ML18095A517
| ML18095A517 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/02/1990 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18095A518 | List: |
| References | |
| LCR-90-12, NLR-N90180, NUDOCS 9010150171 | |
| Download: ML18095A517 (6) | |
Text
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 OCT 0 2 1990 NLR-N90180 LCR 90-12 United States Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR LICENSE AMENDMENT REACTOR TRIP SYSTEM SURVEILLANCE REQUIREMENT 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 Unit Nos. 1 and 2.
Pursuant to the requirements of 10CFR50.91(b)(l), a copy of this request for amendment has been sent to the state of New Jersey.
This amendment request modifies Technical Specification Table 4.3-1, Reactor Trip system Instrumentation Surveillance Requirements, to increase the test interval for Functional Unit 19, Safety Injection Input From SSPS.
The proposed change would make the test interval consistent with the interval for the remainder of the automatic actuation logic for the Reactor Protection System.
Editorial changes to Tables 3.3-1 and 4.3-1 are also being proposed. contains the description and justification for the change, including PSE&G's Determination of No Significant Hazards Consideration. contains the Technical Specification pages revised with pen and ink changes.
PSE&G requests a License Amendment for immediate implementation following NRC review and approval.
Affidavit Attachments Sincerely, floOI
'1v*-
Document Control Desk NLR-N90180 C
Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. T. Martin, 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 OCT O 2 1990
STATE OF NEW JERSEY
)
)
SS.
COUNTY OF SALEM
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REF: NLR-N90180 LCR 90-12 Stanley 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,October 2, 1990
, 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
/J)._/Jl day of !Qe,,,fpve/v, 1990 Q/'Mia.J~ '--t1'.lpAM(Li}
Notary Public of New Jersey My Commission expires
NLR-N90180 ATTACHMENT 1 I.
Description of Change Revise Salem Unit Nos. 1 and 2 Technical Specifications as follows:
- 1)
Change Functional Unit 19 on Tables 3.3-1 and 4.3-1 from "Safety Injection Input from SSPS" to "Safety Injection Input from ESF".
- 2)
Add a Note (5) to the Channel Functional Test of Functional Unit 19 on Table 4o3-l.
Note (5) states "Each train or logic channel shall be tested at least every 62 days on a STAGGERED TEST BASIS."
The present Technical Specifications require the Channel Functional Test for Functional Unit 19 to be performed monthly.
II.
Reason for the Proposed Change
- 1)
"Safety Injection Input from ESF" more accurately describes the portion of the reactor trip logic that is addressed by Functional Unit 19 of the affected tables.
The Solid State Protection System (SSPS) performs input, logic and output functions for both the Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS).
The purpose of Functional Unit 19 is to assure that when the actuation logic for Safety Injection is satisfied in ESFAS, a reactor trip signal is generated.
- 2)
The addition of Note (5) to the Channel Functional Test requirements will reduce the number of channels tested per month from two to one.
.The proposed test frequency is consistent with the Surveillance Requirements for Reactor Trip System Actuation Logic (Table 4.3-1, Functional Unit 22), and ESFAS Automatic Actuation Logic (Table 4.3-2).
III. Justification for the Proposed Change
- 1)
Changing the name of Functional Unit 19 does not change any Technical Specification requirements.
The change is being proposed to clarify that the Safety Injection signal, which is an ESF, results in a reactor trip.
"Reactor Trip from ESF" is consistent with Westinghouse Standard Technical Specifications and Salem Technical Specification Table 3.3-2.
- 2)
Channel Functional Testing of the Automatic Actuation Logic for the RPS and ESFAS is presently required on a 62 day staggered Test Basis.
The only exception is Functional Unit 19 of Table 4.3-1, which requires a Channel Functional Test once per 31 days for each train.
There is no technical basis for testing Safety Injection input to Reactor Trip actuation logic more frequently than the automatic actuation logic for the RTS and ESFAS in general.
The present Technical Specification surveillance frequency is consistent with the earlier revisions of the Westinghouse Standard Technical Specifications (e.g., Revision 2).
The earlier Standard Specifications were based on relay system design, as opposed to the Solid State Protection systems (SSPS) in use at Salem.
