ML18092B341
| ML18092B341 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/30/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18092B342 | List: |
| References | |
| NLR-N86158, NUDOCS 8611040002 | |
| Download: ML18092B341 (7) | |
Text
Public Service Electric and Gas Company Corbin A. McNeill, Jr.
Vice President -
Public Service Electric and Gas Company P.O. Box236, Hancocks Bridge, NJ 08038 609 339-4800 Nuclear
(
October 30, 198~
NLR-N86158 Ref:
LCR 83-10 Off ice of Nuclear Reactor Regulation United States Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014 Attention:
Mr. Vincent s. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing A Gentlemen:
REQUEST FOR AMENDMENT LICENSE CHANGE REQUEST SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 In accordance with the Atomic Energy Act of 1954, as amended and the regulations thereunder, Public Service Electric and Gas Company (PSE&G) hereby transmits copies of this request for amendment and analysis of the changes to Facility Operating License DPR-70 for Salem Generating Station Unit No. 1, and DPR-75 for Salem Generating Station Unit No. 2.
This request is a revision of LCR 83-10, originally submitted on September 19, 1983, which proposes to change the allowable time period to depressurize and vent the reactor coolant system in the event that the Pressurizer Overpressure Protection System (POPS) is inoperable.
This revision to LCR 83-10 introduces a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period to restore the POPS to operability prior to requiring initiation of reactor coolant system depressurization.
Also, a revised determination of no Significant Hazards is provided, pursuant to 10 CFR 50.92.
8611040002 861030.
PDR ADOCK 05000272 p
~
I I
Mr. Vincent S. Noonan, Project Directorate #5 2
10/30/86 Pursuant to 10 CFR 50.9l(b)(l), a copy of this request for amendment has been sent to the State of New Jersey as indicated below.
This submittal includes three (3) signed originals and forty (40) copies.
C Mr. Donald c. Fischer Licensing Project Manager Mr. Thomas J. Kenny Senior Resident Inspector Sincerely, Mr. Samuel J. Collins, Chief Projects Branch No. 2, DPRP Region I Mr. Frank Cosolito, Acting Chief Bureau of Radiation Protection Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 Honorable Charles H. Oberly, III Attorney General of the State of Delaware Department of Justice 820 North French Street Wilmington, DE 19801
STATE OF NEW JERSEY COUNTY OF SALEM
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Ref:
Corbin A. McNeil!, Jr., being duly sworn according to law deposes and says:
I am Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated Oct.
30~ 1986, concerning License Change Request 83-10, is true to the best of my knowledge, information and belief.
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My Commission &plres,.... K 1990 My Commission expires on -----------------
PROPOSED LICENSE CHANGE SALEM GENERATING STATION NO. 1 AND 2 UNITS DOCKET NO. 50-272 AND 50-311 REACTOR COOLANT SYSTEM OVERPRESSURE PROTECTION SYSTEM LIMITING CONDITION FOR OPERATION Description of Change LCR 83-10 Page 1 of 3 Change the action statements in paragraph (a) and (b) of the limiting condition for operation in Technical Specification Sections 3.4.9.3 (Unit 1) and 3.4.10.3 (Unit 2) to read as follows:
- a.
With one POPS inoperable, either restore the inoperable POPS to OPERABLE status within 7 days or depressurize and vent the RCS through a 3.14 square inch vent(s) within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; maintain the RCS in a vented condition until both POPs have been restored to OPERABLE status.
- b.
With both POPS inoperable, either restore at least one inoperable POPS to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or depressurize and vent the RCS through a 3.14 square inch vent(s) within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; maintain RCS in a vented condition until both POPS have been restored to OPERABLE status.
Reason for Change The existing action statements in limiting condition for operation presently require that the Reactor Coolant System (RCS) be depressurized and vented through a 3.14 square inch vent(s) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if both Pressurizer Overpressure Protection System (POPS) relief valves are inoperable or one POPS is inoperable and can not be restored to OPERABLE status within 7 days.
Depressurization and venting of the RCS require that the steam bubble in the pressurizer be eliminated, reactor coolant be degassed to eliminate hydrogen buildup and hence possibility of explosion, and the pressurizer power operated relief valves (PORVs) be gagged open to establish the required vent path.
