ML20247C304
| ML20247C304 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/18/1989 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19302D914 | List: |
| References | |
| GL-88-16, NLR-N89055, NUDOCS 8905240391 | |
| Download: ML20247C304 (14) | |
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Public Service Electric and Gas Company Ct nley LaBruna Public Service Electric and Gas Company P.O. Box 236. Hancocks Bridge, NJ 08038 609-339-4800 vice emoenb Nuclear Operabons May 18, 1989 NLR-N89055 United States Nucleai 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 10CFR50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits a Request For Amendment to Facility Operating License NPF-57 for Hope Creek Generating Station (HCGS). This amendment request revises fuel ^ cycle specific Technical Specifications contained in sections 3/4.2, B3/4.2, 5.3.1 and 5.3.2. It also adds a new definition, CORE DESIGN AND OPERATING LIMITS REPORT (the Report), and a new administrative requirement (6.9.1.9) to submit the Report to the NRC upon its issuance. Attachment 2 contains PSE&G's proposed revisions to the Technical Specifications.
As discussed in Attachment 1, these proposed changes are based on Generic Letter 88-16, in which the NRC provides guidance to licensees regarding the removal of cycle specific operating limits from the individual plant Technical Specifications and their inclusion in a formal operating limits report. In order to retain the same level of assurance that the plant is operated within theLeora operating limits, the Report is controlled by the
,LTechnical-Specifications. PSE&G has determined that the proposed n ghanges"do noti involve a Significant Hazards Consideration.
, I'sihee'thesproposed_ change involves the administrative aspects of coh!6 Assign fand operating . limits, and affects neither the i
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$"c, a.;g ' limits, "PSE(G sbelieves that the' proposed change may be processed l g as a Category 2,, Item 3. amendment request.
I l '@ Generic Letter 8'8-1/i? recommended that the guidance contained in gg its enclosure be f611 owed in order.to assure expeditious NRC eq review of amendment reque,sts. This proposed change is consistent l N with the Generic Letter's~ guidance, with the possible exception l g of the revisions to Technical Specification sections 5.3.1 and
' caa 5.3.2. As discussed in Attachment"1, PSE&G believes that these revisions are consistent with' the intent of the Generic Letter.
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Document Control Desk 5-18-89 NLR-N89055 However, if this aspect of the proposed amendment would cause NRC review to be delayed, please advise us as soon as possible, so that we may respond to any requests for additional information on an expedited basis. Per recent discussions with the Hope Creek NRC Licensing Project Manager, Mr. Clyde Shiraki, PSE&G is requesting approval of this License Change Request in support of the second refueling outage, currently scheduled to begin on September 15, 1989.
Attachment 3 consists of the Report, which contains any information that is being removed by this amendment request. In addition, the Report contains a discussion of the core design requirements, more detailed information regarding the bases and applications of the core operating limits, and description of the fuel bundles and control rods. Appendix A of the Report contains the Technical Specification Limiting Conditions for Operation (LCOs), with the actual values of the cycle specific limits included. Please note that, as indicated by the enclosed affidavit, Appendix B of the Report contains General Electric proprietary information regarding fuel bundle descriptions and should therefore be withheld from public disclosure and should not be reproduced, pursuant to 10CFR2.790.
In accordance with the requirements of 10CFR50.4 (b) (ii) , this submittal includes one (1) signed original, including affidavit, and thirty-seven (37) copies. In accordance with 10CFR50. 91 (b) (1) , a copy of this request has been sent to the State of New Jersey as indicated below. Upon NRC approval, please issue a license amendment which will be effective upon issuance and must be implemented based on the Hope Creek opa ating schedule at the time of issuance (e.g., end of Cycle 2). This latitude provides the necessary time to implement appropriate revisions to the Report and affected procedures.
