ML20246G945

Forwards Mod to 890518 Application for Amend to License NPF-57,removing cycle-specific Operating Limits from Tech Specs & Including Values in Core Operating Limits Rept,Per Generic Ltr 88-16

ML20246G945
Person / Time
Site:	Hope Creek
Issue date:	08/21/1989
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20246G952	List: ML20246G945 ML20246H164
References
GL-88-16, NLR-N89160, NUDOCS 8909010049
Download: ML20246G945 (7)

Text

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Pubhe '3ervice Dectnc and Gas

. Company Steven E. Mittenberger - Public Service Electric and Gas Company P.O. Box 236. Hancocks Bridge, NJ C8038 609-339-4199 w.e r9emaem and chmt Nument Oficer August 21, 1989 NLR-N89160

Reference:

LCR 89-12, Rev.1 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

REVISED REQUEST FOR AMENDMENT l FACILITY OPERATING LICENSE NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 In a letter dated May 18, 1989, Public Service Electric and Gas Company (PSE&G) requested an amendment to Facility Operating License No. NPF-57. Technical Specifications (TS) Sections 3/4.2, B3/4.2, 5.3.1 and 5.3.2. The amendment request (LCR 89-12) was based upon guidance for removal of fuel cycle-specific operating limits from the TS as provided by NRC Generic Letter 88-16. Since the intent of the Generic Letter was to alleviate the burden on NRC and licensee resources associated with the processing of changes to cycle specific parameter limits that are developed according to NRC approved methodologies, PSE&G included, in that request, several changes to TS Der 2in Sections 5.3.1 and 5.3.2 which contain constraints on core 3isign configuration.

In subsequent discussions, NRC staff indicated that only changes directly covered by Generic Letter 88-16 should be in the change request dealing with removal of cycle-specific operating limits from the POWER DISTRIBUTION section of TS and that all other TS modifications should be submitted separately. Those portions of LCR 89-12 to which the NRC staff determined the Generic Letter does not directly apply are being submitted under a separate A go request. Tl fl The modifications in this request (LCR 89-12, Rev. 1) encompass the changes previously requested in LCR 89-12 and do not involve any additional technical issues. Our previously provided supporting information, analyses, and basis for a no significant hazards consideration determination remain applicable. Based upon the above, PSE&G believes that this revision to our amendment request, LCR 89-12, should not require additional public notice, s909010049 890B21 PDR ADOCK 050003S4

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Document Control Desk 08-21-89 NLR-N89160 Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but j implementable within sixty days to provide sufficient time for any associated procedural modifications.

Pursuant to the requirements of 10CFR50.91(b) (1), PSE&G has provided a copy of this amendment request to the State of New Jersey and in accordance with 10CFR50.4 (b) (2) (ii) , this submittal l includes one (1) signed original and thirty-seven (37) copies.

Should you have any questions regarding this request, ve will be pleased to discuss them with you.

Sincerely,

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Attachments l Affidavit l

C Mr. W. T. Russell, Administrator USNRC Region I Mr. C. Y. Shiraki USNRC Licensing Project Manager Mr. G. W. Meyer USNRC Senior Resident Inspector Mr. K. Tosch, Chief, Bureau of Nuclear Engineering New Jersey Department of Environmental Protection l

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' Steven E. Miltenberger, being duly sworn according to law deposes

'T and says:

l I am Vice President and Chief Nuclear Officer of Public Service l 1

Electric.and Gas Company, and as such, I find-the matters set y forth.in our letter.' dated August 21, 1989 ., concerning the Hope Creek Generating Station, are true to the best of my ,

knowledge, information and belief.

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/ j Subscribed}ndSwornto'beforeme 6 4 v # , 1989 this 1 / 57 day of J

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!!otary Public of New Jersey l i

i BLEElf N. OCNS WW NBLIC DF NEw Jggggy My Commission expires on y yCommission Empires J4 is y l

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l PROPOSED CHANGE TO THE TECHNICAL SPECIFICATIONS L BOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 LCR 89-12, REV 1 l

! - I. DESCRIPTION OF THE PROPOSED CHAWGES l This; proposed License Change Request (LCR) would remove cycle-specific core operating limits from the Hope Creek Generating Station Technical Specifications.(TS). The Limiting Conditions for Operation (LCOs) for the-specific core-operating limits will still remain in the TS, but the actual values of the limits will appaar under separate cover, in a CORE 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".

L The specific proposed changes are as follows:

Index. The index will be modified to include a new entry in the TS DEFINITION Section for the definition of the cycle-specific CORE 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 OPERATING LIMITS REPORT which will be generated each cycle and referenced within i the Technical Specifications. Subsequent definitions will be renumbered i as required.

1 3/4.2.1 Average Planar Linear Heat Generation Rate. The LCO and surveillance requirements will be modified to remove all cycle-specific core operating limits and instead will reference the CORE OPERATING LIMITS REPORT.

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 OPERATING LIMITS REPORT.

3/4.2.4 Linear Heat Generation Rate. The LCO and surveillance requirements will be modified to remove all cycle-specific core operating limits and instead will reference the CORE OPERATING LIMITS REPORT.

l l B3/4.2.1 and B3/4.2.3. The Bases for these sections will be revised to l remove references to core operating limit parameters which may change on l a cycle-specific basis or fuel limits which may form the input to another L core operating limit analysis which has been previously approved by the NRC. Any text removed from this section will appear in the CORE OPERATING LIMITS REPORT.

s 6.9.1 Routine Reports. A new reporting requirement will be added to this section which will require that the CORE 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 the operating limits be submitted to the NRC in order to secure 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 burden on NRC and PSE&G resources, as well as provide some schedular flexibility in the fuel cycle, by requiring only that the CORE 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 do not involve an Unreviewed Safety Question per 10CFR50.59 or 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.

i 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. 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.

The current core operating limit Technical Specifications assure that the l cycle-specific parameters are maintained within acceptable limits as defined I by the safety analyses. The corresponding BASES sections describe the regulatory and calculational bases of the core operating limits. Consistent j with Generic Letter 88-16, this amendment request proposes removal of cycle i specific parameters and cycle-specific aspects of their associated BASES sections. Since the information being removed from the Technical l Specifications is included in the CORE OPERATING LIMITS REPORT, which is l referenced by the Technical Specifications, implementation of this amendment  !

request will not reduce the level of assurance provided by the existing '

Technical Specifications.

1 In summary, proposed specification 6.9.1.9 will require that the operating 1 limits be determined each cycle using NRC approved methodology. The l 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 surveillance to verify that the plant is operated within the subject limits will not be affected. Therefore, this amendment request is administrative in nature. i

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IV. SIGNIFICANT HAZARDS CONSIDERATION EVALUATION The proposed changes to the HCGS Technical Specifications:

1. Do not involvt 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 OPERATING LIMITS REPORT). Administratively 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.

Therefore, PSE&G has concluded that this amendment request does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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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 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 OPERATING LIMITS REPORT. NRC approved methodologies are still used to implement the changes, and plant specific evaluations pursuant to 10CFRSO.59 will be performed as )

required.  !

Therefore, PSEGG has concluded that this amendment request does not )

introduce any new or different kind of accident from those previously i evaluated. l l

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 i UFSAR safety analyses are not challenged. This proposed amendment will change the mechanism which reports these core operating limits. The i methodology for establishing the core operating limits has not been  !

changed.

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l -o-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 l As discussed above, PSE&G has concluded that the proposed changes to the HCGS Technical Specifications do not involve a significant hazards consideration since the changes: (i) do not involve a significar.t increase in the l 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.

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