ML20128F175
| ML20128F175 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/02/1993 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20128F180 | List: |
| References | |
| NRL-N92187, NUDOCS 9302110286 | |
| Download: ML20128F175 (12) | |
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NMie servim a
Electric and Gas Company Stanley LaBruna Pubbe Gemce Electrle and Gas company P.0, Don 236; HancN16 Bndge, NJ 08038 603-339-1200 vu rwww. ww owsm FE8 0 21993 j
NLR-N92187 LCR 92-10 United States Nuclear Regulatory Commission l
Document Control Desk Washington, DC 20555 Gentlement LICENSE. AMENDMENT. APPLICATION INSTRUMENTATION REQUIREMENTS FOR SINGLE IDOP OPERATIONS FACILITY OPERATING LICENSE. NPP-57 I
HOPE CREEK GENERATING STATION DOCKET NO. 50-354 This letter submits an application for amendment to Appendix-A of Facility Operating License NPP-57 for the Hope Creek Generating:
i Station and is=being filed.in accordance with 10 CFR:50.90.
The proposed changes'would. provide a:more reasonable period of time.
to reduce the setpoints1of the Average Power Range-Monitors and the Rod Block ~ Monitor when the plant enters single loop' T
operations.
Additionally,.the changes would incorporate. updated' l
core values relative to single loop operations, j includes a detailed description ~of_and' justification for the proposed-changes along with our 10CFR50.92 evaluation of-significant hazards.. Marked up Technical Specification:pages which reflect the proposed change are1 included in Attachment 2.
In accordance with the requirements of 10:CFR 50;91(b) (1), ' a copyn of this submittalt has been-sent to tlue State of New Jersey as-i indicated below.
Upon NRC approval, please issue a' License Amendment which will be-effective uponEissuance~and shall;be j
implemented within 60 days of issuance.
4 Should you have any questions or. comments'on>this submittal, please do-.not hesitate to contact us.- -
Sincerely,-
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Affidavit 1/
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Attachments (2) 0900nr 9302110286:930202 L
PDR ADOCK 05000354-f [.
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Document control Desk 2
FEB 0 21993 NLR-H92187 C
Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.
S. Dombok, Licensing Project Manager U.
S.
Nuclear Regulatory Commission One White Flint' North 11555 Rockville Pike Rockville, MD 20852 Mr. T. P. Johnson (S05)
USHRC Senior Resident Inspector Mr. K. Tosch, Chief NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuulcar Engineering CN 415 Trenton, NJ 08625 t
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REF: 11LR-N92187
- 7 LCR 92-10 STATE OF llEW JERSEY
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SS.
COUliTY OF SALEM
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Stanley LaBruna, being duly sworn according to law deposes and sayst I
I am Vice President - !!uclear Operations of Public' Service Electric and Gan Company, and as such, I find the mattors set forth in our letter dated
, e nearning the FEB 0 21993
!!opo Crook Generating Station, are true to the'best of my knowledge, infcrmation and bellof.
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Subscribed and Sworn to before no thisc[Mcl day of M.brunrt />,1993 v
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}%kLk s
t ew' Jersey tiotary Public of i
KlMBEllLY A.lillt NOTAllY PUUUC Of NEW JEllSEY -
My Comm$ston f.xpires March 9. W =
My= Commission expires-on 4
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KITAO MENP 1 IYOIOGII) QINCl3 'ID 'I1tE 'ITI2HICAL fil'UCIFIGTIOG IJORIE AMD4IMINF AIWICATIOi DUI11LMLNTATIG4 IUUIDEMINIU lut SUCIE IDOP OIUWPIQG IDIE ORIK GINDWTDC !TIATIQ1 l'ACIIJTi OIUMTDC IJORIE NIV-57 NIJH192187 000TP 10. 50-354 101 92-10 I.
11ECRIFI Sj' li!E ISOIOCH) O!NGE A.
- Sirr, loco Omrations IWise Specification 3.4.1.1, "RDC11KUIATIQi SYS'1Di - RDCIICJIATIQi IDOIS", to deleto existiry Action "a.1.e" ard incorporate the affected requirements into new Actions "a.2",
"a.3", and "a.4" as modified below Action "a.2" will pertain to the Average twcr Rarge Monitor (AITN) scram setpoints and require the applicable setpoints to be rMm3 to those applicable for single recirculation loop operation within four hours of entering sirgle loop operations. If the sotpoints associated with arm trip system are rot reduced within four hours, the affected trip system must be placed in the tripped condition and, within the follwiry 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the remainirg setpoints must be reducod.
