ML18094B141
| ML18094B141 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/20/1989 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18094B142 | List: |
| References | |
| GL-89-14, NLR-N89208, NUDOCS 8911060048 | |
| Download: ML18094B141 (7) | |
Text
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i 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 October 20, 1989 NLR-N89208 United states Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR AMENDMENT SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 In accordance with the requirements of 10CFR50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits a request for amendment of Facility Operating Licenses DPR-70 and DPR-75 for Salem Generating Station, Unit Nos. 1 and 2, respectively.
In accordance with 10CFR50.91 (b) (1) requirements, a copy of this request has been sent to the state of New Jersey.
The proposed change modifies Technical Specification Section 4.0.2 and the associated Bases, to remove the 3.25 surveillance limit.
This change is consistent with the guidance provided in Generic Letter 89-14.
The Generic Letter encouraged licensees to amend plant Technical Specifications consistent with the guidance provided.
This amendment request is therefore deemed to be a Category 2 change. includes a description, justification and significant hazards analysis for the proposed change.
Attachment 2 contains the Technical Specification pages revised with pen and ink changes. contains the Technical Specification pages with the changes incorporated.
This submittal includes one (1) signed original, including affidavit, and thirty seven (37) copies pursuant to 10CFR50.4 (b)
(2) (ii).
~~~~~~~~~~~~~~-\\
8911060048 991020 PDR ADOCK 05000272 p
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Document eontrol Desk NLR-N89208 2
10-20-89 Should you have any questions regarding this transmittal, please feel free to contact us.
- Attachment c
Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Sincerely, Mr. w. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
REF:
NLR-N89208 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 of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated October 20, 1989, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscribed and Sworn to before me this dlOY-fz day of
!f('_,'/o ~ 1989 L(,t. -, l_,.11, C/'JA /l, A IA,dt'
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Notary Public of New Jersey My-Commission expires on w.mnL r:t rn:mmt'UJ..
NOTMV Ptmuc OF i~EW JERSEY My Commissio11 E~i;iras May 6. 1993
PROPOSED LICENSE CHANGE SALEM GENERATING STATION UNIT NOS. 1 AND 2 ATTACHMENT 1 LCR 89-13 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 I.
Description of Change In accordance with the guidance provided in NRC Generic Letter 89-14, Technical Specification Section 4.0.2 is modified to remove the 3.25 limit.
The associated Bases Section is updated to reflect this change.
II.
Reason for the Chang~
The removal of the 3.25 limit provides greater flexibility for the use of the provision for extending surveillance intervals, reduces the administrative burden associated with its use, and has a positive effect on safety.
The NRC encourages licensees to modify their Technical Specifications consistent with the guidance provided in Generic Letter 89-14.
The suggested changes have been reviewed by PSE.&G and are considered an improvement to the Salem Generating Station Technical Specifications.
III. Justification for Change The NRC staff has concluded that the removal of the 3.25 limit from Specification 4.0.2 results in a greater benefit to safety than limiting the use of the 25% allowance to extend surveillance intervals.
This safety benefit is incurred when a surveillance interval is extended at a time that conditions are not suitable for performing the surveillance.
Several Technical Specifications require surveillances be performed during a plant shutdown.
When a limit is reached on extending the surveillance interval, a forced plant shutdown to perform these surveillances is generally the only alternative short of a license amendment that defers the performance of the surveillance until the end of the fuel cycle.
A forced shutdown to perform these surveillances is not justified from a risk standpoint to avoid exceeding the 3.25 limit when exceeding these surveillances is within the 25%
allowance.
Some surveillances are designed to be performed during a refueling outage when the plant is in a desirable condition for conducting these surveillances, the risk of performing some of these surveillances during plant operation is greater than the impact on safety of exceeding the 3.25 limit and using the 25% allowance to extend these surveillances.
The safety benefit of performing these surveillances during a plant shutdown is that systems do not have to be removed from service at a time that they are required to be operable.
Also, there is
the administrative burden associated with tracking the use of the 25% allowance to ensure compliance with the 3.25 limit.
On the basis of these considerations, the removal of the 3.25 limit will have an overall positive impact on safety.
IV.
Significant Hazards Consideration The proposed changes to the Technical Specifications:
- 1.
Do not involve a significant increase in the probability or consequence of an accident previously evaluated.
As stated in Generic Letter 89-14, the removal of the 3.25 limit from Specification 4.0.2 results in a greater benefit to safety than limiting the use of the 25% allowance to extend surveillance intervals.
Therefore, it may be concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change does not adversely affect the design or operation of any system or component important to safety.
No physical plant modifications or new operational configurations result from this change.
Therefore, it may be concluded that the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3.
Does not involve a significant reduction in a margin of safety.
As stated in Generic Letter 89-14, the use of the allowance to extend surveillance intervals by 25% can result in a significant safety benefit.
This safety benefit is obtained when a surveillance interval is extended at a time when conditions are not suitable for performing the surveillance.
The safety benefit of allowing the use of the 25% allowance to extend a surveillance interval outweighs any benefit derived by limiting three (3) consecutive surveillance intervals to the 3.25 limit.
- Therefore, it may be concluded that the proposed change does not involve a significant reduction in a margin of safety.
- v.
Conclusions Based on the guidance provided in Generic Letter 89-14, PSE&G has concluded that the proposed change conforms to this guidance and thus satisfies the criteria for a no significant hazards consideration.
ATTACHMENT 2