ML20082B521

Application for Amend to License NPF-58,revising Tech Specs 2.1.2,2.2.1,3.3.1,3.3.6,3.4.1.1,3.4.1.2 & 3.4.1.3

ML20082B521
Person / Time
Site:	Perry
Issue date:	06/28/1991
From:	CENTERIOR ENERGY
To:
Shared Package
ML20082B519	List: ML20082B515 ML20082B521 PY-CEI-NRR-1353, Proposed Tech Specs 2.1.2,2.2.1,3.3.1,3.3.6,3.4.1.1,3.4.1.2 & 3.4.1.3
References
PY-CEI-NRR-1353, NUDOCS 9107150264
Download: ML20082B521 (32)

Text

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SUMMARY

DESCRIPTION OF CIIANGES, SIGNIFICANT llAZARDS AND ENVIRONMENTAL CONSIDERATIONS 9107150264 910628 PDR P ADOCK 05000440 PDR

... , Attachment 1 PY-CEl/NRR-1353 L l Page 1 of 31 l SUMKARY I

Changes to the PNPP Unit 1 Technical Specifications are being proposed in order to provide for implementation of Single Recirculation Loop Operation (SLO). Implementation of SLO requires modifying the Minimum Critical Power Ratio (MCPR) Safety Limit. Average Power Range Monitor (APRM) scram and rod block setpoints, the Maximum Average Planar Linear Heat Generation Rate (MAPLHCR) for all fuel / lattice types through the addition of a SLO MAPLHGR reduction factor, and adjustment of the recirculation system specifications as discussed below. Technical Specification 3.4.1.1 -

Recirculation Loops, acts as the governing specification and directs the actions necessary to operate in SLO. Certain specific actions are identified within the Recirculation Loops specification which must be followed when the single loop operation mode is entered such as imposing the limits and setpoints mentioned above, placing the active recirculation loop flow controllar in the loop manual mode, and imposing certain flow rate and power restrictions to remain within the bounds of the safety analyses and for thermal stress considerations.

Single loop operation is a highly desirable mode of operation in the event that a problem with a recirculation pump, or other component maintenance, renders a recirculation loop inoperative. The current Technical Specifications (through Specification 3.4.1.1, Action a) call for power to be reduced within two hours to below the value specified in Technical Specification Figure 3.4.1.1-1, and for achieving at least Hot Shutdown within the following twelva hours. Therefore, the loss of a recirculation loop currently requires the plant to begin a rapid forced shutdovn with the consequent increaseo potential for a scram during this complex evolution.

Single loop operation provides a significant improvement in plant safety as there is now an alternative to entering the shutdown process with the increased inherent chances of plant trips and the cycling of plant compnents.

The proposed changes vill allov the 'ontirted safe operation of Unit 1 of the Perry Nuclear Power Plant (PNPP) while maintaining continued electrical generation.

An analysis of single recirculation loop operation has been performed by General Electric (GE) entitled, " Single Loop Operation Analysis for the Perry Nuclear Power Plant, Unit 1" (Enclosure 1). This analysis was submitted as

. Appendix 15F to the PNPP Final Safety Analysis Report (FSAR) to present this mode of operation for NRC Staff reviev, although the request to authorize operation in the single loop mode was not processed during the initial licensing proceedings.

This GE safety analysis forms the analytical basis for the Technical Specification changes listed in A* tachruen t 2. To justify single loop operation, potential transients and accidents associated with power operations, as presented in the PNPP Updated Safety Analysis Report (USAR)

Section 6.3.3 and Chapter 15 (including Appendices) of the USAR, vere reviewed and the limiting events reanalyzed at SLO conditions. Containment performance evaluation and reactor internals vibration analysis was also performed. An updated Appendix 15F has been enclosed to reflect the current thermal hydraulic stability criteria (based on more recent events), the recirculation loop drive flow limit (determined from startup testing reactor internals vibration analysis results), and the potential for changes in the single loop operation MAPLHGR reduction factor. The reload analyses provide reverification that single loop operation is acceptable for each subsequent cycle.

,. , Attachment 1 PY-CEI/NRR-1353 L Page 2 of 31 Highlights of the GE safety analysis (Reference 1) for single loop operation of PNPP Unit 1, are presented below:

1. The Minimum Critical Power Ratio Safety Limit is increased during SLO primarily because of slightly increased uncertainties, but the MCPR Operating Limit does not change. The effect of transients during single-loop operation are less sevete than during two loop operation.

These analyses demonstrate that even though the MCPR Safety Limit is higher, there is sufficient MCPR margin in the existing MCPR Operating Limit to ensure safe operation (Sections 15F.2 and 15F.3 of Reference 1).

2. The Appendix K Loss of Coolant Accident (LOCA) analyses shov that a LOCA during single recirculation loop operation could result in a higher Peak Clad 6ing Temperature (PCT) than for two loop operation. Therefore, the MAPLHGR limits are adjusted through the addition of a SLO MAPLHGR reduction factor to maintain the PCT belov 10 CFR 50.46 limits (Section 15F.5.2 of Reference 1).

3. An allovable operating region had been previously incorporated into Technical Specification 3.4.1.1. The recommendations of GE Service and Information Letter (SIL) 380 Revision 1 "BVR Core Thermal Hydraulic Stability," (Reference 7) were previously incorporated into the Technical Specifications, and the interim corrective actions developed by GE and endorsed by NRC Bulletin 88-07 Supplement 1, "Pover Ost!11ations in BVRs," (Reference 8) have been incorporated into plant operating procedures (Section 15F.4 of Reference 1).

4. All applicable parameters of the containment analysis are belov their design limits for SLO (Section 15F.6 of Reference 1).

5. Reactor vessel internals vibration during SLO vas examined. Analysis of startup test data defined a maximum recirculation loop drive flow for single loop operation that ensures vibration levels are within acceptable limits. (Section 15F.7.3 of Reference 1).

The Technical Specification changes required to implement Single Recirculation Loop Operation are as follows:

1. Increase the Minimum Critical Power Ratio Safety Limit from 1.07 to 1.08 to account for additional uncertainties in establishing the safety limit for one recircunation loop operation. (SAFETY LIMITS: Specification 2.1.2 - THERMAL POVER, High Pressure and High Flow)

2. Add new flow biased scram trip setpoint and allovable value equations for SLO to the Specification 2.2.1, " Limiting Safety System Settings -

Reactor Protection System Instrumentation Setpoints" table under the Average Power Range Monitor: Flov Biased Simulated Thermal Pover-High, Functional Unit heading. (Table 2.2.1-1, Item 2.b.)

Add new flow biased rod block trip setpoint and allovable value equations for SLO to the Specification 3.3.6, " Control Rod Block Instrumentation Setpoints" table under the Average Pover Range Monitor: Flow Biased Neutron Flux-Upscale, Trip Function heading. (Table 3.3.6-2, Item 2.a.)

i- , -Attachment 1 PY-CEI/NRR-1353 L Page 3 of 31 Add footnotes to the above two tables, and n statement to the existing note d in Table 4.3.1.1-1, " Reactor Protection System Instrumentation Surveillance Requirements" explaining that temporary APRM gain I

adjustments may be made in lieu of adjusting the APRH flov biased trip setpoint and allovable value equations discussed above to functionally l implement SLO vhile the flow biased equations are being changed. (Table '

2.2.1-1 Note b, Table 4.3.1.1-1 Note d, and Table 3.3.6-2 Note c.)

3. Hodify the Maximum Average Planar Linear lleat Generation Rate Power and Flov Factor parametric curves (HAPFAC and MAPFAC ) to reflect the limit for the current cycle for single loop operation.

P f These curves are located in the Core Operating Limits Report (COLR) . (LC0 3.2.1 - Average Planar Linear Heat Generation Rate and the COLR.)

4. Revise the Recirculation Loops specification Limiting Condition for Operation (LCO) and Action statements, and add Surveillance Requirements I to allow recirculation loop operation with only one loop in service.

Surveillance Requirements and Action statements are being added to verify j the new LCO conditions and to direct the actions tc take if the conditions are exceeded. A detailed description is provided in Part D of this letter. Attachment 3A provides a retyped version of the entire j specification so that the changes can be clearly diitinguished. (LCO 3.4.1.1 - Recirculation Loops)

5. Clarify the Surveillance Requirements of the Jet Pumps specification to provide consistoney between specifications, eliminate confusion in the i applicability of an exception to Specification 4.0.4, eliminate a l redundant requirement for matching recirculation loop flows, clarify terms, and provide revised limits for jet puup diffuser-to-lover plenum dif ferential pressure and add a limit for jet pump flow. A detailed description is provided in Part E of this letter. Attachment 3A provides a retyped version of the entire specification so that the changes can be clearly distinguished. (LCO 3.4.1.2 - Jet Pumps)

6. Hodify the Applicability statement of the Recirculation Loop Flov specification to indicate that the recirculation flow mismatch limits are only applicable during two loop operation. Revise the Action statement l to allow for single recirculation loop operation, and add a 4.0.4 exception to the Surveillance Requirements to allow restart of an idle

! recirculation loop. (LCO 3.4.1.3 - Recirculation Loop Flow) l

7. The inecrporation of the above changes results in renunbering or shifting of the location of various table footnotes and Action statements.

Several references were added to the Bases discussions. Purely editorial changes of this type are simply identified on the marked-up pages in Attachment 3.