Action "a.3" will portain to the Average Iwer Rango Monitor (APIM) rod block setpoints and require ths applicable setpoints to be twhM to those applicable for sirgle recita11ation loop operation within four hours of enterirq sirgio loop operations. If the setpoints associated with ono trip function aru not reduced within four hours, at least one of the affected channels must be placed in the trilpod cordition an:1, within the follwiry 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the remaining setpoints must be reduced. -
Action "a.4" will pertain to the Rod Block Monitor (RIN) trip setpoints and require the applicable setpoints to be reduced to thoco applicable for sirgle rucirculation loop creration within four hours of enterity sirgle loop operations. If the setpoints associated with one trip function are not reduced within four hours, at least one affected channel must be placed in the tripped condition and, within the follwirg 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the remainity setpoints must be reduced.
fl.
Iwer AscCDaign Proctram Ibta Revise the followiry specifications to chargo the value of delta-w' for sirgle loop curation from "7b be determined at a later date" to 9%;
Specification 2.2.1, "RTACIOR PforECTIG4 SYSTD4 HEITUENIATIQi SUITODTPS", Table 2.2.1-1 Specification 3.2.2, "APfM SLTPODTTS" Page 1 of 9
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Atttchr nt 1 LCR 92-10
'* Instrumentation Requirements for SID NhR-N92187 Paviso the follwing cpocifications to charno the value of mininn therm 1 pwer correspcading to corditions in which no tanperature otratification ooairs frm 530% to 538% and delete the associatal footnota (tho 50% valuo for rocimulation flow in the operating locp has boon establishod as tho correct final value)t Specification 3.4.1.1, "RDCIRCUIATIQi SY! TID 4 - RDCIRCUIATIQi LOOPS", Action "a.1.g" and Surveillanco 4.4.1.1.2 Ibses Section 3/4.4.1, "RDCIRCULATIQ1 SYS'ID4" Revise the following specifications to chargo the value of corn f1w with both Rocirculation Pumps at minima spood frun 39% to 40% atd dolots the associated footnote:
Specification 3.4.1.1, "RECIRCULATIQI SYS'IDi - RECIRCULATIQ1 IDOPS", Actions "c" and "d" ani Surveillance 4.4.1.1.1.
C.
Specification 3.0.2 Add a discussion to the bases for Specification 3.0.2 to explain that is not the intent of Specification 3.0.2 that conformnoe to the ACflui requirements precludo the perfornnnoo of curveillance testing to damnstrate the OITPADILITY of a camponent which is boirn returned to service.
II. EFA9CN ITR 4"E HOPOSIG) aUggs A.
Simle 1000 Onoratione Specification 3.4.1.1, Action "a.1.0" carmntly requires the AIT@4 Scram and Rob Block sotpoints and RIN setpoints be rnMM to those applicable for single loop operations within four hours of entering single loop operations. Due to the amount of time required to actually perform those actions and complete the associated survoillance testire, this timo limit boctrnes overly restrictive when singlo loop operations Is entered duo to an uranticipated trip of a Rocirculation Punp. The changes that are proposed in this culmittal provide cercarvative alternativo actions that would provido additional timo to reduce the subject setpoints ard perform associatcd surveillanco tests.
B.
Itwer Ascension Pronram lhta 7ho values presently provided in Ibchnical Specifications for delta-w for
-sir.310 -loop operation, minian therm 1 power coauspording to conditions-in which no temperature stratification occurs, ard core ficM with both Rocirculation Pumpo'at minimum spood aro initial values that were established prior to startup testing.
Final values havo now been determined ard this amerdment request therefore seeks to incorporate thace values.
Pago-2 of 9
Attcchm:nt 1 LCR 92-10 Instrumentation Requirements for SLO HLR-N92187 C.
Srecification 3.0.2 PSE&G bolloves that it is not the intent of Specification 3.0.2 that confonnance to the AcrICH rtquirements procludo the perfonnnoo of surveillance testig to denonstrate the OPERABILITY of a u.@wnt which is boiM returned to service. The charges propocod in this subnittal include a discussion in the bacon of Spocification 3.0.2 which clarifles this point.
III. Jign2F/ShTKH Iut 7tillIm1DGFD OWES h.-- ___ Sirnlo Loon OncratiDDD Spocification 3.4.1.1, Action "a.1.0" currently requires the APIN Scram ard Rod Block setpoints and IEN setpoints to be reduced to those applicable for sirglo loop operations witdir four hours of enteriro singlo loop operations. 'Ihe affected sotn
- s are associated with the flow-biased simulated thennal power upscale functions of the subject instrumentation. After the notpoints are reduced, associated survoillanco tests must be canpleted to verify operability of tlm instruments with the reduced sotpoints in onler to otroply with this action statement.
