ML18094B238

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Application for Amend to License DPR-75,modifying Tech Spec 3.5.2 by Adding Footnote to Surveillance Requirement Stating That one-time Waiver of Max Flow Requirement in Place from 900104 Until Initial Entry Into Mode 5 During Refueling
ML18094B238
Person / Time
Site: Salem PSEG icon.png
Issue date: 01/04/1990
From: Labruna S
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18094B239 List:
References
LCR-90-02, LCR-90-2, NLR-N90005, NUDOCS 9001190043
Download: ML18094B238 (7)
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Text

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Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800 Vice President - Nuclear Operations

  • JAN 0 4 1990 NLR-N90005 LCR 90-02 United states Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

EMERGENCY LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATION 3.5.2 FACILITY OPERATING LICENSE DPR-75 SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 Public Service Electric and Gas Company (PSE&G) hereby submits an emergency request to amend Appendix A of Facility Op~rating Licensing DPR-75 in accordance with 10CFR50.90.

This request modibies Technical Specification 3.5.2, (ECCS Subsystems - Tavg

~350 F), by adding a footnote to Surveillance requirement 4.5.2.h.2.b stating that a one time waiver of the 550 gpm maximum flow requirement is in place from January 4, 1990 until initial entry into Mode 5 during the Unit 2 Fifth Refueling outage.

The requested change is necessary to avoid a plant shutdown and the relatively severe plant transient associated with cooldown and depressurization to support entry into Mode 5 and performance of a new flow test.

The need for this change would not have been foreseen as it is the result of a recently identified error in calculating the actual flow.

The error was discovered during a review of Salem Unit 2 fourth refueling outage surveillance test data.

When the calculational error was corrected, the total pump flow rate was in excess of the value allowed by TS surveillance requirement 4.5.2.h.2.b.

This has resulted-in declaring both trains of ECCS inoperable and entering Specification 3.0.3 *

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I Document Control Desk NLR-N90005 2

~JAN 0 4 1990 It has been determined that the proposed amendment does not involve a significant hazards consideration as defined in 10CFR50.92.

A description of the amendment request and the basis for a no significant hazards consideration determination is

. provided in Attachment 1.

Attachlttent 2 provides the marked up Unit 2 pages.

In accordance with the requirements of 10CFR50.9l(b) (1), a copy of this request has been sent.to the State of New Jersey as indicated below.

PSE&G respectfully requests your immediate attention and issuance of: an emergency amendment.

Should you have any questions; please do not hesitate to contact us.

Affidavit Attachment*

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 New Jersey Department of Environmental Protection Divisiop of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

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STATE OF NEW JERSEY COUNTY OF SALEM

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REF: NLR-N90005 LCR 90-02

s. LaBruna, being duly sworn according to law deposes and says:

I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated January 4, 1990 concerning the Salem Generating Station, Unit No. 2, are true to the best of my knowledge, information and belief.

7 Subscribed and Sworn to before me tht J/1-fi day of9~r*

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1990 Notury Public of New Jersey My Commission expires on

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VANITA FIL M.1\\RSH!\\LL

. NOTARY PUBLIC OF N8i11 JERSEY My Commission E.xpiras May 6, 1993

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NLR-N90005 ATTACHMENT 1 EMERGENCY LICENSE AMENDMENT REQUEST FACILITY OPERATING LICENSE DPR-75 SALEM GENERATING STATION -

UNIT NO. 2 DOCKET NO. 50-311 I.

Description of Proposed Change The proposed change would add a footnote to Surveillance Requirement 4.5.2.h.2.b stating that a one time waiver of the 550 gpm maximum flow requirement is in place from January 4, 1990 until initial entry into Mode 5 during the Unit 2 Fifth Refueling outage.

II.

Reason for Proposed Change During a recent review of surveillance test data obtained during the Unit 2 fourth refueling outage, an error was found in the ECCS flow calculations for the current fuel cycle.

When the error was corrected, the total pump flow rate was in excess of the value allowed by TS surveillance requirement 4.5.2.h.2.b.