Should you have any questions or comments on this transmittal, do 1ot hesitate to contact us. I Sincerely,
/ ,
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l f f ) ' / /tC f W Affidavits (2)
Attachments (3) l
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Document Control Desk 5-18-89 NLR-N89055 C: Mr. C. Y. Shiraki USNRC Licensing Project Manager Mr. G. W. Meyer USNRC Senior Resident Inspector Mr. W. T. Russell, Administrator USNRC Region 1 Mr. K. Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, New Jersey 08625 l
7 s s Ref: NLR-N89055 HCGS LCR 89-12 STATE OF NEW JERSEY )
) SS.
COUNTY OF SALEM )
S. 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 May 18, 1989 , concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.
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h&W Subscribed and Sworn to efore me this M day of , 1989
[otaryPuhicofNewJersey LARAINE Y. BEARD Notary Public of New jeney My Commission Expires May 1,1991 My Commission expires on
l General Electric Company AFFIDAVIT i
l I, Janice S. Charnley, being duly sworn, depose and state as follows: l
- 1. I am Manager, Fuel Licensing, General Electric Company, and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be with- i held and have been authorized to apply for its withholding.
- 2. The information soucht to be withheld is the attached Fuel Bundle Description Report for Public Service Elec. and Gas Company's Hope Creek Generating Station. j
- 3. In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section 757. This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of in-formation which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it... A substantial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring information.. . Some factors to be considered in determining whether given information is one's trade secret are: (1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of mea-sures taken by him to guard the secrecy of the information; (4) the value of the in-formation to him and to his competitors;(5) the amount of effort or money ex-panded by him in developing the information; (6) the ease or difficulty with the which the information could be properly acquired or duplicated by others."
- 4. Some examples of categories of information which fit into the definition of proprietary infor-mation are:
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- a. Information that disclosed a process, method or apparatus where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies;
- b. Information consisting of supporting data and analyses, including test data, relative to a process, method or apparatus, the application of which provide a competitive economic advantage, e.g., by optimization or improved marketability;
- c. Information which if used by a competitor, would reduce his expenditure of resources er improve his competitive position in the design, manufacture, shipment, installation, as- f surance of quality or licensing of a similar product; 1
- d. Information which reveals cost or price information, production capacities, budget levels j or commercial strategies of General Electric, its customers or suppliers, l
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- e. Information which reveals aspects of past, present or future General Electric cus- I tomer-funded development plans and programs of potential commercial value to General Electric;
- f. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection;
- g. Information which General Electric must treat as proprietary according to agreements with other parties.
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- 5. Initial approval of proprietary treatment of a document is typically made by the Subsection i manager of the originating component, who is most likely to be acquainted with the value i and sensitivity of the information in relation to industry knowledge. Access to such documents within the Company is limited on a "ned to know" basis and such documents are clearly identified as proprietary.
- 6. The procedure for approval of external release of such a document typically requires review by the Subsection Manager, Project manager, Principal Scientist or other equivalent author-ity, by the Subsection Manager of the cognizant Marketing function (or delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above. Disclo-sures outside General Electric are generally limited to regulatory bodies, customers and po-tential customers and their agents, suppliers and licensees then only with appropriate protec-tion by applicable regulatory provisions or proprietary agreements.
- 7. The document mentioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found to contain information which is propri-etary and which is customarily held in confidence by General Electric.
- 8. The document mentioned in paragraph 2 above is classified as proprietary because it contains details concerning current General Electric fuel designs which were developed at considerable expense to General Electric which are not available to other parties.
- 9. The information to the best of my knowledge and belief has consistently been held in confi-dence by the General Electric Company, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties have been made pursuant to regulatory provisions of proprietary agreements which provide for maintenance of the infor-mation in confidence.
- 10. Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of the Ge.neral Electric Company and deprive or reduce the availability of profit making opportunities because it would provide other parties, including competitors, with valuable information regarding current General Eleectric fuel designs which were obtained at considerable cost to the General Electric Company. The man-power, computer and manufacturing resources expended by General Electric to develop the current fuel designs are valued at approximately $8 million. In addition, the development of individual bundle and lattice designs required over 120 man-hours and approximately $20,000 in computer resources.
Affidavit Page 2
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STATE OF CALIFORNIA . )
COUNTY OF SANTA CLARA ) ss:
Janice S. Charnley, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.
