ML20137G504

Summary of 850801 Meeting W/Utils,Ge,State of Nj & Conner & Wetterhahn in Bethesda,Md Re Acceleration of Power Ascension Program.List of Attendees & Viewgraphs Encl

ML20137G504
Person / Time
Site:	Hope Creek
Issue date:	08/19/1985
From:	Wagner D Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8508270319
Download: ML20137G504 (35)

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h kj UNITED STATES NUCLEAR REGULATORY COMMISSION e WASHINGTON, D. C. 20555

.....* AUG 191985 Docket No. 50-354 APPLICANT: Public Service Electric & Gas Company (PSE&G)

FACILITY: Hope Creek Generating Station

SUMMARY

OF AUGUST 1, 1985 MEETING REGARDING THE HOPE CREEK POWER ASCENSION PROGRAM At the request of the applicant, a meeting was held on August 1, 1985 in the Bethesda, Maryland offices of the NRC to discuss the acceleration of the Hope Creek Power Ascension Program. Meeting attendees are identified in Enclosure 1 to this meeting summary.

As discussed at the meeting, PSE&G is planning to conduct the Hope Creek Power Ascension Program on an accelerated schedule. Current plans call for going from 0% power to 100% power within 180 days. The domestic average (as reported by PSE&G) for this power ascension is 367 days. PSE&G made a presentation during the meeting detailing some aspects of this accelerated program. The presentaticn notes are included in Enclosure 2 to this meeting summary. Highlights of the meeting and presentation include:

General Electric and Bechtel system specialists will be conducting comprehensive walkdowns of selected plant systems In order to accelerate the power ascension program, PSE&G will request elimination of some tests specified by Ragulatory Guide 1.68 and will request relaxation / deletion of a number of the surveillances called for in the Technical Specifications. Specifically, PSE&G identi-fied 5 categories of methods by which the power ascension program can be accelerated:

1. replace testing with Tech Spec surveillances

2. delete non-essential testing

3. simplify some tests

4. replace tests with data from other tests

5. delete certain Regulatory Guide 1.68 testing In order to accelerate the power ascension program, PSE&G will provide the staff with analyses justifying continued plant operation up to and including full power when certain equipment is out of service'. The identified equipment may include: fecdwater heater (s), MSIVs, HPCI/RCIC and the Standby Liquid Control System.

8508270319 850819 PUR ADOCK 05000354 A PDR

AUG13 E3I PSE&G will propose Tech Spec relaxation during the power ascension program. At the meeting, PSE&G even suggested the use of a Tech Spec appendix which would be effective only during the 0%-5% power range-the appendix would be discarded above 5% power.

PSE&G has been involved in scram reduction program and believe that an accelerated power ascension program can be cctducted while reducing challenges to safety systems.

All relief / exemption requests by PSE&G will be accompanied by technical justifications.

Based on the applicant's presentation and discussion throughout the treeting, the staff made the following comments:

Since PSE&G has reviewed the operating experience at remerous plants to develop bases for the proposed deletion of a number of Tech Spec surveillances, it wculd be helpful to the regulatory process if PSE&G would review the same operating experience for the purpose of identifying areas in which additional or more stringent Tech Specs should be required.

PSE&G should identify as early as possible, each technical issue involved in the deletion of Tech Specs and hold meetings with the NRC technical staff.

- The staff needs a schedule of Power Ascension Program submittals.

- PSE&G should forward for staff review the following information:

1. a list of proposed deviations from Regulatory Guide 1.68 guidance

2. a schedule of when technical justifications for the deviations from Regulatory Guide 1.68 will be provided and the dates by which results of the staff's review are needed

3. identification of the Tech Specs which are proposed to be waived between 0% and 5% power

4. a schedule of when technical justifications for the proposed Tech Spec deletions wi.1I be provided Regarding the last comment above, PSE&G has agreed to supply the staff with the identified information by the end of August 1985.

Dave Wagner, Project fianager Licensing Branch No. 2 Division of Licensing

Enclosure:

As stated DISTRIBUTION t Docket File LDewey,0 ELD cc: See r. ext page . NRC PDR WButler P W Local PDR DWagner LEL. 1 LB#2/DL/BC PRC System EHylton 0 Wagner:lb WButler NSIC 08/y85 08/g/85 LB#2 Reading

AUG 19195d PSE&G will propose Tech Spec relaxation during the power ascension program. At the meeting, PSE&G even suggested the use of a Tech Spec appendix which would be effective only during the 0%-5% power range-the appendix would be discarded above 5% power.

PSE&G has been involved in scram reduction program and believe that an accelerated power ascension program can be conducted while reducing challenges to safety systems.

3 All relief / exemption requests by PSE&G will be accompanied by technical justifications.

Based on the applicant's presentation and discussion throughout the meeting, the staff made the following comments:

Since PSE&G has reviewed the operating experience at numerous plants to develop bases for the proposed deletion of a number of Tech Spec surveillances, it would be helpful to the regulatory process if PSE&G would review the same operating experience for the purpose of identifying areas in which additional or more stringent Tech Specs should be requi red.

PSE&G should identify as early as possible, each technical issue involved in the deletion of Tech Specs and hold meetings with the NRC technical staff.

The staff needs a schedule of Power Ascension Program submittals.

PSE&G should forward for staff review the following information:

1. a list of proposed deviations from Regulatory Guide 1.68 guidance

2. a schedule of when technical justifications for the deviations from Regulatory Guide 1.68 will be provided and the dates by which results of the staff's review are needed

3. identification of the Tech Specs which are proposed to be waived between 0% and 5% power

4. a schedule of when technical justifications for the proposed Tech Spec deletions will be provided Regarding the last comment above, PSE&G has agreed to supply the staff with the identified information by the end of August 1985.

Dave Wagner, Project fianager Licensing Branch No. 2 Division of Licensing

Enclosure:

As stated DISTRIBUTION J Docket File LDewey,0 ELD cc: See next page . NRC PDR WButler

? W Local PDR DWagner

.LfL#.2 M LB#2/DL/BC PRC System EHylton DWagner:lb WButler NSIC 08/y85 08/q/85 LB#2 Reading j

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, a .

PSE&G will propose Tech Spec relaxation during the power ascension program. At the meeting, PSE&G even suggested the use of a Tech Spec appendix which would be effective only during the 0%-5% power range-the appendix would be discarded above 5% power.

PSE&G has been involved in scram reduction programs and believes that an accelerated power ascension program can be conducted while reducing challenges to safety systems.

All relief / exemption requests by PSE&G will be accompanied by technical justifications.