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3 , Attachmsnt 1 PY-CEI/NRR-1353 L Page 4 of 31 l

. DESCRIPTION OF CHANGES A. MCPR Safety Limit Por Single Loop Operation (Specification 2.1.2)

The objective during normal operation and transient events ir to maintain nucleate boiling and avoid boiling transition. This is accomplished by the establishment of operating limit which maintain an adequate margin to the transition boiling region. The figure of merit used for these operating limits is the Critical Power Ratio (CPR). This ratio is defined as the ratio of the criticcl power (bundle power at which boiling transition occurs) to the operating bundle power. The critical power is evaluated at the same mass flux, inlet temperature, e~1 the pressure.

existing for the specified reactor operatinF conditions. Thermal margin is considered to be the nargin from the current operating state to the onset of transition boiling, and is stated in terms of the Minimum Critical Power Ratio (MCPR). MCPR corresponds to the most limiting bundle in the core (i.e., lovest or minimum CPR).

Bounding statistical analyses have been performed which provide conservative MCPR Safety Limits (also referred to as the Puel Cladding Integrity Safety Limit) which are applicable for various modes of operation and all GE BVR fuel designs. The plant-cycle unique MCPR Operating Limit is established to ensure that for a transient of moderate frequency the MCPR vill not reduce to below the Puel Cladding Integrity (or MCPR) Safety Limit. This operating limit is obtained by adding to the MCPR Safety Limit the maximum change in CPR for the limiting operational transient (from rated conditions) postulated to occur at the plant. The Perry Nuclear Power Plant MCPR Safety Limit for two recirculation loop operation is 1.07.

As described in Section 15P.2 of Reference 1, during single loop operation the uncertainties in total core flov and Traversing In-Core Probe (TIP) measurements are greater than during two loop operation. The Safety Limit MCPR is determined using the General Electric Thermal Analysis Basis (CETAB) (Reference 2) which is a statistical model that combines all of the uncertainties in operating parameters and the procedures used to calculate the critical power. -Except for total core

.flov and TIP readings, the uncertainties used in the statistical analysis to determine the MCPR Safety Limit are not dependent on whether coolant flow-is provided by one or two recirculation pumps. A 6% core flow measurement uncertainty has been established for single loop operation (compared to 2.5% t.r two loop operation). The random noise component of

tne TIP reading uncertainty changes during single recirculation loop operation. This results in a GETAB determined TIP reading uncertainty of 9.1% for reload cores for single loop operation (compared to 8.7% for reload cores for two loop operation). The actual TIP reading uncertainty t is less since PNPP uses gamma TIPS versus the neutron TIPS assumed in the GETAB analysis, i

l Because of the increase in these analytical uncertainties the MCPR Safety Limit must be increased by 0.01 to 1.08 during single loop operation. By increasing the MCPR Safety Limit to account for the increased

, uncertainties, it can be shown that during a transient event initiated l from single loop operational conditions that 99.9% of the rods vill avoid I boiling transition (the same criteria as for two loop operation).

i ,

Attachment 1 PY-CEI/NRR-1353 L Page 5 of 31 The increased MCPR Safety Limit for single loop tmeration does not require an increase in the Operating Limit MCPR because analyses performed in support of this change indicate large nargins to the MCPR Safety Limit for the limiting transients initiated from the bounding single loop conditions (see Section 15F.3 and Table 15F.3-3 of Reference 1).

This change revises Specification 2.1.2 to indicate that the MCPR Safety

-Limit for single loop operation is 1.08. In Specification 3.4.1.1 -

Recirculation Loops, the proposed Limiting Condition for Operation

! requires that the MCPR Safety Limit be changed to meet the requirements of Specification 2.1.2 when implementing SLO. The MCPR Safety Limit value of 1.07 in the Action statement of Specification 2.1.2, and in Bases Sections 2.0, 3/4.1.3 and 3/4.2.2 vas replaced vith a reference to Specification 2.1.2 or just referred to as the MCPR Safety Limit to avoid repetition of the tvo loop and single loop values. No changes are directly required to the MCPR Specification (3.2.2) as these limits were relocated to the Core Operating Limits Report (COLR). However, the legend on the power dependent MCPR figure (MCPR ) within the proposed COLR has been revised to indicate that the presEnt single loop operation analysis assumes normal feedva'.er heating. Attachment 4 provides a sample copy of the changed page. The Bases for Section 3/4.2.2 have been modified to discuss the esta'alishment and applicability of the MCPR limits for SLO.

l B. APRH Flow Biased Scram and Rodblock Setpoints for Single Loop Operation (Specifications 2.2.1, 3.3.1 and 3.3.6)

Both the Reactor Protection System (RPS) and the Rod Control and Information System (RC&IS) use recirculation loop flow signals developed by summing the drive flow signals obtained via elbow taps for each loop.

L This flov signal is used to establish setpoints which increcse as core flow increases (i.e. flow-biased setpoints). Vhen the simulated thermal l -- power signal (neutron flux passed through a filter with a time constant of approximately 6.0 seconds to simulate the heat conduction through the fuel) exceeds the setpoint established by the recirculation loop drive flows, a scram occurs. Similarily, a flov biased control rod block setpoint (neutron flux is not filtered for rod blocks) is also established. Therefore, high power operation is only attainable-at high core flows.

The RPS and RC&IS APRM flow biased (Simulated Thermal Power-High scram and Neutron Flux-Upscale rod block) Technical Specification nominal trip setpoint and allovable values are determined by the equations given below. The RPS APRH flow biased scram setpoint automatically adjusts to ensure (in combination with the MCPR Operating Limit) that adequate margin is provided in the event of a transient (non-accident) event such that the transient does not result in a decrease in HCPR to below the Fuel Cladding Integrity (or MCPR) Safety Limit. The RC&IS APRH flow blaced rod block setpoint also adjusts itself automatically based upon the recirculation loop drive flow. The flov biased rod block prevents rod withdrawal and thereby limits the ability to maneuver into pover/flov regions where thermal margin may be reduced, and restricts the ability to maneuver near to the RPS APRH scram setpoints thereby avoiding l unnecessary scrams.

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i ,-

Attachment 1 PY-CEI/NRR-1353 L ,

Page 6 of 31

)

The PNPP low power Operating License Technical Specification Nominal Trip Setpoint and Allovable Value equations for the RPS and RC&IS flov biased trip functions for two recirculation loop operation within the standard l pover/ flow operating domain vere: "

TABLE A Trip Setpoint Allovable Value RPS Flow Biased Scram < 0.66V + 48% < 0.66V + 51%

RC&IS Flow Biased Rod Block 30.66V+42% 30.66V+45%

o Where V is the percentage of the total two recirculation loop drive flow measured at the elbov taps in each recirculation loop.

Vith NRC approval of the PNPP full power Operating License Technical Specifications which approved operation within the Maximum Extended Operating Domain (MEOD), the Nominal Trip Setpoint and Allovable Value equations for the RPS and RC&IS flow biased trip functions for two recirculation loop operation vere revised to the values listed below to

' allow operation within the MEOD. The current Technical Specification values are:

TABLE B Trip Setpoint Allovable Value RPS Flow Biased Scram < 0.66V + 64% < 0.66V + 67%

RC&IS Flov Biased Rod Block 30.66V+58% 30.66V+61%

The difference between the equations for the standard pover/ flow operating domain and those for MEOD is that the y-intercept has been increased by 16%. To illustrate, the y-intercept for the RPS flow biased scram trip setpoint was 48% for the standard pover/ flow operating domain (Table A) and was increased to 64% for MEOD (Table B). Therefore the APRM flov biased scram and rod block lines for MEOD operation vere raised by 16% from the standard pover/ flow operating domain equation value.

Conversely, for single loop operation the y-intercept is reduced from the standard pover/ flow operating domain equation value as described below.

During single recirculation loop operation, reverse flow through the

, ' inactive loop may be established. As a result the actual flow is not the sum of the two indicated recirculation loop jet pump flows. Therefore, the RPS and RC&IS APRM flow biased setpoints must be modified because more drive flov is required for single loop operation to produce a given core flov than is the case for two loop operation. The difference between these loop flows (or delta V) vas conservatively estimated to be 8% of rated recirculation loop drive flov. During the Startup Test Program the difference between the loop drive flows was measured and found to be about 4.2%. However, a value of 8% is used in the single

. loop equations for conservatism.

For single loop operation, the standard pover/ flow operating domain RPS

! and RC&IS APRM flow biased scram and rod block lines were assumed in the analyses. Consequently upon entry into SLO, these lines must be adjusted downward to account for the difference in total core flow between single and two recirculation loop operation.

i . Attachment 1 PY-CEI/NRP.-1353 L Page 7 of 31 The magnitude of the required y-intercept adjustment (5.3%) is derived from the expression 0.66 y 8%. Therefore, the y-intercept for single loop operation within the standard power /flov operating domain is reduced by 5.3% (compare Table n to C). The APRM flow biased scram and control rod block trip setpoint and allovable value equations for single loop operation are:

TABLI C Trip Setpoint Allovable Value RPS Flov Blased Scram < 0.66V + 42.7% < 0.66V + 45.7%

RC&IS Flov Biased Rod Block 30.66V+36.7% 30.66V+39.7%

The overall change in magnitude of the required y-intercept adjustment to initiate SLO (from MEOD conditions during two loop operation) is equal to the difference between the y-intercepts for the MEOD and the standard pover/flov operating domain (16%), plus the difference between the y-intercepts for two loop versus single loop operation within the standard pover/ flow operating domain (5.3%) - for a total reduction of 21.3% (compare Table B to C).