- Executed at San Jose, California, this // ay of 1989.'
.. .. Ms e S. Charnlef neral Electric Company Subscribed and sworn before me this /f dayof M 1989.
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k ' !' Y Notary Public - California Santa Clara County
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'i f,e MARY L KENDALL Notary Put6>CeBomia
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Affidavit Page 3
.. - 4 ATTACHMENT 1 PROPOSED CHANGE TO THE TECHNICAL SPECIFICATIONS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 NLR-N89055 DOCKET NO. 50-354 LCR 89-12 I. DESCRIPTION OF THE PROPOSED CHANGES The purpose of this License Change Request (LCR) is to remove all cycle specific core operating data from the Technical Specifications of the Hope Creek Generating Station. The Technical Specification Limiting conditions for Operation (LCOs) for the specific core operating limits will still exist, but the actual values of the limits will appear under separate cover, in the CORE DESIGN AND OPERATING LIMITS REPORT generated by PSE&G.
This document will be submitted upon issuance to the NRC and will be used by Hope Creek Operations throughout the applicable fuel cycle. The proposed changes are based on the guidance of Generic Letter 88-16, " Removal of Cycle-Specific Parameter Limits from Technical Specifications".
Included in this LCR are proposed changes to Technical Specifications 5.3.1, " Fuel Assemblies" and 5.3.2, " Control Rod Assemblies". Although Generic Letter 88-16 does not contain explicit guidance with respect to changes to Chapter 5 Technical Specifications, PSE&G believes that these proposed changes are consistent with the intent of the Generic Letter. As discussed below, the fuel and control rod assemblies will be described in the CORE DESIGN AND OPERATING LIMITS REPORT and will be evaluated in accordance with NRC approved methodologies.
The specific proposed changes are as follows:
Index. The index will be modified to include a new entry in the DEFINITION section for the definition of the cycle specific CORE DESIGN AND OPERATING LIMITS REPORT. Entries for figures which show core operating limits will be deleted. An entry for the new REPORTING REQUIREMENTS associated with this report will be added. Renumbering of the items in the Index will also be done as required.
1.0 Definitions. A new definition will be added to define CORE DESIGN AND OPERATING LIMITS REPORT which will be generated each cycle and referenced within the Technical Specifications. Subsequent definitions will be renumbered as required.
l 3/4.2.1 Average Planar Linear Heat Generation Rate. The LCO l and surveillance requirements will be modified to remove all cycle specific core operating limits and instead will reference the CORE DESIGN AND OPERATING LIMITS REPORT.
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l 3/4.2.3 Minimum Critical Power Ratio. The LCO and surveillance requirements will be modified to remove all cycle specific core operating limits and instead will reference the CORE DESIGN AND OPERATING LIMITS REPORT.
3/4.2.4 Linear Heat Generation Rate. The LCO and surveillance requirements will be modified to remove all i cycle specific core operating limits and instead will i reference the CORE DESIGN AND OPERATING LIMITS REPORT.
B3/4.2.1 and B3/4.2.3. The Bases for these sections will be revised to remove references to core operating limit parameters which may change on a cycle specific basis or fuel limits which may form the input to another core operating limit analysis which has been previously approved by the NRC. Any text removed from this section will appear in the CORE DESIGN AND OPERATING LIMITS REPORT.
5.3.1 Fuel Assemblies. The text will be modified to refer to the CORE DESIGN AND OPERATING LIMITS REPORT for more detailed fuel design information.
5.3.2 Control Rod Assemblies. The text will be modified to refer to the CORE DESIGN AND OPERATING LIMITS REPORT for more detailed control rod assembly design information.
6.9.1 Routine Reports. A new reporting requirement will be added to this section which will require that the CORE DESIGN AND OPERATING LIMITS REPORT be provided upon issuance to the NRC Document Control Desk, with copies to the Administrator, Region 1 and Resident Inspector.