Based on the applicant's presentation and discussion throughout the meeting, the staff made the following comments:

Since PSE&G has reviewed the operating experience at numerous plants to develop bases for the proposed deletion of a number of Tech Spec surveillances, it would be helpful to the regulatory process if PSE&G would review the same operating experience for the purpose of identifying areas in which additional or more stringent Tech Specs should be required.

PSE&G should identify as early as possible, each technical issue involved in the deletion of Tech Specs and hold meetings with the NRC technical staff.

The staff needs a schedule of Power Ascension Program submittals.

PSE&G should forward for staff review the following information:

1. a list of proposed deviations from Regulatory Guide 1.68 guidance

2. a schedule of when technical justifications for the deviations from Regulatory Guide 1.68 will be provided and the dates by which results of the staff's review are needed

3. identification of the Tech Specs which are proposed to be waived between 0% and 5% power

4. a schedule of when technical justifications for the proposed Tech Spec deletions will be provided and the dates by which results of the staff's review are needed.

Regarding the last comment above, PSE&G has agreed to supply the staff with the identified information by the end of August 1985.

~

Ch oo x Dave Wagner, Project Manager Licensing Branch No. 2 Division of Licensing

Enclosure:

As stated cc: See next page

i 4 Mr. R. L. Mitti Public Service Electric & Gas Co. Hope Creek Generating Station cc:

Gregory Minor Susan C. Remis Richard Hubbard Division of Public Interest Advocacy Dale Bridenbaugh New Jersey State Department of MHB Technical Associates the Public Advocate 1723 Hamilton Avenue, Suite K Richard J. Hughes Justice Comples San Jose, California 95125 CN-850 Trenton, New Jersey 08625 Troy B. Conner, Jr. Esquire Office of Legal Counsel Conner & Wetterhahn ' Department of Natural Resources 1747 Pennsylvania Avenue N.W. and Environmental Control Washington, D.C. 20006 89 Kings Highway P.O. Box 1401 Dover, Delaware 19903 Richard Fryling, Jr., Esquire Mr. K. W. Burrowes, Project Engineer Associate General Solicitor Bechtel Power Corporation Public Service Electric & Gas Company 50 Beale Street P. O. Box 570 T5E P. O. Box 3965 Newark, New Jersey 07101 San Francisco, California 94119 Mr. J. M. Ashley Resident. Inspector Senior Licensing Engineer U.S.N.R.C. c/o Public Service Electric & Gas Co.

P. O. Box 241 Bethesda Office Center, Suit 550 Hancocks Bridge, New Jersey 08038 4520 East-West Highway Bethesda, Maryland 20814 Richard F. Engel Deputy Attorney General Mr. A. E. Giardino Division of Law Manager - Quality Assurance E&C Environmental Protection Section Public Service Electric & Gas Co.

Richard J. Hughes Justice Complex P. O. Box A CN-112P Hancocks Bridge, New Jersey 06038 Trenton, New Jersey 08625 Mr. Robert J. Touhey, Mr. Anthony J. Pietrofitta Acting Director General Manager DNREC - Division of Power Production Engineering Environmental Control Atlantic Electric 89 Kings Highway 1199 Black Horse Pike P. O. Box 1401 Pleasantville, New Jersey 08232 Dover, Delaware 19903 Regional Administrator, Region I Mr. R. S. Salvesen U. S. Nuclear Regulatory Commission General Manager-Hope Creek Operation 631 Park Avenue Public Service Electric ~& Gas Co. King of Prussia, Pennsylvania 19406 P.O. Box A Hancocks Bridge, New Jersey 08038

Public Service Electric & Gas Co. -

2- Hope Creek Generating Station cc:

Mr. B. A. Preston Project Licensing Manager Public Service Electric & Gas Co.

P. O. Box 570 T22A Newark, New Jersey 07101 Ms. Rebecca Green New Jersey Bureau of Radiation Protection 380 Scotch Road Trenton, New Jersey 08628 f

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o b Enclosure 1 APPLICANT: PUBLIC SERVICE ELECTRIC & GAS COMPANY FACILITY: HOPE CREEK GENERATING STATION

SUBJECT:

Hope Creek Power Ascension Program DATE: Thursday, August 1, 1985 Name Organization David Wagner NRC W. R. Butler NRC S. LaBruna PSE&G B. Schell PSE&G Bruce Preston PSE&G R. C. Stirn General Electric (GE)

J. C. Larren GE W. H. Brown GE J. F. Klapproth GE J. N. Ridgely NRC S. Brown NRC Rebecca Green New Jersey Bureau of Radiation Protection Mel Sankovich Gulf States Utilities J. J. Lyash NRC A. R.,Blough NRC P. W. Eselgroth NRC Jerry Mazetis NRC Dick Becker NRC P. J. Pagano GE A. L. Jenkins GE Richard Schaller Illinois Power Paul Telthorsts Illinois Power Byron L. Siegel NRC R. F. Drewnowski PSE&G H. lletterhahn Conner & Wetterhahn R. Fryling PSE&G Walter L. Brooks NRC Daniel Fieno NRC Wayne Hodges NRC George Thomas NRC i

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s Enclosure 2 .

s POWER ASCENSION. TEST PROGRAM ACCELERATION BETHESDA, MD, AUGUST 1, 1985 1

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c PUBLIC SERVICE ELECTRIC a GAS

PSEtG/NRC MEETING POWER ASCENSION TEST PROGRAM ACCELERATION 1 TOPICAL REVIEW 11 OPENING REMARKS S. LABRUNA PSE&G 111 MEETING OBJECTIVES 112 ACCELERATED POWER ASCENSION PROGRAM SCHEDULE 12 BACKGROUND B. SCHELL

. PSE&G 121 STARTUP TEST PROGRAM OBJECTIVES 122 EVOLUTION OF TECHNOLOGY 123 STARTUP TEST EXPERIENCE

SUMMARY

13 POWER ASCENSION TEST PROGRAM S. LABRUNA ACCELERATION PSEgG 131 REDUCTION IN UNPLANNED OUTAGES 132 TEST SIMPLIFICATION AND ELIMINATION 133 TECHNICAL SPECIFICATION EXCEPTIONS 134 AGGRESSIVE PERFORMANCE 14 DISCUSSION /NRC MANAGEMENT FEEDBACK 2 TECHNICAL BASIS PSEgG/GE 21 TEST SIMPLIFICATION AND ELIMINATION 22 TECHNICAL SPECIFICATION EXCEPTIONS 23 DISCUSSION /NRC FEEDBACK A

I 1.1.1 MEETING OBJECTIVES SbkNbONE PkOGRM DETERMINE BASIS ON WHICH NRC WILL CONSIDER EXCEPTIONS REGULATORY GUIDE 1.68 TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS EXPLORE THE USE OF 10CFR50.59 AS A MECHANISM FOR POWER ASCENSION TEST PROGRAM CHANGES -

ASSURE REGULATORY REQUESTS ARE CONSISTENT WITH NRC INTERPRETATIONS OF REGULATIONS AND SUPPORTING LICENSING CRITERIA

?