The current requirement to depressurize and vent the RCS within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not realistic.
Given the amount of time it takes to perform each step, the entire sequence of events required to depressurize and vent the RCS could take up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The current action statement requires RCS depressurization within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with both POPS inoperable.
The proposed change to allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for restoration of one POPS to operability is made based on the availability of a 3.14 square inch vent path and the provisions for preventing low temperature overpressure transients
LCR 83-10 Page 2 of 3 described in the Significant Hazards Consideration.
This vent path is established by opening and tagging one of the inoperable POPS valves and its associated block valve, which provides a path greater than 3.14 square inches.
Significant Hazards Consideration The Pressurizer Overpressure Protection System (POPS) relief valves are provided to protect the RCS from pressure transients which could exceed the limits of Appendix G to 10CFR Part 50 when one or more RCS cold leg temperature is at or below 312°F.
Either POPS valve has adequate relieving capacity to protect the RCS from overpressurization for cases of either heat input or mass input as described in the Technical Specification bases, namely 1) the start of an idle Reactor Coolant Pump (RCP) with the secondary water temperature of the steam generator less than or equal to 50°F above RCS cold leg temperature or 2) the start of a safety injection pump and its injection into the RCS, while the plant is water solid.
Several provisions for prevention of pressure transients below P-7 (when the RCS temperature is below 312°F) presently exist.
Current Specification 3.4.1.3 for startup of an RCP requires that a steam bubble must be established in the pressurizer prior to reactor coolant pwnp start or the SG/RCSAT be verified to be less than 50°F.
Also, Technical Specification 3.5.3 allows a maximum of one safety injection pump to remain operable and power to all inoperable safety injection pumps must be removed by racking out the power supply breakers when the RCS temperature is below 350°F.
Also the shutdown procedure requires that a steam bubble be maintained in the pressurizer during plant cooldowns.
The Residual Heat Removal (RHR) System is put into service once the RCS temperature is below 350°F but ahove 312°F.
The RHR system provides relief capacity comparable to that of a POPS valve for which no credit has been taken in the low temperature overpressure analysis.
Another provision for mitigating pressure transients at low temperature is the availability of a vent path of 3.14 square inches for RCS depressurization and venting.
The proposed change to allow both POPS to be inoperable for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> does not impose a challenge to the fracture toughness limits of 10 CFR 50 Appendix G.
In the unlikely event that the pressure setpoint for POPS actuation (375 psi) is exceeded during this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, depressurization through the 3.14 square inch path may be initiated, and depressurization will be completed within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> allowed by Tech Specs to depressurize and vent the RCS is unrealistically short.
Upon detection that both of the POPS relief valves are inoperable, the RCS will be depressurized and a vent path will be established as soon as realistically
I~..~
I LCR 83-10 Page 3 of 3 achievable.
This depressurization could involve a time period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The intent of the existing Technical Specification to depressurize and vent the RCS upon detection of inoperable POPS relief valves is met and the proposed change does not involve a significant hazards consideration since the following criteria are fulfilled:
- a.
Probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report will not be significantly increased.
The requested change will increase the allowable time period within which the RCS will be depressurized.
However, the protective features described above will be available.
Depressurization of the RCS will be achieved and a vent path will be established through a 3.14 square inch opening(s) as soon as realistically achievable (but within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) so that the maximum RCS pressure will remain below the Appendix G limits.
- b.
The possibility of an accident or malfunction of a different type than any evaluated previously in the safety analysis report will not be created.
The requested change will only extend the allowable time period required to depressurize and vent the RCS, and does not involve any physical change in design.
Protected by existing procedural and administrative measures, this will not impact the safe operation of any system, component or structure required for safety.
- c.
The margin of safety as defined in the basis for any Technical Specification is not significantly reduced.
A vent opening of greater than or equal to 3.14 square inches has sufficient relieving capacity such that the RCS pressure/
temperature limits, as identified in the bases for the Technical Specification is maintained within the Appendix G limits.
With the protective measures described above, the margin of safety will not be significantly reduced with the allowable time period to complete depressurization of the RCS increased to a total of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
REVISED PAGES -
UNIT NO. 1