ML18094B384

Requests Waiver of Compliance from Tech Spec 3.7.1.5 Re MSIV & Tech Spec 3.0.3.Relief Requested to Support Special Test That Will Be Performed in Operational Mode 2 Prior to Shutdown for Upcoming Refueling & Maint Outage at Unit

ML18094B384
Person / Time
Site:	Salem
Issue date:	03/29/1990
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N90056, NUDOCS 9004130160
Download: ML18094B384 (8)

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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 609-339-1200 Vice President - Nuclear Operations MAR 2 9 1990 NLR-N90056 United states Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR REGIONAL WAIVER OF COMPLIANCE TECHNICAL SPECIFICATIONS 3/4.7.1.5 & 3.0.3 FACILITY OPERATING LICENSE DPR-75 SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 Public Service Electric and Gas Company (PSE&G) hereby requests waiver of compliance from the provisions of Technical Specification 3.7.1.5, Main Steam Line Isolation Valves (MSIV's),

and 3.0.3. As discussed in Attachment 1 to this letter, PSE&G's conclusion is that granting this request would involve neither a significant hazards consideration nor any irreversible environmental consequences.

This relief is requested to support a special test that will be performed in Operational Mode 2 (Startup) prior to shutdown for the upcoming refueling and maintenance outage at Unit 2. The test will be a modified version of the stroke test performed per Surveillance Requirement 4.7.1.5. It is being performed in order to help determine the root cause of previous failures to meet the stroke time acceptance criteria of five*seconds.

The requested duration of the waiver is from initial entry to Mode 2 (Startup) prior to Unit 2*ts fifth refueling and maintenance outage, until subsequen~ entry to Mode 4 (Hot Shutdown) . *,_

Regional Waiver of Compliance is being\equested because compliance with the existing Action statements would impose undue restrictions on performance of MSIV testing. Since the test is scheduled for approximately 10:00 PM on Friday, March 30, PSE&G requests expeditious review of this submittal.

Document Control Desk ilAR 2 9 1990 NLR-N90056 This request has been reviewed and recommended for approval by the Salem Generating Station Station Operations Review Commi~tee.

c Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector 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

NLR-N90056

• ATTACHMENT 1 I. TECHNICAL SPECIFICATION 3/4.7.1.5 AND 3.0.3 Salem Unit 2 Technical Specification 3.7.1.5 requires that each MSIV remain operable in modes 1, 2, and 3 (Power Operation, startup and Hot Standby, respectively). The Action Statements allow continued operation with one inoperable MSIV provided that it is maintained closed.

Specification 4.7.1.5 requires that each MSIV be demonstrated operable by verifying full closure within 5 seconds when tested pursuant to Specification 4.0.5.

Technical Specification 3.0.3 requires, in part, that "when a Limiting Condition for Operation is not met except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the specification does not apply . . . 11 II.

SUMMARY

OF CURRENT SITUATION Surveillance testing of the Unit 2 MSIV's was last performed during a controlled shutdown for maintenance on October 14, 1989.

As detailed in Licensee Event Report 50-311/89-016, three out of four MSIV's failed to close within five seconds. The unit was brought to mode 4 (Hot Shutdown) in accordance with Technical Specification 3.0.3. The MSIV's were successfully retested and declared operable following maintenance and troubleshooting of the MSIV hydraulic systems. However, the root cause of the closure time problem has not been conclusively identified.

A safety evaluation to assess the significance of the closure times was performed. This evaluation indicated that the slowest actual closure time (approximately 7.5 seconds) would not have invalidated the conclusions of the licensing basis safety analyses.

Investigations into the root cause of the slow closure times are continuing. PSE&G is maintaining a dialogue with nuclear utilities which have experienced similar problems. Experience at these utilities indicates that water accumulation increases the time required for the top of the MSIV's lower cylinder to exhaust steam through the vent lines, causing an increase in the valve closure time. A comparison of Salem's valve configuration, test procedures and test results to that of the other utilities has not conclusively identified a water accumulation problem at Salem. A significant part of identifying the root cause is data collection during MSIV testing. PSE&G plans to perform a special confirmatory test of the MSIV's while shutting down for the upcoming refueling and maintenance outage.