9 IMPLEMENTATION OF TEST CHANGES REG GUIDE 1,68 APPENDIX B REQUESTS SUBMITTAL OF TEST PROCEDURES NOT LESS THAN 60 DAYS PRIOR TO SCHEDULED FUEL LOADING DATE EVALUATION, DOCUMENTATION, AND IMPLEMENTATION OF THE ACCELERATED POWER ASCENSION PROGRAM PROPOSED CHANGES MAY NOT BE COMPLETED PRIOR TO 60 DAYS BEFORE CORE LOAD PSE&G REQUESTS NRC CONCURRENCE FOR:

SUBMITTING TEST PROCEDURES NOT LESS THAN 3 WEEKS PRIOR TO FUEL LOAD RECOMMENDED APPROACH MINIMIZES POTENTIAL SCHEDULE IMPACT WITHOUT COMPROMISING POWER ASCENSION PROGRAM QUALITY I

1.1.2 ,

ACCELERATED POWER ASCENSION PROGRAM SCHEDULES .

ACTIVITY l JUN I JUL l AUG l SEP l 0CT l NOV l DEC 1

1. REDUCTION OF SHUTDOWNS

& UNPLANNED TRIPS A. REVIEW DATA a--------------a .

R. RECOMMENDATIONS a----------a C. IMPLEMENTATION a----------------------------------------a

2. TEST SIMPLIFICATION &

ELIMINATION A. SYSTEMATIC REVIEW A--------------------------a 0F TESTS / BASES B. RECOMMENDATIONS a----------------A C. NRC APPROVAL a--------------------------------a

3. TECH SPEC EXCEPTIONS A. REVIEW a--------------a B. RECOMMENDATIONS a--------------a C. NRC APPROVAL a______________a -

4. DETAILED 8 FLEXIBLE a----------------------------------------------a SCllEDULING l JUN  ! JUL I AllG I SEP  ! OCT l NOV I DEC I

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HOPE CREEK GENERATNG STATON .

POWER ASCENSION PROGRAM SCHEDULE (185 DAYS) ovtRview 10 0 - 121314 15 ts -

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1 UCENSE TO lAAD FUCL '

2 TUCL LDAD COMPLETE i ,

3 OPEN VESSEL AND HEAT UP TESTING 1 90- 4 nRST GEN SYNC 5 toss Or Orrslit POWER ,

6 LOAD REJ WITHIN BVPASS VLV CAPACITY 80- 7 SHUT 00WN OUT5IDE CONTROL RO0W l

8 RECIRC ONE PUMP TRIP ae g '

j 9 REclRC TWO PUMP TRIP - '" '

.l 10~ TURe STOP VLV TRIP 70 - .

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1g 13 RECIRC PUMP TRIP .

I LaJ 60- 14 GEN LD REJ l 3 15 MStV ISOL k 16 WARRANTY RUN l

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10 0 12 0 84 0 16 0 18 0 200 220 24 0 263 280 '

TIME ( DAYS ) '"' - Y "3/-

1.2 BACKGROUND

1.2.1 STARTUP TEST PROGRAM OBJECTIVES (REGULATORY GUIDE 1.68) o PROVIDE ASSURANCE THAT THE FACILITY HAS BEEN ADEQUATELY DESIGNED AND CONSTRUCTED VALIDATE ANALYTICAL MODELS AND' ASSUMPTIONS o

DEMONSTRATE THAT THE FACILITY CAN BE OPERATED IN ACCORDANCE WITH DESIGN REQUIREMENTS o

PROVIDE OPERATOR TRAINING AND VERIFICATION OF THE ADEQUACY OF OPERATING AND EMERGENCY PROCEDURES (T0 THE EXTENT PRACTICAL)

HIGH QUALITY POWER ASCENSION PROGRAM NEEDED TO MEET OBJECTIVES

2.

1 1.2.1.1 MEETING STARTUP TEST PROGRAM OBJECTIVES 0 EXTENSIVE TESTING PROGRAM DEVELOPED IN 1960'S

, o REGULATORY GUIDE 1,63 ISSUED IN 1973 (REVISION 2, 1978) o SOME TESTING AND PLANNED SCRAMS ELIMINATED IN 1975 o

EVOLUTION OF TECHNOLOGY SINCE 1975 WARRANTS REVIEW 0F STARTUP TEST PROGRAM 4

SIGNIFICANT TECHNOLOGICAL ADVANCEMENTS HAVE BEEN IMPLEMENTED SINCE LAST PROGRAM REVIEW i

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'1.2.2 EVOLUTION OF TECHNOLOGY o IMPROVEMENT IN ANALYTICAL MODELS o QC/QA PROCEDURES

\

o EXTENSIVE BWR TEST DATA BASE / EXPERIENCE o

' EXTENSIVE TESTING AND QUALIFICATION OF KEY TECHNICAL ISSUES o ENHANCED TRAINING PROGRAMS o HIGHLY TRAINED / EXPERIENCED STARTUP STAFF

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o THOROUGH AND AGGRESSIVE PRE-0P TEST PROGRAM o ENHANCED DATA ACQUISITION SYSTEMS o

MORE COMPREHENSIVE TECH SPEC SURVEILLANCE REQUIREMENTS

o. ADVANCED DESIGNS /MORE REALISTIC DESIGN CRITERIA o LICENSEE EXPERIENCE TECHNOLOGICAL EVOLUTION ENSURES THAT STARTUP TEST PROGRAM OBJECTIVES CAN BE MET WITH HIGH QUALITY ACCELERATED POWER ASCENSION TEST PROGRAM

1.2.2.1 APPLICATION OF TECHNOLOGICAL EVOLUTION TO STARTUP TEST PROGRAM OBJECTIVES OBJECTIVE TECHNOLOGICAL EVOLUTION

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O PR0 VIDE ASSURANCE THAT THE 0 THOROUGH AND AGGRESSIVE FACILITY HAS BEEN PRE-0P TEST PROGRAM ADEQUATELY DESIGNED AND 0 DETAILED SYSTEM WALKTHROUGHS CONSTRUCTED 0 QA/QC PROCEDURES 0 VALIDATE ANALYTICAL MODELS 0 EXTENSIVE TESTING OF KEY AND ASSUMPTIONS TECHNICAL ISSUES 0 IMPROVEMENT IN ANALYTICAL MODELS -