Due to the amount of time requittd to actually perfonn those actions and octuplete the associated surveillance testirn, the four hour time lianit boccanos overly rostrictivo when sirglo loco operations in entered due to an unanticipated trip of a recirunation punp. If these actions cannot be aanpleted within four hours, Specification 3.4.1.1, Action 3 requires the plant to be placed in at least hot shutdown within the next twolve hours. 'Iho changes that are pmposed in this subnittal would pmvide a conservativo alternato course of action that would pmvido additional time to reduce the subject sotpoints and perfonn associated surveillance tests.
In accordance with the pmpocod changco, the requirement to reduce the subject setpoints within four hours of enterirg sirgle loop operations would still exist. Ilowever, pmvisions would be added such that, with the setpoints of a sirgio trip systenVfunction arcociated with each of.
the three instrunentation grwps (i.e., APIM Scram and Rod Block ard REN) not reduced within four hours, that trip systenVfunction would be placed in the tripped condition. The sotpoints of that instrumentation would then be Itquired to be reduced to the applicable values within the followirg six hours.
In accordance.with the propocod actions, upon uranticipated entry into sirgle loop operations, attenpts would be made to reduce the sotpoints of
. all speciflod instrumentation within four tours. As a minim 2m, the setpoints of at least one trip systanVfunction associated with each of the three instrumentation groups (i.e., AITM Scram and Rod Block and RIH) would be reduced ard surveillance tests canpleted. 7ho remaining trip systenVfunction(s) 9 auld be placed in the trippcd corylition. They would i
runain in the tripped condition except as required to be taken out of the tripped condition durirg performance of the associated surveillance tests.
Page 3 of 9
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Attcchr nt 1 LCR'92-10 Instrumentation Requirements for SLO HLR-H92187 Dy conservatively requirirn the setpoints of at loast one trip systanVfunction per instnmentation group to be reducod to thoso applicablo. ~ silyle 2xp operations ard the other trip syntanVfunction to be placoc. 1 the trippcd condition, theru is assurance that a scram anVor red bluck would bo initiated by t1m AInt2 and/or RIN if the reduced setpoints are reached. mis cordition could exist for up to six hours at Milch tim all remainity setpoints would be requirud to be reductd.
Loso propocod charges would prtnido a ucIn reasonable anount of tim to' take the required actions than the current action Itquirenanta M1110 presentirg no negativo impact on plant safety.. Power Ascension 14Wnum Ibta Lbita-w for sifelo 1000 operatiOD 1 20 method usod to calculato dolta-w, in general, couuspciv3s with the guidelines provided in General Electric docunent 24A1715, Sirgle Rocirculation Pump Operation (mo-A22-4370-0007(1)) and is outlined below: 1. Develop the two loop relationships for coro Flow versus Core Plato differential prescuro ard Coro Flow versus percent of Rated Rocirculation Drive Flow. a. Collect data durirn two loop gxtration. b. Calculato socord order regression-fits for Core Flow as a function of Core Plato differential pressure ard percent of Rated Rocirculation Drive Flow, c. Determine the value of Rated Rocirculation Drive Flow. 2. Cbiloct Sirgle loop Operation data for Core Power, l Rocirculation Drive Flow and Coro Plato differential pressure. mis-is done over a rargo of Recirculation Pump spood up to the mximum allowod by Technical Specifications (90%' rated). 3. (bnvert Sirgio Isop Operations core Plato differential pressure - to Core Flow us12g the two loop relationships datormined in step 1.' (Core Flow Yoruus Coro Plato differential pressure is in3cpenient of two loop or sirgle loop operation).- 4. Convert Rocirculation Drive Flows to percent of Ratod'usirg the value determined.in stop 1. 5. Compare ~Coro Flow in Single Imop Operation to Core Flow in 'IWo Incp Operation for the same percent Rocirculation Drive Flow.: 6. Calculato delta-w by determinirg the mximum difference between L the two drivo flow rates (two loop ard sirgle loop drive flows)- for the cann Coro Flow. l-Page 4 of'9