The relay systems consisted of separate groups of cabinets for the RTS and ESFAS systems.
There was an identifiable input signal from Safety Injection to Reactor Trip.
Therefore, a monthly Channel Functional Test was specified, which is consistent with the other individual functions for reactor trip (e.g., Pressurizer Pressure -
High).
The more current revisions of Westinghouse Standard Technical Specifications (e.g., Revision 4) are more appropriate for SSPS systems.
Because the SSPS performs ESFAS and RTS functions utilizing logic cards, testing Functional Unit 19 is performed as part of the test of Automatic Actuation Logic for RTS/ESFAS.
Reactor Trip from Safety Injection is part of the RPS logic, internal to SSPS.
Therefore the Channel Functional Test of Functional Unit 19 is actually a logic test, rather than a test of a discrete input to the Reactor Trip System.
Salem Technical Specifications require logic testing once per 62 days on a Staggered Test Basis.
However, requiring monthly testing of Functional Unit 19 in effect requires monthly Automatic Logic Testing.
Therefore, the proposed change is consistent with generally accepted testing requirements for RTS and ESFAS.
That is, Functional Units providing input to RTS/ESFAS receive a Channel Functional Test monthly, whereas Automatic Actuation Logic is tested on a 62 day staggered Test Basis.
In Revision 4 of the Westinghouse Standard Technical Specifications, the Safety Injection Input from ESF is tested on a refueling cycle, via a Trip Actuating Device Operational Test ("Channel Functional Test" is no longer used in Westinghouse Standard Technical Specifications).
This test is comparable to the 18 month manual SSPS functional input check presently required at Salem.
IV.
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The changes proposed herein for the Salem Generating Station Unit Nos. 1 and 2 Technical Specifications:
(1) do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change of Functional Unit 19 of Tables 3.3-1 and 4.3-1 from "Safety Injection Input from SSPS" to "Safety Injection Input from ESF" does not substantively change any Technical Specification requirement. It is intended to more accurately describe the function, whose purpose is to assure that a Safety Injection signal results in a Reactor Trip.
Safety Injection is an Engineered Safety Feature (ESF) function.
Reactor Trip system {RTS) and Engineered Safety Feature Actuation System (ESFAS) functions, which comprise the Reactor Protection System (RPS), are performed by the Solid State Protection System (SSPS).
The proposed change to the Safety Injection Input from ESF Channel Functional Test frequency {Table 4.3-1) is consistent with the present RTS/ESFAS testing requirements at Salem Generating Station.
Because Functional Unit 19 is a logic function internal to SSPS, the proposed test interval of 62 days is consistent with Automatic Actuation Logic testing of RTS/ESFAS in general.
The monthly test frequency presently required is more appropriate for the Functional Units that provide an identifiable input to the RPS from a process parameter (e.g.,
Pressurizer Pressure - High).
The monthly requirement for Functional Unit 19 is based on earlier revisions of Westinghouse Standard Technical Specifications, which were more appropriate for RPS and ESFAS systems using relays instead of solid state circuits.
In the relay systems, RTS and ESFAS functions were performed by separate sets of cabinets.
The Safety Injection signal provided a discrete input from the ESF cabinets to the Reactor Trip function, thereby warranting monthly testing.
Testing Automatic Actuation Logic on a 62 day Staggered Test Basis has been determined to provide an acceptable level of safety.
Since Functional Unit 19 is part of the logic, testing should also be required on the same frequency as the rest of the RPS logic.
Therefore, the proposed change does not involve a significant increase in the probability or consequences in an accident previously evaluated.
(2) do not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change does not involve any changes to RTS/ESFAS actuation logic, nor does it involve any design changes or new configurations.
Therefore, the proposed change does not introduce the possibility for any new or different kind of accident.
{3) involve a significant reduction in a margin of safety.
The change in the testing frequency will be consistent with the Automatic Actuation Logic testing frequency that has previously been shown to assure an acceptable margin of safety with respect to RTS/ESFAS reliability.
The proposed change does not involve a significant reduction in any margin of safety.