0 DEMONSTRATE THAT THE O ENHANCED DATA ACQUISITION FACILITY CAN BE OPERATED IN SYSTEM ACCORDANCE WITH DESIGN 0 MORE COMPREHENSIVE TECH REQUIREMENTS SPECS 0 PROVIDE OPERATOR TRAINING 0 ENHANCED TRAINING PROGRAM

, AND VERIFICATION OF THE 0 HIGHLY TRAINED AND ADEQUACY OF OPERATING AND EXPERIENCED STARTUP STAFF EMERGENCY PROCEDURES (T0 THE EXTENT POSSIBLE)

COMBINATION OF HOPE CREEK POWER ASCENSION PROGRAM AND ,

TECHNOLOGICAL EVOLUTION ENSURES OBJECTIVES ARE MET j, .._ ...,,.,.r.,,,_'._./ _-,.,<.,..,,,,.... .t_-..- ...-----.--I =- - -

1,2,3 STARTUP TEST EXPERIENCE SuffARY 'i

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STARTJ' P TIMES * -

OVERALL DOMESTIC BEST TIME DOMESTIC OVERSEAS & FOREIGN DOMESTIC TIME PERIOD AVERAGE AVERAGE AVERAGE a FOREIGN a

HYDR 0 PRE 0P - BEGIN FUEL LOAD 22 MONTHS 8 MONTHS 14 PONTHS 5 MONTHS BEGIN FUEL LOAD - END FUEL LOAD 18 DAYS 14 DAYS 16 DAYS 8 DAYS

, END FUEL LOAD - BEGIN HEATUP 48 DAYS 30 DAYS 37 DAYS 13 DAYS BEGIN HEATUP - RATED T,P 16 DAYS 10 DAYS 13 DAYS 5 DAYS RATED T,P - FIRST SYNCH 44 DAYS 25 DAYS 32 DAYS 6 DAYS TEST CONDITION 1 23 DAYS 16 DAYS 18 DAYS I DAY TEST CONDITION 2 57 DAYS 31 DAYS 41 DAYS 13 DAYS TEST CONDITION 3 35 DAYS 39 DAYS 38 DAYS 17 DAYS TEST CONDITION 4 2 DAYS 12 DAYS 9 DAYS 1 DAY TEST CONDITION 5 4 DAYS 11 DAYS 9 DAYS 3 DAYS TEST CONDITION 6 114 DAYS 64 DAYS 96 DAYS 42 DAYS WARRANTY RUN 6 DAYS 7 DAYS 7 DAYS 5 DAYS BEGIN FUEL LOAD - END WARRANTY 367 DAYS 259 DAYS 316 DAYS 114 DAYS

• FOR PLANTS BEGINNING COMMERCIAL OPERATION BETWEEN 1978 AND MID 1983 NOTE THE LARGE DIFERENCES BETWEEN THE BEST TIME AND AVERAGE TIME FOR EACH TEST,. CONDITION

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0 271 DAYS UNPLANNED SCRAMS = 11 PLANNED SCRAMS = 4 MAJOR OUTAGES = 99 DAYS NOTE LARGE DELAY BETWEEN FUEL LOADING AND llEATUP l .

' RECENT BWR STARTUP TEST EXPERIENCE -

TESTING DAYS TEST CONDITION UNSCHEDULED SCHEDULED

• ACTUAL.'

ACTIVITIES _

OPEN VESSEL 28 29 50 HEATUP 14 14 13 TC 1 11 TC 2 ' 10 20 15 23 TC 3 9 21 23 TC 4 1 9

1 TC 5 0 5 3 TC 6 25 1

23 32 WARRANTY RUN 11 11 0 TOTAL 131 137 134 ESTIMATE INCLUDES PLANNED SHUTDOWNS DOES AND S NOT INCLUDE TIME LOST DUE TO UNSCHEDULED PLANT UNPLANNED ACTIVITIES HAVE LARGE SCHEDULE IM PSE8G WANTS TO DECREASE BOTH SCHEDULED AND UNSCHEDULED ACTIVITIES O

13 POWER ASCENSION TEST PROGRAM ACCELERATION 131 REDUCTION IN UNPLANNED OUTAGES 1311 DETAILED SYSTEM WALXTHROUGHS

-PRE-TEST TUNING / TROUBLESHOOTING 1312 SCRAM REDUCTION PROGRAM 1313 EQUIPMENT 00T OF SERVICE ANALYSIS 132 TEST SIMPLIFICATION AND ELIMINATION 1321 MAJOR ACTIVITIES 1322 CATEGORIZATION OF TESTING ACCELERATION ALTERNATIVES 133 TECHNICAL SPECIFICATION EXCEPTIONS 134 AGGRESSIVE PERFORMANCE

1311 DETAILED SYSTEM WALKTHROUGHS .

PRE-TEST TUNING / TROUBLESHOOTING -

EXAMPLE:

0FFGAS SYSTEM

• FORECAST OF TROUBLE SPOTS OFFGAS SYSTEM FLOW LIMITATIONS

-GE SYSTEM DESIGN EXPERTISE

-PAST EXPERIENCE & DATA BASE TRAMP URANIUM REQUIRES CHARC0AL TREATMENT OF 0FFGAS AT STARTUP

• DETAILED SYSTEM WALKTHROUGH UTILITY ENGINEER TEAM EFFORT *A/E ENGINEER ST0 ENGINEER

• GE SPECIALIST

• IDENTIFY PROBLEMS 8 RECOMMEND

• PROBLEMS DIVIDED INTO 2 GROUPS:

MODIFICATIONS 1. MODIFICATION IS MANDATORY BEFORE STARTUP

2. MODIFICATION AS BETTERMENT AT FIRST OUTAGE

• TUNE SYSTEM DURING PRE-OPS

• REVIEW MODIFICATIONS 8 TRAIN OPERATORS OPERATING,ANDTRAINING PROCEDURES IDENTIFY AND CORRECT PROBLEMS BEFORE THEY RESULT IN STARTUP DELAYS

i SYSTEM CANDIDATES FOR " WALK-THROUGH" FEEDWATER CONDENSATE SYSTEM DIVISION I, II, III AC/DC POWER NEUTRON MONITORING SYSTEM 0FFGAS SYSTEM STANDBY GAS TREATMENT SYSTEM (FRVS)

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RADIATION MONITORING SYSTEM I -

ELECTRICAL SEPARATION '

LEAK DETECTION SYSTEM ' -

WATER TREATMENT SYSTEMS RADI0 ACTIVE WASTE REACTOR WATER CLEANUP FUEL POOL COOLING AND CLEANUP CONTROL ROD DRIVE RCIC SYSTEM HPCI SYSTEM RHR SYSTEM FLOOR AND EQUIPMENT DRAINS