In the event that an MSIV is determined to be inoperable, Technical Specification 3/4.7.1.5 does not contain provisions to allow cycling to reestablish operability during modes 2 and 3.

If more than one MSIV is inoperable, actions to bring the unit to mode 4 (Hot Shutdown) would be required pursuant to Technical Specification 3.0.3. Because the MSIV emergency closure feature relies on Main Steam pressure_, testing is not possible in mode 4.

In addition, forced shutdown to mode 4 would have an adverse impact on the shutdown evolutions planned for the refueling and maintenance outage (reactor coolant system degassing, etc.).

In order to assure proper operation of the MSIV hydraulic system, the MSIV's are opened when the differential pressure across the valve is 50 psi or less. Opening MSIV's serves to lower the differential pressure across the MSIV's that are closed.

Conversely, closing MSIV's makes it more difficult to maintain acceptable differential pressures without decreasing total main steam line pressure. This situation is exacerbated by the fact that existing minor steam line leaks (which have been identified for repair) make it impractical to balance the pressure to open the valves. Therefore, in order to assure that the test may be successfully completed for all MSIV's, it is desirable to be able to keep open MSIV's with stroke times between five and eight seconds.

This situation could not be avoided for two reasons:

1) The special test for which this relief is requested will be performed in Mode 2, thereby requiring a planned shut.down.

The fifth refueling outage is the first planned shutdown (not initiated by a Technical Specification Action Statement) subsequent to experiencing the slow MSIV closure times in October, 1989. Therefore, the schedule for this request is based on the refueling and maintenance outage schedule.

2) The requested waiver is necessary to allow performance of the special test to assess the root cause of MSIV slow closure. Permanent provisions similar to those requested herein will be submitted as a License Change Request for Salem Units 1 and 2. PSE&G's Determination of No Significant Hazards Consideration, based on evaluations to assess the impact of increasing the allowable MSIV closure time, has recently been completed. There is an important distinction between this requested waiver and the License Change Request (LCR). The LCR will propose that the acceptable valve closure time is increased from 5 to 8 seconds. This request proposes to allow MSIV's that stroke between 5 and 8 seconds be allowed to remain open, but only for the duration of the remainder of the special test. All MSIV's which close in greater than 5 seconds during the special test will be declared inoperable. All MSIV's will

be verified Operable while returning to power following the refueling and maintenance outage.

Given the special nature of the test, and the short period of time between completion of the (LCR) and the scheduled performance of the proposed test, PSE&G believes that the situation was unavoidable and that a Regional Waiver of Compliance is the appropriate mechanism for the requested relief.

III. REQUEST FOR REGIONAL WAIVER OF COMPLIANCE PSE&G hereby requests a waiver of compliance for the requirements of Salem Unit 2 Technical Specification 3.7.1.5. Specifically, the following provisions are requested:

With one or more MSIV inoperable in mode 2 or 3, operation in mode 2 or 3 may proceed, subject to the following:

1) MSIV(s) declared inoperable because their stroke times are greater than 8 seconds are maintained closed.

2) MSIV(s) declared inoperable because their stroke times are greater than 5 seconds but less than or equal to 8 seconds may remain open for the remainder of the time that the waiver is in effect.

3) Inoperable MSIV(s) may be cycled during operation in Mode 2 or 3 to collect additional valve operability data.

4) The requirement to enter Technical Specification 3.0.3 in the event that more than one MSIV is declared inoperable is waived.

5) The above provisions are effective upon entry into Mode 2 prior to the fifth refueling outage, and expire upon subsequent entry into Mode 4.

If approved, the request will preclude entry into Technical Specification 3.0.3 in the event that more than one MSIV is inoperable. Since Technical Specification 3.0.3 would require initiation of actions to enter mode 4 within one hour, PSE&G is requesting that this request be approved prior to the commencement of MSIV testing, which is scheduled for approximately 10:00 PM on Friday, March 30, 1990.

