ML18095A759

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Application for Amends to Licenses DPR-70 & DPR-75, Consisting of Rev 1 to License Change Request 88-06,changing TS Sections 3.0 & 4.0 by Incorporating Provisions of Generic Ltr 87-09
ML18095A759
Person / Time
Site: Salem  PSEG icon.png
Issue date: 02/20/1991
From: Labruna S
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18095A760 List:
References
GL-87-09, GL-87-9, NLR-N90121, NUDOCS 9102270162
Download: ML18095A759 (35)
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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

. fEsi 2 O 1991 NLR-N90121 LCR 88-06, Rev. 1 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REVISED LICENSE AMENDMENT APPLICATION GENERIC LETTER 87-09 CHANGES FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 SALEM GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-272 AND 50-311 This letter constitutes an application for amendment to Appendix A of Facility Operating Licenses DPR-70 and DPR-75 for the Salem Generating station Units 1 and 2 and is being filed in accordance with the. provisions of 10 CFR 50.90. The changes being proposed address a number of problems relative to the existing provisions contained in Sections 3.0 and 4.0 of the Technical Specifications by incorporating the changes endorsed by GenericrLetter 87-09. A brief summary of each of the subject problems is provided below.

The first problem addressed by Generic Letter 87-09 and this license amendment application involves unnecessary restrictions on mode changes imposed by the existing provisions of Specification 3.0.4. The unnecessary restrictions have been caused by inconsistent application of exemptions to Specification P 3.0.4. The solution endorsed by the generic letter allows for a consistent application of the exemptions by modifying Specification 3.0.4 to permit mode changes for Technical Specifications whose action requirements permit unlimited continued operation if compliance with the remedial measures specified in the action statement for the subject Technical Specification is maintained. This solution has been adopted and incorporated into this license amendment application.

The second problem involves unnecessary shutdowns required by Specification 4.0.3 when surveillance intervals are inadvertently  ;*

exceeded. In the generic:: le~ter, the NRC staff has endorsed 24 '. {

hours as an acceptable time interval for completing a missed

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NLR-N90121  ::

  • Document Control Desk
  • FEB 2 o 1991 surveillance when the allowed outage time of the action requirements is less than this limit. Specification 4.0.3 is appropriately modified to incorporate this allowance.

The third problem involves possible conflict between Specification 4.0.4 and the action requirements of individual Technical Specifications. Specification 4.0.4 prohibits mode changes when surveillance requirements have not been performed within the specified surveillance interval. A conflict with individual action requirements exists when a mode change is required as a consequence of the action requirement and a surveillance requirement that becomes applicable as a result of the required mode change has not been performed within the specified surveillance interval. The solution endorsed by the generic letter is to modify Specification 4.0.4 to state that its provisions shall not prevent passage through or to operational modes as required to comply with action requirements. This solution has been adopted and is proposed in this amendment application.

PSE&G originally responded to Generic Letter 87-09 in a license amendment application dated August 8, 1988 (NLR-N88089). The NRC reviewed the original application and identified a number of issues requiring resolution prior to granting approval of the proposed changes. The identified issues were discussed and resolved during a meeting with the NRC staff on March 14, 1989.

Subsequent to the March 14 meeting and prior to submittal of a revised amendment application, the NRC raised additional generic issues and required that these be addressed in the revised application. contains a discussion of each of the original and supplemental issues and describes the manner in which each of the issues was resolved. A revised description, justification, and significant hazards analysis for the proposed changes is included in Attachment 2. Attachment 3 contains a summary showing the proposed disposition of each Technical Specification 3.0.4 exemption relative to retention or removal. An evaluation for each of the Specifications that would receive a relaxation from mode change restrictions with approval of the proposed changes to, Technical Specification 3.0.4 is provided in Attachment 4. - contains the Technical Specification pages revised with pen and ink changes.

Upon NRC approval, please issue a License Amendment which will be effective upon issuance and shall be implemented within 60 days of date of issuance. In accordance with 10 CFR 50.91(b) (1), a copy of this request has been sent to the state of New Jersey as indicated below.

Document NLR-N90121 Cont~hl ~k

  • FEB 2 o 1991 Should you have any questions or comments on this transmittal, do not hesitate to contact us.

Sincerely, Affidavit Attachments {5) 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

COUNTY OF SALEM )

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 FEB 2 0 1991 , concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the.best of my knowledge, information and belief.

1991 Notary 1-Public of New Jersey VANITA M. MARSHALL NOTARY PUBLIC Of r~~ JERSEY

' I ,'

Illy Commission Eltpiras May 6, 1993 My Commission expires on

50-272 SALEM 1 PSE&G DMENT APPLICATION REVISED LIGENSE A,.l\1EN09 CHANGES GENERIC LETTER s7- .

.* 02/20/91. .. 9102270162 REC'D W/LTR DTD

-NOTICE-.

THE ATTACHED FILES ARE OFFICIAL RECORDS OF THE INFORMATION &

REPORTS MANAGEMENT BRANCH.

