LR-N04-0554, Response to Request for Additional Information Request for Change to Technical Specifications LCR S04-06 Definition of Operable

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Response to Request for Additional Information Request for Change to Technical Specifications LCR S04-06 Definition of Operable
ML050130177
Person / Time
Site: Salem  PSEG icon.png
Issue date: 01/06/2005
From: Brothers M
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR S04-06, LR-N04-0554, TAC MC3857, TAC MC3858
Download: ML050130177 (23)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236

'JAN '0 6 2005 0 NziclearIlLC PSEG LR-N04-0554 LCR S04-06 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS LCR S04-06 DEFINITION OF OPERABLE SALEM GENERATING STATION UNIT NOS. I AND 2 DOCKET NOS. 50-272 AND 50-311 FACILITY OPERATING LICENSE NO. DPR-70 AND DPR-75 By letter dated July 23, 2004, PSEG Nuclear LLC submitted a license amendment request LCR S04-06 (LR-N04-0238, TAC #s MC3857 and MC3858), for the Salem Generating Station Units 1 and 2 requesting approval of a change to the Technical Specifications related to the definition of OPERABLE and shutdown power requirements. By letter dated November 24, 2004 the Nuclear Regulatory Commission staff requested additional information to complete their review. This letter provides our response to the requested information (Attachment 1).

Changes to the No Significant Hazards Analysis were made. A revised No Significant Hazards Analysis is provided as Attachment 2. There are no changes to the No Significant Hazards Analysis conclusions. A complete set of revised proposed changed pages is also provided as Attachment 3.

In accordance with 10CFR50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey.

If you have any questions or require additional information, please contact Mr. Courtney Smyth at (856) 339-5298.

95-2168 REV. 7/99

I Document Control Desk . JAN 0 6 2005 LR-N04-0554 I declare under penalty of perjury that the foregoing is true and correct.

Executed on Sincerely, I (bate)

A 1l Michael H. Brothers Vice President - Site Operations Attachments (3)

Document Control Desk JAN '0 6 2005 LR-N04-0554 C: Mr. S. Collins, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Collins, Project Manager - Salem & Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 08C2 Washington, DC 20555 USNRC Senior Resident Inspector - Salem (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625

Document Control Desk LR-N04-0554 LCR S04-06 REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION DEFINITION OF OPERABLE SALEM GENERATING STATION. UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By letter dated July 23, 2004, PSEG Nuclear, LLC (PSEG) submitted a request for changes to the Salem Nuclear Generating Station, Unit Nos. 1 and 2 (Salem), Technical Specifications (TSs). The proposed changes would modify the TS definition of OPERABLE, with respect to available power sources. Additionially, the proposed change would modify the TS action statements for shutdown AC and DC electrical power requirements. The NRC has been reviewing your application and has determined that the following information is required to complete our review:

1. In support of the change to the definition of OPERABLE, you state that the proposed change improves clarity, removes any potential confusion, and is consistent with the Improved Standard Technical Specifications (ISTS). Additionally, you state that the intent of your current TS 3.8.1.1 is to allow operation to be governed by the time limits of the Limiting Condition for Operation of the normal or emergency power source, rather than the corresponding action statement for each affected system or component (which would be allowed by the proposed change to the definition of OPERABLE). The proposed change to the definition of OPERABLE will affect all Technical Specifications, not just TS 3.8.1.1. Although it is not necessary to address the effect on each TS individually, the global effect this change would cause does need to be addressed.

PSEG Response:

Salem TS were revised by License Amendments 253 (Unit 1) and 234 (Unit 2) expressly to allow operation, during Mode 1 - 4, to be governed by the time limits of the Limiting Condition for Operation (LCO) of the normal or emergency power source (LCO 3.8.1.1), rather than the corresponding action statements for each affected system or component or LCO 3.0.3. The definition of OPERABLE was not changed at that time because it would have impacted the application of the definition of OPERABLE during Modes 5 & 6, which was beyond the scope of License Change Request S01-02. However, based on discussions in a conference call on November 4, 2004 we understand that, by not changing the definition of OPERABLE with License Amendments 253 and 234 an inconsistency was created between the definition of OPERABLE and LCO 3.8.1.1.