AttC;hment 1 LCR 92-10 Instrumentation Requirements for SLO HLR-N92187 '1ho results of the calculations outlined above nru as follcus loop A in service Loop B in carvico Cyclo Delta-w D31ta_-w 1 8.56% 7.82% 2 8.45% 8.50% 3 8.30% 0.70% Insed upon the above results, IEELG is hereby prquairy to incorporate a conservative value of 9% for delta-9. 141nimum therm 1 rower corrennondim to corditiom in khich no terr >erature stratification occurs 'Iho coru per ard flow values correspording to conditions in Wich no tenperaturo stratification occurs volu determined during power ascension testirn. Rather than determinirg acLmal minimum power and - flow values, the test verified that for certain set conditions, no. tenparaturn stratification occurred. 'Ihe conditions of the test welv as follcust Reactor Power Activo Imp Flow Rat;_Date (% Rated) (t Rated) 11/01/86 37 no active loop 38 no steady-stata SIO data 11/01/86 53 90 (Icop A) 11/08/86 38 no activo loop. All test con:litions showed no temperaturo stratification occurred. Insofar as sirgle loop data is available only for relatively high ficw conditions, IEE&G is conservatively proposing to retain the value of 50% core flow ard incorporate the value of 38% thermal'- power. A test to determino the actual minimum values would necessitato sirgle loop operations for appruximately:16 hours. IEE&G does not fool that this is necessary since the conservativo values that atu being propocod will havo insignificant operational impacts. Page 5 of 9 _4
Attachment 1 LCR 92-10 Instrumentation Requirernents for SLO 11LR-1192187 .Qgre flcw with botil_Becitullation PLmro at minimm sics) Spccification 3.4.1.1, Action "d", requitra that with total core ficw less than this va.1.uo ard therm 1 pcuer greater than the limit specified in Figure 3.4.1.1-1 (this figure corruspoMs to the 80% Rod Pattern lino), actions are initiatal to reduce therm 1 pcuer belcw the limit spccified in Figure 3.4.1.1-1 or increase coro flow to greater than 45% rated. '1 hose actions are similar to thoco specificd in imC Dulletin 88-07, Supplcutent 1, " Power Oscillations in Dollirg Water Reactors" which states the core flow valuo to be 40%. PSE&G is proposirg to incorporato the conscIvativo value of 40% in order to retain consistency with the requiremnts of Dulletin 88-07 rather than incorporato an additions 1 value that_would represent ooro fits with both Recirculation purps at minimum spood. C. Srspification 3.0.2 i hhen a channel of instrumentation required by Technical Specifications m1 functions or fails to moot surveillanco acceptanco criteria it is declared inoperable and the ascociated action statamnt(s) is enterod. Several ermifications require inoperable instnmentation channels to be placed in the trippcd condition. U, dor these monditions ard in accordance with specification 3.0.2, compliance with the applicable specification exists when an inoperablo instrumentation channel is placed in the tripprxl condition within the speciflod time period. Plant operation my then continue either iMofinitely or for a certain allowable out of service time, deperiding on the specific specification. In either case however, it is prudent frcxu koth a plant safety and l operational perspective to repair the subject instnmentation ard ruturn l it to service as soon as possible. '1herefore, after a mlfunctioning instnment is declared inoperable and removed frun servloe, troubleshooting is corducted and corrective mintenwice perfomod. When the maintenance is ocatpletod, the II.M.nment is expected to be onco again fully functional. However, before declarirq the instrument operable an:1 exiting the associated action statement, applicable surveillance testa must be conducted to yfrify that the. instnment is in fact operable. In order to perform surveillance testirn, the instrument must be taken I out of the trippcd condition. 'Iherefore, although the instnment remains administratively inoperable, ard all constraints ard time limits of the i action statenent remain in effect, the instnment is taken out of the i tripped condition for post-mintenance surveillance testirg..If the-instument meets all applicable acceptance criteria, it is then l administratively declared operable ard the action statement is exited. If however, it fails to fulfill any of the applicable acceptanco criteria it is again removed frun service ard the action statement ard associated time limits remain in effect, uninternipted. PSE&G believes that this fully fulfills the intent of Specification 3.0.2 and is therefore submittirg this change request to clarify this point.in the bases section. Page 6 of 9