II. REASON FOR THE PROPOSED CHANGES The major advantage of this amendment request is that routine changes to the thermal limits on the core operations can be made, using NRC approved methodology, without Technical Specification amendments. The current Technical Specifications require that i the operating limits be submitted to the NRC in order to secure l their approval prior to restart. This imposes a schedular constraint on the reload process by requiring finalization of the operating limits well in advance of restart, to allow sufficient time for NRC review. This proposed change would remove an undue l burden on NRC and PSE&G resources, as well as provide some l schedular flexibility in the fuel cycle, by requiring only that the CORE DESIGN AND OPERATING LIMITS REPORT be sent to the NRC upon issuance (i.e., prior to restart). Changes to the Report may be made without prior NRC approval if they involve neither an Unreviewed Safety Question per 10CFR50.59 nor a change to the Technical Specifications. Therefore, mid-cycle changes in core operating limits would also be made possible without the need for Technical Specification amendments from the NRC.
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III. JUSTIFICATION FOR THE PROPOSED CHANGES The NRC has encouraged licensees to propose Technical Specification changes that are consistent with the guidance provided in the enclosure to Generic Letter 88-16. With the possible exception of the proposed revisions to Sections 5.3.1 and 5.3.2, this amendment request conforms to that guidance.
Note that while Generic Letter 88-16 does not explicitly discuss changes to the BASES section, it is PSE&G's interpretation that such changes fall within the scope of " individual specifications" to which the Generic Letter refers.
In addition, it has been indicated that conforming amendments would be expeditiously reviewed by the NRC Licensing Project Manager for the facility. Although PSE&G believes that the proposed changes to Section 5.3.1 and 5.3.2 are consistent with the intent of Generic Letter 88-16, we request that the NRC notify PSE&G if these changes are deemed to be outside the scope of the Generic Letter, in order to assure expeditious processing of any requests for additional information.
The current core operating limit Technical Specifications assure that the cycle specific parameters are maintained within acceptable limits as defined by the safety analyses. The corresponding BASES sections describe the regulatory and calculational bases of the core operating limits. Consistent with Generic Letter 88-16, this amendment request proposes removal of cycle specific parameters and cycle specific aspects of their associated BASES sections. Since the information being removed from the Technical Specification in included in the CORE DESIGN AND OPERATING LIMITS REPORT, whicn is referenced by the Technical Specifications, implementation of this amendment request will not reduce the level of assurance provided by the existing Technical Specifications.
Section 5.3.1 currently contains a description of the configuration of the fuel assemblies presently in use at HCGS.
The proposed changes to section 5.3.1 will remove some specific fuel assembly design features, thereby allowing fuel assembly changes without prior NRC approval. The CORE DESIGN AND OPERATING LIMITS REPORT will contain more detailed information regarding fuel assembly design, and will be referenced by Technical Specification 5.3.1. Proposed specification 6.9.1.9 will require PSE&G to use core operating limits as determined by NRC-approved General Electric Standard Application For Reactor Fuel (GESTAR II). Since NRC approval of GESTAR II is based on review of the specific fuel assembly designs described therein, PSE&G will still be required to use fuel assemblies that have been pre-approved by the NRC. Utilization of analytical methodologies and/or fuel designs that are not within the scope of the most recently approved version of GESTAR II will require an amendment request. Therefore, PSE&G believes that the proposed revision to section 5.3.1 is administrative in nature and is consistent with the intent of Generic Letter 88-16.
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The proposed changes to section 5.3.2, " Control Rod Assemblies,"
are analagous to the proposed changes to section 5.3.1 discussed above. PSE&G intends to replace some of the existing HCGS control blades with compatible hafnium tipped control blades supplied by ABB-ATOM during the second refueling outage. These control blades have been generically approved for use by the NRC via references 1 and 2.
Pending NRC approval of this LCR, a plant specific evaluation of the new control blades will be completed and documented under the provisions of 10CFR50.59. This evaluation will address the compatibility of the new control rod blades with the existing blades. ABB-ATOM control blades have been successfully installed under the provisions of 10CFR50.59 at other U.S. BWRs (e.g.,
LaSalle).
