ML18093A829

Application for Amend to License DPR-75 Re Electric Equipment Protective Devices for Containment Electrical Penetrations.Application Copy Also Sent to State of Nj Per 10CFR50.91(b)(1).Fee Paid

ML18093A829
Person / Time
Site:	Salem
Issue date:	05/10/1988
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLR-N88072, NUDOCS 8805130099
Download: ML18093A829 (7)

Text

Public Service Electric and Gas

-Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4199 Vice President -

Nuclear Operations May 10, 1988 NLR-N88072 United States Nuclear Regulatory Conunission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR AM~NDMENT SALEM GENERATING STATION UNIT NO. 2 FACILITY LICENSE NO. DPR-75 DOCKET NO. 50-311 In accordance with the requirements of 10 CFR 50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits an emergency request for amendment of Facility Operating License

.DPR-75 for Salem Generating Station Unit No. 2. In accordance with the requirements of 10 CFR 170.21, a check in the amount of

$150.00*is attached. ,In accordance with the requirements 10 CFR 50.9l(b)(l), a copy of this request has been sent to the State of New Jersey.

This amendment request (Attachment 1) revises Technical Specification 3/4.8.3, Electrical Equipment Protective Devices, for the containment electrical penetrations. This change allows PSE&G to avoid an unnecessary plant shutdown as a result of a lack of backup overcurrent protection for 36 containment electrical penetrations. Attachment 1 also contains further discussion and justification for the proposed revision including a justification of the emergency circumstances. PSE&G requests your immediate attention and issuance of an emergency amendment by 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> on May 12, 1988. Pursuant to 10 CFR 50.4(b) (2)

(ii), this submittal includes one (1) signed original with affidavit, and thirty seven (37) copies.

8805 f30099 ~gii~)g 11 PDR *ADOCK DCD p

Document Control Desk 2 May 10, 1988 Should you have any questions relative to this matter, please contact us immediately.

Sincerely, Affidavit Attachments (2) c Mr. D. c. Fischer USNRC Licensing Project Manager Mr. R. w. Borchardt 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

Ref: SGS LCR 88-05 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

Steven E. Miltenberger, being duly sworn according to law deposes and says:

I am Vice President and Chief Nuclear Officer for the Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated May 10, 1988, concerning Salem Generating Station License Change Request 88-05, are true to the best of my knowledge, information and belief.

me 1988 My Commission expires on M. DONALD l VONS NOTARY PUBLIC OF NEW JERSEY MY COMMISSION EXPIRES JANUARY 27, 1989

ATTACHMENT 1 PROPOSED EMERGENCY CHANGE TO LCR 88-05 TECHNICAL SPECIFICATIONS SALEM GENERATING STATION UNIT NO. 2 LICENSE NO. DPR-75 I. DESCRIPTION OF CHANGE The requested emergency change would revise item (a) of the ACTION statement of Specification 3/4.8.3 to be consistent with the wording of Draft Revision 5 of the Standard Technical Specifications and would read as follows:

ACTION With one or more of the containment penetration conductor overcurrent protective device(s) shown in Table 3.8-1 inoperable:

a. Restore the protective device(s) to OPERABLE status or de-energize the circuit(s) by tripping either the primary or backup protective device, or racking out or removing the inoperable primary or backup device within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, declare the affected system or component inoperable, and verify the primary or backup protective device to be tripped, or the primary or backup device racked out or removed at least once per 7 days thereafter; the provisions of Specification 3.0.4 are not applicable to overcurrent devices in circuits which have their primary or backup protective device tripped, or which have the primary or backup device racked out or removed, or ...

II. REASON FOR CHANGE The proposed change is required to prevent an unneccesary plant shutdown due to insufficient coordination between the backup overcurrent protective device and the containment penetration thermal failure curve.

