ML18093A444
| ML18093A444 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/13/1987 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8710190290 | |
| Download: ML18093A444 (5) | |
Text
Public Service Electric and Gas Company Corbin A. McNeill, Jr.
Senior Vice President -
Nuclear Public Service Electric and Gas Company P.O. Box236, Han cocks Bridge, NJ 08038 609 339-4800 OCT 13 1987 NLR-N87187 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR DISCRETIONARY ENFORCEMENT TECHNICAL SPECIFICATION 3.8.1.1 FACILITY OPERATING LICENSE DPR-75 SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311
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Public Service Electric and Gas Company ( PSE&G) hereby requests"* -
discretionary enforcement of Technical Specification Action Statement 3.8.1.1.a for Salem Unit 2.
As discussed in Attachment 1 to this letter, plant operation subsequent to the granting of this request would not create a significant hazard to public health and safety.
The requested relief would provide an additional three day period beyond the current 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time limit indicated in Action Statement 3.8.1.1.a to restore the electrical power systems to operable status.
The purpose of this request is to enable the degassing of the No. 1 Station Power Transformer insulating oil.
To degas the transformer oil, the transformer must be isolated.
Consequently, one of the two offsite 500 Kv power supplies must be removed from service.
Although Salem Unit 1 will be in a refueling outage and not adversely affected by the isolation of the transformer, Salem Unit 2 will be in power operation and require the operability of two independent offsite circuits.
Discretionary enforcement is being requested as opposed to a permanent change to the Technical Specifications in this situation as the degassification of the transformer oil represents a unique preventative maintenance occurrence.
This
~ctivity would not be performed unless sample results indicate that degassification is necessary.
Oil sampling to allow this determination is performed on the station power transformers every six months.
The planned degassification of the No. 1 Station Power Transformer insulating oil during the current refueling outage represents the only time this activity will have been performed since the transformer was initially put into service.
The most recent oil sample results for the No. 2
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Station Power Transformer do not indicate that degassification would be necessary in the near future.
Although PSE&G cannot guarantee that neither Station Power Transformer will have to be degassed at any time in the future, the need to perform this activity will be rarely encountered over the life of the plant.
The projected date for the performance of this activity is October 25, 1987.
We ask that your response to this request for discretionary enforcement be provided as soon as possible for planning purposes.
Subsequept to your approval of this request, PSE&G will submit a report identifying all actions taken within 14 days of the completion of the transformer maintenance.
If you have any questions with regard to this request, please do not hesitate to contact us.
Sincerely, Attachment C
Mr. D. c. Fischer USNRC Licensing Project Manager Mr. T. J. Kenny USNRC Senior Resident Inspector Mr. w. T. Russell, Administrator USNRC Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628
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i STATE OF NEW JERSEY SS.
COUNTY OF SALEM Corbin A. McNeil!, Jr., being duly sworn according to law deposes and says:
I am Senior Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated October 13, 1987
,,concerning Facility Operating License DPR-75 for Salem Generating Station, are true to the best of my knowledge, information and belief.
Subscribed and Sworn to before me
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day of (JC{~
, 1987 I' --.Notary Public of New Jersey
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My Commission expires on
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EILEEN M. OCHS NOTARY PUBLIC Of NEW JERSEY Wl.Y commission Expires July 16, 1992
ATTACHMENT 1 Technical Specification 3/4.8.1.1 Technical Specification (TS) 4.8.1.1 identifies the operability requirements for A.C. electrical power sources.
Specifically, TS 4.8.1.1.a requires "Two physically independent circuits between the offsite transmission network and the onsite Class lE distribution system (vital bus system)".
The basis for this specification combined with the other Tech. Specs. for A.C. and D.C power sources is to "ensure that sufficient power will be available to supply the safety related equipment requirement for (1) the safe shutdown of the facility and (2) the mitigation and control of accident conditions within the facility."
The required minimum A.C and D.C. power sources and distribution system satisfy the requirements of General Design Criterion 17 of Appendix "A" to 10CFR Part 50.
Summary of Current Situation The No. 1 Station Power Transformer, which provides one of the two offsite power supplies from the 500 Kv power distribution system to the emergency power distribution system, requires preventative maintenance.
A recent sample of the transformer insulating oil revealed high gas levels in the oil.
The proper method for degassing the oil requires the transformer to be isolated from the distribution system.
This results in the removal of one of the two offsite power (500 Kv) systems from service.
Th~ degassification technique reqbire~ the oil to be completely drained from the transformer, under vacuum, then filtering the oil and refilling the transformer with the oil.
The time required to simply pump the 26,500 gallons of insulating oil to and from the processing equipment is greater than 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> (flow rate approximately 1,000 gallons per hour).
The estimated duration for performing the degassification is six days.
This will allow for time to perform required sampling on the oil and will accomodate any difficulties which are encountered during the degassification process.
Presently, Technical Specification 3.8.1.1.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for an offsite circuit to be inoperable.
As such, an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are needed, beyond that allowed by the action statement, to perform the degassif ication.
Request for Discretionary Enforcement PSE&G intends to perform the degassif ication of No. 1 Station Power Transformer during the present Salem Unit 1 refueling outage, (the projected date is October 25, 1987) with Unit 1 defueled.
Consequently, Unit 1 will meet its Technical Specification requirements of one offsite transmission network for Modes 5 and 6.
However, removal of the transformer for 6 days would require Unit 2 to be shut down from power operation after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
PSE&G therefore requests that NRC Region I-grant discretionary enforcement of Technical Specification Action
Statement 3.8.1.1.a., for a period that would permit power operation for an additional three days beyond the presently allowed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, to allow for proper degassification of the No.
1 Station Power Transformer.
Operation under the requested discretionary enforcement will not place the plant in an unsafe condition.
PSE&G believes that there is ample technical justification for the requested relief, in that:
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0 The degassif ication of the transformer will be performed with all onsite lE vital distribution equipment for both Salem Unit 1 and 2 OPERABLE.
The 13.8 Kv gas turbine will be available as an additional source of power to the emergency distribution system.
The distribution system downstream of the remaining (No.
- 2) Station Power Transformer is designed with redundance and is capable of supplying power to both Salem Units 1 and 2 emergency power distribution systems.
In addition, load requirements for Salem Unit 1 during the degassification will be minimal as the reactor will be defueled at the time.
With one unit in a defueled condition, it will not be possible to encounter a worst case emergency load profile (LOCA on one unit, shutdown of the other).
The Salem units have been designed to be capable of being safety shut down from full power operation in the event of a loss of all offsite power as stated in the UFSAR, Section 8.1.4.1.
Maintaining vital power systems in excess of the Unit 1 Technical Specifications, along with having the gas turbine (13.8 Kv) generator available add further assurance that the units will be maintained in a safe condition.
The degassif ication of the No. 1 Station Power Transformer will enhance its overall reliability.
Two offsite 500 Kv power sources will be maintained operable.
Thus, redundant offsite power sources will be available to the No. 1 Station Power Transformer.
The degassification of the transformer will not be performed during forecasted severe weather conditions (i.e., tornado, hurricane, etc.).