ML20235W096

Application for Amend to License NPF-57,revising Tech Specs 3.9.1,4.9.2 & 3/4.9.6 to Add Clarification & Consistency to Refueling Specs Re Ref Measurements,Load Setpoints & Travel Limits & Raise Min Source Range Monitor Count Rate

ML20235W096
Person / Time
Site:	Hope Creek
Issue date:	02/27/1989
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20235W101	List: ML20235W096 ML20235W154
References
NLR-N89027, NUDOCS 8903100491
Download: ML20235W096 (11)

Text

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o- f Public Service

. Electric and Gas Company Ctanley La8runa Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800

. va I temient - Nucie Operaions FEB 27 509 NLR-N89027 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR AMENDMENT FACILIT*I OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) hereby transmits an application to amend Appendix A of Facility Operating License NPF-57 in accordance with 10 CFR 50.90. This amendment request will change Technical Specifications 3.9.1, 4.9.2, 3/4.9.6 and the associated Bases. The changes add clarification and consistency to the refueling specifications with respect to reference measurements, load setpoints and travel limits which will, in turn, permit control rods to be transported in a vertical position - as designed. The changes would also conservatively raise the minimum allowable Source Range Monitor (SRM) count rate in Specification 4.9.2 to agree with SRM requirements imposed elsewhere in the specifications.

A description of the requested amendment, supporting information and analyses for the change, and the basis for a no significant hazards consideration determination are provided in Attachments 1 and 3. As detailed, PSE&G has determined that the proposed change does not involve a significant hazards consideration. The revised Technical Specification pages, marked-up with proposed revisions, are contained in Attachment 2.

Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but implementable within sixty days to allow for any germane -

procedural revisions. l Pursuant to 10 CFR 50.4(b)(2)(ii), this submittal includes one (1) signed original and thirty-saven (37) copies and, in accordance with 10 CFR 50.91(b)(1), PSE&G has provided a copy to the State of New Jersey.

8903100491 890227 -

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l Document Control Desk 2 FEB 2 71989 Should you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely,

./ /C!6tc r -

Affidavit Attachments (3)

C Mr. W. T. Ruasell, Administrator, USNRC Region 1 Mr. C. Y. Shiraki USNRC Licensing Project Manager Mr. G. W. Meyer USNRC Senior Resident Inspector

'Ms. J. Moon, Interim Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering 1

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REF: LCR 89-02 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

Stanley LaBruna, being duly sworn according to law deposes and says:

I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated , February 27, 1989 , concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.

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Subscribed and Sworn to before me this MY L day of O4WZ2/L, 1989 0 A > Y6_

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's Notary Public of New Jersey VANITA M. MARSHALL NOTAllY PUBLIC OF NEW JER8N My Commission Expirn May 6,1998 My Commission expires on l

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? , -j ATTACHMENT 1 PROPOSED CRANGE TO THE TECHNICAL SPECIFICATIONS FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 LCR 39-02 I. DESCRIPTION OF THE PROPOSED CHANGES As:shown on the marked-up Technical Specification (TS) pages in Attachment 2, make the following changes:

A. Revise Specification 3/4.9.1, REACTOR MODE SWITCH, to clarify that only one hoist (the main hoist) requires the fuel-loaded interlock:

1) Change ).9.1.b.3 to read " Refuel platform main hoist fuel-loaded."

B. -Revise Specification 3/4.9.2, INSTRUMENTATION, to ensure that at least 3 counts are indicated when more than sixteen fuel. bundles are in the core. This change vill remove a reference to 0.7 cps that was inadvertently overlooked when other references were' removed by Amendment 14 to the Facility Operating License:

1) Change 4.9.2.c to read " Verifying that the channel count rate is at least 3 cps:"

2) Delete the asterisk footnote on page 3/4 9-4.

C. Revise Specification 3/4.9.6, REFUELING PLATFORM, as follows:

1) Move 3.9.6 and 4.9.6.1 from page 3/4 9-8 to page 3/4 9-9 leaving page 3/4 9-8 intentionally blank.

2) . Change 3.9.6, LIMITING CONDITION FOR OPERATION (LCO),

to clarify that only the refueling platform main hoist will be used for moving fuel within the reactor pressure vessel.