Following entry into SLO the setpoints for this instrumentation (and other affes,ed instrumentation) must be adjusted as required by the proposed Specification 3.4.1.1 - Recirculation Loops. Adjustment of the actual instrumentation setpoints is a complex evolution requiring a time period beyond that which may be considered reasonable for applying new limits for SLO. Contained within the low power Technical Specifications were provisions for the use of APRM gain adjustments to compensate for fuel peaking factor concerns during plant startup. Application of this type of feature for an interim period upon entering SLO in order to functionally implement the instrumentation setpoints has been approved for other nuclear plants. The magnitude of the required APRM gain adjustment to functionally implement the new setpoints on an interim basis following entry into SLO is 21.3% (based on the previous discussion). These APRM gain adjustments can be implemented within a reasonably short period of time. A notice of adjustment vill be posted on the reactor control panel indicating that the APRM gains have been adjusted to functionally implement the SLO flow biased equations. The time period for use of APRM gain adjustments is limited to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to ensure the APRM flov biased setpoints are adjusted and the gain adjustment is removed within a reasonable time period. This change therefore requires the application of the new setpoints within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> but allows the adjustment of the APRM gains to accomplish this requirement for an interim period of up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (as described in the footnotes to Specifications 2.2.1, 3.3.1, 3.3.6 and 3.4.1.1). Also, Table 4.3.1.1-1 note d has been revised to indicate that the APRM gain adjustments are not included in the 2% tolerance on specifying when to do an APRM calibration. This same exception was contained within the low power Technical Specifications for compensating for peaking factor concerns.

During SLO, power levels cannot be attained where the High Flow Clamped setpoint is needed for protection. Therefore, it is not necessary to specify a setpoint for this feature and it is not required to be operable during SLO.

i , Attachment 1 PY-CEI/NRR-1353 L Page 8 of 31 The new setpoint equations are reflected in Tahle 2.2.1-1, Item 2.b and Table 3.3.6-2, Item 2.a; the RPS scram and RC&IS control rod block instrumentation tables respectively. In Specification 3.4.1.1 the Limiting Condition for Operation and Action statements specify that the requirements of Specifications 2.2.1 and 3.3.6 must be met when implementing single loop operation. Also, footnotes have been added to Specifications 2.2.1, 3.3.1, 3.3.6 and 3.4.1.1 to indicate that the APRM gains can be adjusted to functionally implement the setpoints while the actual setpoint equations are being changed over. The Bases for Sections 2.2.1 and 3/4.3.6 have been modified to discuss the reduced APRM setpoints (and APRM gain adjustments) for SLO.

C. MAPLHGRs for Single Loop Operation (Specification 3.2.1 and the COLR)

The Average Planar Linear Heat Generation Rate (APLHGR) limit (otherwise referred to as the maximum APLHGR - or MAPLHGR) is applicable to a specific planar height for a specific fuel / lattice type. If the operating MAPLHGR does not exceed the MAPLHGR limits then the acceptance limits of 10 CFR 50.46 (i.e., 2200 F peak clad temperature, 17% maximum cladding oxidation, and 1% maximu.n hydrogen generation) vill not he exceeded during the design basis LOCA as described in Section 6.3 of the PNPP Updated Safety Analysis Report (USAR).

During single loop operation the MAPLHGR limits are multiplied by a single loop MAPLHGR reduction factor determined each cycle as part of the reload safety analysis. The single loop MAPLHGR reduction factor for the current cycle is calculated by GE and presented as part of the results in the Supplemental Reload Licensing Submittal (Reference 3) and vill be incorporated into the Core Operating Limits Report.

The single loop MAPLHGR reduction factor for the cycle is the smallest of the factors calculated for all the fuel types in the core. This single loop MAPLHGR reduction factor is presented as the " clamp" value on the power and flow dependent MAPLHGR Factor (MAPFAC) figures in the Core Operating Limits Report (COLR). Attachment 4 provides a sample copy of pages from the COLR reflecting this change. Future reload analyses provide reverification that this limit still applies with the new fuel types, or the limit is changed. The reduction of MAPLHGR is a result of an earlier boiling transition following a LOCA during single loop operation than following a LOCA during two loop operation. This is further discussed in Section 15F.5 of Reference 1. This earlier boiling transition is due to loss of forced coolant 41ov resulting from the assumed double ended rupture of the recirculation suction line in the operating loop (loss of nucleate boiling is assumed to occur at 0.01 seconds into the event regardless of the initial MCPR).

1 1

4 o- Attachment 1 PY-CEI/NRR-1353 L Page 9_of_31 No changes are directly required to the APLHGR Specification (3.2.1) as these limits were relocated to the Core operating Limits Report.

However, the single-loop MAPLHGR reduction factor calculated for the CE8 fuel installed-in the core during the last two reloads is 0.80 (see the Supplemental Reload Licensing Submittals (References 3 and 4) transmitted to the NRC in letters PY-CEI/NRR-1288L and 0935L, dated January 30, 1991 and November 28, 1988 respectively) versus 0.84 calculated for the GE6 fuel in the USAR Appendix.15F analysis-(Reference 1). The power and flow dependent MAPFAC figures proposed for the COLR (MAPFAC and MAPFACg )

indicatethiscorerestrictivecurrent" clamp"valueof0.80basedonthe Cycle 3 reload analyses.

The Bases have been modified to discuss the establishment of the MAPFAC and MAPLHGR limits for SLO and differences between the-ECCS analyses for two loop and single loop operation.

D. Modifications to the Recirculation Loops Specification to Implement Single Recirculation Loop Operation (Specification 3.4.1.1)

The Recirculation Loops Specification _- 3.4.1.1, is the governing specification directing the actions to be taken during single recirculation loop operation. A markup of Specification 3.4.1.1 is provided in Attachment 3. A retyped version of Specification 3.4.1.1 is provided for convenience in Attachment 3A. A summary of the changes to Specification 3.4.1.1 is provided here, with more details provided in Sections D.1 through D.4.

The Limiting Condition for Operation (LCO) of Specification 3.4.1.1 specifies an allowable operating region for two tecirculation loop operation by explicitly stating core flov and thermal power restrictions (current items a and b respectively). In order to simplify the proposed LCO for presenting both two and single recirculation loop operation,

__ Items a and b have been combined into one paragraph within the LCO. This

( allovable operating region is applicable for both two and single recirculation loop operation. LCO 3.4.1.1.a vould indicate that two recirculation loop operation is acceptable without any cpecial conditions, and LCO 3.4.1.1.b would direct adjustments to certain I specifications limits and setpoints, and impose pover/ flow and equipment l operation restrictions to ensure operation is within the bounds of the l safety analyses during SLO.

l The six conditions necessary to implement single recirculation loop operation are:

l

1. Increase the MCPR Safety Limit by 0.01 when in SLO to account for increased-core flow measurement and TIP reading

. uncertainties.

2. Reduce the APLilGR limits through the use of a single loop operation MAPLHGR reduction factor to account for the differences in the ECCS analyses between two and single recirculat!on loop operation.

-P . Attachment l' PY-CEI/NRR-1353 L i Page 10 of 31 l

3. Revise the APRM Flow Biased Scram and Control Rod Block Trip Setpoint and Allovable Value equations to reflect'~the indicated '

drive flow changes resulting from SLO operation.

4. Establish a recirculation loop drive flow limit cor.sistent with the reactor internals-vibration analyses. -

5. Place ths recirculation flow control system for the operating loop in-the Loop Manual mode to minimise flow control valve oscillations.

6. Limit thermal power to less than or equal to 2500 Megavatts-thermal (MVt) (slightly less than 70% of RATED THERHAL POVER) to remain within the bounds of the safety analyses.

Action statement a has been deleted from Specification 3.4.1.1 (transferred to Specification 3.4.1.3) as it is no longer applicable to place the plant in HOT SHUTD0VN within a certain time period when one recirculation loop is inoperable, provided that the changes described in the LC0 to implement single loop operation are made. This transferred action provides direction when it is not' desired to enter SLG and the recirculation loop jet pump - flow mismatch limits cannot be met.

Also,-Action Statements have been added to ensure that the appropriate actions are taken if any of the above single loop operation Limiting Conditions for Operation are found outside their respective limits (or to verify that the LCOs are within limits during the initial surveillance

_ period following' entry into SLO).

t  ;

The operating limits and setpoint changes specified within LCO 3.4.1.1.L.1 are initially verified to be in place upon initial entry into SLO in accordance with the new Action 3.4.1.1.a and are then checked at the normal surveillance frequency specified within the applicable

-specification. New Action statements (3.4.1.1.b, e and d) and l Surveillance Requirements (SR) (4.4.1.1.3) have been addei to ensure that the single loop flov and power limits are maintained, and that the recirculation flow control system is maintained in the Loop Hanual mode during SLO.-

L A new Action statement (3.4.1.1.e) and Surveillance Requirement 1:

(SR 4.4.1.1.4) has been added for operation at lov thermal power or low recirculation loop flow conditions to specify temperature limits that must be met prior to increasing thermal power or recirculation loop flow, i- and actions to be_taken if these limits are exceeded, to avoid thermal-l shock to the control rod and in-core guide tube housings due to the

[ potential for thermal stratification at these conditions.

l l Additionally, a reference to the temporary APRM gain adjustment method l in lieu of adjusting the APRM flov biased scram and rod block setpoints footnote has been made within LCO 3.4.1.1.b.l.c and Action a.

l

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. ... Attachment 1-PY-CEI/NRR-1353 L Page il of 31 The LCO for Specification 3.4.1.1 specifies that the restricted region of the power / flow map _should not be entered during normal operation. Action e of.the current Specification provides actions for when core flow it less than 45% of rated core flow and thermal power is greater than the

. limit shovn in Figure 3.4.1.1-1. These actions are being retained as Action g within the revised specification. The guidance for these limits may be found in Ceneral Electric Service Information Letter SIL-380, Revision 1, "BVR Core Thermal Hydraulic Stability" (Reference 7).

