace 3/4 2-2 l
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l The proposed changes would modify the APRM flow- l biased upscale scram / control rod block setpoints !
and allowable values in Specification 3.2.2. The ;
manner in which this change would be accomplished is described below:
l a) Change the APRM flow-biased upscale scram I
trip setpoint from 5 (0.66 (w - delta w)**
+ 51%)T to 5 (0.58 (w - delta w)** + 59%)T.
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1 ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND '
ALLOWABLE VALUE REVISIONS NLR-N94029 b) Change the APRM flow-biased upscale scram allowable value from 5 (0.66 (w - delta w)**
t 54%)T to 5 (0.58 (w - delta w)** + 62%)T.
c) Change the APRM flow-biased upscale control rod block setpoint from $ (0.66 (w - delta w)** + 42%)T to 5 (0.58 (w - delta w)**
+ 50%)T.
d) Change the APRM flow-biased upscale control rod block allowable value from $ (0.66 (w -
delta w)** + 45%)T to 5 (0.58 (w - delta w)**
+ 53%)T.
- 3. Chances to Table 3.3.6-2 on Pace 3/4 3-59 The proposed changes would modify the APRM flow-biased upscale control rod block setpoint and allowable value in Table 3.3.6-2. The manner in which this change would be accomplished is described below:
a) Change the APRM flow-biased upscale control rod block setpoint from 5 0.66 (w - delta w)
+ 42%* to 5 0.58 (w - delta w) + 50%*.
l b) Change the APRM' flow-biased upscale control rod block allowable value from 5 0.66 (w -
delta w) + 45%* to 1 0.58 (w - delta w)
+ 53%*.
LCR 94-27 B. RBM Setooint Revision and Transfer of Control to the COLR This license amendment application proposes changes associated with the Rod Block Monitor (RBM).
Specifically, the proposed changes would transfer control of the RBM - upscale rod block setpoint and allowable value to the Core Operating Limits Report (COLR). A descriptions of the proposed changes is as follows:
I 1. Chances to Table 3.3.6-2 on Pace 3/4 3 l l
The proposed changes would modify the RBM -
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ATTACHMENT 1 LCR 94-02, 94-27' AND 94-28 APRM RBM AND RCS SETPOINT AND ALLOWABLE VALUE REVISIONS NLR-N94029 t I
upscale-setpoint and allowable value. The changes also relocate control of the RBM upscale intercepts to the COLR. The manner in which this 4 change would be accomplished is described'below: ,
a) Change the RBM - upscale rod block setpoint from 5 0.66 (w - delta W) + 40%* with a maximum of $ 106% to 5 0.66 (w - delta w) ,
+ (Z - 66)%* with a maximum of 5 Z% where Z ,
is defined in the COLR. !
b) Change.the RBM - upscale rod block allowable !
value from 5 0.66 (w - delta w) + 43%* with a maximum of 5 109% to 5 0.66 (w - delta w) ;
+ '(Z - 63)%* with a maximum of 5 (Z + 3)% ;
I where Z is defined in the COLR.
I c) Add a footnote which states the following:
1 "The value of Z is specified in the Core Operating Limits Report."
- 2. Chances to Section 6.9.1.9 ,
a This section would be modified to require that l core operating limits be established and j documented in the COLR for the applicable limits -
contained in Specification 3/4.3.6, Control Rod Block Instrumentation.
LCR 94-28 C. RCS Recirculation Flow Revisions This license amendment application proposes changes associated with the Reactor Coolant System (RCS) l recirculation flow upscale trip setpoint and allowable value. Specifically, the proposed changes would revise i the RCS recirculation flow upscale trip setpoint and l allowable value to reflect 105% of rated core flow. A description of the proposed changes is as follows: ;
- 1. Chances to Table 3.3.6-2 on Pace 3/4 3-59 i
The proposed changes would' modify.the RCS I recirculation flow upscale trip setpoint and allowable value. The manner in which this change Page 3 of 13
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! ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND ALLOWABLE VALUE REVISIONF NLR-N94029 1 I
would be accomplished is described below:
i a) Change the RCS recirculation flow upscale l trip setpoint and allowable value from 108%
! and 111% to 111% and 114%, respectively.
l l II. REASON FOR THE PROPOSED CHANGES l
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! LCR 94-02 i
1 i A. Chances to APRM Flow-Biased Scram / Control Rod Block l
t Currently, when power is reduced due to recirculation pump flow, the margin between APRM flux levels and the APRM flow-biased scram setpoint decreases. This decrease is the result of a mismatch between the slopes l of the APRM flow equation and the core flow versus core i power equation for constant load line. APRM flow j equation slopes are currently specified at 0.66w, l actual core flow versus core power slopes are l approximately 0.58w, w represents recirculation drive flow in percent rated (the Hope Creek Power / Flow Map is provided in Attachment 3, Page 1-3). In the event of a
, transient (e.g., recirculation pump runback or single recirculation pump trip) current APRM flow equations provide decreased operating margin.