THEY HAVE BEEN CHARGED TO YOU FOR A LIMITED TIME PERIOD AND MUST BE RETURNED TO THE RE-CORDS & ARCHIVES SERVICES SEC-TION P1-22WHITE FLINT. PLEASE DO NOT SEND DOCUMENTS CHARGED OUT THROUGH THE MAIL. REMOVAL OF ANY PAGE(S) FROM DOCUMENT FOR REPRODUCTION MUST BE RE-FERRED TO FILE PERSONNEL.

-NOTICE-

,1*

ATTACHMENT 1 DESCRIPI'ION OF ISSUES AND RESULTING RESOLUTION REVISED LICENSE AMENDMENT APPLICATION NLR-N90121 GENERIC LETTER 87-09 CHANGES LCR 88-06, REV. 1 SALEM GENERATING STATION FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Introduction After reviewing PSE&G's original amendment application, the NRC identified a number of issues which they felt required further review and resolution prior to granting approval of the proposed changes. These issues (Issues 1 through 4 below) were discussed during a meeting with members of the NRC staff on March 14, 1989.

The NRC documented the resolution of these issues in a letter to PSE&G dated March 29, 1989. Subsequent to the March 14 meeting, the NRC identified a number of generic issues (Issues 5 through 7 below) which PSE&G was requested to address. This attachment summarizes the manner in which each issue was resolved and describes the method by which each resolution has been factored into the present amendment request.

Issue/Resolution 1 PSE&G originally proposed to clarify Specification 3.0.4 by adding the parenthetical phrase "(entrance into a lower OPERATIONAL MODE)" following the word "shutdown". Our purpose in adding the phrase was to provide additional clarification to avoid misinterpretation of the requirement. The NRC staff agreed that such a clarification would be consistent with the intent of the generic letter but felt such a change should be pursued in a generic manner to avoid propagating differences in individual plant Technical Specifications (TSs). During the meeting on March 14, 1989 between PSE&G personnel and members of the NRC staff, it was agreed that PSE&G would either (1) recommend the change to the .Westinghouse Owners' Group (WOG) for inclusion in the MERITS program and, if accepted by the WOG, incorporate the clarification into Specification 3.0.4, or (2) incorporate the clarification into the Bases for Specification 3.0.4. As a result of the timing of the MERITS submittal and our decision that placing the clarification in the Bases would be sufficient, we chose the second option and our revised license amendment application consequently includes a clarifying statement in the Bases for Specification 3.0.4.

Page 1 of 4

Attachment 1 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 Issue/Resolution 2 PSE&G originally chose not to delete the exemptions to Specification 3.0.4. Many action statements with 3.0.4 exemptions still require that some definitive action (e.g.,

collection of grab samples) be taken in a specified time interval. Our purpose in not deleting the exemptions was to avoid concern regarding (1) whether the new 3.0.4 would allow a change in modes prior to completing the definitive actions required by the action statement and (2) the fact that violation of Specification 3.0.4 would occur in addition to violation of the individual specification if a required action were not completed within the allowed time interval following a mode change. These issues were discussed at the March 14 meeting and the NRC staff clarified that the new 3.0.4 allows mode changes prior to completing required actions, but if the actions are not completed within the required time interval, the uncompleted action would constitute a violation of Specification 3.0.4. It was agreed that 3.0.4 exemptions need not be deleted when individual specifications are exempt from both Specifications 3.0.3 and 3.0.4;_however, when the specification is exempt from 3.0.4 but not 3.0.3, the exemption should be dispositioned in accordance with the Generic Letter guidance. This revised amendment application reflects this agreement. In order to avoid confusion regarding the intent of the remaining 3.0.4 exemptions,

  • the Bases for Specification 3.0.4 has been modified to clarify that the portion of 3.0.4 that is exempted by the remaining 3.0.4 exemptions is that portion stating that entry into an operational mode or other specified condition shall not be made when the conditions of the LCO are not met and the associated action requires a shutdown if they are not met within the specified time interval (i.e., Part (a) of Specification 3.0.4).

Issue/Resolution 3 We originally deleted a phrase from the Bases for Specification 4.0.3. The phrase implied that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit for performing missed surveillances applies when mode changes are made under a 4.0.4 exemption. During normal plant startup, conditions required for performing a surveillance requirement might not be attained within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit. Our purpose in proposing this deviation was therefore to avoid problems associated with surveillances which cannot be performed until a given condition is attained. This issue was discussed at the March 14 meeting, and the NRC staff stated their position to be that the time interval, whether it is the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit or the allowed outage time of the action statement, begins when the plant reaches the conditions necessary to perform the test. This issue was resolved by agreeing that the phrase indicating that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit applies during mode changes made under a 4.0.4 exemption should remain, and if a surveillance cannot be Page 2 of 4

Attachment 1 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 performed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit, a change to the individual specification would be proposed. This revised amendment application reflects this agreement. A sentence has been added to the Bases for Specification 4.0.3 to document the the NRC position regarding surveillances which cannot be performed until certain conditions are achieved. In light of the NRC position on this issue, no changes to individual specifications are deemed necessary.