3) Consolidate 4.9.6.1, 4.9.6.2 and 4.9.6.3, SURVEILLANCE REQUIREMENTS, into section 4.9.6. Revise section 4.9.6 l to make corrections to the present specifications with regard to: (i) the specific uses of, and surveillance tests for, various refueling platform hoists, (ii) reference points from which certain limit measurements l

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LRefueling: Platform . LCR 89-02.

4 are.taken, (iii) hoist travel limits, and (iv) ro'd block interlock load setpoints.as;follows:

a. Change 4.9.6.1.to 4.9.6 sinceLthe succeeding  !

sections, 4.9.6.2 and 4.9.6.3, are combined into' one surveillance section. This section~is also i revised'to' indicate that it applies to all ;l refueling platform hoists. )

b. Insert 4.9.6.b by combining 4.9.6.2.a and '< l

4. 9. 6. 3. a . :  !

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c. Change 4.9.6.1.b to 4.9.6.c and revise to specify a shift of reference from the ' top of active fuel'-

to the ' point of attachment of the grapple to the

' fuel bail. handle'. -Also revise the main hoist uptravel stop setpoint with regard to the' distance J

between the' refueling-cavity normal water level and.the new point of reference.

d. Insert 4.9.6.d by combining 4.9.6.-2.b and 4.9.6.3.b. . In addition, 4.9.6.2.b and 4.9.6.3.b are revised to reflect the~ shift in reference j point discussed above.

e. Change 4.9.6.1.c to 4.9.6.e.

f. Change 4.9.6.1.d to 4.9.6.f and raise the loaded rod block setpoint from 485 pounds to 535 pounds.

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g. Change 4.9.6.1.e to 4.9.6.g.  ;

h. Delete 4.9.6.2.a and 4.9.6.3.a by combining under  :

4.9.6.b. j

1. Delete 4.9.6.2.b and 4.9.6.3.b by combining under l 4.9.6.d.  ;

j. Delete 4.9.6.2.c and 4.9.6.3.c.

s Additionally, revise BASES Section 3/4.9.6 as indicated i 4) on the marked-up page in Attachment 2~to address the  ;

above modifications.

II. R.JMOJ[ FOR THE PROPOSJD CHMGJJ These changes are necessary to more accurately reflect HCGS' plant design and operation, clarify the use of installed refueling equipment, and eliminate unnecessary surveillance testing.

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Refueling Platform LCR 89-02 Certain dimensional changes in up-travel limits are made which l

increase clearances - thereby allowing unencumbered movement of '

control rods out of the reactor pressure vessel (RPV) and through a " cattle chute" radiation shield that rests on the RPV flange.

One change, to 4.9.6.1.d, raises the hoist loaded rod block setpoint to permit transport of blade guides without causing a rod block. Alco, a correction to 4.9.2.c is included that adjusts the required count rate on the Source Range Monitor (SRM) channels, during refueling, from 0.7 cps (with signal-to-noise ratios 2 2) to 3.0 cps with more than 16 fuel bundles in the core. A previous change to Table 3.3.6-2 in Amendment 14 removed a similar footnote, that was developed and used for initial fuel load only, which permitted SRM counts to be as low as 0.7 cps when signal-to-noise was 2 2. The same provision in TS 4.9.2.c and its associated footnote were overlooked at that time.

Plant-specific supporting information and results of the analysis that justify these proposed changes are included in the following section.

III. JUSTIFICATION FOR THE PROPOSED CHANGES The primary purpose for the proposed changes is to enable the hoisting of control rods high enough to clear the flange of the reactor pressure vessel and radiation shielding " cattle chute" fixture that contacts the vessel flange when transporting them out of the reactor vessel. When control rods must be removed and replaced during a refueling outage, Hope Creek Generating Station (HCGS) is restricted by the current hoist up-travel limits from transporting control rods out of the vessel in the manner in which they were designed to be moved... suspended vertically from the hoist. Instead, the lower end of the control rod assembly must have a separate line attached to pull the assembly out of true vertical, thereby increasing the bottom clearance of the assembly when passing into the " cattle chute". The change will eliminate this situation while adding both operational flexibility and clarity to this specification. The justification for each proposed clarification or revision is provided below:

1. Changes to 3.9.1.b.3 and 3.9.6 indicate that the main hoist is the only hoist to be used at HCGS for moving fuel within the reactor pressure vessel. While UFSAR Section 9.1.4.2.10.2 states that fuel handling is performed using the main hoist fuel grapple and this requirement is implied by the wording in the TS SURVEILLANCE REQUIREMENTS section, it is not directly stated in the TS LIMITING CONDITION FOR OPERATION (LCO). The proposed change will clarify the required use of only the main hoist for fuel movement within the reactor pressure vessel.