The proposed changes would revise the APRM flow-biased scram / control rod block setpoints and allowable values to be consistent with the core flow versus core power l l slope. These changes would improve utilization of the i ELLLA region of the power / flow map thereby providing additional operating margin for reduced recirculation l flow conditions. In addition, the proposed changes would improve power ascension capability to full power.
LCR 94-27 i
B. RBM Setpoint Revision and Transfer of Control to the ;
COLR I
The proposed changes transfer control of the RBM -
upscale rod block setpoint and allowable value to the COLR. This would permit subsequent changes to the setpoint and allowable value using NRC approved methodology, without a Technical Specification Page 4 of 13 l
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s ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND i ALLOWABLE VALUE REVISIONS NLR-N94029 amendment. This proposed change would remove an undue burden on NRC and Public Service Electric & Gas (PSE&G) resources if future changes would be pursued.
l LCR 94-28 l C. RCS Recirculation Flow Revisions Currently, the RCS recirculation flow upscale trip l
setpoint and allowable value are specified at 108% and 111% of rated core flow, respectively. This trip setpoint and allowable value are based on operation up ,
- to 100% of rated core flow. l l
l As part of Amendment 15 (SER dated March 15, 1988), the l HCGS was licensed to operate up to 105% of rated core flow. These proposed changes would revise the RCS ,
recirculation flow upscale trip setpoint and allowable j value to 111% and 114%, respectively. The revised trip l setpoint and allowable value would be based on 105% of l rated core flow. These changes would provide improved i l operating margin for subsequent operation up to 105% of ;
! rated core flow and make the RCS recirculation flow l l
upscale trip setpoint and allowable value consistent l with Amendment 15.
j III. JUSTIFICATION FOR THE PROPOSED CHANGES LCR 94-02 A. Chances to APRM Flow-Biased Scram / Control Rod Block l The original analysis supporting operation in the ELLLA region are contained in NEDC-31487, " Increased Core i 1
Flow and Extended Load Line Limit Analysis for Hope Creek Generating Station Unit 1 Cycle 2," dated November 1987. A copy of NEDC-31487 is included as 1 Attachment 3 to this letter. The analysis contained in NEDC-31487 addresses the full range of transient and accident events relevant to ELLLA extension and presents results of calculations and justification for
, tne proposed changes. In addition, cycle specific l analyses performed in support of Reload 5/ Cycle 6 present additional calculations of limiting MCPR transients utilizing the proposed changes. A copy of the Reload 5/ Cycle 6 report (GE Document No. 23A7219)
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f ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 j APRM RBM AND RCS SETPOINT AND j ALLOWABLE VALUE REVISIONS NLR-N94029 is included as Attachment 4 to this letter. PSE&G i notes that impact of ELLLA operation on anticipated l transients without scram is evaluated in Section 7.6.1.7.2 of the UFSAR.
The transient analyses presented in NEDC-31487 and the Reload 5/ Cycle 6 report demonstrate that licensing calculation results (e.g., 105 percent flow, 100
-percent power for pressurization transients) bound the ,
ELLLA region results (e.g., 87 percent flow, 100 percent power). These conclusions apply to all relevant MCPR events such as pressurization, rod withdrawal and flow runout events. . In addition, other l relevant areas such as overpressure protection, loss-of-coolant accident, containment, reactor internals, ;
- flow-induced vibration and reactor internal pressure ,
l difference were evaluated and analyses has determined ;
that the results are within allowable design limits.
l The proposed changes to the APRM flow-biased
! scram / control rod block setpoints and allowable values ,
l have been previously approved by the NRC for Limerick .
Unit 1 in a Safety Evaluation Report (SER) dated i August 14, 1987.
l l LCR 94-27 l l
l B. RBM Setnoint Revision and Transfer _of Control to the I COLR The proposed changes would transfer control of the setpoint and allowable value for the RBM - Upscale rod block to the COLR. Technical Specification 6.9.1.9,
, " Core Operating Limits Report," requires that the analytical methods used to determine core operating l limits be those previously reviewed and approved by the NRC and that the core operating 1.imits be determined such that all applicable limits of the safety analysis are met.
The setpoint and allowable value incorporate a controlling value which will be specified in the COLR and noted as such by reference in the Technical i Specifications. Therefore, the setpoint and allowable i value would continue to be controlled in a manner that would ensure that safety analysis limits are met and l implementation of the proposed changes would not reduce Page 6 of 13
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ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND ALLOWABLE VALUE REVISIONS NLR-N94029 the level of assurance provided by the existing l Technical Specifications.