Issue/Resolution 4 PSE&G originally modified a sentence in the Bases for Specification 4.0.4 which implied that all action requirements would delay placing the facility into a lower mode. At the March 14 meeting, it was agreed that the word "would" could be changed to the word "could" in the third paragraph on Page B 3/4.0-6.

This agreement is reflected in our revised amendment application.

Issue/Resolution 5 The NRC expressed a concern regarding prioritization of maintenance on equipment affected by the relaxation in mode change restrictions permitted by the proposed changes to TS 3.0.4. The specific concern was whether the timeliness of repairing inoperable equipment would be affected in cases in which the present TS 3.0.4 requires equipment to be restored to operable status prior to changing modes, but the proposed TS 3.0.4 would allow mode changes and indefinite operation with the equipment inoperable.

Administrative Procedure NC.NA-AP.ZZ-0009(Q), "Work control Process", contains the basic requirements for scheduling and performing corrective maintenance. NC.NA-AP.ZZ-0009(Q)

Attachment 5, "Work Order Priorities", contains the following Corrective Maintenance Outage Priority:

11 01 11 The following types of malfunctions/work activities shall be addressed/performed during an outage.

Corrective Maintenance - Malfunction renders Technical Specification related equipment inoperable or causes the unit to operate in a reduced load capacity. These have the clear potential for developing into a larger problem if left uncorrected.

An inoperable steam generator safety valve (which is presently exempt from TS 3.0.4) is provided as an example of a Category 01 corrective maintenance activity .

  • Page 3 of 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 to NC.NA-AP.ZZ-0009(Q) also prioritizes non-outage related work, based on impact on safe plant operation and the potential for a condition to degrade into a more serious problem.

Based on the controls presently in place, PSE&G believes that no additional measures regarding prioritization of corrective maintenance activities are warranted.

Issue/Resolution 6 The NRC requested assurance that mode changes are controlled so that the relaxation in mode change restrictions permitted by the proposed TS 3.0.4 is implemented in a prudent manner. Salem's Integrated Operating Procedures (IOPs) will be revised to include checklists which must be completed prior to entering higher modes of operation (e.g., Mode 5 to Mode 4). The checklists will identify all Technical Specification Action Statements (TSASs) in effect in the current mode and all TSASs that will be in effect upon entry into the intended mode of operation. Approval of the checklist by the Nuclear Shift Supervisor and the Senior Nuclear Shift Supervisor will be a prerequisite for the mode change.

Issue/Resolution 7 The NRC requested an evaluation of the individual Technical Specifications for which proposed TS 3.0.4 provides relaxation in mode change restrictions. Specifically, PSE&G has been asked to verify that the remedial measures prescribed in the subject TSASs provide an acceptable level of safety to permit the use of the proposed change to TS 3.0.4.

PSE&G, in conjunction with Westinghouse, has completed the requested evaluation. The results of the evaluation are provided in Attachment 4 of this submittal. Based on the results, all affected-TSASs provide an acceptable level of safety to permit the use of the proposed change to TS 3.0.4.

Page 4 of 4

  • ATTACHMENT 2 DESCRIPI'ION OF CHANGES AND SIGNIFICANT HAZARDS EVALUATION LICENSE AMENDMENT APPLICATION GENERIC LETTER 87-09 CHANGES SALEM GENERATING STATION NLR-N90121 LCR 88-06, REV. 1 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 I. Identification of the Proposed Changes The changes described in this amendment application are being proposed in accordance with the guidance provided in NRC Generic Letter 87-09. The proposed changes revise the general requirements on the applicability of limiting conditions for operation and surveillance requirements in Sections 3.0.4, 4.0.3 and 4.0.4 and update the corresponding Bases sections to reflect these modifications. The proposed changes also incorporate NRC proposed improvements to the Bases for unchanged portions of Sections 3.0 and.4.0. The proposed changes are described in further detail below.
1. Changes to Specification 3.0.4 Specification 3.0.4 has been modified in accordance with the guidance in Generic Letter 87-09 by allowing mode changes in accordance with the action requirements when conformance to them permits continued operation for an unlimited period of time. In addition, since the present Technical Specifications (TS) omit the phrase "or to" from the sentence stating that this provision shall not prevent passage through or to operational modes as requ"ired to comply with action requirements, we have made the appropriate correction to bring our existing TS into conformance with the the current Westinghouse Standard TS (NUREG-0452, Revision 4) and the guidance in Generic Letter 87-09. Finally, the sections of this specification have been labeled to avoid confusion and to provide additional clarification.
2. Changes to Specification 4.0.3 Specification 4.0.3 has been modified in accordance with the guidance of Generic Letter 87-09 by incorporating the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance and making the suggested editorial changes.
3. Changes to Specification 4.0.4 Specification 4.0.4 has been modified in accordance with the guidance of Generic Letter 87-09 by incorporating the sentence which clarifies that this specification shall not prevent passage through or to operational modes to comply with action requirements .
  • Page 1 of 8

Attachment 2 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

4. Bases Changes The Bases for Specifications 3.0.4, 4.0.3, and 4.0.4 have been updated to reflect the changes incorporated into the specifications. The Bases for unchanged portions of Sections 3.0 and 4.0 have also been modified in accordance with the guidance in Generic Letter 87-09. As noted in Attachment 1, we have included additional clarification 1) in the Bases for Specification 3.0.4 regarding the word "shutdown" and regarding exemptions to the specification and 2) in the Bases for Specification 4.0.3 regarding the NRC position on when the time interval begins for surveillances which cannot be performed until certain conditions are attained.