Our July 23, 2004 License Change Request (LCR) S04-06 stated the following:

"The proposed changes improve clarity of the TS and remove potential conflicting requirements. The current TS can be interpreted to require equipment supported by an inoperable AC source to also be declared inoperable, since the definition of OPERABLE in the Salem Unit I & 2 TS specifies that both 'normal and emergency 1

Document Control Desk LR-N04-0554 Attachment I LCR S04-06 power' are needed. However, TS 3.8.1.1 allows operation to continue up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for an A.C. circuit, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for 2 inoperable A.C. circuits, or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for a diesel generator before equipment supported by an inoperable AC source needs to be declared inoperable, if the redundant supported equipment is inoperable.

Specification 3.8.1.1 is intended to allow operation to be governed by the time limits of the action statement associated with the Limiting Condition for Operation (LCO) of the normal or emergency power source, rather than the corresponding action statement for each affected system or component. The proposed changes to the definition of OPERABLE are consistent with ISTS and specifies that either 'normal or emergency power' are needed. The proposed change to the definition of OPERABLE removes any potential confusion." We believed the question posed had been resolved by Amendments 253 and 234 and therefore, had not considered this change to modify the manner in which the plant is operated.

Based on our November 4, 2004 conference call, we understand that adopting the ISTS definition of OPERABLE may be considered to increase the time for commencing a shutdown from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (i.e., the difference between 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> under LCO 3.0.3 and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under LCO 3.8.1.1 Action b). This change is nonetheless considered justified since the likelihood of a Design Basis Event (DBE) combined with a Loss of Offsite Power (LOOP) during the additional 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> is so low as to be not significant.

The No Significant Hazards Consideration analysis has been revised to address this condition (See attached revised No Significant Hazards Consideration Analysis, Attachment 2).

2. Your submittal states that the LCOs for AC and DC sources and distribution during Modes 5 and 6 and during movement of irradiated fuel assemblies are modified to be consistent with the intent of the ISTS. The proposed required actions for LCO 3.8.1.2, "Electrical Power -

Shutdown," would state "With less than the above minimum required A.C. electrical power sources OPERABLE, immediately declare the affected required features inoperable, or suspend all operations involving CORE ALTERATIONS or positive reactivity changes until the minimum required A.C. electrical power sources are restored to OPERABLE status."

The ISTS include an additional requirement of suspending the movement of irradiated fuel.

Explain why this requirement has not been included in the action statement for 3.8.1.2.

PSEG Response:

ISTS include an additional requirement of suspending the movement of irradiated fuel as an option for a loss of an offsite circuit. The requirement of suspending the movement of irradiated fuel is not optional when the one required DG is inoperable.

ISTS only require one DG and one offsite circuit whereas Salem TS require one offsite circuit and two DGs. We agree that the TS should require suspending the movement of irradiated fuel, operations involving positive reactivity additions, and immediately initiate action to restore one required DG to OPERABLE status. These actions are added to the TS in the attached revised proposed changed pages. Conforming changes to the proposed TS bases are also made. The attached revised complete set of proposed changed pages to replace the corresponding pages in Attachment 2 of our July 23, 2004 License Change Request LCR S04-06.

2

Document Control Desk LR-N04-0554 Attachment I LCR S04-06

3. Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.91(a) you provided your analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92.

In support of your negative response to Question 1, you stated that the proposed changes would not modify the manner in which the plant is operated. The NRC staff believes that with less power systems required to be operable per the TSs, the manner in which the plant is operated will indeed be changed. Either provide a revised justification for this response, or explain how the proposed change will not modify the manner in which the plant is operated.

PSEG Response: - -

We agree that the proposed changes could change the manner in which the plant is operated. However, the revisions to LCO 3.8.1.2 will not result in fewer required features being available without backup power than the current specifications allow. The allowance for one EDG (or bus) to supply all required features is not operationally or safety significant since all required features will continue to have the minimum required diversity of AC power. The proposed specifications would only provide flexibility to continue refueling or resume refueling when no required features are affected by a power system inoperability. The following has been added to the attached No Significant Hazards discussion: "The allowance for one EDG to supply all required features in Modes 5 & 6 is not operationally or safety significant since all required features will continue to have required backup power. Further, no changes to the design of structures, systems, or components (SSC) are made and there are no effects on accident mitigation."