Upon approval of the proposed changes, the COLR will be revised to incorporate the above revisions and, in I accordance with Technical Specification 6.9.1.9, I submitted to the NRC.
The proposed relocation of the selected RBM - upscale l rod block setpoints to the COLR have been previously l approved by the NRC for Nine Mile Point Unit 2 in a SER ;
dated June 19, 1990. 1 l
LCR 94-28 C. RCS Recirculation Flow Revisions The original analysis used to support operation up to 105% of rated core flow is contained in NEDC-31487.
The analysis presented in NEDC-31487 bound the affects 1 of the revised RCS recirculation flow upscale trip I setpoint and allowable value. NEDC-31487 addresses the full range of transient and accident events associated with operation up to 105% of rated core flow.
In addition, cycle specific analysis performed for Reload 5/ Cycle 6, have incorporated the assumption of operation up to 105% of rated core flow and have confirmed that operation is within allowable design limits.
I IV. BIGNIFICANT HAZARDS CONSIDERATION EVALUATION ;
1 PSE&G has, pursuant to 10CFR50.92, reviewcd the proposed amendment to determine whether the request involves a significant hazards consideration. We have determined that operation of the Hope Creek Generating Station in accordance with the proposed changes:
- 1. Would not involve a significant increase in the probability or consequences of an accident previously evaluated.
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ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND ALLOWABLE VALUE REVISIONS NLR-N94029 LCR 94-02 A. Chances to APRM Flow-Biased Scram / Control Rod Block The proposed changes to the Average Power Range Monitor (APRM) flow-biased scram / control rod block
! setpoints and allowable values were evaluated using NRC approved procedures and methods. The j results of this evaluation are demonstrated in )
l NEDC-31487. Application of this change in APRM l
flow-biased scram / control rod block setpoints and allowable values to Reload 5/ Cycle 6 is confirmed l
in General Electric Document No. 23A7219.
l Analysis presented in NEDC-31487 demonstrate that !
performance in the ELLLA region is within design limits for overpressure protection, stability, loss-of-coolant, containment, reactor internals, flow-induced vibration, and reactor internal pressure difference. Impact of ELLLA operation on anticipated transients without scram is evaluated in Section 7.6.1.7.2 of the UFSAR. Application of ELLLA region extension to Reload S/ Cycle 6 has bern confirmed in GE Document No. 23A7219.
l Because operation with the APRM flow-biased
- scram / control rod block setpoints and allowable values is within the bases reviewed and approved by the NRC in the UFSAR, this change does not significantly increase the possibility or consequences of an accident previously evaluated.
LCR 94-27 j B. Transfer of RBM Setnoint Control to the COLR
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The proposed changes would transfer control of the setpoint and allowable value for the rod block monitor (RBM) - Upscale rod block to the Core Operating Limits Rel' ort (COLR). Technical Specification 6.9.1.9, " Core Operating Limits Report," requires that the analytical methods used to determine core operating limits be those previously reviewed and approved by the NRC and that the core operating limits be determined such that all applicable limits of the safety analysis Page 8 of 13 l
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'I ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND 1 ALLOWABLE VALUE REVISIONS NLR-N94029 l
are met.'
The setpoint and allowable value incorporate a controlling value which will be specified in the COLR and noted as such by reference in the Technical Specifications. Therefore,-the setpoint and allowable'value would continue to be controlled in a manner that would ensure that safety analysis limits.are met and implementation of the proposed changes would not reduce the level of assurance provided by the existing " anical Specifications. Based upon.the above ... o rma tion ,
we conclude that implementation of the proposed change would not significantly increase the probability or consequences of an accident .l previously evaluated. l LCR 94-28 l
C. RCS Recirculation Flow Revisions j The original analysis used to support. operation up to 105% of rated core flow is contained in NEDC- l 31487. NEDC-31487 addresses the full range of l transient and accident events associated with operation up to 105% of rated core flow. The i affects of operation with the revised RCS i recirculation flow upscale trip setpoint and allowable value are bounded by-the analysis presented in NEDC-31487.
In addition, cycle specific analysis performed for Reload 5/ Cycle 6, have incorporated the assumption of operation up to 105% of rated core flow and have confirmed that operation is within allowable design limits.
! Based on the'above information, we conclude that the proposed change would not significantly increase the probability or consequences of an accident previously evaluated.
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ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND ALLOWABLE VALUE REVISIONS NLR-N94029 P
- 2. Would not create the possibility of a new or different kind of accident from any accident previously evaluated.