An editorial change to the Bases for Specification 3.0.5 is also included. The present Bases, which is based on a standard plant design with two Emergency Diesel Generators (EDGs), is being revised to reflect the fact that Salem Generating Station uses three EDGs. The change does not affect any Technical Specification requirements.

The changes to the Bases for Specification 4.0.2 endorsed by Generic Letter 89-14 were approved by the NRC (Amendment 106 for Unit 1 and Amendment 83 for Unit 2) since our original amendment application was submitted in August 1988 and are consequently reflected on the marked up TS pages of this

  • 5.

submittal.

Chancres to Individual Specifications The 3.0.4 exemptions have been removed for those specifications which meet the modified removal criteria established during the March 14, 1989 meeting.

Attachment 5 contains the revised TS pages showing the specific changes being proposed.

II. Reason for the Proposed Changes NRC Generic Letter 87-09 provides recommendations and guidance for resolving a number of problems encountered relative to the applicability of limiting conditions for operation and surveillance requirements in TS Sections 3.0 and 4.0. The NRC has encouraged licensees to propose changes to their TSs in accordance with the guidance provided in the Generic Letter. The suggested modifications have been reviewed by Public Service Gas and Electric Company (PSE&G) and are deemed to constitute an improvement to the Salem Generating Station TS. PSE&G has therefore decided to propose the enclosed changes in accordance with the guidance provided in the Generic Letter .

  • Page 2 of 8

Attachment 2 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

  • III. Summary of Additional Changes/Clarifications Included Generic Letter 87-09 and its enclosures provide guidance and model specifications for Sections 3.0, 4.0, and their Bases.

While still clearly meeting the intent of the Generic Letter, our proposed changes include a number of additional changes and clarifications. Each of these changes/clarifications is described below.

1. Our proposed changes include additional clarification regarding the meaning of the term "shutdown" as used in Specification 3.0.4. This clarification has been included in the Bases for Specification 3.0.4.
2. The 3.0.4 exemptions have not been removed for specifications which also include a 3.0.3 exemption. In addition, a sentence has been added to the Bases for Specification 3.0.4 to provide clarification regarding interpretation of the remaining 3.0.4 exemptions.
3. The parts of Specification 3.0.4 have been labeled to avoid confusion and to provide additional clarification.
4. A sentence on Page B 3/4.0-6 has been modified. The sentence stating, "When a shutdown is required to comply with action
  • 5.

requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing "would" has been changed to "could".

" The word A sentence has been added to the Bases for Specification 4.0.3 to document the NRC position regarding surveillances which cannot be performed until certain conditions are achieved.

IV. Justification for the Proposed Changes A. Specification 3.0.4 Changes Specification 3.0.4 currently states that entry into an operational mode or other specified condition shall not be made unless the LCO is met without reliance on the provisions of the action requirements. In general, individual specifications that have action requirements which allow continued operation contain exemptions to Specification 3.0.4; however, exemptions to 3.0.4 have not been consistently applied and their bases are not well documented.

As stated in Generic Letter 87-09, Specification 3.0.4 unduly restricts facility operation when conformance to the action requirements provides an acceptable level of safety for continued operation. For an LCO that has an action Page 3 of 8

Attachment 2 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 requirement permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition in accordance with the action requirements is consistent with the NRC's regulatory requirements for an LCO. As stated in the Generic Letter, the restriction on a change in operational modes or other specified conditions should apply only where the action requirements establish a specified time interval in which the LCO must be met or a shutdown of the facility would be required.

B. Specification 4.0.3 Specification 4.0.3 states that failure to perform a surveillance within.the specified time interval shall constitute a failure to meet the operability requirements of the LCO. Therefore, if a surveillance requirement is not met as a result of failure to schedule the required surveillance test, the LCO would not be met and the action requirements must be followed as when the test shows that the system or component is inoperable. Some action requirements have short allowable outage limits and do not establish a practical time limit for the completion of the surveillance.