4. Your submittal states that the proposed changes are consistent with the ISTS. Currently, TS 3.8.1.2 requires two separate and independent emergency diesel generators (EDGs) to be operable while in Modes 5 and 6. This is not consistent with the ISTSs, which require one EDG to be operable in Modes 5 and 6. Provide a discussion of why the Salem TSs require more EDGs to be operable in shutdown Modes. If applicable, identify significant differences in loads supported by the different EDGs.

PSEG Response:

The Salem plants were designed with two safety trains similar to the "standard" plant in the ISTS. However, the Salem plants' safety trains are powered by three EDGs rather than the two EDGs assumed in the ISTS. Salem TS 3.8.1.2 requires two separate and independent emergency diesel generators (EDGs) to be operable while in Modes 5 and 6 to assure that backup power is available to at least one train of safety features as intended by the ISTS. Nevertheless, with proper component and bus management, for the Salem plants, it is often achievable to provide the TS required features backup power from a single EDG. Therefore, as long as backup power can be 3

. Document Control Desk LR-N04-0554 Attachment I LCR S04-06 provided to the TS required features it is reasonable to allow the movement of irradiated fuel as permitted in the proposed TS. The only significant difference in supported equipment for Modes 5 and 6 is that the "C" EDG cannot supply backup power to any Residual Heat Removal (RHR) pump.

In addition to the changes noted above in response to specific RAI questions we have identified several editorial changes to the proposed changed pages. These changes are listed below:

1. The statement of the surveillance requirements 4.8.2.2 and 4.8.2.6.1 for Salem Unit 1 have been changed to conform to the wording of the like surveillance for Salem Unit 2. The Unit 1 SR 4.8.2.2 has added "and inverters" and changed "indicated power availability" to "voltage on the bus". The Unit 1 SR 4.8.2.6.1 has changed "indicated power availability" to "voltage on the bus".
2. A period has been added to the Note for Salem Unit 2 to correct the number of the referenced surveillance requirement 4.8.1.1.2.g Since there is no change in intent, and the changes are of an editorial nature, there is no effect on the No Significant Hazards Consideration analysis. These changes are included in the attached revised set of proposed changed pages that replace the corresponding pages in Attachment 2 of our July 23, 2004 License Change Request LCR S04-06.

4

Document Control Desk LR-N04-0554 LCR S04-06

5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration PSEG Nuclear LLC (PSEG) has evaluated whether or not a significant hazards consideration is involved with the proposed changes by fodcusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment" as discussed below:
1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The likelihood of an event is not significantly increased since the proposed changes do not alter the types of equipment required to be OPERABLE to supply the minimum required diversity of AC power. Also, the probability of occurrence or the consequences for an accident is not significantly increased by the proposed changes since the minimum configuration of equipment required by individual TS will remain available. Further, the proposed changes do not alter the way any structure, system or component (SSC) functions, do not significantly modify the manner in which the plant is operated, and do not significantly alter equipment out-of-service time. The change to the difference between 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> under LCO 3.0.3 and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under LCO 3.8.1.1 Action b is not significant since the likelihood of a Design Basis Event (DBE) combined with a Loss of Offsite Power (LOOP) during the additional 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> is so low as to be not significant. The allowance for one EDG to supply all required features in Modes 5 & 6 is not operationally or safety significant since all required features will continue to have required backup power. Further, no changes to the design of structures, systems, or components (SSC) are made and there are no effects on accident mitigation.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The possibility of a new or different kind of accident from any accident or malfunction in the Salem Updated Final Safety Analysis Report (UFSAR) is not created. The allowable outage time is consistent with requirements of Improved Standard Technical Specifications and does not introduce any new or different failure from any previously evaluated or change the manner in which safety systems are operated. The associated system

