ML18092A918

Application for Amends to Licenses DPR-70 & DPR-75,revising Tech Specs Re Containment Isolation Valves.Fee Paid

ML18092A918
Person / Time
Site:	Salem
Issue date:	11/27/1985
From:	Corbin McNeil Public Service Enterprise Group
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML18092A919	List: ML18092A918 ML18092A920
References
LCR-84-22, NUDOCS 8512110244
Download: ML18092A918 (10)

Text

Public Service Electric and Gas Company Corbin A. McNeill, Jr. Public Service Electric and Gas Company P.O. Box236, Han cocks Bridge, NJ 08038 609 339-4800 Vice President -

Nuclear November 27, 1985 Re f : LC R 8 4- 2 2 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Washington, D. C. 20555 Attention: Mr. Steven A. Varga, Chief Operating Reactors Branch 1 Division of Licensing Gentlemen:

REQUEST FOR AMENDMENT FACILITY OPERATING LICENSES DPR-70 AND DPR-75 UNIT NOS. 1 AND 2 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 In accordance with the Atomic Energy Act of 1954, as amended and the regulations thereunder, we hereby transmit copies of our request for amendment and our analyses of the changes to Facility Operating Licenses DPR-70 and DPR-75 for Salem Generating Station, Unit Nos. 1 and 2.

This amendment request consists of changes to the technical specifications regarding containment isolation valves.

In accordance with the fee requirements of 10CFR170.21, a check in the amount of $150.00 is enclosed.

Pursuant to the requirements of *10CFR50. 91, a copy of this request for amendment has been sent to the State of New <'~~rsey as indicated below.

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8512110244 851127 PDR ADOCK 05000272 P PDR

Mr. Steven A. Varga 11-27-85 This submittal includes three (3) signed originals and forty (40) copies.

Sincerely, Enclosure C Mr. Donald C. Fischer Licensing Project Manager Mr. Thomas J. Kenny Senior Resident Inspector Mr. Samuel J. Collins, Chief Projects Branch No. 2, DPRP Region 1 Mr. Frank Cosolito, Acting Chief Bureau of Radiation Protection Department of Environmental Protection 380 Scotch Road Trenton, N.J. 08628 Honorable Charles M. Oberly, III Attorney General of the State of Delaware Department of Justice 820 North French Street Wilmington, Delaware 19801

Re f : LC R 8 4 - 2 2 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

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

I am a Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated Nov. 27, 1985 , concerning our Request for Amendment to Facility Operating Licenses DPR-70 and DPR-75, are true to the best of my knowledge, information and belief.

Subscribed and Sworn to before me this <X2~ day of 'fl~ , 1985 Notary Public of New Jersey DONNA G. HITCHNER NOTARY PUBLIC OF NEW JERSEY My Commission expires on My Commission Expires March 24, 1987

'.~. .*,

PROPOSED CHANGE TECHNICAL SPECIFICATIONS SALEM UNIT NOS. 1 AND 2 Ref; LCR 84-22 DESCRIPTION OF CHANGE Modify Sections 3.6.3.l and 3.6.3,for Units 1 and 2 respectively, in accordance with the attached marked-up pages.

REASON FOR CHANGE This change will allow an inoperable isolation valve to satisfy i~s OPERABILITY requirements if the valve is maintained closed to isolate its affected penet~ation.

- - - SIGNIFICANT HAZARDS EVALUATION - See page 4 of 6 DESCRIPTION OF ADDITIONAL CHANGES Table i.6-1 of Technical Specifications Section ~.6.3.l requires the addition, deletion and reclassification of numerous valves. The types of changes involved have been divided into five groups of valves *to facilitate discussion of the reason for each -change.

The first change consists of adding the following valves:

1 (2)C5900 11 (21)55181 11 (2l)VC17 11 (2l)CS2 1 (2)CS901 11 (2l)SS182 11 (2l)VC18 12 (22)C52 1 (2)C5902 11 (21)551-88 11 (2l)VC19 11 (2l)C548 1 (2)C5903 11 (21)SS189 11 (2l)VC20 12 (22)CS48 1 (2)5A262 13 (23)85181 12 (22)VC17 11 (2l)CA360 l (i)5A264 13 (23)SS182 12 (22)VC18 12 (22)CA360 l (2)SA2n5 13 (23)55184 12 ( 2 2) VCl 9 1 (2)CA1714 1 (2)SA2n7 13 (23)55185 12 (22)VC20 1 (2)CA1715 1 ( 2) 5_A268 1 ( 2) NT34 1 (2)CC119 1 (2)SA270 1 (2)DR30 1 (2)5All9 1 1:!)FP148 Page 1 of I;

~ REASON FOR CHANGE This change will ensure t~at the Technical Specifications Table 3.6-1 conforms to 10CFR50, Appendix J. Currently, the table is not in agreement with this document. The deficiency in the table was identifi~d during Type C leak rate testing.

PSE&G reevaluated the valves and determined that they should be considered containment isolation valves subject to Type C testing.

DESCRIPTION OF CHANGE The second change-consists of shifting valves from exempt from I

Type C testing to reguired for Type C testing. The valves are ...

as follows:

1 (2)VC2 1 (2)SA118 1 ( 2 )VC3 1 (2)WL190 1 (2)VC6 1 (2)SF36 1 (2)VC9 1 (2)WL191 1 (2)VC10 1 (2)SF22 1 (2)VC13 1 (2)VC14 REASON FOR CHANGE This change will ensure that the Technical Specifications Table 3.6-1 conforms to 10CFR50, Appendix J. *Currently, the table is not in agreement with this document. The defici~ncy in the table was identified during Type C leak rate testing.