Following the Mr.rch 9,1988 power oscillation event at LaSalle Unit-2, the NRC issued Bulletin 88-07, and 88-07 Supplement 1 (Reference 8) regarding specific actions to be taken to avoid the region of potential instability and the actions to be taken if entry does occur. These actions have been incorporated into PNPP procedures as committed to within letters to the NRC in response to this Bulletin (References 9 through 12). These actions are applicable for inadvertant entries into the restricted region during single or two loop operation, and also address plant conditions _vhen_no recirculation pumps are running due to a trip:of both recirculation pumps (or of one recirculation pump when operating in the single loop mode). Implementation of the Bulletin actions provides for continued safe plant operation in the interim until long-term corrective actions are developed and put in place. CEI is also

-an active member of the BVR Owners Group-Stability Committee, which under oversight by-the NRC is_ pursuing long term solutions and vill take action when these are fully developed and approved.

D.1 Recirculation Pump Drive Flow-Limit (LCO 3.4.1.1.b.2, Action b, and

'SR 4.4.1.1.3.a)

As described in Section 15F.7.3 of Reference 1, all components met the simplified vibration _ acceptance criteria (absolute sum of all modal responses method) during two recirculation loop operation, and, during single loop operation, all components with the exception of the in-core -

guide tubes also met the same conservative criteria at drive flows up to and including 48,500 gpm. To allow operation at this drive flow during SLO,'the fatigue usage of the in-core guide tubes was evaluated using test data-from the test point with the highest recirculation loop drive-flow and thus the highest vibration amplit:1 des. For components which exceed the simplified vibration acceptance criteria (in this case the in-core guide tubes), the cumulative fatigue analysis methodology described in NRC Regulatory Guide 1.20 " Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing," (Reference 13) can be used.

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Attachment 1 PY-CBI/NRR-1353 1.

Page 12 of 31 Using-this methodology the fatigue life of the in-core guide tubes during-single loop operation was found to be 8.18 years at a recirculation drive flow of-48,500 gpm as described in Reference 1. Therefore it can be conservatively concluded that'the in-core guide tubes are structurally adequate to withstand flow-induced vibrations at drive flows less than or equal to the above value for a period of 8 years in single loop operation. All the other reactor internal components have vibration stress amplitudes below the endurance limit at this flow condition (48,500 gpm) and thus are expected to have an unlimited fatigue life during SLO.

Monitoring of the time duration in the single loop operational mode vill be performed in accordance with plant procedures. Eight years of fatigue life in the single loop operational' mode (for the limiting component -

the in-core guide tubes), represents a very large margin to the anticipated single loop operation usage. Based on these results a drive i-flow limit of 48,500 gpm is proposed as the single loop operation recirculation loop drive flow limit within the LCO to Specification 3.4.1.1, Recirculation Loops. The startup test data and the vibration and fatigue analysis performed indicates that all internal components of the_ reactor vessel vill be within acceptable vibration limits at this drive flov.

The recirculation loop drive flow limit for SLO is incorporated in the Specification 3.4.1.1 Limiting Condition for Operation - Item b,2, as well as in Action statement b, Surveillance 4.4.1.1.3.a and the Bases to the recirculation system specifications.

D.2 Recirpalation Flow Control Mode (LCO 3.4.1.1.b.3, Action c, and SR 4.4.1.1.3 b)

The curc9nt operating license for PNPP permits operation in all modes of recirculation flow control frem Loop Manual (position control) to Master Manual (flux control)._ The design is such that recirculation flow o control may be optimizedpfor.all pover/ flow conditions.

During single loop operation there is an-increase in drive flov and neutron flux noise versus two loop operation. This noise may cause unnecessary operation of the recirculation flow control valves in the flow control or flux control modes. Therefore, the recirculation flow controller for the operating loop should be placed in the Loop Manual (position control) mode to avoid this condition.

-This requirement is incorporated in the Specification 3.4.1.1 Limiting Condition for Operation - Item b.3, as well as in Action statement c, Surveillance 4.4.1.1.3.b and the Bases to the recirculation system specifications.

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t .o1 Attachment 1 i PY-CEI/NRR-1353 L Page 13 of 31 .

i D.3 Thermal Power Limit (LCO 3.4.1.1.b.4, Action d, and SR 4.4.1.1.3.c) l 1

During two recirculation loop operation core maneuvering is restricted to within the pover/ flow conditions specified on the current cycle Maximum .

Extended Operating Domain (MEOD) pover/ flow map. As described in Section I 15.F.3.1 of Reference 1, the analyses supporting single recirculation loop operation have been performed for the operating domain of the standard pover/ flow map (see USAR Figure 4.4-2) except thermal power was limited to 2500 Megavatts-thermal (MVt) (slightly less than 70% of rated i thermal power). Therefore, thermal power during single loop operation is i restricted to a maximum of 2500 MVt. I I

I This thermal power limit for SLO is incorporated in the Specification 3.4.1.1 Limiting Condition for Operation - Item b.4, as well as in Action j statement d, Surveillance 4.4.1.1.3.c and the Bases to the recirculation j system specifications.  ;

D.4 Thermal Stress Limits (Action e and SR 4.4.1.1.4) ,

During two recirculation loop operation forced coolant Gov is adequate J l to prevent thermal stratification in the bottom head region of the reactor pressure vessel (RPV). Thermal stratification is the formation of.a stagnant. layer of relatively cold water. If the layer of cold water were suddenly mixed with varm water such that the temperature in the i

region of the bottom head suddenly inercased then penetrations in the bottom head could expand at a rate different-than the bottom head, possibly resulting in the formation of cracks at these penetrations.

Single loop operation at low power or low flow conditions could potentially allow thermal stratification to occur. Analysis and prior operating experience for GE BFis under single loop operational conditions L

has demonstrated that operation with thermal power greater than or equal to 30% of Rated Thermal Power (RTP) and/or greater than 50% of rated (two loop) recirculation loop jet pump flow does not 1ead to thermal

~

l. stratification. Alternatively, operation belov 30% of RTP or 50% of rated recirculation loop jet pump flow conditions is permitted if the proposed Action e and Surveillance Requirement 4.4.1.1.4 are performed and the differential' temperatures are demonstrated to be within the defined limits prior to increases in power or flow. If operating l flexibility is needed testing may be performed during SLO to determine the actual recirculation loop jet pump flow that leads to the onset of stratification. A Technical Specification change vould then be submitted to-replace the 50% of rated core flow value with a lover measured value

! (plus some additional margin for conservatism). Differential temperature requirements (4.4.1.1.'4.b and c) do not apply when the loop not in

-operation is isolated from the reactor pressure vessel. Guidance for these limits is provided in General Electric Service Information Letter SIL-251, " Control of RPV Bottom Head Temperatures," (References 14 1

and 15). Also, to be consistent with Specification 3.4.1.4, Idle l'

7 Recirculation Loop Startup, (which contains the same temperature requirements) a statement has been added to the surveillance requirements indicating that the differential temperature requirement of 4.4.1.1.4.a does not apply when the reactor pressure vessel is belov 25 psig.

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e' 4 Attachment-1 PY-CEl/NRR-1353 L Page 14 of 31 These differential temperature limits during SLO are inenrporated in Action statement e, Surveillance 4.4.1.1.4 and are described within the Bases to the recirculation system specifications.

E. Jet Pump Operability (Specification 3.4.1.2)

Several clarifications are being requested to the Surveillance Requirement of Specification 3.4.1.2 - Jet Pumps, to implement single recirculation loop operation and clear up some inconsistencies within the specification. The first paragraph of Surveillance Requirement 4.4.1.2 ,

currently states that the surveillance is to be performed prior to exceeding 25% of RATED _THERHAL POVER (RTP) while part d provides an exception to Specification 4.0.4 allowing the surveillance to be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 25% of RTP. Therefore, modifications are suggested to clarify the initial surveillance frequency. The statement within SR 4.4.1.2 about "both recirculation loop indicated flows are in compliance with Specification 3.4.1.3" is removed since this requirement is not applicable during single ,

recirculation loop operation and since appropriate requirements for matching of both recirculation loop jet pump flows (during two loop operation) are already contained within Specification 3.4.1.3 vhich applies in.the same Operational Conditions. Several inconsistencies in usage regarding the terms-recirculation loop flov (nov renamed recirculation loop jet pump flow for clarity), recirculation loop drive flow, and total core flov are also corrected to be consistent with other specifications. Also, Surveillance Requirement 4.4.1.2.c is being revised to indicate that either jet pump differential pressure or flov

-are acceptable criteria for recognition of jet pump degradation in accordance with the resolution of NRC Bulletin 80-07, "BVR Jet Pump Assembly Failure" (Reference 16) as described within NUREG/CR-3052 which closed out-this Bulletin.