As stated in the Generic Letter it is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed. The vast majority of surveillances demonstrate that systems or components in fact are operable. Since the allowable outage time limits of some action requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements may apply, the Generic Letter proposes a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit for conducting missed surveillances for action requirements having allowable outage times less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit was developed based on consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as the safety significance of the delay in completion of the surveillance. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit balances the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with action requirements before the surveillance can be completed.

c. Specification 4.0.4 Specification 4.0.4 prohibits entry into an operational mode or other specified condition when surveillance requirements have not been performed within the specified surveillance Page 4 of 8

Attachment 2 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

  • interval. A conflict can arise when a mode change is required as a consequence of shutdown action requirements and when the surveillance requirements that become applicable have not been performed within the specified surveillance interval. The potential for a plant upset and challenge to safety systems is heightened if surveillances are performed during shutdown to comply with action requirements. As stated in the Generic Letter, it is not the intent of Specification 4.0.4 to prevent passage to or through operational modes to comply with action requirements and it should not apply when mode changes are imposed by action requirements. *
v. Significant Hazards Consideration Evaluation The proposed changes to the SGS Technical Specifications:
1. Do not involve a significant increase in the probability or consequences of an accident previously evaluated.

A. Changes to Specification 3.0.4 The existing requirements of Specification 3.0.4 prohibit entry into an operational mode or other specified condition unless the LCO

  • is met without reliance on the action requirements. In general, specifications that have action requirements that allow unlimited continued operation contain exemptions to Specification 3.0.4; however, the 3.0.4 exemptions have not been consistently applied and some specifications which have action statements which provide an acceptable level of safety to permit continued operation for an unlimited amount of time do not contain exemptions to the requirements of Specification 3.0.4. Entry into an operational mode or other specified condition in accordance with the action requirements is consistent with the NRC's regulatory requirements for an LCO that has an action requirement permitting unlimited continued operation. The NRC staff has stated in Generic Letter 87-09 that Specification 3.0.4, as it currently exists, unduly restricts facility operation when conformance to the action requirements provides an acceptable level of safety for continued operation. The changes being proposed to Specification 3.0.4 therefore allow entry* into an operational mode or other specified condition in accordance with the action requirements for all LCOs having action requirements which permit continued operation for an unlimited amount of time, and thereby provide for consistent application of the provisions of this specification. Each LCO affected by the proposed changes to Specification 3.0.4 has been evaluated. The evaluation has verified that the remedial measures contained in the action Page 5 of 8

Attachment 2 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

  • requirements for each affected LCO provide an acceptable level of safety to permit the use of the_proposed Specification 3.0.4. Since conformance to the action requirements for the affected specifications establishes an acceptable level of safety for unlimited continued operation, the proposed changes to Specification 3.0.4 will not significantly increase the probability or consequences of a previously analyzed accident or malfunction of equipment important to safety.

B. Changes to Specification 4.0.3 Since the vast majority of surveillance tests demonstrate that systems or components are operable, it is overly conservative to assume that a system or component is inoperable solely because a surveillance test has not been performed. When a surveillance is missed, the question is primarily one of unverified operability which can be demonstrated by performing the specified surveillance test. Specification 4.0.3, as it currently exists, assumes immediate equipment inoperability. Since the allowable outage time limits of some action requirements do not provide an appropriate time period for performing a missed surveillance before shutdown requirements apply, a time limit of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is being proposed as an acceptable period in which to complete a missed surveillance test. As stated in the generic

  • letter, the proposed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period balances the risks associated with allowing continued operation during completion of the missed surveillance against the risks associated with the potential for a plant upset or challenge to safety systems when the alternative is a plant shutdown to comply with the action requirements before the surveillance can be completed. The proposed changes to-Specif ication 3.0.4 will therefore not significantly increase the probability or consequences of any previously -

analyzed accident or malfunction of equipment important to safety.

c. Changes to Specification 4.0.4 As stated in the Generic Letter, it is not the intent of Specification 4.0.4 to to prevent passage to or through operational modes to comply with action requirements and it should not apply when mode changes are imposed by action requirements. The potential for a plant upset and challenge to safety systems is heightened if surveillances are performed during shutdown to comply with action requirements.

Therefore, the proposed change will not significantly increase the probability or consequences of a previously analyzed accident or malfunction of equipment important to safety *

  • Page 6 of 8

~ttachment 2 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

2. Do not create the possibility of a new or different kind of accident from any accident previously evaluated.

A. Changes to Specification 3.0.4 Implementation of the proposed change to TS 3.0.4 has been evaluated and determined to be consistent with the present accident analyses. The proposed relaxation in mode change restrictions for those TS which presently allow unlimited continued operation upon successful completion of remedial measures will not introduce any new accident scenarios for the Salem Generating Station. The proposed changes will therefore not create the possibility of a new or different kind of accident from any accident previously evaluated.

B. Changes to Specifications 4.0.3 and 4.0.4 The proposed changes to Specifications 4.0.3 and 4.0.4 do not involve any modifications to existing plant equipment, do not alter the function of any plant systems, and do not introduce any new operating configurations or new modes of plant operation.

The proposed changes will therefore not create the possibility* of a new or different kind of accident from any accident previously evaluated .

  • 3. Do not involve a significant reduction in a margin of safety.

