ML20215B789
| ML20215B789 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/08/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| NLR-N86189, NUDOCS 8612120319 | |
| Download: ML20215B789 (4) | |
Text
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i Pubhc Service Electric and Gas Cornpany C:rbin A. McNeill, Jr.
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609339-4800 Vice President -
Nuclear NLR-N86189 December 8, 1986 Director of Nuclear Reactor Regulation United Stated Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Attention:
Ms. Elinor Adensam, Director Project Directorate #3 Division of BWR Licensing
Dear Ms. Adensam:
REQUEST FOR AMENDMENT FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) submitted a Reques t for Amendment to Facility Operating License NPF-57 on December 5, 1986 regarding Hope Creek Generating Station (HCGS)
Technical Specifications 3.2.3, MINIMUM CRITICAL POWER RATIO, and 3.3.4.2, END-OF-CYCLE, RECIRCULATION PUMP TRIP SYSTEM INSTRUMENTATION.
The request was submitted as a standard license change request; however, the results of a recirculation pump trip test, conducted after our submittal, necessitate an escalation of our request to Emergency Classification, pursuant to the intent of 10CFR 50.91(a)(5).
The emergency situation occurred at 1625 on December 7, 1986 when evaluation of recirculation pump trip test data, obtained during the Full Power Load Rejection Test on December 6, 1986, revealed that the flow coastdown did not satisfy a Level 1 Test Criteria.
While the results of the pump test were only marginally above the acceptance criteria for successful coastdown flow, and the affected transient analyses are only limiting at End of Cycle, the absence of a docketed analysis bounding the actual measured coastdown flow during a design pressurization transient places the plant in an unanalyzed condition.
Since our December 5, 1986 amendment request is supported by the attached General Electric Company analysis that bounds the unacceptable flow coastdown values measured during the test by assuming no recirculation pump trip at all, immediate approval of our amendment request can prevent an unnecessary delay in plant startup, currently scheduled for 0800 on Tuesday, December 9, 1986.
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4 Ms. Elinor Adensam 2
12-8-86 Pursuant to the requirements of 10CFR50.91, the State of New Jersey has been notified verbally and, as indicated below, has been sent a copy of this request.
Sincerely, Attachment C
Mr.
D.
H. Wagner Licensing Project Manager Mr.
R. W.
Borchard t Senior Resident Inspector Mr. David M.
Scott, Acting Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 Honorable Charles M. Oberly, III Attorney General of the State of Delaware 820 North French Street Wilmington, DE 19801 i
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December 4 1986 MC 395, (408) 925-3580 Responds to:
Mr. R. F. Drawnowski GP-96-305 c/o Supervisor - Work Center (12-ME)
Public Service Electric & Gas Co.
P.O. Box A Hancocks Bridge, NJ 08038
Dear Mr. Drewnowski:
SUBJECT:
HOPE CREEK PROJECT HOPE CREEK END-07-CYCLE RFC PSE6G has expressed concern over the potential for a violation of the MCPR limit as a result of the planned Load Rejection Startup Test.
Based as experiences of other plants under startup conditions General Electric does not feel that there is a safety concern on failure of RPT during initial plant operation (a Recirculation Pump Trip (RPT) is not required during first part of the fuel cycle). Therefore no approach to MCPR limits are expected to occur. The issue is strictly a licensing basis calculation that will influence the calculated required operating limit.
Even though the MCPR limit has a maximum impact for a RPT at end-of-cycle conditions PSE&G has stated a concern that a failure to stay within the safety 10mit during this test could result in the NRC enforcing the current Technical Specification on ECC RPT Out-of-Service.
In order to bound the FSAR Chapter 15 transient evens which take credit for the EOC NYr function, a re-analysis of the lim.~. ag events (Load Rejection with Bypass Failure and feedwater Contro'
.c Failure) has been done assuming that the EOC RPT fails to function.
.cas any potential failure of the EOC RPT coastdown test results to mee the MCPR criteria curves can be accomodated by utilizing the required C?R Operating Limits for the EOC RPT inoperable condition. This (new) curve (shown on attached Figure 3.2.3-1 of the Hope Creek Technical Specifications) can be used throughout the first fuel cycle for condittens whera the EOC RPT function is known to be out of service. To summarize, the MCPR value given in this curve is considered to be overly conservative for the following reasons:
- 1. The current Technical Specification curve for RPT is based on first cycle IOC conditions (i.e., the most reactive condition).
- 2. The attached curve considers a lack of EOC RPT at any time throughout the cycle and is therefore based en a " worst-case" senario and is valid for all power levels.
- 3. The attached curve considers not only the Load Rejection with
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Bypass failure Transient but also the Feedvater Controller This is done inorder to address both the ODYN Failure event.
Option A and Option B evaluations of operating limits with RPT Out-of-Service.
General Electric has evaluated the implementation of the new curve under the criteria of 10CFR50.59 and has found 1) the probability of occurrence or the consequence of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report is not increased; 2) there is no possibility of an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report as a result of the used of this new curves and 3) the margin of safety as defined in the basis for Technical Specification is not reduced (for the first cycle of operation). If needed the attached curve is felt to be sufficient to obtain NRC concurrence to continue operation following the Load Rejection test at power levels above 25-30% power until such time as a specific plant assessment can be made incorporating the data to be obtained from the scheduled test.
It should furthermore jus noted that any change in the Technical Specification curva does not impact the plant's LOCA analysis as the curve only addresses transient conditions.
In addition to the attached new curve General Electric is attaching excerpts from the Limerick Technical Specification to assist PSE&G in developins a proposed Technical Specification to 30 with the rew curve.
If you have any questions regarding this submittal, please call me or Mr. Noel Shirley, Senior Licensing Engineer at (408) 925-1192.
Very truly yours, J.C. Larrow Project Manager Hope Creek Project Response Required:
cc R.S. Salvesen - w/a B.A. Preston - w/a
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