The wording of the first paragraph of Surveillance Requirement (SR) 4.4.1.2 contains an apparent conflict in that it currently states that the jet pump surveillances ' vill be performed prior to exceeding 25% of RATED THERHAL POVER vhile Surveillance Requirement 4.4.1.2.d indicates that the provisions of Specification 4.0.4 are not applicable provided that the surveillance is performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 25% of RTP. -The intent of this surveillance requirement is to require the jet pump surveillances to be performed at power levels exceeding 25% of RTP because attempts to perform these surveillances at less than 25% of RTP do not provide reliable or consistent data. This has been verified with General Electric and is based on industry experience. Therefore, the wording in the first paragraph of SR 4.4.1.2 has been revised to eliminate the inconsistency. Difficulty in obtaining reliable data is usually experienced during routine startups since OPERATIONAL CONDITIONS 1 and 2 are entered before 25% of RTP is approached, but also when, for a plant which had been operating at power levels greater than 25% of RTP, power must be reduced to belov 25% of RTP for some reason.

4-e Atta'hment c l~ -

PY-CEI/NRR-1353 L Page 15 of 31 To clarify the' intent as it applies to either situation, the vords " prior to THERMAL POVER exceeding 25% of RATED THERHAL POVER and at-least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while gteater than 25% of RATED THERHAL POVER" vill there- *

, fore be changed to "at least once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s-when THERHAL POVER is greater than 25% of RATED THERHAL POVER." Surveillance Requirement 4.4.1.2 part d is being reformatted as a continuation of the first paragraph and is no longer listed as a separate surveillance requirement, as it is really a general statement applicable to all the parts of SR 4.4.1.2.

The exception to Specification 4.0.4 is still needed to allow the individual surveillances to be performed when power levels are greater than 25% of RTP, rather than prior to entry into Operational Condition 1 or 2.

The last sentence of the first paragraph of Surveillance Requirement 4.4.1.2 currently refers to Specification 3.4.1.3 - Recirculation Loop Flov. Specification 3.4.1.3 requires that the two recirculation loop flows be balanced to within certain limits-during two recirculation loop operation. This " matched flow" condition is only applicable during two recirculation loop operation. The primary purpose of the various checks performed under Surveillance Requirement 4.4.1.2 Parts a, b and c are to -

verify jet pump integrity / operability. This only requires checking performance or verifying certain relationships within each recirculation loop and does not necessarily require comparing or matching recirculation loop jet pump flows. For example, part a of Surveillance Requirement  ;

4.4.1.2 requires monitoring the recirculation loop drive (or pump) flow versus flow control valve (FCV) position relationship for each recirculation loop. Part c currently requires comparing the jet pump diffuser-to-lover-plenum differential pressure for each jet pump to an average differential pressure established from the jet pumps on the same recirculation loop. Performance of these surveillances does not require

-having the indicated FCV positions for each recirculation loop matched since each loop is evaluated independently. Since Specification 3.4.1.3 applies in the same operational conditions as Specification 3.4.1.2 (during OPERATIONAL CONDITIONS 1 and 2), the requirements of Specification 3.4.1.3 (for matching -recirculation loop jet pump flows to within-the required limits) must continue to be met during performance of-

-the Surveillance Requirements under Specificaticn 4.4.1.2 when in two recirculation loop operation. In single recirculation loop operation Specification 3.4.1.3 no longer applies. Therefore, it is not necessary to include a reference to Specification 3.4.1.3 within Surveillarce Requirement 4.4.1.2.

T The wording within Surveillance Requirement 4.4.1.2 is being revised to clarify that the current term " recirculation loop flow" in this particular specifications usage vould correspond to " recirculation loop drive flov" elsewhere and is being changed to be consistent. The term

" total' core flow" is now being changed to ":ecirculation loop jet pump flow" to apply to both SLO and TLO. and is teing revised for consistency between Specifications 3.4.1.1, 3.4.1.2 and ?.4.1.3.

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o y Attachment 1 PY-CEI/NRR-1353 L ,

Page 16'of 31 .I For example, the flov measured in. Surveillance Requirement 4.4.1.2 part a is actually the driving (or recirculation punp) flow in the recirculation loop before the. jet pumps are reached. In Specification 3.4.1.3 the recirculation loop jet pump flov is the flov from a particular recirculation loop at the discharge of the jet pumps, 'Ihis change vill allow the nomenclature to be consistent between the recirculation system specifications. The first paragraph of Surveillance Requirement 4.4.1.2 and parts a and b have been revised to reflect the correct terminology. -

Also, " total core flow" is ob'ained by summation of the two recirculation

-loop jet pump flows, but the flov for each recirculation loop is obtained independently. To clarify this specification for SLO the term " total core flow" is removed. Total core flow does not have the same definition during single loop operation as it does for two loop operation, considering the back flow through the idle recirculation loop.

Therefore, collection of recirculation loop jet pump flov data is sittituted for total core flow data. (The summation of the two recirculation loop jet pump flows is the total core flov during two loop operation, and each loop is evaluated independently against the recirculation' loop drive flow for that loop.) Recirculation loop jet pump flov in this usage provides a true and meaningful comparison of loop characteristics for either two or single tecirculation loop operation. The Recirculation System Bases have been revired to clarify the various recirculation system flow terms. '

The changes to SR 4.4 l.2 part c are based on General Electric Service and Information Letter (SIL) Number 330, " Jet Pump Beam Cracks,"

(Reference 17) and.NUREG/CR-3052, " closeout of IE Bulletin 80-07: BVR Jet Pump Assembly Failure," (Reference 18). The NUREG recognized the SIL as providing acceptable guidelines for verifying jet pump operability and for closcout.of Bulletin 80-07, "BVR Jet Pump Assembly Failure" (Reference 16). Both NUREG/CR-3052 and SIL-330 recognize that a 10%

deviatf.on f rom normal between the jet pump rlow and the average jet pump flow is an acceptable criterion. Both documents also recognized that either differential pressure and/or flow could be monitored, depending on a plant's particular instrumentation, and that a 10% change in jet pump.

flow corresponds to at least a 20% change in-differential pressure.

At PNPP, indication for both jet pump dif fuser-to-lover plenum differential pressure and jet pump flow is provided for each jet pump from the same differential pressure sensor associated with each jet pump.

- Therefore, if jet pump dif fuser-to-lover plenum differential pressure is the monitored variable, then 20% should be the acceptance criterion for that variable. The current Surveillance Regt.irement (4.4.1.2 part c) however, specifies 10% (deviation) as the acceptance criterion for jet pump diffuser-to-lover plenum differential pressure. This value is too restrictive relative to differential pressure and is not the value specified in SIL-330 as.an acceptance criterion for that variable.

Therefore, it is requested to modify the surveillance acceptance criterion to be 10% for jet pump flov and 20% for jet pump diffuser-to-lover plenum differential pressure.

. . Attachment 1 i PY-CEI/NRR-1353 L l Page 17 of 31 During normal power operations all jet pumps (20) are tequired to be operable. Vith one or more jet pumps inoperable llot Shutdovn must be achieved within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. As noted in the Bases for the recirculation system specifications, while an inoperable jet pump is not in and of itself a reason to declare a recirculation loop inoperable, it may be indicative of a jet pump failure which could impact the reflood capability of the core if a design basis LOCA vere to eccur. Therefore, a shutdown requirement is appropriate.

The current surveillance requirements require all jet pumps to be demonstrated operable by comparison of several parameters to known performance characteristics. In the case of single loop operation these characteristics vill be different than for two loop operation. During single loop operation, surveillance testing can only directly demonstrate that the jet pumps in the operating loop are operable. Since the backflov through the jet pumps in the non-operating loop is extremely lov (less than 10% of rated jet pump flow), the loads on these jet pumps have been demonstrated to be quite small (based on prior operational experience at other BVRs) compared to the loads during normal tvo loop operation. Therefore, it is extremely unlikely that a failure could occur that vould result in jet pump diffuser displacement and consequent loss of two-thirds core height refloodability. The jet pumps in the non-operating loop are considered operable based on the lov expected loading, prior acceptable surveillance results during two recirculation loop operation, or inspection of the jet pumps during refueling or shutdowns. As a result, only the 10 jet pumps in the operating loop need to be (and can be) directly demonstrated operable during single loop operation and the first sentence of SR 4.4.1.2 is revised to reflect this.

Also, the footnote indicating that the specified relationships (characteristic curves) are established during the startup test program has been revised to reflect PNPP's current operational versus startup testing status by noting that these relationships are established at the beginning of each operating cycle, or in the case of single loop operation during first use of SLO in an operating cycle.

These jet pump relationships are incorporated in Surveillance 4.4.1.2 and their establishment is discussed within the Bases to the recirculation -

system specifications.

F. Recirculation Loop Flow Mismatch (Specification 3.4.1.3)

During two recirculation loop operation it is required that the recirculation loop flows be matched to comply with certain assumptions used in the design basis Loss of Coolant Accident (LOCA) analysis. For a LOCA during two recirculation loop operation, caused by a recirculation loop pipe break, the intact loop is assumed to provide coolant flov during the first few seconds of the accident. The initial core flow decrease is rapid because the recirculation pump in the broken loop ceases to pump almost immediately since it has lost suction. The pump in the intact loop coasts dovn relatively slowly. This pump coastdown governs the core flow response for the next several seconds until the jet pump suction is uncovered. The two recirculation loop analyses assume both loops are operating at essentially the same flov (within certain limits) prior to the accident.