III. SAFETY EVALUATION The intent of this Specification is to provide assurance that containment integrity will not be jeopardized by the failure of a containment electrical penetration due to a random electrical fault inside containment concurrent with a LOCA an~ a failure of the affected circuits primary protective device. The periodic surveillance required by the specification provides assurance that the primary and secondary interrupting devices selected for use in these circuits are of high reliability and therefore can be expected to fullfill their required function. The function of the primary and backup devices is defined within the context of this specification as the capability to interrupt the maximum available fault current prior to the magnitude and duration of the current exceeding the thermal capability of the penetration module.

1

The analysis performed by PSE&G determined that in 37 of the circuits listed in Table 3.8-1, the required backup overcurrent protection for the penetration module does not exist. Primary overcurrent protection exists for all circuits listed in Table 3.8-1.

The present ACTION statement requires that the backup circuit breaker be tripped within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to de-energize the affected circuit should either the primary or backup overcurrent protective device become inoperable. De-energizing the circuit removes the potential for loss of containment integrity under the postulated scenario. At Salem Unit 2, the backup-device in many instances is a main incoming bus breaker and the primary device is an individual load feeder breaker. As a result, tripping of the backup device results in multiple circuits being de-energized in order to protect a single penetration. Tripping of the load feeder breaker (i.e. the primary protective device) de-energizes that portion of the circuit passing through the penetration and therefore, provides the same level of isolation as tripping the backup device. Additionally, tripping of the primary device restores the backup device to an operable condition for all other design requirements.

IV. JUSTIFICATION OF EMERGENCY CIRCUMSTANCES A review of those circuits listed in Table 3.8-1 of the Specification was performed under an existing PSE&G program to document the present Salem Electrical Distribution System (EDS) design basis. As a result, approximately 54 circuits were identified which required detailed engineering analysis to assess operability of the backup device. This number has been reduced to 37 circuits on the basis of the engineering review.

In parallel with the technical evaluation of the affected circuits, PSE&G initiated the required design change and procurement activities necessary to repair all the affected circuits. However, due to the large number of circuits and equipment availability problems, PSE&G will only be able to complete repair of 5 circuits within the present ACTION s~atement guidelines.

Therefore, as a consequence of its ongoing review of the Salem EDS design basis, PSE&G has; (i) identified a condition which could not reasonably have been forseen, (ii) exhausted all available means of returning the affected circuits to operable status , and (iii) identified a condition which will force the shutdown of Salem Unit No.2 unless the requested change is granted by 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> on May 12, 1988. It is our belief that this request satisfies the requirements of 10 CFR 50.91(a)(5) pertaining to the granting of emergency changes to license requirements.

V. SCHEDULE FOR ATTAINING COMPLIANCE Each of the 37 circuits listed in Attachment 2 have been reviewed to assess the impact on continued plant operation. This assessment included a review of normal operating and safety requirements. A total of 32 circuits have been classified as non-essential and will be repaired between now and prior to start up after the next Salem Unit 2 refueling outage. That outage is presently scheduled to begin in 2

September of 1988. The 5 circuits classified as essential to support operation of the unit will be repaired within the ACTION statement guidelines.

VI. SIGNIFICANT HAZARDS CONSIDERATION EVALUATION The probability and consequences of previously analyzed accidents are not increased as a result of the requested change. Tripping of the primary protective device de-energizes that portion of the circuit passing through the containment electrical penetration thereby eliminating the potential for failure of the affected penetration.

Additionally, operability of equipment and systems which are powered from the circuits listed in Table 3.8-1 and which are required for accident mitigation is assured through satisfaction of other Technical Specification LIMITING CONDITIONS FOR OPERATION and ACTION Statements associated with the particular component or system.

The intent of Technical Specification 3/4.8.3 is to preserve containment integrity by reducing the potential for failure of a containment electrical penetration. This protection is achieved by isolating that portion of the circuit passing through the affected penetration. The configuration of the circuits listed in Table 3.8-1 of the specification is such that the required isolation can be achieved by tripping either the primary or backup protective device.