1312 SCRAM REDUCTION RECENT STARTUPS AVERAGE 25 SCRAMS DURING STARTUP PROGRAM 5 PLANNED TESTING 11 EQUIPMENT FAILURE

, 5 OPERATOR ERROR 4 SURVEILLANCE TE' STING / INSTRUMENT CALIBRATION EACH SCRAM COSTS APPR0XIMATELY 3 DAYS SCRAM REDUCTION PROGRAM BEING IMPLEMENTED REVIEW SCRAM HISTORY OF RECENT BWR STARTUPS REVIEW DESIGN AND INSTALLATION OF CRITICAL SYSTEMS REVIEW STARTUP,. OPERATING MAINTENANCE AND SURVEILLANCE TEST PROCEDURES FOCUSING 6N SCRAM REDudTION -

IMPLEMENT REVIEWS ,

PROGRAM TO REDUCE UNPLANNED SCRAMS BASED ON A SPECIFIC TRAINING FOR PERSONNEL PROCEDURAL CONTROLS EQUIPMENT MODIFICATIONS PROCEDURE REVISIONS SPECIFIC TESTING TRAINING FOR STARTUP TEST PERSONNEL ON STARTUP l .

l PROGRAM CONSISTENT WITH NRC/ INDUSTRY GOALS FOR SCRAM

' REDUCTION ACCELERATE POWER ASCENSION TEST PROGRAM WHILE REDUCING CHALLENGES TO SAFETY SYSTEMS L

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1.3.1.3 EQUIPMENT OUT OF SERVICE o

ANALYSES TO JUSTIFY CONTINUED PLANT OPERATION UP TO AND INCLUDING FULL POWER WHEN CERTAIN EQUIPMENT IS OUT OF SERVICE ,.

s o SPECIFIC EQUIPMENT MAY INCLUDE:

SINGLE RECIRCULATION LOOP OPERATION .

FEEDWATER HEATERS MAIN STEAM ISOLATION VALVES _.

HIGH PRESSURE ECCS EQUIPMENT (HPCI/RCIC)

^

STANDBY LIQUID CONTROL SYSTEM CONTINGENCY PLANNING WHICH MAINTAINS MARGINS TO ESTABLISHED SAFETY CRITERIA

1. 3'. 2 TEST SIMPLIFICATION AND ELIMINATION -

1.3.2.1 MAJOR ACTIVITIES O PRELIMINARY NRC REVIEW / CONCURRENCE OF CONCEPT o SYSTEMATIC REVIEW 0F SYSTEM REQUIREMENTS / BASES

, REGULATORY REQUIREMENTS INDUSTRY STANDARDS '

VENDOR REQUIREMENTS o

SYSTEMATIC REVIEW 0F STARTUP TEST SPECIFICATIONS AND PREVIOUS STARTUP TEST EXPERIENCE o

IDENTIFICATION OF TEST SIMPLIFICATION / ELIMINATION o DETAILED ENGINEERING ANALYSES DOCUMENT CHANGES o LICENSING APPROVAL / IMPLEMENTATION AS REQUIRED SYSTEMATIC APPROACH TO ENSURE QUALITY IS MAINTAINED FOR ACCELERATED TEST PROGRAM I

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1.3.2.2 CATEGORIZATION OF TESTING ACCELERATION ALTERNATIVES FIVE CATEGORIES OF TESTING ACCELERATION IDENTIFIED

1. REPLACE TESTING WITH TECH SPEC SURVEILLANCE

2. DELETION OF NON-ESSENTIAL TESTS

3. SIMPLIFICATION OF TESTING

4. REPLACEMENT OF TESTING WITH DATA FROM OTHER TESTS

5. DELETE SELECTED REG GUIDE 1.68 TESTING o

TEST SIMPLIFICATION OR ELIMINATION APPLICATION OF TECHNOLOGICAL EVOLUTION TECHNOLOGICAL IFROVED EXTENSIVE ENHANCED EXPERIENCED THOROUGH ENHANCED INCREASED VOLUTION ANALYTICAL QA/QC BWR TEST TRAINING & TRAINED PRE-0P DATA ACQ. TECH SPEC CATEGORY METHODS PROCEDURES EXPERIENCE PROGRAMS STAFF TESTING SYSTEMS SUR. REQTS l 1. REPLACE TEST W/ X X X X

TECH SPEC SURV.

2. DELETE NON- X X

• ESSENTIAL TESTS

3. SIMPLIFY TESTING X X X X X

4. REPLACE TEST WITH X X X X X X OTHER TEST DATA S. DELETE TEST X X X .X X X X PATP = POWER ASCENSION-TEST PROGRAM

1.3.3 TECHNICAL SPECIFICATION EXCEPTIONS 0

TECHNICAL SPECIFICATION REQUIREMENTS BASED ON FULL POWER LICENSE WITH EXPOSED FUEL 0

TECHNICAL JUSTIFICATION EXISTS FOR SELECTED EXCEPTIONS DURING LOW POWER (5% OR LESS) PHASE OF STARTUP TESTING LOW POWER LEVEL / LOW EXPOSURE FUEL YIELD LOW DECAY HE LEVELS

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REDUCED CORE COOLING REQUIREMENTS LOW POWER LEVELS RESULT IN LOW FISSION PRODUCT INVENTORY RADI0 ACTIVITY-RELEASE RATES WELL BELOW NRC SOURCE TERMS o

EXAMPLE OF TECHNICAL SPECIFICATION EXCEPTIONS ECCS AVAILABILITY i

PUBLIC HEALTH AND SAFETY IS NOT IMPACTED WITH TECH SPEC EXCEPTIONS 4

134 AGGRESSIVE PERFORMANCE TEST PROGRAM DURATION CAN BE REDUCED BY MANAGEMENT ATTENTION AND COMMITMENT MINIMlZE PRE 0PERATIONAL TEST PROGRAM DEFERRALS DETAILED PLANNING AND SCHEDULING ADEQUATE RESOURCES POWER ASCENSION ORGANIZATION STAFFED WITH DEDICATED AND EXPERIENCED PERSONNEL FIVE SHIFTS OF QUALIFIED STARTUP TEST PERSONNEL DEDICATED STAFF FOR COORDINATION, PLANNING, AND TEST REVIEW STARTUP TEST ADMINISTRATIVE CONTROLS TO ENSURE PROPER TEST SE0llENCING AND SC,HEDULING -