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Attachment 1-PY-CEI/NRR-1353 L' Page 18 of 31 If a LOCA occurs with a flov mismatch between the two loops, the analysis-conservatively assumes the pipe break is in the loop with the higher

-flov. The: flow coastdown and core response is potentially more severe in this case since the intact loop is starting at a lower flow rate and the core response-is the same as if both loops were operating at the lower flow rate. As described within Part C of this letter and Section 15F.5-of Reference 1 a plant-specific LOCA analysis has been performed for PNPP assuming only one operating recirculation loop. This analysis demonstrates that in the event of a LOCA caused by a pipe break in the operating recirculation' loop, the ECCS response vill provide adequate.

core cooling provided the APLHCR limits are reduced through multiplication.by a single loop operation HAPLHGR reduction factor (which is less than 1.0). The limiting transient analyses of Chapter 15 of the USAR have also been performed for single recirculation loop operation (Reference 1) and demonstrate sufficient flow coastdown characteristics to maintain fuel thermal margins during abnormal operational events tL above the single loop operation Safety Limit MCPR as described in Part A of this letter and Sections 15F.2 and 15F.3 of Reference 1.

These recirculation loop flow mismatch limits (note this term is being changed to recirculation loop jet pump flov - as previously described in Part E of this-letter for consistency throughout the specifications) only

- apply during-two recirculation loop operation. The Applicability of Specificatien 3.4.1.3 has been revised to indicate this. Also, vithin

- LCO items a and b the term " recirculation flov" is being changed for clarity to " core flow". Recirculation flov in this specifications useage is the total. flow recirculating through the core (i.e., the sum of the two tecirculation loop jet pump flows - which is equal to the core flow).

The current Actions direct the operator to restore any recirculation loop jet pump flow mismatch (using the.new terminology) to within limits within 2 hcurs or,-falling that, to begin to place the unit in Hot Shutdovn as directed by-Action a of Specification 3.4.1.1 (based on two-recirculation loop operation and the corresponding analysis). Since

, Action.a is being removed from Specification 3.4.1.1 (since it is not applicable in Specification 3.4.1.1 foloving implementation of SLO) it is no longer appropriate to refer to it there. Therefore. the Specification -

3.4,1,1 Action a words are being combined into the current Action o of this Specification (3.4.1.3). This relocated action provides direction for when the mismatch limits cannot be maintained and it is not desired to enter SLO, that pover be reduced to less than the limit specified on

! Figure 3.4.1.1-1 and a plant shutdown be initiated. As an alternative,- ,

revised Action b permits the operator to shutdown one of the recirculation loops and take the actions required for entry into single loop operation per Specification 3.4.1.1 1f the flov~ mismatch limits can

, not be met. This vould place the unit in compliance with the ECCS-LOCA L evaluation for single recirculation loop operation.

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. . Attachment 1 PY-CEI/NRR-1353 L j Page 19 of 31 l'

An exception to the provisions of Specification 4.0.4 is added to Surveillance requirement 4.4.1.3. This exception is necessary since this specification is only applicable during two recirculation loop operat{on (the and 2(PPLICABILITY has been during two recirculation revised loop to read operation" to "0PERATIONAL clarify this), and CONDITIONS 1 therefore, upon startup of an idle tecirculation loop during SLO (return operation) the APPLICABILITY of this specification vould be entered.

Vithout this 4.0.4 exception, the mismatch surveillance vould be required to be preformed prior to entering the Applicability of the LCO, hovever it is not possible to satisfy the mismatch limits until atter an idle recirculation pump nas been restarted and the flow control valves have been adjusted. Therefore this 4.0.4 exception is needed to permit a return to two recirculation loop operation from the single loop condition.

SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Commissions's Regulations, 10 CFR 50.92, which state that the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accidec.t previously evaluated, (2) create the possibility of a new or different kind of accident from any previously evaluated, or (3) involve a significant reduction in a margin of safety.

CEI has reviewed the proposed amendment with respect to these three factors and has determined that the proposed changes do not involve a significant hazard. A discussion with respect to significant hazards for each of the changes is presented in the following sections:

A. MCPR Safety Lirit For Single Loop Operation The MCPR Safety Limit of 1.07 is increased by 0.01 during single loop operation to 1.00. This change is due to the increased uncertainties in core flow and neutron flux (TIP) measurements. The basis for the MCPR Safety Limits are found in the GE fuel licensing topical report " General Electric Standard Application For Reactor Fuel," (Reference 19). The basis for the proposed single loop operation MCPR Safety Limit is found in Appendix 15F to the PNPP Updated Safety Analysis Report (Reference 1).

1) The MCPR Safety Limit is set such that no fuel damage is expected to occur if the limit is not violated. The method used to determine the MCPR Safety Limit is NRC approved, the General Electric BVR Thermal Analysis Basis (CETAB) (Reference 2). This method combines operating parameter uncertainties with uncertainties in the CPR calculational method to establish the MCPR Safety Limit. The safety limit for single loop operation increases due to increases in the operating parameter uncertainties.

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. 4 Attachm:nt 1 PY-CEI/NRR-1353 L {

Page 20 of-31 l Because the MCPR Safety Limit for single loop operation is set such that 99.9% of the fuel rods in the core are expected to avoid transition boiling, the single loop operation MCPR Safety Limit performs the same function and meets the same NRC approved acceptance criteria as the two loop value, and thus this change does not increase the probability or consequences of any event previously analyzed.

2) The MCPR Safety Limit does not represent a limit from which automatic actions are initiated, that if the action did not occur, or that, if it occurred at a different value, would result in increased consequences for an accident or transient.

The MCPR Safety Limit is adjusted in the conservative direction to account for increased uncertainties associated with core flov and flux measurements during single loop operation. No changes are made to the PNPP facility, so this change does not create the possibility of a different type of event than pteviously analyzed.

3) The MCPR Safety Limit is set at a point at which 99.9% of the fuel rods in the core are expected to avoid transition boiling, hence avoiding fuel damage. The MCPR Safety Limit is combined with the change in CPR from the limiting transient event for the current cycle to establish an Operating Limit MCPR.

Operatiun at or above the Operating Limit MCPR ensures that the MCPR Safety Limit vill not be violated during the limiting transient event.

The methods for determining the Safety Limit and Operating Limit MCPR are described in GETAB (Reference 2). These methods have received NRC approval. No changes to these methods are proposed. For the MCPR Safety Limit the actual physical limit to measure against is difficult to directly determine. For this reason conservative limits vere defined. For example, i actual fuel damage in the event of a transient does not occur l automatically if the MCPR decreases to 1.0; this-only means i that 50% of the fuel rods may experience transition. boiling.

At the specified value defined as the Technical Specification MCPR Safety Limit (1.06 for cycle 1, 1.07 for reload and susequent cycles, 1.08 for single loop operation) the l probability is that at least 99.9% of all fuel rods in the core j vill avoid transition boiling. All of these values have the same margin of safety; they correspond to a HCPR of 1.0 plus an

' adjustment for statistical uncertainties for each mode / cycle of operation. This method for setting the safety limits has been l approved by the NRC in GESTAR (Reference 19). The actual margin of safety is between the MCPR Safety Limit and an

< unknown fuel failure point (e.g., perhaps a HCPR equal to 0.8).

L The fuel vould actually have to remain in this condition for L some time period for fuel damage to occur; nonetheless the MCPR

!~ Safety Limit is a convenient measuring point.

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7 i Attachmant 1 PY-CEI/NRR-1353 L '

Page 21 of 31

. Analysis performed by General Electric l'n support of single loop operation (Reference 1) indicates that the two loop Operating Limit MCPR bounds the single loop Operating Limit MCPR,'hence-this limit does not need to be changed. Operation at or above the Operating Limit MCPR calculated each cycle for the limiting transients (as adjusted-by the pover-and flow dependent MCPR factors for off-rated conditions) ensures that, in the ever.t of the limiting transient from its vorst case i conditions, the resulting MCPR vould not be reduced to below the Fuel Cladding Integrity Safety Limit (or MCPR Safety Limit) and hence does not involve a significant reduction in the margin of safety.

B. APRM Flow Biased Scram and Control Rod Block Setpoints for Single i Loop Operation The APRM flow biased scram setpoint in combination with the Operating Limit MCPR ensures that the Fuel Cladding Integrity MCPR Safety Limit is not violated during a transient event. The APRM flov biased control rod block setpoint is set such that control rods may not be maneuvered to allow power to increase to the scram setpoints._ These setpoints use a flow input from the recirculation system flov instrumentation to develop a signal which varies vith recirculation loop drive flow. This allows the setpoints to perform their automatic protective function over the entire range of the pover/flo,t map.

Both the APRM flov biased scram and control rod block setpoints are adjusted during single loop operatio'a to account for the portion of

l. the operating loop flov vhich produces reverse flow through the inactive loop jet pumps.

1)- The APRM flov biased scram setpoint is established such that if the Operating Limit MCPR is being adhered to, then the MCPR Safety Limit vill.not be violated during the limiting operational transient. APRM gain adjustments functionally implement the protective functions of the APRM flot ased equations while the equations are being changed over. The setpoints vill be adjusted in the conservative direction (relative to two loop operation) for single loop operation to account for reverse flow in the idle loop jet pumps.

Therefore, this change does not result in an increase in the probability or consequences of an accident previously' analyzed.

2) While the APRM flov biased scram and control rod blocks provide automatic action, the setpoints are only exceeded when the reactor power (neutron flux) increases to exceed the setpoints.

Power increases of this- type occur from transient events (of which the limiting events have been analyzed) or by misoperation of the control rods, both of which have been analyzed in Chapter 15 and/or Appendix 15F. Therefore, this amendment does not result in the possibility of an accident l different than those previously analyzed.

