ML20238C768

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Application for Amend to License NPF-57,revising Tech Spec Tables 1.1 & 4.3.6-1 for Rod Block Monitor Trip Function Creating New Surveillance Frequency for Channel Functional Test.Fee Paid
ML20238C768
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 09/02/1987
From: Corbin McNeil
Public Service Enterprise Group
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20238C770 List:
References
NLR-N87163, NUDOCS 8709100361
Download: ML20238C768 (7)
v • d • e


Text

~ -e Pubhc Service ,

Electric and Gas Company Corbin A. McNeill, Jr. Pubhc Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4800 Senior Vice President -

  • ' September 2, 1987 NLR-N87163 ,

United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR AMENDMENT FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 In accordance with the requirements of 10CFR50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits a request for amendment of Facility Operating License NPF-57 for Hope Creek Generating Station (HCGS). In accordance with the requirements of 10CFR170.21, a check in the amount of $150.00 is enclosed. In accordance with the requirements of 10CFR50.91(b)(1), a copy of this request has been sent to the State of New Jersey as indicated below.

This amendment request revises Technical Specification Tables 1.1 and 4.3.6-1 for the Rod Block Monitor (RBM ) trip function. These changes (see Attachment 2) create a new surveillance frequency for the RBM CHANNEL FUNCTIONAL TEST in order to eliminate confusion between Table 4.3.6-1 and Specification 3/4.1.4.3. Attachment 1 contains further discussion and justification for these proposed revisions. This amendment request, pending the necessary review and approval, requires no special consideration regarding the date of issuance or effective date.

This submittal includes one (1) signed original, i nclud i ng affidavit, and thirty-seven (37) copies pursuant to 10CFR50.4(b)(2)(ii).

Should you have any questions on the subject transmittal, please do not hesitate to contact us.

Sincerely,

~

Enclosure (check) /j ()

Affidavit f Attachments (2) J g 8709100361 870902 .

PDR p

ADOCK 05000354, PDR .

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Document Control Desk 2 9-2-87 C Mr. G. W. Rivenbark USNRC Licensing Project Manager Mr. R. W. Borchardt

'USNRC Senior Resident Inspector Mr. W. T. Russell, Administrator USNRC Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 1

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Ref: LCR 87-16' STATE'OF NEW:JERSE )

., SS.

COUNTY OF. SALEM. )

Corbin~A. McNeill,'Jr., being duly sworn according to law deposes and says:

I am Senior' Vice President of Public Service Electric and Gas

~

Company, and'as such, I find the. matters set forth in o'ur letter

? dated. September 2, 1987 , concerning Facility Operating License

~

.NPF-57 for Hope Creek Generating Station, is true to the best of my knowledge,.information and belief.

-x Subscribp and Sworn to pefpre me this 1 day of Ad le.-r 1987

/

e ./. N LARAINE Y. BEARD Notary Publc of Ne w 3*

_fNotaryp9ublicofNewJersey My Commissioc. Exphes MoY}'*{993 My Commission expires on L

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. ATTACHMENT 1 PROPOSED. CHANGE TO THE. TECHNICAL SPECIFICATIONS FACILITY OPERATING LICENSE-NPF-57 HOPE- CREEK GENERATING STATION

' DOCKET NO. 50-354 LCR 87-16

' I'. DESCRIPTION OF THE CHANGE Revise Technical Specification Table 4. 3. 6-1 Trip Function 1-- Rod ' Block Monitor ( RBM), as well as Table 1.1, by-

. creating a new Surveillance Frequency which' properly identifies when the CHANNEL FUNCTIONAL TEST for the RBM must

. be performed in order to satisfy OPERABILITY requirements

( see. Attachment 2 for the marked-up pages) .

II. JUSTIFICATION FOR THE CHANGE Technical Specification 3/4.3.6 describes OPERABILITY requirements for Control Rod Block Instrumentation including the trip functions associated.with the Rod Block Monitor

( RBH) . Currently Table 4.3.6-1 requires all Control Rod Block Instrumentation, with the exception of the trip functions associated with the Scram Discharge Volume and Reactor Mode Switch, to pass their respective CHANNEL FUNCTIONAL TEST within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior'to startup, if not performed within the previous 7 days . ( i. e. Note ( b) ) .

However, in the case of the RBM, Technical Specification 3/4.1.4.3' indicates that the RBM shall be OPERABLE in OPERATIONAL CONDITION 1, when THERMAL POWER is greater than or equal to 30% of RATED THERMAL POWER. Although this APPLIC ABILITY is similarly shown in Table 4. 3. 6-1 through the use of the asterick note, the CHANNEL FUNCTIONAL TEST column contains the designator S/U, which as defined in Table-1.1 indicates that the test'must.be performed prior to each startup. Because of the disagreement between these two specifications. Hope Creek. Generating Station ( HCGS) has conservatively required the RBM CHANNEL FUNCTIONAL TEST to be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to startup, if not performed within the past 7 days even though the subject trip function is not required to be'0PERABLE until reaching 30% of RATED THERMAL POWER.

