ML18094A740

Application for Amends to Licenses DPR-70 & DPR-75, Correcting Tech Spec Tables 3.3-1,3.3-3,4.3-1,4.3-2,3.3-6 & 3.4-1 & Tech Spec 4.4.7.2 Re Reactor Trip Sys Instrumentation

ML18094A740
Person / Time
Site:	Salem
Issue date:	09/13/1989
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18094A741	List: ML18094A740 ML18094A742
References
NLR-N89033, NUDOCS 8910060290
Download: ML18094A740 (8)

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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 13, 1989 NLR-N89033

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United States Nuclear Regulatory Commission *"

Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR AMENDMENT FACILITY OPERATING LICENSE DPR-70 AND DPR-75 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 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 a request for amendment of Facility Operating License DPR-70 and DPR-75 for Salem Generating Station (SGS), Unit Nos. 1 and 2. Pursuant to the requirements of 10CFR50.91(b) (1), a copy of this request has been sent to the State of New Jersey as indicated below.

This request supersedes the previously submitted (PSE&G letter NLR-N86110, dated August 29, 1986) License Change Request (LCR) 86-01. Therefore, PSE&G hereby requests that LCR 86-01 be withdrawn. This submittal is based on a request from the NRC Licensing Project Manager to separate unrelated technical items and, submit them as individual LCRs for ease of review. The attached change request includes corrections to Technical Specification Tables 3.3-1, 3.3-3, 4.3-1, 4.3-2, 3.3-6 and 3.4-1 as well as specification 4.4.7.2. These corrections also include those previously requested by LCR 84-15, which was withdrawn by PSE&G letter NLR-N89020, dated February 20, 1989. The corrections are intended to correct typographical errors, achieve consistency between units and to achieve consistency with the Westinghouse Standard Technica_l Specifications. Other items previously in LCR 86-01 are being submitted as a separate request.

The proposed changes are administrative in nature in that they correct typographical errors, achieve consistency between units and/or achieve consistency with the previously reviewed Westinghouse Standard Technical Specifications. Additionally, one of the proposed changes is requested to comply with Generic

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• i bocument Control Desk 2 09-13-89 NLR-N89033 Letter 82-16. Since the proposed changes are administrative and consistent with NRC guidelines, a significant amount of specialized technical review effort should not be required.

Therefore, PSE&G believes that the proposed change can be classified as a category 2 change.

Enclosure 1 contains further discussion and justification for the proposed revisions. Enclosure 2 is a markup of the existing Technical Specifications. Attachment 3 is a typed version of the requested changes. This submittal includes one (1) signed original, including affidavit, and thirty-seven (37) copies pursuant to 10CFR50.4(b) (2) (ii).

Should you have any questions on the subject transmittal, please do not hesitate to contact us.

Sincerely, Attachments c Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Mr. w. T. Russell, Administrator Region I Ms. J. Moon, Interim Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

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COUNTY OF SALEM )

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, and as such, I find the matters set forth in our letter dated September 13, 1989 , concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.

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".:,-Notary P~1blic of New Jersey , .

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• 'NOTARY PUBUC OF NEW JERSEY My Commission expires on My Cr.....,'" !gnl Jlly 16, 1992 ..

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'PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS SALEM UNIT NOS. 1 AND 2 Description of Change Revise Technical Specifications listed below to add clarification, to achieve consistency, or to correct typographical errors. The revisions are identified on the attached pages.

1. Revise Unit 1 and 2 Technical Specification Table 3.3-1, Functional Units 16 and 17 (Reactor Coolant Pumps Undervoltage and Underfrequency). The minimum channels operable is being changed from four to three.

2. Revise Unit 1 and Unit 2 Technical Specification Table 3.3-1, Functional Units 1, 5 and 6A, and Unit 1 and Unit 2 Table 4.3-1, Functional Units 5, 21 and 22. The

• footnote under APPLICABLE MODES is being changed from a stand alone note to 3*, 4*, 5*. The *footnote is being deleted from Unit 1 and Unit 2 Table 4.3-1, Functional Unit 6.

3. Revise Unit 1 and Unit 2 Technical Specification Table 3.3-1, Functional Unit 6A Description to "Control Rod Drive System Energized."

4. Revise Unit 1 Technical Specification Tables 3.3-3 and 4.3-2, Functional Unit Bf Emergency Trip of Steam Generator Feedwater Pumps - Start Motor Driven (Auxiliary Feedwater) Pumps to add Mode 2 to APPLICABLE MODES. Revise Unit 2 Technical Specification Table 3.3-3 Functional Unit Bf to correct the number of channels and revise Action 22 to be consistent with Unit

1. The *footnote is no longer applicable with the replacement of Action Statement 22.

5. Revise Action Statement 20 in Unit 1 and 2 Table 3.3-3, to allow one channel of functional units 4b and Ba (Steam Line Isolation and Auxiliary Feedwater Automatic Actuation Logic) to be bypassed for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing.

6. Change table notation in Unit 2 Technical Specification Table 3.3-6, for Action Statement number 24 to correct the number of the referenced specification.

7. Revised numbering for Unit 2 Surveillance Requirements 4.4.7.2 on reactor coolant system operational leakage.

B. Correct descriptions of SJ 144 valves in Unit 2 Specification Table 3.4-1.

NLR-NB9033

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'Reason and Justification for Change

1. This change corrects typographical errors in the Technical Specifications. For four-loop plants, three channels are required to be operable. The change brings the specifications into conformance with Westinghouse Standard Technical Specifications (NUREG-0452, Revision

4) *

2. This change clarifies the intended Applicable Modes for which this instrumentation is to be OPERABLE and for which the appropriate surveillances are to be performed.