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Refueling Platform LCR 89-02

2. Changes to 4.9.2.c and the associated footnote provide a conservative correction which simply deletes a provision that should have been removed along with similar wording which was eliminated from TS Table 3.3.6-2 in Amendment 14.

3. Change to 4.9.6.1 renumbers this section to 4.9.6 since this section and the succeeding sections 4.9.6.2 and 4.9.6.3 are combined. This section is also revised to indicate that it applies to all refueling platform hoists.

4. Changes to 4.9.6.1.a2 4.9.6.1.c and 4.9.6.1 t e (which become 4.9.6.a, 4.9.6.e, and 4.9.6.g respectively) only involve renumbering.

5. Change to 4,9 t 6 1 L1b (which becomes 4.9.6.c) specifies a shift of reference from the ' top of active fuel' to the

' point of attachment of the grapple to the fuel bail handle' and revises the main hoist uptravel stop setpoint with regard to the distance between the refueling cavity normal water level and the new point of reference. As shown in the Analysis of Refueling Bridge Uptravel Limits (see Attachment 3), the new value of 6'6" from the point of attachment of the grapple to the fuel bail handle corresponds to the present TS limit of 8' from top of active fuel. The tolerance (+ 3"/ - 0") assigned to the main hoist uptravel stop limit defines a range in which to set the stop that provides adequate clearance for transporting loads over the fuel transfer " cattle chute" while continuing to ensure that no fuel bundle is raised higher than the height assumed in fuel handling accident analyses.

Radiological doses at the refueling platform are not increased by this change since the combined effect of the revised reference point and the dimensional change to the uptravel limit result in no change in the actual height of the fuel bundle with respect to the surface of the refueling cavity water when withdrawn to the normal uptravel stop.

6. Chang _e to 4.9.6.1.d (which becomes 4.9.6.f) raises the loaded rod block setpoint from 485 pounds to 535 pounds, thereby allowing a blade guide to be hoisted by the main hoist without tripping the rod block interlock - this problem is encountered during control rod replacements.

7. Changes to 4.9.6.2.a and 4.9 6.3.a 1

involve the combination of duplicative specifications for the frame mounted and monorail mounted auxiliary hoists, under 4.9.6.b.

8. Changes to 4.9.6 1 _2.b and 4.9.6.3,b involve the combination of duplicative specifications for both auxiliary hoists Page 4 of 7

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. 1 Refueling Platform LCR 89-02 under 4.9.6.d. Additionally, the point of reference and dimension for the uptravel stops for the two hoists are i changed to permit transport of control rods out of the RPV and through the " cattle chute" without the use of special rigging arrangements currently required to prevent interference problems in the chute.

As demonstrated in the Analysis of Refueling Bridge Uptravel Limits (see Attachment 3), the height of a hoisted control rod assembly permitted by the revised uptravel stop does not adversely affect the assumptions or results of the fuel handling accident analysis. The accident remains bounded by the height of a fuel bundle which cannot be lifted or moved using the auxiliary hoists (precluded by the proposed TS 3.9.6, the auxiliary hoists' overload cutoffs, and procedural controls).

Radiation dose rates associated with a control rod assembly at the up-travel limit would be slightly increased by this change; however, the calculated dose rate will remain less than dose rate calculated for a fuel bundle hoisted to its current TS up-travel stop.

9. Chances to 4.9.6.2.c and 4.9.6.3.c involve an elimination of unneccesary surveillance requirements for rod block interlocks on the auxiliary hoists. These hoists are not used for transferring fuel bundles and therefore do not need to have " fuel-loaded" rod blocks.

III. 10 CFR 50.92 SIGNIFICANT_!MZARDS CONSIDE_ RATION _ ANALLSIS PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed amendment to determine whether the changes involve a significant hazards consideration.

1. The operation of Hope Creek Generating Station (HCGS) in accordance with the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment does not involve a change to any structure, component or system that affects the probability of any accident previously evaluated in the Updated Final Safety Analysis Report (UFSAR). The consequences of all previously evaluated accidents have been analyzed and the following conclusions have been reached:

1) The changes to TS 3.9.1.b.3 and 3.9.6 clarify the use of the main hoist as the only hoist permitted for fuel Page 5 of 7

Refueling Platform _LCR 89-02 1'

movement within the reactor pressure vessel (RPV).  ;

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2) The change to TSJ4.9.6.1.b does not allow a: fuel bundle to be lifted any higher than previously permitted and adds a minimum height-hoisted tolerance to ensure that a bundle will have adequate clearance over the fuel transfer chute floor.