In summary, proposed specification 6.9.1.9 will require that the operating limits be determined each cycle using NRC approved methodology. The individual specifications in section 3/4 will retain the ACTION statements required in the event that any of the subject limits are exceeded. Performance of the surveillance to verify that the plant is operated within the subject limits will not be affected. Therefore, this amendment request is administrative in nature.
IV. SIGNIFICANT HAZARDS CONSIDERATION EVALUATION The proposed changes to the HCGS Technical Specifications:
- 1. Do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change will not affect the way that accidents will be evaluated. The accident analyses, and the associated core operating limits used as input to these analyses, will still be evaluated per General Electric Standard Application for Reactor Fuel (GESTAR II), which ,
uses methods recognized and approved by the NRC. Operation of the core will still be governed by the Limiting conditions for Operation (LCOs), the requirements of which remain unchanged, but the limiting parameters for core operation in these LCOs will be reported in a separate document (CORE DESIGN AND OPERATING LIMITS REPORT).
I Administrative 1y controlling the limiting parameters in a separate document will not increase the probability of an accident occurring, nor increase the potential consequences of an accident, because the evaluation method is the same as that previously approved by the NRC.
i The proposed revision to section 5.3.1 will enable HCGS to l change fuel assemblies without a license amendment. The core operating limits will still be determined based on the Page 4 of 6
1 NRC approved methodology of GESTAR II. Since NRC approval of GESTAR II is predicated on review of specific fuel assembly designs, HCGS will still be using NRC approved fuel designs.
The proposed revision to Section 5.3.2 will allow HCGS.to use ABB-ATOM hafnium tipped control blades as replacements for the existing General Electric control blades. These control blades have been previously approved by the NRC on a generic basis. The 10CFR50.59 evaluation that will be performed prior to control blade replacement will address any plant specific concerns and will assure that the probability or consequences of an accident will not be increased. The requirements of specificggion 3/4.1.3 will continue to assure that the control rods are OPERABLE, with acceptable scram times. The NRC approved ABB-ATOM methodology will be applied specifically to the HCGS.
There' fore, PSE&G has concluded that this amendment request does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Do not create the possibility of a new or different kind of accident from any accident previously evaluated.
Removing cycle specific Technical Specifications in favor of placing them in the CORE DESIGN AND OPERATING LIMITS REPORT and referencing them in the Technical Specifications does not involve any physical plant modifications per se, nor does it introduce any new operational configurations. It does, however, offer the flexibility to refuel and restart and perform certain core design changes without cycle-specific Technical Specification amendments. These activities are still controlled by the Technical Specifications via reference to the CORE DESIGN AND OPERATING LIMITS REPORT. NRC approved methodologies are :
still used to implement the changes, and plant specific evaluations pursuant to 10CFR50.59 will be performed as required.
Therefore, PSE&G has concluded that this amendment request does not introduce any new or different kind of accident from those previously evaluated.
- 3. Do not involve a significant reduction in a margin of safety.
The development of core operating limits will still be done using the methods of GESTAR II, which have been previously approved by the NRC. These methods will set the limiting parameters for core operation such that the Safety Limits as defined by the Technical Specifications and UFSAR safety analyses are not challenged. This proposed amendment will change the mechanism which reports these core operating Page 5 of 6 l
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limits. The methodology for establishing the core operating limits has not been changed.
The removal of specific design information from sections 5.3.1 and 5.3.2 of the Technical Specifications does not result in a reduction in the margin of safety since NRC approved methodologies are still applied to reactor core design, as described in the CORE DESIGN AND OPERATING LIMITS REPORT. Design changes are still subject to the provisions of 10CFR50.59.
Therefore, this amendment request does not involve a significant reduction in a margin of safety as defined in the basis for any Technical Specification.
V. CONCLUSION As discussed above, PSE&G has concluded that the proposed changes to the HCGS Technical Specifications do not it'.volve a significant hazards consideration since the changes: (i) do not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) do not create the possibility of a new or different kind of accident from any previously evaluated, and (iii) do not involve a significant reduction in a margin of safety.
VI. REFERENCES
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