This change makes this Technical Specification more consistent with the Westinghouse Standard Technical Specifications. The *footnote in Table 4.3-1, Functional Unit 6, is redundant as the Applicable Modes are already specified and, by definition, modes 3, 4 and 5 include the area addressed by the "*" (Reactor Trip Breakers closed and the Rod Drive System capable of pulling rods). Thus, its removal only clarifies the requirements.

3. This change alleviates the confusion associated with the word Startup since STARTUP is defined as MODE 2 only.

Therefore the description is being changed to clarify that the source range monitors should be functional whenever control rods are capable of being moved. This change should make clear the specified condition (control rod drive system energized), to ensure that compliance is maintained.

4. The APPLICABILITY requirement was inadvertently listed as only MODE 1 for Unit 1. The Unit 2 specification was inadvertently taken directly from the Standard Technical Specifications. This specification is not applicable to the Salem design, which uses 1 channel per pump instead of two as reflected in the Standard Technical Specifications.

This change is requested to make the Technical Specifications for both units agree and to respond to a specific NRC request for the correction of Unit 1 in Enclosure 1 to Generic Letter B2-16, Status Summary of NUREG-0737 Technical Specifications for Salem 1 and 2.

This change supersedes LCR B4-15, dated March 15, 1986.

5. This change corrects a typographical error in the action statement, which currently allows only one hour for surveillance testing. Unit 1 Functional Unit 4b, Action 13 was previously changed to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by Amendment 60.

Action 13 for Unit 1 is equivalent to Action 20 for Unit 1 Functional Unit Ba and Unit 2, Functional Units 4b and Ba. The proposed change to two hours brings the specifications into conformance with the Westinghouse NLR-NB9033

'- r Standard Technical Specifications, and makes similar surveillance test requirements consistent throughout Table 3.3-3.

6. Action Statement 24 for an inoperable radiation monitoring system channel currently refers to Specification 3.4.6.1, the specification for steam generators. It is being corrected to refer to Specification 3.4.7.1 for reactor coolant system leak detection.

7. Currently, there are two specifications numbered 4.4.7.2. They are being renumbered to 4.4.7o2ol and 4.4.7.2.2 for clarity.

8. The SJ-144 valves are described in the table as being in high-pressure safety injection lines to the RCS hot legs. They are actually in the lines to the cold legs.

Significant Hazards Consideration The proposed changes to the Technical Specifications do not involve a significant hazards consideration because operation of Salem Units 1 and 2 in accordance with these changes would not:

A. Involve a significant increase in the probability or consequences of an accident previously evaluated.

1. Changing the required number of operable channels from 4 to 3 corrects a typographical error. Operation with a minimum of 3 channels has been previously reviewed and approved for a 4 loop plant via the Westinghouse Standard Technical Specifications (STS), Rev. 4 (NUREG-0452). This change will provide necessary flexibility in operations. Since this requirement was previously approved, it will not increase the probability or consequences of a previously evaluated accident.

2. The proposed change does not change the Applicable Modes requirements, it only provides clarification to ensure proper interpretation. As such, the proposed change will not increase the probability or consequence of a previously evaluated accident.

• 3. The proposed change only changes the description of the Functional Unit to provide clarification. As such, the proposed change will not increase the probability or consequence of a previously evaluated accident.

4. Adding Mode 2 to the applicable mode column for Unit 1 corrects a typographical error and makes Unit 1 consistent with Unit 2 and the STS. Modification of the NLR-N89033

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Unit 2 channel information corrects the Technical Specifications to accurately reflect the design of Salem Unit 2. The incorrect information is a result of improperly using the STS during drafting of the Unit 2 specifications. Correction of this typographical error will not increase the probability or consequence of a previously evaluated accident since the Technical Specifications will now be accurate, and reflect previously approved Technical Specifications (Unit 1).

5. Extending the allowable bypass time from 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is consistent with the requirements of the STS and with other action statements for similar equipment in Table 3.3-2. Since this bypass time has been previously reviewed via the STS and Unit 1 Amendment 60 and can be considered an administrative change, the proposed change will not increase the probability or consequence of an accident that has been previously evaluated.

6. Correction of a typographical error so that the action statement references the correct section assures that proper actions will be taken. This change does not increase the probability or consequences of a previously evaluated accident.

7. Renumbering of a specification is purely an adminis-trative change which allows for easier procedural references. As such the proposed change will not increase the probability or consequence of a previously evaluated accident.

8. The proposed change corrects an improper description of a component and as _such is an admiilistrati ve change. As such the proposed change will not increase the probabil-ity or consequence of a previously evaluated accident.

B. It does not create the possibility of a new or difference kind of accident previously evaluate.

As demonstrated above, all of the proposed changes could be considered to be typographical or changes made for consistency or clarification. As such these changes have either been previously reviewed via the STS or are purely administrative and would not create the possibility for a new or different type of accident.

c. It does not involve a significant reduction in a margin of safety.

As discussed above, these changes are administrative and do not change the Technical Specifications in a way that would reduce the margin of safety.

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'Conclusion Based on the above discussions, PSE&G has concluded that the proposed changes satisfy the criteria for a no significant hazards consideration.

NLR-N89033 I_