Document Control Desk LR-N04-0554 LCR S04-06 and equipment configurations are no different from those previously evaluated. Therefore a different accident is not created. In addition, the proposed changes cannot initiate an accident. Further, the proposed changes do not change the design function or operation of any SSCs.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed changes continue to provide assurance that an event coincident with failure of an associated diesel generator or offsite power circuit will not result in complete loss of safety function of critical required redundant systems or equipment. In addition, the proposed changes do not change the margin of safety since no SSCs are changed. The results of accident analysis remain unchanged by the proposed.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, PSEG concludes that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

Document Control Desk LR-N04-0554 LCR S04-06 Revised set of proposed changed pages that replace the corresponding pages in Attachment 2 of our July 23, 2004 License Change Request LCR S04-06.

DEFINITIONS

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or
c. Reactor coolant system leakage through a steam generator to the secondary system.

MEMBER(S) OF THE PUBLIC 1.16 MEMBER(S) OF THE PUBLIC shall be all those persons who are not occupationally associated with the plant. This category does not include employees of PSE&G, its contractors, or vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant.

OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.17 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip setpoints, and in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent controls and Radiological Environmental Monitoring programs required by Section 6.8.4 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.9.1.7 and 6.9.1.8 respectively.

OPERABLE - OPERABILITY

$ 1.18 A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or S device to perform its specified safety function(s) are also capable of S performing their related support function(s). _

OPERATIONAL MODE - MODE 1.19 An OPERATIONAL MODE (ie., MODE) shall correspond to any one inclusive combination of core reactivity condition, power level and average reactor coolant temperature specified in Table 1.1.

SALEM - UNIT 1 1-4 Amendment No.

DEFINITIONS

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or
c. Reactor coolant system leakage through a steam generator to the secondary system.

MEMBER(S) OF THE PUBLIC 1.16 MEMBER(S) OF THE PUBLIC shall be all those persons who are not occupationally associated with the plant. This category does not include employees of PSE&G, its contractors, or vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant.

OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.17 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip setpoints, and in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent controls and Radiological Environmental Monitoring programs required by Section 6.8.4 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.9.1.7 and 6.9.1.8 respectively.

OPERABLE - OPERABILITY 1.18 A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency S electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of

, performing their related support function(s).

OPERATIONAL MODE - MODE 1.19 An OPERATIONAL MODE (ie., MODE) shall correspond to any one inclusive combination of core reactivity condition, power level and average reactor coolant temperature specified in Table 1.1.

SALEM - UNIT 2 1-4 Amendment No.

ELECTRICAL POWER SYSTEMS SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class lE distribution system (vital bus system), and
b. Two separate and independent diesel generators with:
1. Separate day tanks containing a minimum volume of 130 gallons of fuel, and
2. A common fuel storage system containing a minimum volume of 23,000 gallons of fuel, and
3. A fuel transfer pump.

APPLICABILITY: MODES 5 and 6.

SDuring movement of irradiated fuel assemblies.S ACTION:

a. With lone the above minimum required A.C. electrical power sources

<notf OPERABLE, ~immediately declare the affected required features~

anoperable, org suspend all operations involving CORE ALTERATIONS'

<movement of irradiated fuel, and) positive reactivity changes until the minimum required A.C. electrical power sources are restored to OPERABLE status.

2 b. With two of the required diesel generators not OPERABLE, suspend all

> operations involving CORE ALTERATIONS, movement of irradiated fuel, and all operations involving positive reactivity additions, and immediately initiate action to restore one required DG to OPERABLE status.

SURVEILLANCE REQUIREMENTS

NOTE----------------------------------

The following surveillances are not required to be performed to maintain operability during Modes 5 and 6. These surveillances are: 4.8.1.1.1.b, 4.8.1.1.2.d.2, 4.8.1.1.2.d.3, 4.8.1.1.2.d.4, 4.8.1.1.2.d.6, 4.8.1.1.2.d.9, 4.8.1.1.2.e, 4.8.1.1.2.f, and 4.8.1.1.2.g.

4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1, 4.8.1.1.2, 4.8.1.1.3 (except for requirement 4.8.1.1.3.a.2) and 4.8.1.1.4.

SALEM - UNIT 1 3/4 8-5c Amendment No.