The final flow values were 553.14 gpm for No. 21 CCP and 554.6 gpm for No. 22 CCP.

This has resulted in declaring both trains of ECCS inoperable and entering specification 3.0.3.

This emergency license amendment is therefore required to prevent shutdown of SGS Unit 2.

III. Justification for Proposed Change Operation with existing ECCS conditions will not place the plant in an unsafe condition.

PSE&G believes that there is ample technical justification for the requested relief.

PSE&G has previously evaluated similar conditions at Unit 1 in LER 89-020-00 dated June 14, 1989.

The conditions analyzed in the

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Unit 1 LE~ were on the order of 15% in excess of the 550 gpm requirement.

The existing conditions at Unit 2 are on the order of 1% in excess of the 550 gpm limit.

As a result, the Unit 1 analysis bounds the existing Unit 2 conditions.

The basis for the ECCS upper limit is pump runout protection.

At pump runotit, cavitation could o*ccur.

Cavitation would result from the loss of sufficient suction pressure to the pump.

The required Net Positive Suction Head (NPSH) for the maximum flow is 23 feet.

For accident conditions, the minimum possible RWST tank level reached would be at *15.24 feet, which corresponds to 40 feet available NPSH.

At this minimum RWST tank level, suction is re-aligned to the discharge of the RHR pumps during ECCS actuation.

The minimum NPSH available to the Centrifugal Charging Pumps would occur just before re-alignment with the RWST at 15 feet.

As can be seen from the above data, the available NPSH far exceeds the required amount (i.e., 7-0%)

  • The increased flow rate would place a higher load requirement on the pump motor.

Since the motors of the Unit 1 pumps were determined to be sized to accommodate the increased flow rate, a similar conclusion can be made for the Unit 2 motors since the flow increase is smaller and the Unit 2 motors are identical in design to the unit 1 motors.

The increased horse power required to produce the increased flow would place an additional load on the emergency D/Gs.

Since the increased load for the Unit 1 conditions* would not exceed the allowable 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> continuous load rating, a similar conclusion can be made for the Unit 2 conditions since the flow increase is smaller *

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The expected increased flow to the RCS during postulated ECCS injection and recirculation phases would not impact the cooling function of the system.

We therefore conclude that, with the existing conditions, t~e affected Unit 2 systems and components would be able to perform their intended safety functions, and temporary operation under existing conditions would not adversely affect the health and safety of the public.

Furthermore, we believe that an emergency license change provides a safer course of action than imposing an unnecessarily severe transient to shut down the plant.

IV.

Significant Hazards Consideration Evaluation The proposed change to the SGS Technical Specifications:

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Does not involve a signit'icant increase in the probability or consequences of an accident previously evaluated.

Based on the technical justification provided in Section III, the affected Unit 2 systems and components would be able to perform their intended safety functions during operation under existing conditions.

We therefore conclude that operating with existing ECCS conditions until the Unit 2 Fifth Refueling Outage would not adversely affect public health and safety and would not increase the probability or consequences of a previously analyzed accident.

Does not create the possibility of a new or different kind of accident from any accident previously evaluated

  • The proposed change impacts a plant operating parameter associated with the ECCS system; however, since the affected systems and components can perform their intended safety functions while operating with the modified pump parameter,

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operation on a temporary basis with the modified parameter will not create the possibility of a new or different kind of accident.

Does not involve a significant reduction in a margin of safety.

Based on the technical justification provided in Section III above, the affected Unit 2 systems and/components would be able to perform their intended safety functions during operation under existing conditions.

We therefore conclude that no safety margin will be significantly reduced while operating under existing ECCS conditions.

conclusion As discussed in Item IV above, PSE&G has concl.uded that the proposed change to the Technical Specification does not involve a Significant Hazards Consideration since the change (i) does not involve a significant increase in the probability or consequences of a previously analyzed accident, (ii) does not create the possibility of a new of different kind of accident, and (iii) does not involve a significant reduction in a margin of safety.

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