The purpose of the RBM system is to monitor the local neutron flux levels during the withdrawal of a selected rod, and' automatically generate rod blocks to the Reactor Manual Control System when the monitored neutron flux levels exceed pre-established limits which are allowed to vary with recirculation driving flow. As stated in the Technical Specification Bases for Specification 3/4.1.4, in the event of an erroneous rod withdrawal from locations of high power Page 1

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density during high power operation, the RBM serves to protect fuel from exceeding thermal limits thereby preventing fuel damage. The high power operations are further discussed in Final Safety Analysis Report ( FSAR)

Section 7.7.1.1.2.2 in that "an automatic bypass of the RBM rod block occurs when the power level is below a preselected le vel. . . indi cati ve that local fuel damage is not a threat and that RBM action is not required." This conclusion is I again reached in the HCGS response to NRC Question 421.54 which states that although the RBM is a nonsafety grade component which may be actuated during the course of an anticipated operational occurrence ( transient), the system is not required to mitigate the accidents discussed in Chapter 15, specifically PSAR Section 15. 4.1 and 15.4.2. I Therefore, Technical Specification 3/4.1.4.3 was developed {

with the requirement for the RBM to be OPERABLE whenever {

THERMAL POWER was greater than or equal to 30% of RATED {

THERMAL POWER.

The proposed change would correct the CHANNEL FUNCTIONAL TEST column of Technical Specification Table 4.3.6-1 to agree with Specification 3/4.1.4.3 by creating a new designator, Z, which in turn would be defined in Table 1.1 ast "During startup, prior to exceeding 30% of RATED THERMAL POWER, if not performed within the previous 7 days." With the use of this new designator, a new note for Table 4.3.6-1, Note ( d) would also be required in order to include the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restriction currently provided by Note ( b) . In addition, Note ( c) would still be applicable since the change only revines when the testing is to be performed not what is included in such testing.

Public Service Electric and Gas Company ( PSE&G) has decided that the proposed change is the best manner in which to resolve the discrepancy since the change: (i) clearly indicates that the testing is not required prior to startup (i.e. the designator S/U is not being used), ( ii) maintains consistency with the existing intent of Technical Specification 3/ 4.1. 4. 3 and the asterick note without revising either, and (iii) minimizes the potential for misinterpretation by the operator by removing differing sets of OPERABILITY requirements for the same feature in separate portions of the Technical Specifications. In addition, with the proposed change in place. HCGS could proceed with a normal startup up to 30% of RATED THERMAL POWER, at which time the RSM CHANNEL FUNCTIONAL TEST must be performed.

Although the movement of control rods must be halted in order to perform the testing, the latitude permitted by this change would allow a quicker startup to power operations below 305 RATED THERMAL POWER without waiting for the RBH testing to be completed.

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III. SIGNIFICANT HAZARDS CONSIDERATION EVALUATION-The -proposed change to the HCGS Technical Specifications:

'(1) Does not involve a significant increase in the probability or consequences of an accident previously analyzed. Technical Specification 3/4.1.4.3_ specifies that the RBM'shall be OPERABLE whenever THERMAL POWER is greater than or equal to.30% of RATED THERMAL POWER. . Below 30% of'

' RATED THERMAL POWER the RBM system is automatically bypassed; therefore,_ whether or not the system has a CHANNEL FUNCTIONAL TEST performed prior to startup is immaterial so long as THERMAL POWER is below 30% of RATED THERMAL POWER.

Hence, it can be concluded that the proposed change does not significantly increase the probability or consequences of an accident previously analyzed because the change only revises when a test for OPERABILITY is to be performed, not the fact-that such a test will be performed.

( 2) Does not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed change does not involve _a modification to the RBM system, including when the system is required to be functional. The proposed change only involves planning considerations and hence it can be concluded that the proposed change does not create the possibility of a new or different kind of accident than any previously analyzed.

( 3) Does not involve a significant reduction in a margin of safety. Once again the Technical Specification power limit of 30% of RATED THERMAL POWER for OPERABILITY of the RBM is not changing, nor is the actual requirement to perform a CHANNEL FUNCTIONAL TEST prior to reaching 30% of RATED THERMAL POWER. Therefore the. safety margins for the  ;

RBM are still maintained and it~can be concluded that the  !

proposed change does not involve a reduction in the margin of safety.

Finally, this amendment request conforms to Example (i) for Amendments That Are Not Likely To Involve Significant Hazards Considerations ( published in Federal Register Volume

51. _ Numbe r. 4 4, dated March 6, 1986) in that this change is a purely administrative change to achieve consistency throughout the Technical Specifications as well as involving a change in nomenclature. In addition, based upon the discussions provided in the above three subparagraphs, PSELG concludes that the proposed change does not involve a Significant Hazards consideration.

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I ATTACHMENT 2

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