ELECTRICAL POWER SYSTEMS SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system (vital bus system), and
b. Two separate and independent diesel generators with:
1. Separate day tanks containing a minimum volume of 130 gallons of fuel, and
2. A common fuel storage system containing a minimum volume of 23,000 gallons of fuel, and
3. A fuel transfer pump.

APPLICABILITY: MODES 5 and 6.

JDuring movement of irradiated fuel assemblies.t ACTION:

a. With of' the above minimum required A.C. electrical power sources OPERABLE, immediately declare the affected required features, 0 IS inoperable, ore suspend all operations involving CORE ALTERATIONS>

movement of irradiated fuel, and, positive reactivity changes until the minimum required A.C. electrical power sources are restored to OPERABLE status.

b. With two of the required diesel generators not OPERABLE, suspend all 5 operations involving CORE ALTERATIONS, movement of irradiated fuel, and all operations involving positive reactivity additions, and immediately initiate action to restore one required DG to OPERABLE status.

SURVEILLANCE REQUIREMENTS

NOTE----------------------------------

The following surveillances are not required to be performed to maintain operability during Modes 5 and 6. These surveillances are: 4.8.1.1.1.b, 4.8.1.1.2.d.2, 4.8.1.1.2.d.3, 4.8.1.1.2.d.4, 4.8.1.1.2.d.6, 4.8.1.1.2.d.9, 4.8.1.1.2.e, 4.8.1.1.2.f, and 4.8.1.1.2 ,g.

4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1, 4.8.1.1.2, 4.8.1.1.3 (except for requirement 4.8.1.1.3.a.2) and 4.8.1.1.4.

SALEM - UNIT 2 3/4 8-7a Amendment No.

ELECTRICAL POWER SYSTEMS A.C. DISTRIBUTION - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.2 As a minimum, two A.C. electrical bus trains shall be OPERABLE and energized from sources of power other than a diesel generator but aligned to an OPERABLE diesel generator with each train consisting of:

1 - 4 kvolt Vital Bus 1 - 460 volt Vital Bus and associated control centers 1 - 230 volt Vital Bus and associated control centers 1 - 115 volt Instrument Bus energized from its respective inverter connected to its respective D. C. bus train.

APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies.

ACTION:

With less than the above complement of A.C. busses and inverters OPERABLE and energized, u dte *ehiev ecedc dr suspend all operations involving CORE ALTERATIONS, positive reactivity changes, and movement of irradiated fuel assemblies until the minimum required A.C. electrical power sources are restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.8.2.2 The specified A.C. busses B shall be determined OPERABLE and energized from A.C. sources other than the diesel generators at least once per 7 days by verifying correct breaker alignment and indicated

.voitage onv~t4hejbusses.

SALEM - UNIT 1 3/4 8-7 Amendment No.

ELECTRICAL POWER SYSTEMS A.C. DISTRIBUTION - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.2 As a minimum, two A.C. electrical bus trains shall be OPERABLE and energized from sources of power other than a diesel generator but aligned to an OPERABLE diesel generator with each train consisting of:

1 - 4 kvolt Vital Bus 1 - 460 volt Vital Bus and associated control centers 1 - 230 volt Vital Bus and associated control centers 1 - 115 volt Instrument Bus energized from its respective inverter connected to its respective D. C. bus train.

APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies.

ACTION:

With less than the above complement of A.C. busses and inverters OPERABLE and energized, m ar I suspend all operations involving CORE ALTERATIONS, positive reactivity changes, and movement of irradiated fuel assemblies until the minimum required A.C. electrical power sources are restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.8.2.2 The specified A.C. busses and inverters shall be determined OPERABLE and energized from A.C. sources other than the diesel generators at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses.

SALEM - UNIT 2 3/4 8-9 Amendment No.

ELECTRICAL POWER SYSTEMS 125-VOLT D.C. DISTRIBUTION - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.4 As a minimum, the following D.C. electrical equipment and bus shall be energized and OPERABLE:

2 - 125-volt D.C. busses, and 2 - 125-volt batteries, each with at least one full capacity charger, associated with each of the above D.C. busses.

APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies.

ACTION:

With less than the above complement of D.C. equipment and busses OPERABLE, iimmediately declare the affected required features inoperable, or suspend all operations involving CORE ALTERATIONS, positive reactivity changes, and movement of irradiated fuel assemblies until the minimum required 125Volt D.C. electrical power sources are restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. busses shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated power availability.

4.8.2.4.2 The above required 125-volt batteries and chargers shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2.

SALEM - UNIT 1 3/4 8-10 Amendment No.

ELECTRICAL POWER SYSTEMS 125-VOLT D.C. DISTRIBUTION - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.4 As a minimum, the following D.C. electrical equipment and bus shall.-

be energized and OPERABLE:

2 - 125-volt D.C. busses, and 2 - 125-volt batteries, each with at least one full capacity charger, associated with each of the above D.C. busses.

APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies.

ACTION:

With less than the above complement of D.C. equipment and busses OPERABLE, Simmediately declare the affected required features inoperable, or, suspend all operations involving CORE ALTERATIONS, positive reactivity changes, and movement of irradiated fuel assemblies until the minimum required 125Volt D.C. electrical power sources are restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. busses shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and indicated power availability.

4.8.2.4.2 The above required 125-volt batteries and chargers shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2.

SALEM - UNIT 2 3/4 8-12 Amendment No.

ELECTRICAL POWER SYSTEMS 28-VOLT D.C. DISTRIBUTION - SHUTDOWN LIMITING CONDITION FOR OPERATION

-3.8.2.6 As a minimum, the following D.-C. electrical equipment and bus shall be energized and OPERABLE:

1 - 28-volt D.C. bus, and 1 - 28-volt battery and at least one full capacity charger associated with the above D.C. bus.

APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies.

ACTION:

With less than the above complement of D.C. equipment and busses OPERABLE, Simeditel delar th afectd rquiedfeatures inoperable, or suspend all operations involving CORE ALTERATIONS, positive reactivity changes, and movement or irradiated fuel assemblies until the minimum required 28Volt D.C.

electrical power sources are restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.8.2.6.1 The above required 28-volt D.C. bus shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and tvoltage on the bus.

4.8.2.6.2 The above required 28-volt batteries and charger shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.5.2..

SALEM - TTTP

-at 1- _/* B-13

'4Id U lv Amendment No.

      • *5 A Al **VDIII; V.

ZAVJ -1

ELECTRICAL POWER SYSTEMS 28-VOLT D.C. DISTRIBUTION - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.6 As a minimum, the following D. C. electrical equipment and bus shall be energized and OPERABLE:

1 - 28-volt D.C. bus, and 1 - 28-volt battery and at least one full capacity charger associated with the above D.C. bus.

APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies.

ACTION:

With less than the above complement of D.C. equipment and busses OPERABLE, declare the affected required features inoperable, ore suspend all operations involving CORE ALTERATIONS, positive reactivity changes, and movement or irradiated fuel assemblies until the minimum required 28Volt D.C.

electrical power sources are restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS

=================================================================

4.8.2.6.1 The above required 28-volt D.C. bus shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and voltage on the bus.

4.8.2.6.2 The above required 28-volt batteries and charger shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.5.2.

SALEM - UNIT 2 3/4 8-15 Amendment No.

I

Insert for Bases 3/4.8 ELECTRICAL POWER SYSTEMS page 3/4 8-2 An offsite circuit would be considered inoperable if it were not available to one required train. Although two trains are required by LCOs 3.8.2.2 and 3.8.2.4, the one train with offsite power available may be capable of supporting sufficient required features to allow continuati'o'n'-f CORE ALTERATIONS and irradiated fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's actions.

With the offsite circuit or diesel generator not available to all required trains, the option exists to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With both required diesel generators inoperable, the minimum required diversity of AC power sources is not available. Therefore, it is required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required shutdown margin or boron concentration. Suspending positive reactivity additions that could result in failure to meet the minimum shutdown margin or boron concentration limit is required to assure continued safe operation.