PROCEDURE CONTROLS PERSONNEL TRAINING AND OllAllFICATION PROPER TEST IMPLEMENTATION STARTUP TEST PROCEDURES REVIEWED TO ENSilRE TECHNICAL AND OPERATIONAL COR,RECTNESS SPECIFIC TRAINING OF STARTUP TEST AND OPERATIONS PERSONNEL REVIEW OR WALKTHROUGH OF PROCEDURES RUN PROCEDURES ON SIMULATOR WHERE POSSIBLE ABILITY TO ACQUIRE AND USE UNPLANNED TRANSIENT DATA HIGHLY TRAINED / EXPERIENCED STARTUP STAFF COMMITTED TO HIGH QUALITY POWER ASCENSION TEST PROGRAM

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1,4 DISCUSSION /NRC FEEDBACK NRC/PSE8G WORK TO ENSURE A MEANINGFUL ACCELERATED POWER ASCENSION TEST PROGRAM MAINTAIN QUALITY / SAFETY MINIMIZE TRANSIENTS AND THERMAL CYCLING

- REGULATORY GUIDE 1.68 ESTABLISHES BASIS FOR NRC REVIEW 0F ACCEPTABLE ALTERNATIVE TEST METHODS SELECTED TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS CAN BE EXCEPTED BELOW 5% POWER SOME TESTS CAN BE ELIMINATED / SIMPLIFIED ALL SAFETY REQUIREMENTS WILL BE. SATISFIED MANY TESTS ARE OVERSPECIFIED RELATIVE TO 1985 TECHNOLOGY EXPEDITED NRC REVIEW UTILIZATION OF THE 50.59 PROCESS FOR UNANTICIPATED CHANGES TO THE POWER ASCENSION PROGRAM TIMELY REVIEW 0F POWER ASCENSION RELATED LICENSING SUBMITTALS ,

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2. TECHNICAL DISCUSSION 2.1 TEST SIMPLIFICATION AND ELIMINATION 2.1.1 EVOLUTION OF TECHNOLOGY 2.1.2 APPLICATION OF TECHNOLOGY 2.1.3 CATEGORIZATION OF TESTING ACCELERATION 2.1.4 EXAMPLES 2.2 TECHNICAL SPECIFICATION EXCEPTIONS 2.

2.1 BACKGROUND

2.2.2 .ECCS FUNCTIONAL TESTING ,

I 2.3 DISCUSSION /NRC FEEDBACK 4

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2.1.1 EVOLUTION OF TECHNOLOGY ,'

o IMPROVEMENT IN ANALYTICAL MODELS

- THERMAL HYDRAULICS / TRANSIENT ANALYSIS

- LOCA/ECCS ANALYSIS - VIBRATIONS ANALYSIS

- CORE PHYSICS - PIPING ANALYSIS o QC/QA PROCEDURES I FUEL DESIGN a MANUFACTURING o EXTENSIVE BWR TEST DATA BASE / EXPERIENCE

- QUALIFICATION OF MODELS

- ASSESSMENT OF REQUIRED TESTS'

- REVIEW 0F PREVIOUS BWR STARTUP EXPERIENCE .

i o

EXTENSIVE TESTING AND QUALIFICATION OF KEY TECHNICAL ISSUE

- THERMAL HYDRAULIC STABILITY / TRANSIENT PERFORMANCE

- CORE PERFORMANCE (GAMMA SCANS) - POOL SCRUBBING

- ACCIDENT PERFORMANCE (LOFT, FIST) - NEW LOADS  : ,

- GETAB/GEXL CORRELATIONS 4 TESTING o ENHANCED TRAINING PROGRAMS

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- BWR SIMULATORS

- INSTRUMENTATION & CONTROLS LABS / TRAINING

- CHEMISTRY LABS / TRAINING o HIGHLY TRAINED / EXPERIENCED STARTUP STAFF o THOROUGH AND AGGRESSIVE PRE-0P TEST PROGRAM

- DETAILED SYSTEM WALKTHROUGHS

- BENCH CALIBRATION OF CONTROLLERS .

l 0 ENHANCED DATA ACQUISITION SYSTEMS o

MORE COMPREHENSIVE TECH SPEC SURVEILLANCE REQUIREMENTS

! o ADVANCED DESIGNS /MORE REALISTIC DESIGN CRITERIA i - GE BARRIER FUEL j - CONTROL CELL CORE DESIGN

- GETAB/GEXL SAFETY LIMIT BASES

! o LICENSEE EXPERIENCE

- KWU DRY FUEL LOADING i

- KWU BENCH CALIBRATION OF CONTROLLERS l

- JAPANESE SCRAM REDUCTION EXPERIENCE h

1 j  :

2.1.2 APPLICATION OF TECHNOLOGICAL EVOLUTION TO '.,'

• STARTUP TEST PROGRAM OBJECTIVES OBJECTIVE TECHNOLOGICAL EVOLUTION O PROVIDE ASSURANCE THAT THE 0 THOROUGH AND AGGRESSIVE FACILITY HAS BEEN PRE-0P TEST PROGRAM ADEQUATELY DESIGNED AND 0 DETAILED SYSTEM WALKTHROUGHS CONSTRUCTED 0 QA/QC PROCEDURES 0 VALIDATE ANALYTICAL MODELS 0 EXTENSIVE TESTING 0F KEY

, AND ASSUMPTIONS TECHNICAL ISSUES 0 IMPROVEMENT IN ANALYTICAL MODELS ,

0 DEMONSTRATE THAT THE 0 ENHANCED DATA. ACQUISITION' FACILITY CAN BE OPERATED IN SYSTEM ACCORDANCE WITH DESIGN 0 MORE COMPREHENSIVE TECH REQUIREMENTS SPECS 0 PROVIDE OPERATOR TRAINING 0 ENHANCED TRAINING PROGRAM AND VERIFICATION OF THE 0 HIGHLY TRAINED AND ADEQUACY OF OPERATING AND EXPERIENCED STARTUP STAFF EMERGENCY PROCEDURES (TO THE EXTENT POSSIBLE) i COMBINATION OF HOPE CREEK POWER ASCENSION PROGRAM AND TECHNOLOGICAL EVOLUTION ENSURES OBJECTIVES ARE MET

. . . _ . . .v ., .

~ '

2.1.1 CATEGORIZATION OF TESTING ACCELERATION .-

o FIVE CATEGORIES OF TESTING ACCELERATION IDENTIFIED

1. REPLACE TESTING WITH TECHNICAL SPECIFICATION ' -

SURVEILLANCE

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INCREASED TECH SPEC SURVEILLANCE PROVIDES REQ .