As a result, the requested change does not create the possibility for a new or different kind of accident from any that has been previously evaluated.

The proposed change does not involve a reduction in any margin of safety. As stated above, the isolation of a penetration can be accomplished by tripping either the primary or backup overcurrent protective device. As such, existing margins of safety are maintained. Additionally, the isolation of the penetration by tripping the primary device provides an increased margin of safety in that associated equipment (i.e. other than that of the affected circuit) that would have been lost by opening the backup breaker, would still be available to the operator for transient response.

Based on the above, PSE&G has determined that the requested change does not involve a significant hazards consideration.

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ATTACHMENT 2 ~i LIST OF AFFECTED CIRCUITS I

' ~ r COMPONENT PENETRATION CABLEMK COMMENTS C21A LIGHT DIST. PNL. 2-45 1FL4YA-F Not required for power operation 21 !NCR FLUX DET "A" 2-46 2G7XB-G Required 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />s/31 days for flux 22 !NCR FLUX DET "B" 2-46 2G7XC-G mapping. Circuits are normally de-23 !NCR FLUX DET II c II 2-46 2G7XQ-G energized. Modifications to be 24 !NCR FLUX DET "D" 2-50 2E7XB-E accomplished prior to next scheduled 25 !NCR FLUX DET "E" 2-50 2E7XC-E flux map.

26 !NCR FLUX DET "F" 2-50 2E7XQ-E 21 CON IODINE REMOV. 2-46 2G7XA-G Not required for power operation 22 CON IODINE REMOV. 2-46 2E7XA-E Not used in accident analysis I 21 RX CLT DRN TK PP 2-46 2G7XE-G 1 of 2 pumps required for power opera-  :

22 RX CLT DRN TK PP 2-50 2E7XE-E tion. Repairs to be made within A :i action statement guidelines. ~

21 RCP OIL LFT pp 2-46 2G7XF-G Not required at power, normally 22 RCP OIL LFT PP 2-46 2G7XK-G de-energized 23 RCP OIL LFT PP 2-50 2E7XE-E 24 RCP OIL LFT PP 2-50 2E7XE-E 21 RCP MOTOR HTR 2-50 2E7XD-E Not required at power, normally 22 RCP MOTOR HTR 2-50 2E7XP-E de-energized 23 RCP MOTOR HTR 2-46 2G7XD-G 24 RCP MOTOR HTR 2-46 2G7XP-G 21SJ44 SUMP-RH VALVE 2-El 2A3YBE-A Essential to power operation repairs 22SJ44 SUMP-PH VALVE 2-E2 2B3YBK-B to be made within action statement uidelines 21 CON SUMP PUMP 2-48 2G7XYG-G Essential to power operation repairs 22 CON SUMP PUMP 2-49 2E7XYG-E to be made within action statement uidelines PZR HTRS 12,13,14 2-6 2EP1X-E Tech Spec requires two groups of ~

PZR HTRS 21,22,40 2-6 2EP2X-E heaters @150KW/group. This is large ..,

PZR HTRS 23,24,50 2-6 2EP3X-E group of B/U htrs. Control group and PZR HTRS 25,26,53 2-6 2EP4X-E small group of B/U htrs. are adequate PZR HTRS 27,28,55 2-6 2EP5X-E for operation. These circuits will be PZR HTRS 29,30,58 2-6 2EP6X-E de-energized.

PZR HTRS 31,32,60 2-6 2EP7X-E PZR HTRS 33,62,63 2-28 2EP8X-E PZR HTRS 35,36,65 2-28 2EP9X-E PZR HTRS 37,38,67 2-28 2EP10X-P PZR HTRS 39,40,70 2-28 2EP11X-P PZR HTRS 41,42,72 2-28 2EP12X-P PZR HTRS 43,44,75 2-28 2EP13X-P PZR HTRS 45,46,77 2-28 2EP14X-P