The proposed changes do not involve a significant reduction in any margin of safety. Conversely, the proposed changes provide numerous benefits as described below.

A. Changes to Specification 3.0.4 The changes to Specification 3.0.4 provide for consistent application of 3.0.4 exceptions. Each TS affected by the proposed changes to Specification 3.0.4 have been evaluated. The evaluation has verified that the remedial measures contained in the action requirements for each affected LCO provide an acceptable level of safety to permit the use of the proposed Specification 3.0.4.

B. Changes to Specification 4.0.3 The changes to Specification 4.0.3 provide a time limit for performing missed surveillances which balances the risks associated with allowing continued operation during completion of the missed surveillance against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a plant shutdown to comply with the action requirements before the surveillance can be completed.

Page 7 of 8

Attachment 2 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

c. Changes to Specification 4.0.4 The proposed changes to Specification 4.0.4 eliminate potential conflict between individual TSs, Specification 4.0.3, and Specification 4.0.4.

As a result, the potential for unnecessary shutdowns, delayed start-ups, plant upsets, and challenges to safety systems will be reduced by implementing the proposed changes, and the proposed changes will not result in a reduction of any margin of safety.

VI. Conclusion As discussed in Item V above, PSE&G has concluded that the proposed changes to the Technical Specifications do not involve a significant hazards consideration since the changes (i) do not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) do not create the possibility of a new or different kind of accident from any accident previously evaluated, and (iii) do not involve a significant reduction in a margin of safety .

Page 8 of 8

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  • ATTACHMENT 3 DISPOSITION OF 3.0.4 EXEMPTIONS REVISED LICENSE AMENDMENT APPLICATION GENERIC LETTER 87-09 CHANGES SALEM GENERATING STATION NLR-N90121 LCR 88-06, REV. 1 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Introduction Specifications containing 3.0.4 exemptions may be placed into one of three categories: (1) specifications for which the 3.0.4 exemptions are retained because they contain a 3.0.3 exemption in addition to the 3.0.4 exemption, (2) specifications for which the 3.0.4 exemptions are retained because they have actions statements which place limitations on continued operation, and (3) specifications for which the 3.0.4 exemptions are removed because they have action statements which allow unlimited continued operation in accordance with the action statement requirements. All specifications having 3.0.4 exemptions have been reviewed and placed into one of these categories. The results are summarized in Table 1 below .
  • DISPOSITION OF 3.0.4 EXEMPTIONS Unit 1 Specification Page No. Disposition
1. 3.3.1.1 3/4 3-5
a. Functional Units Removed Requiring Action 2
b. Functional Units Removed Requiring Action 6
c. Functional Units Retained (2)

Requiring Action 7

2. 3.3.2.1 3/4 3-21 Retained (2)

Functional Units Requiring Action 14

3. 3.3.3.1 3/4 3-35 Retained (1)
4. 3.3.3.2 3/4 3-39 Retained (1)
  • Page 1 of 5

Attachment 3 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

  • Unit 1 Specification 5.

6.

3.3.3.3 3.3.3.4 Page No.

3/4 3-40 3/4 3-43 Disposition Retained (1)

Retained (1)

7. 3.3.3.5 3/4 3-46 Retained (2)
8. 3.3.3.6 3/4 3-49 Retained ( 1)
9. 3.3.3.7 3/4 3-53 Retained (2)
10. 3.3.3.8 3/4 3-58 Retained (1)
11. 3.3.3.9 3/4 3-64 Retained (1)
12. 3.4.3 3/4 4-5 Removed
13. 3.4.8 Action a 3/4 4-20 Retained (2)

. 14. 3.4.9.3 3/4 4-30 Removed

15. 3.4.10.1 3/4 4-32 Retained (2)
16. 3.7.1.1 3/4 7-1 Removed
17. 3.7.1.5 3/4 7-10 Removed Actions for Modes 2 and 3
18. 3.7.8.1 3/4 7-26 Retained (1)
19. 3.7.10.1 Action a 3/4 7-34 Retained (1)
20. 3.7.10.2 3/4 7-37 Retained (1)
21. 3.7.10.3 3/4 7-39 Retained (1)
22. 3.7.10.4 3/4 7-40 Retained (1)
23. 3.7.11 3/4 7-42 Retained (1)
24. 3.9.12 3/4 9-12 Retained (1)
25. 3 .11.1. 2 3/4 11-5 Retained (1)
26. 3 .11.1. 3 3/4 11-6 Retained (1)
27. 3 .11.1. 4 3/4 11-7 Retained (1)
28. 3.11.2.2 3/4 11-12 Retained (1)
29. 3 .11. 2. 3 3/4 11-13 Retained (1)

Page 2 of 5 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 Unit 1 Specification Page No. Disposition

30. 3.11.2.4 3/4 11-14 Retained (1) *
31. 3.11.2.5 3/4 11-15 Retained ( 1)
32. 3.11.3 3/4 11-17 Retained (1)
33. 3.11.4 3/4 11-19 Retained (1)
34. 3.12.1 3/4 12-2 Retained (1)
35. 3.12.2 3/4 12-11 Retained (1)
36. 3.12.3 3/4' *12-13 Retained (1)