2. DELETE SELECTED NON-ESSENTIAL TESTS

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THOROUGH PRE-0P TEST!NG ENSURES SYSTEM PERFORMANCE PREVIOUS TEST EXPERIENCE PROVIDES ADDITIONAL ASSURAN

3. SIMPLIFICATION OF TESTING -

REDUCED NUMBER OF TEST STEPS

- PREVIOUS TEST EXPERIENCE JUSTIFIES REDUCED TEST STEP

- IMPROVED ANALYTICAL MODELS PROVIDE IMPROVED PREDICTION OF SYSTEM PERFORMANCE RELAXATION OF TEST CRITERIA

- ANALYSIS WITH IMPROVED MODELS ASSURES ACCEPTABLE SYSTEM PERFORMANCE WITH RELAXED CRITERIA

- PREVIOUS TEST EXPERIENCE INDICATES OVERCONSERVATIVE CRITERIA

4. REPLACEMENT OF TESTING WITH DATA FROM OTHER TESTS I

MULTIPLE TESTING NOT REQUIRED WITH ENHANCED DATA ACQUISITION SYSTEM j -

PRE-0P TESTING (E.G., BENCH CALIBRATION OF CONTROLLERS).

4 l 5. DELETE SELECTED REG GUIDE ~1.68 TESTING -

i 1 - PREVIOUS EXTENSIVE TESTING JUSTIFIES TEST DELETION

2.1.4 EXAMPLES TEST SIMPLIFICATION OR ELIMINATION TECHNOLOGICAL I MROVED EXTENSIVE ENHANCED EXPERIENCED THOROUGH ENHANCED INCREASED VOLUTION ANALYTICAL QA/QC BWR TEST TRAINING & TRAINED PRE-0P DATA ACQ. TECH SPEC CATEGORY METHOOS PROCEDURES EXPERIENCE PROGRAMS STAFF TESTING SYSTEMS SUR. REQTS

1. REPLACE ST-19 W/ X X X X TECH SPEC SURV.

i

2. DELETE ALF TEST X X X

3. SIWLIFY ST-29 X X X X X (RECIRC) TESTING

4. REPLACE ST-27 TT X X X X X X W/ OTHER DATA S. DELETE ST-21 CORE X X X X X ~

X X POWER-VOID MODE -

2.1.4 CATEGORY 1 EXAMPLE -

REP, LACE TESTING WITH TECH SPEC SURVEILLANCE

TEST NUMBER 19 - CORE PERFORMANCE OBJECTIVE: TO EVALUATE THE CORE THERMAL POWER AND FLOW, TO EVALUATE CORE THERMAL MARGIN, AND FEEDBACK DATA INTO THE DESIGN PROCESS REQUIREMENTS:

DEMONSTRATE COMPLIANCE WITH TECHNICAL .

, SPECIFICATION THERMAL LIMITS 0

TECHNICAL SPECIFICATIONS DEFINE MONITORING REQUIREMEN AT LEAST ONCE PER 24 HOURS WITHIN 12 HOURS AFTER 15% THERMAL POWER INCREASE 0

OPERATING PLANT DATABASE ADEQUATELY CONFIRMS BASIC D ,

CHARACTERISTICS 0

EXPERIENCED STAFF WILL BE AVAILABLE TO ASSIST OPERATIONS PERSONNEL IN IMPLEMENTATION OF SURVEILLANCE PROCEDURES 0 REG GUIDE 1,68 OBJECTIVES MET 0

EXTENSIVE GAMMA SCAN MEASUREMENTS HAVE QUALIFIED DESIGN PROCESS HISTORIC GROWTH OF TECH SPEC REQUIREMENTS JUSTIFY

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REPLACING TEST WITH TECH SPEC SURVEILLANCE EXTENSIVE TESTING AND OPERATING PLANT DATABASE JUSTIFIES ELIMINATING FORMAL FEEDBACK OF DATA c.- - - - --- - _ . , - - - . - . - .- - , . - _ _

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2.1.4 CATEGORY 2 EXAMPLE DELETE SELECTED NON-ESSENTIAL TESTS AUTO LOAD FOLLOWING (ALF) TESTING ,

OBJECTIVE: TO DEMONSTRATE THE PRESSURE CONTROL SYSTEM AND RECIRCULATION FLOW CONTROL SYSTEM PERFORMANCE ,

DURING THE AUTO LOAD FOLLOWING MODE OF OPERATION

. REQUIREMENTS: DEMONSTRATE NON DIVERGENT SYSTEM RESPONSE TO STEP CHANGES IN SYSTEM INPUTS WHILE OPERATING i

IN THE ALF MODE 0 AUTO LOAD FOLLOWING MODE.IS NOT A SAFETY RELATED SYSTEM 0 CONTROL MODE WILL BE DISABLED i -

ALL OPERATING BWR'S OPERATE WITH ALF MODE' DISABLED -

O IN ACCORDANCE WITH REG GUIDE 1.68 4

I 1

NON-ESSENTIAL SYSTEM / COMPONENT j TESTING CAN BE DELETED I

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2.1.4 CATEGORY 3 EXAMPLE - -

I SIMPLIFY TESTING TEST NUMBER 29 - RECIRCULATION FLOW CONTROL SYSTEM OBJECTIVE:

DEMONSTRATE ACCEPTABLE RECIRCULATION FLOW CONTROL SYSTEM PERFORMANCE FOR DESIRED MODES OF OPERATION REQUIREMENTS:

DEMONSTRATE THAT THE TRANSIENT RESPONSE OF ANY SYSTEM RELATED VARIABLE TO ANY TEST INPUT DOE NOT DIVERGE o

IMPROVED ANALYTICAL MODELS PROVIDE MORE ACCURATE PREDICTIONS OF SYSTEM BEHAVIOR o

EXTENSIVE BWR TEST EXPERIENCE PROVIDES BEST ESTIMATES OF CONTROLLER SETTINGS -.I o

BENCH CALIBRATION OF CONTROLLERS PERFORMED DURING PRE-0P PHASE OF TESTING o

ENHANCED DATA ACQUISITION SYSTEM PROVIDES SUBSTANTIAL INFORMATION FROM EACH TEST _

o EXPERIENCED GE CONTROL SYSTEMS ENGINEER WILL BE ON SITE

, TO FINE TUNE SYSTEM o KWU EXPERIENCE QUALIFIES APPROACH t

o REGGUfDE1.68OBJECTIVESMET NUMBER OF FLOW CONDITIONS AND TEST

• INPUTS CAN BE REDUCED BECAUSE OF EXTENSIVE BWR TESTING AND PRE-0P CALIBRATION

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2.1.4 CATEGORY 4 EXAMPLE i

REPLACE TEST WITH DATA FROM OTHER TEST

} TEST NUMBER 27 - TURBINE TRIP AT TEST CONDITION #3

OBJECTIVE

DEMONSTRATE THE RESPONSE OF THE REACTOR AND CON l SYSTEMS TO PROTECTIVE TRIPS IN THE TURBINE / GENER REQUIREMENT:

DEMONSTRATE ACCEPTABLE PERFORMANCE OF THE BYPASS VALVES, FEEDWATER SYSTEM RESPONSE (WATER' LEVEL j

CONTROL), RECIRCULATION PUMP C0ASTDOWN AND HEAT FLUX / PRESSURE PREDICTIONS DURING A TURBINE TRIP o

TURBINE TRIP (ST-27) PERFORMED INSTEAD OF LOAD REJECT LOW POWER TO DEMONSTRATE BYPASS. VALVE PERFORMANCE o

FEEDWATERCONTROLSYSTEMISTUNEDINST-23A/LEVELRESPONSE i

CAN BE CHECKED DURING FULL POWER LOAD REJECTION TEST -

o C0AST DOWN.0F RECIRCULATION PUMPS CAN BE CHECKED DU POWER LOAD REJECTION TEST o

ENHANCED DATA ACQUISITION SYSTEMS ALLOW SUBSTANTIAL A 0F DATA TO BE OBTAINED FROM FULL POWER LOAD REJECTION TEST o

IMPROVED ANALYTICAL MODELS AND QUALIFICATION TO PLANT ASSURES ACCURATE PREDICTION OF SYSTEM RESPONSE l

0 OTHER SYSTEM RESPONSES THOROUGHLY CHECKED DURING PRE-0 i

OTHER TESTS (E.G., SCRAM OPERATION, S/RVS, TSV CLOSURE TIME) o EXTENSIVE OPERATOR / STAFF TRAINING FOR PLANNED SCRAMS ACHIEVED ON BWR SIMULATOR o REG GUIDE 1,68 OBJECTIVES MET

}

i IMPROVED MODELS, TESTING EXPERIENCE, SIMULATOR TRAINING AND ENHANCED DATA ACQUISITION SYSTEMS JUSTIFY REPLACEMENT '-

WITH DATA FROM OTHER PLANNED TEST i

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1 2.1.4 CATEGORY 5 EXAMPLE - ~

'. DELETE TEST TEST NUMBER 21 - CORE POWER-VOID MODE RESPONSE OBJECTIVE: MEASURE THE STABILITY OF THE CORE POWER-VOID DY RESPONSE AND DEMONSTRATE ACCEPTABLE BEHAVIOR TO LIM REQUIREMENTS: .

DEMONSTRATE THAT THE RESPONSE OF SYSTEM VARIABLE TO A CONTROL ROD MOVEMENT DOES NOT DIVERGE

~

o MEASUREMENT OF SYSTEM STABILITY TO CONTROL R0D MOVEMEN DEVELOPED FOR SMALL REACTOR CORES

' CORE WIDE DISTURBANCE PROVIDES MORE MEANINGFUL DAT LARGE CORES (E.G., PRESSURE DISTURBANCES FROM TUNING OF STEAM BYPASS AND PRESSURE CONTROL SYSTEM)

NORMAL OBSERVATIONS OF OPERATIONAL POWER MANEUVERS  :

PROVIDES SUFFICIENT DATA o

EXTENSIVE SPECIAL TESTS HAVE BEEN PERFORMED TO DEMONSTRA STABILITY CHARACTERISTICS OF BWR'S PEACH BOTTOM 2, 1978 VERMONT YANKEE, 1981

- CAORS0, 1983 LEIBSTADT, 1984 BROWNS FERRY, SINGLE LOOP OPERATION, 1985 o

SPECIAL TESTS USED ENHANCED DATA ACQUISITION SYSTEMS TO PROVIDE MAXIMUM INFORMATION o

NEW STABILITY LICENSING BASIS NO LONGER REQUIRES TEST SIL-380 RECOMMENDS MONITORING 0F SYSTEM BEHAVIOR MONITORING CAN BE PERFORMED DURING TEST CONDITION 5 IMPROVED ANALYTICAL MODELS DEMONSTRATE FUEL LIMITS ARE NOT EXCEEDED MORE COMPREHENSIVE TECHNICAL SPECIFICATIONS DETAILED PROTOTYPE TESTING JUSTIFIES TEST DELETION

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2.2 TECHNICAL SPECIFICATION EXCEPTIONS 2.

2.1 BACKGROUND

0 TECHNICAL SPECIFICATION REQUIREMENTS BASED ON FULL PO OPERATION WITH EXPOSED FUEL 0

TECHNICAL JUSTIFICATION EXISTS FOR EXCEPTIONS DURIN POWER PHASE (5% POWER OR LESS) 0F POWER ASCENSION LOW POWER LEVEL / LOW EXPOSURE FUEL YIELD LOW D LEVELS REDUCED CORE COOLING REQUIREMENTS ,

LOW POWER LEVELS RESULT IN LOW FISSION PRODUC RADI0 ACTIVITY RELEASE RATES WELL BELOW NRC SOUR TERMS o

EXAMPLE OF TECHNICAL SPECIFICATION EXCEPTIONS ECCS AVAILABILITY PUBLIC HEALTH AND SAFETY IS NOT IMPACTED WITH TECH SPEC EXCEPTIONS

'.l '.

• e 2.2.2 ECCS AVAILABILITY 0

TEMPORARY TECH SPEC EXCEPTION FOR ECCS SYSTEMS DURING LOW POWER OPERATION AND SHUTDOWN OBJECTIVE OF TECil SPEC ASSURE SUFFICIENT ECCS SYSTEMS AVAILABLE TO MITIGATE DESIGN BASIS TRANSIENTS AND ACCIDENTS MINIMUM SYSTEM REQUIREMENTS:

BELOW 5% POWER, ECCS SYSTEMS CAN HAVE RELAXED TECHNICAL SPECIFICATIONS BASIS FOR EXCEPTION:

1. LOCA CONSIDERATIONS:

SHOREHAM TESTIMONY INDICATES THAT BELOW 5% POWER, PCT IS LESS THAN 2200 *F FOR 1 HOUR ASSUMING NO WATER INJECTION SYSTEMS AVAILABLE REALISTIC ANALYSIS SHOWS 2-3 HOURS 1 WATER INJECTION SYSTEM CAN MAINTAIN PCT NEAR NORMAL OPERATING TEMPERATURES SIMILAR RESULTS EXPECTED FOR HOPE CREEK

2. TR'ANSIENT CONSIDERATIONS:

LIMITING EVENT - LOSS OF FEEDWATER FLOW AND/0R LOSS OF 0FFSITE POWER l

- ASSUME HPCI/RCIC NOT AVAILABLE ANTICIPATED BOILOFF RATE DUE TO LOW DECAY HEAT SIGNIFICANTLY LESS THAN DURING LOCA

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