IV. COMPENSATORY MEASURES Based on the justification presented below, no additional compensatory measures are needed to support this request.

V. JUSTIFICATION FOR THE PROPOSED WAIVER OF COMPLIANCE This requested Waiver of Compliance is intended to allow for the performance of a special confirmatory test of the MSIV's during shutdown for the Salem Unit 2 fifth refueling outage. The test will be a modified version of the full closure stroke time test performed per Surveillance Requirement 4.7.1.5. A 10CFR50.59 evaluation for modifying the surveillance test procedure has determined that the test will not involve an Unreviewed Safety Question.

Justification for Proposed Time Duration of the Request PSE&G is requesting that the proposed waiver of compliance be effective upon entry into Mode 2 prior to the fifth refueling and maintenance outage, and expire upon subsequent entry into Mode 4.

The test will be performed in Mode 2. The proposed request includes a waiver of the requirements of Technical Specification 3.0.3, which would otherwise require entry into Mode 4 if more than one MSIV is declared inoperable. A required Mode 4 entry may result in premature termination of the test and complications in the orderly shutdown for the refueling and maintenance outage.

Therefore, the proposed time duration is necessary to assure that the performance of the special test is not adversely affected by the Technical Specification requirements.

Determination of No Significant Hazards Consideration This proposed Waiver of Compliance:

1) Does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Inoperable MSIV's with stroke times greater than 8 seconds will be maintained closed, except for brief periods during cycling to collect additional valve operability data. MSIV's are performing their safety function when they are closed.

MSIV's with stroke times between 5 and 8 seconds that remain open would not involve a decrease in safety. An evaluation has been performed to demonstrate that an 8 second MSIV stroke time would not invalidate the results of the analyses supporting Salem Generating Station's current licensing basis. A description of this evaluation will be provided in a separate submittal supporting a proposed amendment to the Salem Technical

Specifications. All MSIV's with stroke times greater than 5 seconds will be declared inoperable while the requested waiver is in effect.

cycling the inoperable MSIV's will be performed in accordance with approved plant procedures for valve stroke time testing. A special test procedure, based on the current surveillance procedure, has been prepared in accordance with 10CFR50.59.

This request proposes allowing inoperable MSIV's to be cycled without first requiring entry to Mode 4 or lower. Inoperable valves will be closed if they are not being stroke tested per the special procedure. Requiring entry to Mode 4 prior to allowing a valve to be retested does not provide any reduction in probability or consequences of an accident *.

The automatic closure logic for** the MSIV' s will not be defeated during the testing. Open MSIV's will be able to receive their ESF steam line isolation closure signals while testing is in progress.

Therefore, the proposed waiver does not involve an 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 requested waiver does not introduce any design changes to the Salem Generating Station. The only requested provision that allows a different configuration is the one that allows MSIV's with stroke times between 5 and 8 seconds to remain open for the duration of the test. PSE&G's conclusion, based on an evaluation of increased closure times, is that an 8 second stroke time does not involve a Determination of No Significant Hazards Consideration. The basis for this conclusion will be submitted in support of a License Change Request.

None of the provisions requested herein introduce any new accident scenarios to the Salem Generating Station. Therefore, 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.

Based on PSE&G's conclusion regarding an 8 second MSIV stroke time described above, allowing valves with stroke times less than 8 seconds to remain open during the special test does not involve a reduction in a margin of safety. None of the other requested provisions potentially affect safety margins. Therefore, the proposed change does not involve a reduction in a margin of safety.

Determination that the Request does not Involve Irreversible Environmental Consequences The requested waiver provides Technical Specification relief to allow performance of a special test of the MSIV's. Neither the requested waiver nor the test allow for any increase in effluents that may be released offsite. The test does not involve an increase in radiation exposure to personnel. As provided above, PSE&G's conclusion is that the proposed waiver does not involve a Determination of No Significant Hazards Consideration.

Therefore, the request does not involve any irreversible environmental consequences.