LCR 94-02 i A. Chances to APRM Flow-Biased Scram / Control Rod Block The proposed changes to the APRM flow-biased scram / control rod block setpoints and allowable values would not alter the function of the APRM system nor involve ~any type of plant modification.
In addition, operation _with the revised APRM flow- '
biased scram / control rod block setpoints and allowable values would not create any new operating modes, accident scenarios, equipment.
failure modes, or fission product release paths. ,
Based upon the above information, we conclude that '
the proposed changes would not create the '
possibility of a new or different kind of accident from any accident previously evaluated.
LCR 94-27 B. Transfer of RBM Setooint Control to-the COLR.
The proposed transfer of control of the RBM i setpoint and allowable value to the COLR would not alter the function of the RBM system nor involve any type of plant modification. In addition, i operation with the revised setpoint and allowable f value would not create any new operating modes, ;
accident scenarios, equipment failure modes, or l fission product release paths. Based upon the ;
above information, we conclude that the proposed I changes would not create the possibility of a new I or different kind of' accident from any accident :
previously evaluated.
LCR 94-28 l C. RCS Recirculation Flow Revisions The proposed changes would not alter the function of the RCS recirculation flow upscale trip function nor involve any type of plant Page 10 of 13 i
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ATTACHMENT 1 LCR 9 4 -0 2 , 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND l ALLOWABLE VALUE REVISIONS NLR-N94029 j modification. In addition, operation with the i revised RCS recirculation flow upscale trip l setpoint and allowable value would not create any new operating modes, accident scenarios, equipment failure modes, or fission product release paths.
Based upon the above information, we conclude that the proposed changes would not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. would not involve a significant reduction in a margin of safety.
LCR 94-02 A. Chances to APRM Flow-Biased Scram / Control Rod Block
. The Bases for Hope Creek Technical Specification 2.2.1 state that the APRM setpoints were selected to provide adequate margin for the safety limits while allowing operating margins that reduce the possibility of unnecessary shutdowns.
The proposed changes would ensure that these objectives are met. The Minimum Critical Power Ratio (MCPR) operating limit specified in the Hope Creek COLR was determined using the APRM flow-biased scram / control rod block setpoints and allowable values proposed in this amendment application and has been chosen to ensure that the cladding safety limit would not be violated during normal plant operations and anticipated transients. Since the operating limit MCPR is chosen such that the cladding safety limit is maintained, adequate margins for the safety limits are ensured. The proposed changes would also serve to ensure that the objective of avoiding unnecessary shutdowns is met by furnishing greater margin between the operating envelope and the setpoint at lower flows.
Based on the above information, we conclude that the proposed changes would not significantly reduce a me gin of safety.
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ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND ALLOWABLE VALUE REVISIONS NLR-N94029 LCR 94-27 B. Transfer of RBM Setooint Control to the COLR The proposed transfer of control of the RBM setpoint and allowable value to the COLR would not affect the methodology for establishing the core operating limits. The setpoint and allowable value are modified to incorporate a controlling value which will be included in the COLR and indicated as such by reference in the Technical Specifications. Therefore, the setpoint and allowable value would continue to be controlled in a manner that would ensure that safety analysis e limits are net, we conclude that implementation of the proposed changes would not significantly reduce a margin of safety.
LCR 94-28 C. RCS Recirculation Flow Revisions The HCGS was licensed to operate up to 105% of ,
rated core flow as part of Amendment 15. The l analysis used to justify operation up to 105% of l rated core flow is contained in NEDC-31487. NEDC- !
I 31487 addresses the full range of transient and accident events associated with operation up to 105% of rated core flow. The affects of operation with the revised RCS recirculation flow upscale trip setpoint and allowable value are bounded by the analysis presented in NEDC-31487.
In addition, cycle specific analysis performed for Reload S/ Cycle 6, have incorporated the assumptions of operation up to 105% of rated core flow and have confirmed that cperation is within allowable design limits.
Based on the above information, we conclude that the proposed changes would not significantly reduce a margin of safety.
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] ATTACHMENT 1 LCR 94-02, 94-27 AND 94-28 APRM RBM AND RCS SETPOINT AND ALLOWABLE VALUE REVISIONS NLR-N94029 V. CONCLUSION As discussed above, PSE&G has concluded that the proposed
, changes to the Technical Specifications do not involve a !
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! significant hazards consideration since the changes: (i) 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 different kind of accident from any accident previously evaluated, and (iii) do not involve a significant reduction in a margin of safety.
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l LICENSE CHANGE REQUEST 94-02, 94-27 and 94-28 NLR-N94029
! FACILITY OPERATING LICENSE NPF-57 l HOPE CREEK GENERATING STATION
! DOCKET NO. 50-354 l
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