Unit 2 Specification . Page No.** Disposition

1. 3.2.4 3/4 2-15 Retained (2)
2. 3.3.1.1 3/4 3-5
a. Functional Units Removed Requiring Action 2
b. Functional Units Removed Requiring Action 6
c. Functional Units Retained (2)

Requiring Action 7

3. 3.3.2.1 3/4 3-22
a. Functional Units Retained (2)

Requiring Action 14

b. Functional Units Retained (2)

Requiring Action 22

4. 3.3.3.1 3/4 3-38 Retained (1)
5. 3.3.3.2 3/4 3-42 Retained (1)
6. 3.3.3.5 3/4 3-43 Retained (2)
7. 3.3.3.6 3/4 3-46 Retained (1)
8. 3.3.3.7 3/4 3-50 Retained (2)
9. 3.3.3.8 3/4 3-53 Retained (1)

Page 3 of 5

Attachment 3 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 Unit 2 Specification Page No. Disposition

10. 3.3.3.9 3/4 3-59 Retained (1)
11. 3.4.5 3/4 4-8 Removed
12. 3.4.9 Action a 3/4 4-23 Retained (2)
13. 3.4.10.3 3/4 4-31 Removed
14. 3. 4 .11.1 3/4 4-33 Retained (2)
15. 3.6.1.3 Action a 3/4 6-4 Retained (2)
16. 3.7.1.1 3/4 7-1 Removed
17. 3.7.1.5 3/4 7-10 Removed Action for Modes 2 and 3
18. 3.7.8 3/4 7-21 Retained (1)
19. 3.7.10.1 Action a 3/4 7-31 Retained (1)
20. 3.7.10.2 3/4 7-34 Retained (1)
21. 3.7.10.3 3/4 7-36 Retained (1)
22. 3.7.10.4 3/4 7-37 Retained (1)
23. 3.7.11 3/4 7-39 Retained (1)
24. 3.8.3.1 3/4 8-16 Removed
25. 3.9.12 3/4 9-13 Retained (1)
26. 3 .11.1. 2 3/4 11-5 Retained ( 1)
27. 3 .11.1. 3 3/4 11-6 Retained (1)
28. 3 .11.1. 4 3/4 11-7 Retained (1)
29. 3 .11. 2. 2 3/4 11-12 Retained (1)
30. 3.11.2.3 3/4 11-13 Retained (1)
31. 3 .11. 2. 4 3/4 11-14 Retained (1)*
32. 3.11.2.5 3/4 11-15 Retained (1) 33 3.11.3 3/4 11-17 Retained (1)
34. 3.11.4 3/4 11-19 Retained (1)

Page 4 of 5 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 Unit 2 Specification Page No. Disposition

35. 3.12.1 3/4 12-2 Retained (1)
36. 3.12.2 3/4 12-11 Retained (1)
37. 3.12.3 3/4 12-13 Retained (1)

(1) This specification contains a 3.0.3 exemption in addition to the 3.0.4 exemption and the 3.0.4 exemption is therefore retained in accordance with the agreement reached at the March 14, 1989 meeting between the NRC and PSE&G. This agreement is documented in a letter to PSE&G from the NRC staff dated March 29, 1989.

(2) The action requirements of this specification require shutdown if the LCO is not met within a specified time interval or do not permit continued operation for an unlimited amount of

  • time and the 3.0.4 exemption is therefore retained in accordance with the guidance of Generic Letter 87-09.
  • License Change Request 84-01, dated May 31, 1990, proposed adding a 3.0.3 exemption to this TS.

Page 5 of* 5

ATTACHMENT 4 EVALUATION OF INDIVIDUAL SPECIFICATIONS AFFECTED BY PROPOSED TECHNICAL SPECIFICATION 3.0.4 LICENSE AMENDMENT APPLICATION NLR-N90121 GENERIC LETTER 87-09 CHANGES LCR 88-06, REV. 1 SALEM GENERATING STATION FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 The Salem Technical Specifications were reviewed with respect to the application of TS 3.0.4 as modified by Generic Letter 87-09.

First, the individual TS that would be affected by the proposed change to TS 3.0.4 were identified. Where relaxation of mode change restrictions occurs for an individuai specification, it was reviewed to determine whether the applicable remedial actions provide an acceptable level of safety (i.e., are consistent with the present safety analyses). A discussion of each of the affected TS is provided below.

TS 3.1.1.1 Shutdown Margin Tavg > 200 deg F (Modes 1, 2, 3, & 4)

Proposed TS 3.0.4 would not place restrictions on mode changes.

The action does not require shutdown (a mode reduction). The action requires immediate initiation of boration at 10 gpm of 20,000 ppm boric acid solution or equivalent until the shutdown margin is restored. Shutdown margin requirements provide

  • sufficient reactivity margin to assure the core will remain subcritical following all transients and design basis events.