PSE&G reevaluated the valves and determined that they are "

containment isolation valves subject to Type C testing.

Page 2 of 6

DESCRIPTION OF CHANGE The t~ird change addresses the deletion of certain valves currently listed as subject to Type C testing. The valves are, as follows:

11 (2l)GB4 11 (2l)SS94 12 (22)GB4 12 (22)SS94 13 ( 23 )GB4 13 (23)SS94 14 ( 24) G:R4 14 ( 24 )SS94 REASON FOR CHANGE This change will ensure continued conformance of Technical Specifications Table 3.6-1 to 10CFRSO, Appendix J. Although subjecting the GB4 and SS94 valves to Type C testing does not violate 10CFRSO, ~ppendix J,.deletion from testing will save time and resources. This change was id.entified during Type C leak rate testing. PSE&G reevaluated the valves and determined that the valves could be removed from Type C testing.

DESCRIPTION OF CHANGE The fourth change is the deletion of valves from the list of CIVs:

11 (2l)SS93 12 (22)SS93 13 (23)SS93

• 14* ( 24) SS93 Page 3 of 6

.. REASON FOR CHANGE -

This change will ensure that Technical Specifications Table 3.6-1 conforms to 10CFR50, Appendix J. Deletion of these valves will decrease confusion when classifying the valves.

PSE&G reeval u-ated the valves, and determined they could be deleted.

DESCRIPTION OF CHANGE The fifth change is the addition of the option to use 1(2)CC117 or 1(2)CC118 as outside isolation.

REASON FOR CHANGE This change will ensure that the Te;chnical Specifications Table 3.6-1 conforms to 10CFR50, Appendix J. Currently, Table 3.6-1 lists both valves subject to Type c testing. PSE&G has reevaluated these valves and determined only one must meet Type C requirements because a check' valve inside containment meets requirements as an automatic isolation valve.

SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS The change to the LIMITING CONDITION FOR OPERATIPN (Sections 3.6.3.l and 3.6.3) is clarifying in nature since the function of the isolation valves in the table is to be able t9 shut, isolating each valve's.affected penetration; therefore, if the valve is shut and administratively controlled in that. position, it is performing its intended function and can, by definition, be considered OPERABLE .

The addition of valves to Table 3.6-1 subject to Type c testing does not involve a significant hazard. The change constitutes additional control presently not included in the Technical Specifications (more stringent surveillance re qui rem en t)

• Page 4. of 15

SIGNIFICANT HAZARDS.CONSIDERATION ANALYSIS (cont'd)

The deletion of.valves 11(21)-14(24)GB4 and 11(21)-14(24)SS94 from Type C testing does not involve a significant hazard.

These valves are connected to the secondary side of the steam generator and will not be exposed to atmosphere during postulated loss of coolant 1 accident. Also, they are not a postulated containment leakage path. Automatic isolation of these valves is in resp9nse to requirements other than containment isolation. Inclusion of the GB4 and SS94 valves penalizes, unnec~ssarily, the results of loc~l leak rate testing on the containment.

The deletion ot valves 11(21)-14(24)SS93 does not constitute a significant hazard. These remote manual valves are part of the Steam Generator Blowdown Sampling System upstream of the Steam Generator Blowdown Isolation Valves SS94. The portion of the Stearn Generator Blowdown Sampling system inside containment meets requirements to be considered a closed system "inside containment. As a closed system, valve SS93 does not act as a containment isolation barrier.

The-option of using either 1(2)CC117 or 1(2)CC118 as the outside isolation barrier does not constitute a significant hazard. The Component Cooling Water Supply to the RCP motor is isolated on* a Phase B isol*ation signal. The supply line to the RCP has two motor operated valves, 1(2)CC117 and 1(2)CC118, outside containment and a check valve inside containment. Based on ? definition of a Category B penetratiof), this line is requireci to have one automatic valve -

inside containment and one automatic valve outside containment. Since check valves are considered automatic isolation valves when used inside containment, only one of the outside valves (either 1(2)CC117 or 1(2)CC118) is necessary to meet Type C testing requirements.

Page 5 of 6

SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS (cont'd)

These chanqes are deemed to not involve a siqnif icant hazarrts consideration. There is no increase in the probability or consequence of any previously analyzed accident nor is any new accident created by the operation of the Salem Units with these changes ~n place since there is no physical chanqe to any component or system from that oriqinally assumed in the accident analyses.

Margins of safety are either improved (by addinq valves to Tahle 3.* 6-1 constituting additional suryeillance testinq) or remain the same (in those instances where clarification of the term, OPERABILITY, or of what valves should be considerert isolation v~lves is provided) *

• The Commission has provided examples in the Federal Register (48FR14870) as guidance for AP1.endments That Are Considered Not Likely To Involve A Siqnificant Hazards Consideration. The chanqes constitute either a.clarification o_f isolation valve OPERABILITY, which corresponds to exa:M-nle *(vi) provided by the Com!".1.ission; mor.e stringent surveillance*testinq added to the existing technical specifications, which corresponds to example (ii) provided by the CoMmission; or deletion of. valves which were incorrectly cons~dered to be isolation valves and whose removal would be the result of a*

snall clarification or refinement of the evaluation methods used to determine valve classification, which also corresponds to example (vi), provided by the Commission.

Page 6 of 6

REVISED PAGES - UNIT NO. 1