ML18094A716
| ML18094A716 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/25/1989 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18094A717 | List: |
| References | |
| RTR-REGGD-01.052, RTR-REGGD-1.052 NLR-N89157, NUDOCS 8910020253 | |
| Download: ML18094A716 (6) | |
Text
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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 and Chief Nuclear Officer September 25, 1989 NLR-N89157 United states Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
REQUEST FOR AMENDMENT SALEM GENERATING STATION UNIT NO. 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 In accordance with the reqliirements of 10CFR50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits a request for amendment of Facility Operating License DPR-75 for Salem Generating Station (SGS), Unit No. 2.
Pursuant to the requirements of 10CFR50.90(b) (1), a copy of this request has been sent to the State of New Jersey as indicated below.
The proposed change.requests a modification to the Control Room Emergency Air Conditioning System, Auxiliary Building Exhaust Air Filtration System and Fuel Handling Area Ventilation system Technical Specification surveillance requirements.
The changes clarify the acceptance criteria for in-place testing of charcoal adsorbers and HEPA filter banks in accordance with Regulatory Guide* 1.52, Revision 2, March 1978.
The proposed changes are considered administrative in nature since they are requested to clarify existing requirements.
A significant amount of technical review should not be required.
Therefore, PSE&G believes that the proposed change can be classified as a Category 2 change. contains further discussion and justification for the proposed revisions. is a markup of the existing Technical Specifications to reflect the specifications as requested. is a retype of the Technical Specifications incorporating the proposed changes.
This submittal includes one (1) signed original, including affidav_it, and thirty-seven (37) copies pursuant to 10CFR50.4. (b) (2) (ii).
, \\
Document Control Desk NLR-N89157 2
09-25-89 Should you have any questions on this subject transmittal, please do not hesitate to contact us.
Attachments c
Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Mr. w. T. Russell, Administrator Region I Mr. Kent Tosch, Chief Sincerely, New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
STATE OF NEW JERSEY COUNTY OF SALEM
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SS.
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REF:
NLR-N89157 Steven E. Miltenberger, being duly sworn according to law deposes and says:
I am Vice President and Chief Nuclear Officer of Public Service Electric and Gas Company, forth in our letter dated Salem Generating Station, and as such, I find the matters set September 25, 1989, concerning the Unit No. 2, are true to the best of my knowledge, information and belief.
Subscribed and Sworn to before me this
,;;?r-Y--11 day of ~fU11._~ 1989
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'7n >-xCid4k,j/
No~ary Public of New Jersey My Commission expires on
~.;.AN~T ;~ Ui. f;*lARS~I;~LL NOTARY PUBLIC OF NEW JERSEY My Commission Expires May 8, 1993
PROPOSED LICENSE CHANGE SALEM GENERATING STATION UNIT NO. 2 ATTACHMENT 1 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 I.
Description of Change LCR 89-08 Revise Salem Unit 2 Technical Specification Surveillance Sections 4.7.6.l(b)l, 4.7.7(b)2 and 4.9.12(b)2 to specify the in-place testing acceptance criteria, in addition to referencing the appropriate sections of Regulatory Guide 1.52, Revision 2, March 1978.
II.
Reason for the Proposed Change NRC Combined Inspection Report 50-272/89-03 and 50-311/89-03 identified a confusing situation regarding test gas removal efficiency acceptance criteria, as specified in TS Section 4.7.7 for Salem Unit 2.
As a result, the NRC/NRR Project Manager, for Salem Generating Station, requested that PSE&G submit a license change to clarify TS 4.7.7 surveillance criteria for Salem Unit
- 2.
PSE&G agreed to pursue a TS change in our response to the Inspection Report.
Further review of the Unit 2 TS uncovered similar wording in two additional TS sections.
This amendment request addresses all of the identified TS sections, satisfies our commitment to clarify this area and provides consistency between Salem Unit 1 and 2 Technical Specifications.
III. Justification for the Proposed Change The proposed change clarifies the in-place testing acceptance criteria for charcoal adsorbers and HEPA filter banks, to preclude an unnecessary plant shutdown due to overly restrictive test criteria.
The present wording of the surveillance sections, indicates that the test procedures addressed in the specified sections of Regulatory Guide 1.52 should be used to conduct in-place testing.
Reg. Guide sections C.5.c and C.5.d specify an acceptance criteria of: penetration less than 0.05% for HEPA filter banks and bypass leakage through charcoal adsorber section less than 0.05%. N~C Generic Letter 83-13 provides clarification of the relationship between the guidance provided in Regulatory Guide 1.52, Revision 2, and ANSI N510-1975, concerning the testing requirements of the HEPA filters and charcoal adsorber units.
Generic Letter 83-13 states that a" 0.05% value. is applicable when a HEPA* filter or charcoal adsorber efficiency of 99% is assumed, or 1% when a HEPA filter or charcoal adsorber efficiency of 95% or less is assumed in the NRC staff's safety evaluation.
(use the value assumed for the charcoal adsorber efficiency if the value for the HEPA filter is different from the charcoal absorber efficiency in the NRC staff's safety evaluation)."
Salem Generating Station UFSAR specifies that the charcoal filters are designed to absorb at least 90% of elemental and methyl iodines contacted at rated flow.
The UFSAR goes on to state that HEPA filters remove at least 99% of all particles 0.3 micron and larger in size.
Based on the design requirements of the components and the guidance provided in the Generic Letter, the appropriate testing value should be 1% not 0.05%.
This is consistent with Salem Unit 1 Technical Specifications, which apply to similar system components, but do not directly reference Regulatory Guide 1.52.
The proposed change precludes any misinterpretation of the testing acceptance criteria, by clearly indicating the proper values in the appropriate Technical Specification surveillance sections.
IV.
Significant Hazards Analysis Consideration The proposed changes to the Technical Specifications:
- 1.
Do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes, which are administrative in nature, do not impact any accident analysis used to support operation of the Salem Generating Station.
Furthermore, the proposed changes do not adversely affect the design or operation of any system or component important to safety.
Consequently, the reliability of the performance of plant safety functions is not adversely affected.
The inclusion of the specific in-place testing acceptance criteria, within the associated Technical Specification surveillance section, is requested to clarify the testing criteria.
Therefore, it may be concluded that the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
l
- 2.
Do not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes do not adversely affect the design or operation of any system or component important to safety.
No physical plant modifications or new operational configurations will result from these changes.
Therefore, it may be concluded that the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
- 3.
Do not involve a significant reduction in a margin of safety.
The proposed changes clarify existing Technical Specification surveillance requirements.
The changes do not make any physical alterations to the plant and are consistent with previously reviewed and approved Technical Specifications (Salem Unit 1), and Regulatory guidance (Generic Letter 83-13).
Therefore, it may be concluded that the proposed changes do not involve a significant reduction in a margin of safety.
- v.
Conclusions Based on the information presented above, PSE&G has concluded that the proposed changes satisfy the criteria for a no significant hazards consideration.