, Attachr nt 1 LCR 92-10 Instrumentation Requirements for SLO NLR-N92187 IV. filGHFICMfI'INAIMI CCtGJIHRTICriJNAllMlgi ISE&G has, pursuant to 10 CFR 50.92, reviewed the pmpocod amendment to detennine whether our request involves a significant har. anis consideration. Wo lavo detonninod that operation of the llopa Crook Generatirrj Station in accordanoo with the propocod changes: 1. Will not involvo a significant increaso in the probability or consoquences of an accident previously ovaluata3. b. Simle 1o0n Operations Arperdix 15C of the !!opo Creek UlTAR contains the singlo loup analysis that was completed for ISE&G by General Electric. Section 15.C.3.2 evaluates a rod withdrawal error event khile in sirglo loop operations and states: "20 rod withdrawal error at rated power is given in the IEAR. %cso n'ulysos are perforaxi to demonstrate, even if the operator ignores all instrument indications arri the alarn kbich could occur durirg the courto of the transient, the rod block system will stxp rod withdrawal at a minimum critical power ratio (MCPR) Which is higher than the fuel claddire integrity safety limit. Modifloation of the rud block equation (bolow) ard 1cwor power assures the MCPR safety limit is not violated." IMlativo to the idT@b, Section 15.C.3.2 corritdes: "Iho AHM trip settirgs are flow biased in the sam manner as the rod block monitor trip settings. W erefore, the AH M rod block and scram sottings are subject to the sam precodural changes as the rod ' block monitor trip sottings discussed abovo." to changes proposed in this subnittal would require an APIM ant /or RIN channel to be placed in the tripped condition if its sotpoints have not been reduoal within four hours of enterirg sirgle loop operations. m is would ensure that if thermal power reached tho-sotpoint of the channel that has been reduced, the trip function would occur at the sotpoint applicable to sirgic loop operation. Based on those conservativo actions, it is concludod that the proposal charges will not involve a significant increase in the probability or consequences of an accident previously evaluated. B. Power Aseemion Prmram thta 2 0 proposed changes incorporate plant values which lave boon conservatively detonnined from power ascension tests as discussed in Section III.B of this submittal. In two cases, the proposed values are more limiting than those presently contained in the affected specifications and.in the third case, the value has not' boon specified until now. W erefore, the proposed changes will not involvo a significant increase in the probability or consequences of an accident previously evaluated. Page 7 of 9
Attcch: nt 1 LCR 92-10
- Instrumentation Requirements for SLO llLR-1192187 C.
sorcification 3.0.2 h proposcd dwrjes meruly clarify the intent of Specification 3.0.2 ard are therefore viewcd as administrative in nature. 2. Will not creato the possibility of a now or different kin! of accident frun any accident previously evaluated. A. Simlo loon Onerations 'Ihe onnstraints inposcd by the propcoed changes will ensure that, while in sirgle loop operations, tho subject trip functions will still occur at the setpoints applicable to single loop operations urder the same time limits as the present specification (i.e., within four hours of enterirg sirgle loop operations). Id11tionally, the proposcd changes will-not involve any physical diarges to the plant. B. Ptwer Ascension Prociram Data 1ho proposcd charges will not involvo any physical charges to the plant ard have been conservatively determined as discusscd in Section III.B of this submittal. C...... Spegification 3.0.2 h proposed charges merely clarify the intent of Specification 3.0.2 ard are thereforn viewod as administrativo in naturn. 3. Will not 'involvo a significant ruduction in a mrgin of safety. A. Simle Iron Operations 'Ihe proposed charges will provide a more reasonable period of time to reduce the setpoints of the AITMs ard RIM by requirity conservativo actions to be taken. h se actions will ensure that the applicable trip functions will still occur at the setpoints applicable to sirgle loop operations within the same tim pericd as currently specificd (i.e., four hours). These changes, thereforo, will not involve a reduction in a margin of. safety. B. Power Ascension Prvnntii Data Insofar as each of the proposed coru values that would be incorporatcd by this subnittal were conservatively determined as described in Section III.B of this_ subnittal, it can be concluded ' that thezu will be no reduction in mrgin of safety, page 8 of 9
Att^c!c:nt 1 LCR 92-10 ^ Instrumentation Requirements for SLO HLR-N92107 .Q. Specification 3.0.2 h propcccd charges merely clarify tho intent of Specification 3.0.2 and are therefore viewod as administrativo in naturo. V. ENCIIRJICtf Based on the preocxlirq discussion, PSE&G has concludcx1 that the propoood chargo to the Technical Specifications dcca not involvo a significant hazards consideration insofar as the chargos (1) doos not lawolve a significant increaso in the probability or conscquences of an accident previously evaluated, (ii) does not create the rossibility of a new or diffarent }dni of accident frun any accident previously evaluated, and (iii) dcca not involvo a significant reduction in a margin of safety. l l I l l j.- Page 9 of 9}}