3/4.8 ELECTRICAL POWER SYSTEMS BASES (Continued) or components that are associated with the other train that has power, results in starting the completion times for the Action. The specified time is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE AC supplies (one offsite circuit and three DGs for Condition (a), two offsite circuits and two DGs for Condition (b), or three DGs for Condition (d)) are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required system or component's function may have been lost; however, function has not been lost. The completion time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required system or component. Additionally, the completion time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. The completion time for Condition d (loss of both offsite circuits) is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed for one train without offsite power (Action 3.8.1.1.a.2). The rationale is that Regulatory Guide 1.93 allows a completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required system or component failure exists, this assumption is not the case, and a shorter completion time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate.

The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that

1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.

The Applicability of specifications 3.8.2.2, 3.8.2.4, and 3.8.2.6 includes the movement of irradiated fuel assemblies. This will insure adequate electrical power is available for proper operation of the fuel handling building ventilation system d movement of irradiated fuel in the spent fuel pool.

The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are based upon the recommendations of Regulatory Guide 1.9, "Selection of Diesel Generator Set Capacity for Standby Power Supplies,"

March 10, 1971, and Regulatory Guide 1.108, "Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977. Regulatory Guide 1.108 criteria for determining and reporting valid tests and failures, and accelerated diesel generator testing, have been superseded by implementation of the Maintenance Rule for the diesel generators per 10CFR50.65. In addition to the Surveillance Requirements of 4.8.1.1.2, diesel preventative maintenance is performed in accordance with procedures based on manufacturer's recommendations with consideration given to operating experience.

The minimum voltage and frequency stated in the Surveillance Requirements (SR) are those necessary to ensure the Emergency Diesel Generator (EDG) can accept Design Basis Accident (DBA) loading while maintaining acceptable voltage and frequency levels. Stable operation at the nominal voltage and frequency values is also essential in establishing EDG OPERATILITY, but a time constraint is not imposed. The lack of a time constraint is based on the fact that a typical EDG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are riot dampened out by load application. In lieu of a time constraint in SALEM - UNIT 2 B 3/4 8-2 Amendment No. 239

3/4.8 ELECTRICAL POWER SYSTEMS BASES (Continued)

If at any time during these conditions a redundant required system or component subsequently becomes inoperable, this completion time begins to be tracked. Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System, or one required DG inoperable, coincident with one or more inoperable required support or supported systems or components that are associated with the other train that has power; results in starting the completion times for the Action. The specified time is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE AC supplies (one offsite circuit and three DGs for Condition (a), two offsite circuits and two DGs for Condition (b), or three DGs for Condition (d)) are adequate to supply electrical power to the onsite Class lE Distribution System. Thus, on a component basis, single failure protection for the required system or component's function may have been lost; however, function has'nbt been lost. The completion time-takes into account the component OPERABILITY of the redundant counterpart to the inoperable required system or component. Additionally, the completion time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. The completion time for Condition d (loss of both offsite circuits) is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed for one train without offsite power (Action 3.8.1.1.a.2). The rationale is that Regulatory Guide 1.93 allows a completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required system or component failure exists, this assumption is not the case, and a shorter completion time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate.

The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that 1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.

The Applicability of specifications 3.8.2.2, 3.8.2.4, and 3.8.2.6 includes the movement of irradiated fuel assemblies. This will insure adequate electrical power is available for proper operation of the fuel handling building ventilation system during movement of irradiated fuel in the spent fuel pool. Vtr4& 4 ->

The Surveillance Requiremen s trating the OPERABILITY of the diesel generators are based upon the recommendations of Regulatory Guide 1.9, "Selection of Diesel Generator Set Capacity for Standby Power Supplies,"

March 10, 1971, and Regulatory Guide 1.108, "Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977. Regulatory Guide 1.108 criteria for determining and reporting valid tests and failures, and accelerated diesel generator testing, have been superseded by implementation of the Maintenance Rule for the diesel generators per 10CFR50.65. In addition to the Surveillance Requirements of 4.8.1.1.2, diesel preventative maintenance is performed in accordance with procedures based on manufacturer's recommendations with consideration given to operating experience.

SALEM - UNIT I B 3/4 8-2 Amendment No. 253

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