3) The requested change to TS 4.9.6.1.d does raise the setpoint at which the fuel-loaded rod block is actuated, however, the setpoint remains below the redundant interlock setpoint of 550 pounds and at a value conservatively less than the weight of a fuel bundle; therefore, the basis for the fuel-loaded rod block (to ensure no control rod is removed while fuel is being handled) remains satisfied.

4) The change to 4.9.6.2.b and 4.9.6.3.b raises, by approximately two feet, the height to which a control rod assembly can be lifted by the auxiliary hoists; however, this height remains conservatively within the the analysis for a fuel handling (bundle drop)-

accident. Additionally, the calculated radiation dose rate (3.6 mr/hr at the surface of the water in the refueling cavity) from a control rod withdrawn to the amendment-requested height will remain less than the calculated dose rate from a fuel bundle withdrawn to its current uptravel limit by the main hoist (7.6 mr/hr one foot above the surface of the water in the refueling cavity).

5) The elimination of the fuel loaded rod block interlock for the monorail and frame-mounted auxiliary hoists does not impact an evaluated accident. The rod block is unnecessary for these two auxiliary hoists because they are specifically precluded from lifting any fuel bundle by the wording of the proposed TS 3.9.6, by  ;

procedure, and by the overload cutoff limits of TS l 4.9.6.b.

6) The revision to 4.9.2.c and its associated footnote adds conservatism by ensuring at least 3 cps on the SRMs regardless of signal-to-noise ratios.

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Refueling Platform LCR 89-02

2. The operation of Hope Creek Generating Station (HCGS) in accordance with the proposed change will not create the possibility of a new or different kind of accident from any previously evaluated.

The changes proposed in the measurement point of reference and the associated dimensional revision to the uptravel limit setpoint for fuel bundles do not introduce any actual change in uptravel limits. Fuel bundles will be hoisted to the same height as the present TS permits. The change to the height to which a control rod may be lifted is within the bounds of the present UFSAR analysis for a fuel bundle lifted to its permitted limit -

considering both a dropped fuel bundle accident and radiological dose rate at the refueling platform. There is no new accident consideration introduced by combining the surveillance requirements for the frame-mounted and monorail mounted auxiliary hoists since the previous TS requirements were identical for each. Eliminating the fuel-loaded rod block for these two hoists eliminates a surveillance requirement which is meaningless since the hoists are not permitted to handle fuel bundles.

The revision to 4.9.2.c and its associated footnote is more conservative, requiring the higher 3 cps SRM count rate regardless of signal-to-noise ratio.

3. The operation of Hope Creek Generating Station (HCGS) in accordance with the proposed change does not involve a significant reduction in a margin of safety.

The proposed increase in height to which a control rod may be hoisted is within the bounds of the previous analysis for a fuel bundle drop. Although the calculated radiation dose rate, at the refueling cavity water surface, from a control rod raised to the proposed uptravel limit will be somewhat greater than the dose rates corresponding to the current uptravel. limit, the dose rate will remain well below the levels currently produced by a fuel bundle at its uptravel limit. The increase in the setpoint for the fuel-loaded rod block interlock for the main hoist is within the present setpoint for the redundant fuel-loaded rod block interlock setpoint. The fuel-loaded rod block interlock has no safety importance for the auxiliary hoists since they do not handle fuel bundles. The revision which increases the required minimum SRM counts adds to the margin of safety.

IV. CONCLUSION Based upon the analysis presented above and the information contained in Attachment 3, PSE&G has determined that the proposed changes do not involve a Significant Hazards Consideration.

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ATTACIIMENT 2 PROPOSED TECIINICAL SPECIFICATION CIIANGES The following Technical Specification changes reflect the Request for Amendment regarding the Refueling Platform (LCR 89-03)

TS 3/4.9.1 Page 3/4 9-1 TS 3/4.9.2 Page 3/4 9-4 TS 3/4.9.6 Page 3/4 9-8 and 9-9

• TS Bases 3/4.9.6 Page B 3/4 9-2 v

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