. . Attachmtnt 1 PY-CEI/NRR-1353 L-Page 22 of-31

3) These APRM flow biased setpoints (or as adjusted by the APRH gains during interim operation) provide initiation of protective action to maintain safety limits (scram) and operating limits (control rod block). The changes are in the conservative' direction (relative to two loop operation) and account for reverse flov in the idle loop jet pumps during single loop operation. These changes are intended to maintain the existing margin of safety during SLO. As a result, these changes do not reduce the margin of safety.

C.- HAPLHGR Limits For Single Loop Operation 10 CFR 50.46 establishes acceptance criteria for Emergency Core Cooling System (ECCS) performar.ce. In'particular, limits are placed upon the peak cladding temperature, maximum cladding oxidation, and maximum hydrogen generation during a design basis Loss-of-Coolant Accident (LOCA). HAPLHGR limits are established such thate if adhered-to during steady state operation, the above limits (peak cladding temperature, etc.) vill not be exceeded during the design basis LOCA.

1) The probability of a LOCA is the same as that currently -

established within the USAR and is unaffected by any changes made for SLO. This Technical Specification change provides a reduction factor for the current two loop operation HAPLHGR limits to adjust for single loop operation. The single loop reduction factor is calculated based on methods described in

" General Electric Company Analytical Model for a Loss of Coolant Accident," as amended for one recirculation loop out-of-service (References 5 and 6). The MAPLHGR is reduced by the single loop HAPLHGR reduction factor to account for the

-earlier occurrence of transition boiling associated with a LOCA event during single loop operation. The SLO HAPLHGR ensures that the ECCS acceptance criteria of 10 CFR 50.46 are met during a design basis LOCA from SLO conditions, the same criteria as for two recirculation loop operation. Therefore, the proposed change does not result in an increase in the probability of, or an increase in the consequences of, an event previously analyzed.

2) The HAPLHGR limits are not setpoints from which automatic actions are initiated such that if exceeded would increase the consequences of a transient or an accident. The HAPLHGR limits are conservatively adjusted during single loop operation to account for the earlier boiling transition during a LOCA from the single loop operating condition so this change does not create the possibility of an accident ot transient different than that previously analyzed.

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4 Attachment 1 I.- PY-CEI/NRR-1353 L 9 Page 23 of 31

4 3)- The HAPLHCR limit at-each exposure point is the limit belov vhich during a design basis LOCA the ECCS acceptance criteria '

of 10 CFR 50.46 are satisfied. The existing two loop operation MAPLHGR limits are adjusted in the conservative direction to account for earlier boiling transition and the same acceptance s

' criteria are satisfied during single loop operation.

Therefore, the proposed amendment does not reduce the margin of safety.

D.1 Recirculation Pump Drive Flow Limit A recirculation pump drive flow limit has been established based upon startup test cesults and the results of a reactor internals vibration and fatigue analysis performed for PNPP. The results indicated that vibrution levels vere within acceptable limits for single loop operation at this drive flow limit.

1) During two loop operation no recirculation loop drive flow limit exists because the loop flows are balanced so that little vibration occurs. Single loop operation requires that a drive flow limit be imposed. Analysis demonstrates (see USAR Section 15F.7.3) that operation at or below this drive flow limit ensures vibration levels are acceptable and therefore, there is no significant increase in the probability of component failure during SLO. The consequences of various component failures was considered as part of the selection of the various transient events analysed in Chapter 15 and the more limiting set analysed for SLO. Therefore, operation within the region bounded by the drive flow limit does not increase the probability or consequences of an accident or transient previously analyzed.

2) Upon entering into the .ningle loop operational mode the operator is instructed by the Technical Specifications (implemented through operating instructions) to reduce drive flow to less than or equal to the single loop drive flov limit, and periodically verify that this limit is in effect-through performance of surveillances. By maintaining-this restriction no accidents or transients different than those previously analyzed are expected to occur.

l

3) The drive flov limit for single loop operation was established based upon vibration and fatigue analyses with actual PNPP l- start-up test data. This limit establishes a region in which the reactor internals vibration is maintained within acceptable limits, therefore there is no reduction in the margin of safety, i

i i I

l . . Attachment 1 PY-CEI/NRR-1353 ',

Page 24 of 31 D.2 Recirculation Flov Control Mode The design tf the recirculation flow control system allows operation in the Loop Manual (position control), Flux Manual-(flow control),

and Master Manual (flux control) modes. Hovever, during single loop operation only the Loop Manual mode of control vill be allowed.

During single loop operation there is an increase in core flow noise and neutron flux noise, which may lead to flow control valve

" hunting" during single loop operation if the Flux Manual or Master Manual modes are used.

1) During two recirculation loop operation the loss of feedvater heating transient with the recirculation flow controller in the Loop Manual mode of operation is the most severe transient with regard to CPR. Because of the lover power level associated v,*th single loop operation the loss of feedvater heating transient is less severe than the presiously analyzed transient in the USAn (or the current reload analysis) for two loop operation.

Also, by placing the recirculation flow controller in the Loop Manual mode of operation, potential oscillations leading to an increase in core flow and a possible decrease in MCPR are avoided. Therefore this change does not result in an increase in the probability or consequences of an accident or transient previously analyzed.

2) Operation of the recirculation flow control system in the Loop Manual mode is bounded by the design of PNPP. This mode of flow control is utilized during single loop operation to avoid recirculation flow control system flow oscillations due to the associated core flow and/or neutron flux noise. As a result the proposed change does not result in the possibility of a transient or accident different from those previously enalyzed.

3) Operation with the recirculation flow control system in the Loop Han 1 Mode has been previously enslyzed in the FNPP Updated Saf; Analysis report (see response to question 1). For single loop operation the results for the limiting transients analyzed vare found to be less severe than for two loop operation.

Tbcrefore operating with the recirculation flow controller in Loop Manual does not result in a reduction in the margin of safety.

D.3 Thermal Power Limit The current design for PNPP allows two recirculation loop operation at up to 3579 Megavatts-thermal (MVt) which corresponds to 100% rated thermal power. Analysis performed for PNPP to support single recirculation loop operation supports operation at 2500 MVt, which is slightly less than 70% of rated thermal power.

.- .. Attachment 1 PY-CE1/NRR-1353 L Page 25 of;31

1) . Reduction of the maximum thermal power limit in no way intluences the probability of a transient or accident. This reduced power corresponds to that portion of total core flov lost going from two loop operation to single loop operation at 100% of rated thermal power. The single loop analyses performed in support of this change demonstrate that operation at this thermal power limit is conservative and thus the consequences of a transient or accident are less than the previously analyzed events for two loop operation due to the reduced initial power level, or adjustments are made, such as the imposition of a cycle-specific SLO HAPLHGR reduction factor so that consequences remain within acceptable limits.

Therefore, there is no increase in either the probability or consequences for the reduced thermal power operational limit '

implicit within SLO.

2) The thermal power limit does not represent a limit from which automatic actions are initiated, that if the action did not occur, or that, if it occured at a different value, vould result in increased consequences for an accident or transient.

This limit is set in the conservative direction and is intended to account for the reduced core flov available during single loop operation. No changes are made to the PNPp facility, therefore this change does not create the possibility of a transient or accident not previously analyzed.

3) The analyses in support of this change vere performed at 2500 MVt. As a result, changes to limits and setpoints have been made based on the assumed analysis conditions to provide the same level of protection in single loop operation as is currently in place for two loop operation. Therefore, this-change does not reduce the margin of safety.

D.4 Thermal Stress Limits During two loop operation forced coolant flow is adequate to avoid

- thermal stratification. However, at low power or low flow c nditions during-single loop operation thermal stratification may occur in the reactor vessel bottom head. If core flov increases st4denly, then hot vater may sweep the colder water out of the bott>m head region which may result in high thermal stress

- cond2tions to the recirculation system, or to the control rod' drive

.(CRD) and in-core guide tube housing velds.

1) To ovoid this thermal stressing of the recirculation system, the CRD and the in-core guide tube housings. surveillance requirements are imposed to ensur'e that differential temperatures between the coolant in the reactor vessel bottom head and top head, the active and inactive recirculation loop, and the inactive loop and the vessel are maintained below specified limits prior to an increase in power or flov.

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, , Attachment 1 PY-CEI/NRR-1353 L Page 26 of 31

-This surveillance is only required to be performed prior to power and flov increases during single loop operation with power less than or equal to 30% of rated thermal power.1or flov less than or equal to 50% of rated core flov. These limits are conservat vely set such that this change does not increase the d

probability or consequences of an event previously analyzed.

2) The proposed limits are provided to avoid the potential for repeated thermal stressing of the recirculation system, or the CRD and in-core housing velds. These values are conservatively set to avoid occurrences which may lead to thermal overstress conditions in the velds mentioned above. -Therefore, this change does not create the possibility of a different cype of event than previously analyzed.

3) Maintaining the limits stated above during single loop operation vill avoid conditions which may lead to high thermal stressing of the recirculation system, or the CRD and in-core guide tube housing velds. Therefore, stress levels experienced will not differ from those experienced during two loop operation, and hence this change vill not reduce the currcnt margin of safety.

E. Jet Pump Operability During single loop operation the performance characteristics observed to demonstrate jet pump operability are different than I those characteristics observed during two loop operation. This specification provides the direction to use single loop operation performance characteristics. The single loop operation characteristics vill be determined prior to extended operation in this mode. Only the jet pumps in the operating recirculation loop are required to be directly demonstrated operable during SLO.

i 1)' The current performance characteristics used to determine jet-

pump operability are determined during the startup test program (each cycle) for two recirculation loop operation. This change recognizes that single loop operation characteristics must be determined during first useage of the single loop mode of i

operation each cycle. As noted in the Bases for this Technical Specification, an inoperable jet pump is not, in and of itself, a sufficient reason to declare a recirculation loop-inoperable, but it does, in the case of a design basis LOCA, increase the blovdown area and reduce the capability for reflooding the core. The proposed changes vill demonstrate continued operability of the jet pumps in the operating loop during single loop operation.

l

e e Attschmtnt 1 FY-CEl/NRR-13$3 L Page 27 of 31 1

Removing the requirement to match the recirculation flow control valve positions to within the limits specified in Specification 3.4.1.3 does nothing except eliminate a redundant requirement since the same OPERATIONAL CONDITIONS apply to both specifications and this is only a meaningful condition during two recirculation loop operation. Clarifying the intent of the 1 4.0,4 exception and the performance conditions of the. I surveillance with respect to 25% of RTP eliminates ambiguity within the specification.

The editorial changes have been made to consistently identify and use terms between specifications. This vill enhance the j useability of the specifications. i The proposed change to the specified acceptable deviation f'om patternr established for individual jet pump dif fuser-to-lover i plenum differential pressures (from 10% to 20%) and establishment of a 10% allowable flov deviation is consistent with the recommendations of SIL-330 which establishes these i values as acceptable ludica*. ions of jet pump operability. i l

These changes do not involve a significant increase in the probability or consequences of a design basis accident because jet pump operability vill continue to be verified in accordance with the intent of the basis behind the surveillance requirements. There is no change in operability requirements, only that these are revised to account for single loop operation therefore, this change does not increase the probability or the consequences of an accident or transient previously analyzed.

2) This change maintains the requirement that all jet pumps be

' operable while accounting for different performance characteristics during single loop operation. No change is made to the plant design. Therefore, the proposed change does not result-in the possibility of an event other than that previously analyzed.

3) The proposed changes do not involve a significant reduction in a margin of safety. Removing the requirement to match the recirculation flows vill not affect the margins of safety assumed in any plant design calculation since, as noted earlier, loop flow mismatch vill be maintained within the limits stated in Specification 3.4.1.3 during two recirculation loop operation and the misratch limits are meaningless during single loop operation. Although there is a change to the allovable deviation from established patterns currently stated for the jet pump dif fuser-to-lover plenum dif ferential pressures for declaring a jet pump operable, SIL-330 establishes 20% as an acceptable criterion for differential pressure (and 10% for flov), both of which are recognized and approved by the NRC in NUREG/CR-3052.

4 . Attachmant 1 PY-CEI/NRR-1353 L Page 28 of 31 1 The remaining proposed channa, af fecting the vording of the Specification (including the applicability of the Surveillance Requirements), do not change the intent or implementation of the requirements of this Technical Specificatien and vill not result in any reduction of effectiveness in verifying jet pump operability or integrity. All jet pumps in an operating recirculation loop are required to be demonstrated operable per Specification 3.4.1.2. This proposed change clarifles that performance characteristics censistent with single loop operation must be established for operation within that mode.

During single loop operation, the surveillances can only directly demonstrate the 10 jet pumps in the operating loop to be operable. Since the flov through the jet pumps in the non-operating loop is extremely lov (less than approximately 10% of rated jet pump flow), the loads on the jet pumps have been demonstrated to be minor compared to the loads during normal operation and failure is very unlikely (this conclusion is based on operational experience for other BVRs in SLO).

Also, acceptable past two loop operation and/or inspection I during refuelings/shutdovns demonstrate the integrity of the .

jet pumps. As a result, only the 10 operating jet pumps in the l

operating loop are directly demonstrated operable during single loop operation. Therefore, jet pump operability vill continue to be demonstrated for single and two loop operation, and the requirements of Specification 3.4.1.2 are maintained. As a result, there is no reduction in the margin of safety.

F. Recirculation Loop Flov Hismatch During two loop operation recirculation loop flow mismatch must be maintained within limits to be consistent with the assumptions of the ECCS analysis. This change permits continued single loop operation when loop flows exceed specified limits, and cannot be restored within two hours. Once one recirculation loop is shutdown, I the' matching criteria are no longer applicable or-meaningful. This

specification also maintains the currently existing option to shutdown the plant rather than enter SLO.

1) Technical Specification 3.4.1.3 ensures that an assumption of l the tvo recirculation loop operating ECCS analysis is l_ maintained. This change allows single loop _ operation when the two loop mismatch limits cannot be maintained. By taking the actions to enter SLO required by Specif' ration 3.4.1.1 the flow mismatch limit is no longer required and analysis demonstrates that the consequences are not increased. Taking these actions in no vay influences the probability of a LOCA. The action to I

shutdown the plant rather than enter SLO is already contained in the Technical Specifications.

, . Attachment 1 PY-CEI/NRR-1353 h Page 29 of 31 l

i l

Also, adding a 4.0.4 exception for startup of an idle recirculation loop (to return to two loop operation) is consistent with the intent of the original Specification's Action statement a which allowed a period of , to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for restoration of limits. Actual startup of an lu4e recirculation loop and matching of limits can be accomplished in a matter of minutes. Therefore, therc is no increase in the probability or consequences of an accident or transient.

2) During single loop operation the only transient that is not possible during two loop operation is an idle recirculation loop stattup. This transient has been previously analyred in USAR Section 15./:.4. Therefore, allowing one loop to be shutdown does not represent a configuratit or transient different than those previously analyzed.

3) When one of the recirculation loops is shut? vn, the limiting condition for operation of Specification 3.4.1.1 directs that the MCPR Safety Limit, fuel / lattice type specific HAPLilGRs, instrumentation setpoints and equipment operation parameters be adjusted to conservative values for single loop operation.

During shutdown the transients / accidents of concern for a loop flow mismatch are eliminated. Therefore, there is no reduction in the margin of safety.

Environmental Conslacration The Cleveland Electric Illuminating Company has reviewed the proposed Technical Specification change against the criteria of 10 Crn 51,22 for environmental considerations. As shovn above, the proposed change does not involve a significant hazards consideration, nor increase the types and amounts of e'fluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, CEI concludes that the proposed Technical Specification change meets the criteria given in 10 CFR 51.2;(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

. . Attachment 1 PY-CE!/NRR-1353 L Page 30 of 31 l

REFERENCES

1. Petty Nuclear Power Plant (PNPP) Updated Safety Analysis Repot t (USAR), Appendix 15F, " Recirculation Single Loop Operation" (Enclosure 1 to this Single Loop Operation Technical Specification Change Request Letter.)

2. General Electric Document NED0-10958-A, " General Electric BVR Thermal Analysis Basis (CETAB): Data, Cottelation and Design Application,"

Janunty 1977.

3. " Supplemental Reload Licensing Submittal fot the Petry Nuclear Power Plant Unit 1 Reload 2. Cycle 3," GE Document 23A6492 Rev. 0 (September 1990).

4. " Supplemental Reload Licensing Submittal for the Perry Nuclear Power Plant Unit 1, Reload 1, Cycle 2," GE Document 23A5948 Rev. 1 (November 1988).

5 General Electric Document NEDE-20566-A, " General Electric Company Analytical Hodel for a Loss of Coolant Accident," September 1976.

6. General Electric Document NEDO-20566-2, " General Electric Company Analytical Hodel for a Lcss-of-Coolant Analysis in Accordance vith 10 CFR 50 Appendix K, Amendment No. 2 - One Recirculation Loop Out-of-Service", February 1977.

7. General Electric (GE) Service and Information Letter (SIL) No. 380.

Revision 1, "BVR Cote Thermal llydraulic Stability," February 10 1984.

8. Nuclear Regulatory Commission (NRC) Bulletin 88-07, Supplement 0 and 1 "Pover Oscill,ations in Boiling Vater Reactors," 1988.

9. Letter from A. Kaplan (CEI) to USNRC, " Response to NRC Bulletin 88-07 Power Oscillations in BVR's," September 12, 1988 (PY-CEI/NRR-0907 L).

10. Letter from A. Kaplan (CEI) to USNRC, " Supplemental Response to NRC Bulletin 88-0/," November 1, 1988 (PY-CEI/NB'.0933 L).

11. Letter from A. Kaplan (CEl) to USNRC, " Supplemental Response to NRC Bulletin 88-07," December 2, 1988 (PY-CEI/NRR-0947 L).

12. Letter from A. Kaplan (CEI) to USNRC, " Bulletin 88-07 Supplement 1 Power Oscillations in BVR's," February 15, 1989 (PY-CEI/NRR-0968 L).

13. USNRC Regulatory Guide 1.20, Revision 2, " Comprehensive Vibration Assessment Program for Reactor Internals During Precpetational and Initial Startup Testing," May 1976,

14. GE SIL h 251, " Control of RPV Bottom llead Temperatures,"

October 31, 1977.

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F o . Attachment 1  !

PY-CEI/NRR-1353 L  !

Page 31 of 31 l l

15.  !

GE SIL No. 251 Supplement 1. "BVR Vessel Bottom llead Coolant  ;

Temperature Heasurement," July 1980.

16. NRC Bulletin 80-07, "BVR Jet Pump Assembly Failure," 1980.

[

17. GE SIL No. 330 " Jet Pump Beam Cracks," June 9, 1980.

18. - NUREG/CR-3052, "Closcout of IE Bulletin 80-07: BVR Jet Pump Assembly Failure," November 1984. f l

19.. " General Electric Standard Application for Reactor Fuel (CESTAR II)," (

NEDE-24011-P-A and US (latest approved revision).

f-NJC/ CODED /3661 L 4

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