Shutdown margin is considered an initial condition process variable because it is periodically monitored to provide assurance that the unit is operating within the bounds of safety analysis assumptions. Safety analyses which rely on shutdown margin limits are the steam line break and boron dilution events.

The shutdown margin is the major factor limiting the power level which the core may reach during a return to criticality for the steam line break analysis. A shutdown margin of less than 1.6%

delta k/k would result in an unanalyzed condition and thus immediate initiation of boration is required to restore the shutdown margin. Remedial measures contained in the action statement require immediate initiation and continued boration until the shutdown margin is restored.

It is concluded that the action statement provides an acceptable level. of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

Page 1 of 12

Attachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

Proposed TS 3.0.4 does not place restrictions on mode changes.

The action does not require a shutdown (a mode reduction). The justification for TS 3.1.1.1 above is applicable to this TS.

It is therefore concluded that the action statement provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

TS 3.1.2.1 Boration Systems - Shutdown (Modes 5 & 6)

Proposed TS 3.0.4 does not place restrictions on mode changes; it would allow a mode change from 5 to 6 and 6 to 5, with no boration flow path available, provided all core alterations and positive reactivity changes are suspended. TS 3.1.1.2 requires a Mode 5 shutdown margin of greater than or equal to 1.0%

delta k/k. TS 3.9.1, applicable in Mode 6, requires a boron concentration of greater than or equal to 2000 ppm or k f f less than or equal to 0.95, whichever is more restrictive. Tfie application of proposed TS 3.0.4 to TS 3.1.2.1, alone, would allow a transition from Mode 5 to Mode 6. The shutdown margin/boron concentration requirements of TS 3.1.1.2 and 3.9.1, combined with the restrictions on positive reactivity changes and core alterations of TS 3.1.2.1, provide an acceptable level of safety to permit the use of the proposed change to TS 3.0.4. No additional restriction on mode changes is required.

TS 3.1.2.3 Charging Pump - Shutdown (Modes 5 & 6)

Proposed TS 3.0.4 does not place restrictions on mode changes.

Since the charging pump provides motive force for the boron to the RCS, the evaluation for TS 3.1.2.1 is applicable. It is therefore concluded that the action statement provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

Ul TS 3.1.2.5 Boric Acid Transfer Pumps - Shutdown (Modes 5 & 6)

Proposed TS 3.0.4 does not place restrictions on mode changes.

The boric acid transfer pumps provide motive force to move boron from the boric acid tank to the RCS to meet the shutdown requirements for mode changes between Modes 5 and 6. As such, the evaluation for TS 3.1.2.1 is applicable. It is therefore concluded that the action statement provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4, and no additional restriction on mode changes is required.

Page 2 of 12

Attachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 U1 TS 3.1.2.7 Borated Water Source --Shutdown (Modes 5 & 6)

U2 TS 3.1.2.5 Proposed TS 3.0.4 does not place restrictions on mode changes.

Since TS 3.1.2.5 involves the lack of a boration source, the evaluation for TS 3.1.2.1 is applicable. It is therefore concluded that the action statement provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

TS 3.1.3.1 Movable Control Assemblies - Group Height (Modes 1&2)

Proposed TS 3.0.4 does maintain restrictions on mode changes for actions (a) and (b). Proposed TS 3.0.4 does not place restrictions on mode changes for action (c), which allows continued operation as long as remedial measures are taken. The operability of the shutdown and control rods are initial assumptions in safety analyses which assume rod insertion upon reactor trip. Maximum rod misalignment directly affects core power distributions and assumptions of available shutdown margin.

The limits on shutdown or control rod alignments assure that the assumptions in the safety analyses will remain valid. The requirement to maintain the rod alignment to within plus or minus 12 steps is conservative. The minimum misalignment assumed in

  • safety analysis is 24 steps (15 inches), and in some cases a total misalignment from fully withdrawn to fully inserted is assumed.

When a rod becomes misaligned, it can usually be moved and is still trippable, as per the application of TS 3.1.3.1 action (c).

If the rod can be realigned within one hour, local xenon redistribution during this short interval will not be significant and operation may proceed without further restriction. This would also apply if the operator should choose to realign the remainder of the rods in the group to within plus or minus 12 steps of the misaligned rod while maintaining the rod sequence and insertion limits (Thermal Power Limits of TS 3.1.3.5 will apply).

The following are the four requirements to continue power operation:

1. Reevaluation of the affected accident analyses within 5 days, to verify that the previously analyzed results will remain valid for the duration of operation under these conditions.
2. Periodic verification of shutdown margin requirements per TS 3.1.1.1,
  • Page 3 of 12

Attachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

  • 3. Verification of the Heat Flux and Nuclear.Enthalpy Rise Hot Channel Factors to be in accordance with their limits within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and
4. Reduction of thermal power to 75% of Rated Thermal Power (RTP) and reduction of the Power Range Neutron Flux--High trip setpoints to 85% of RTP.

Adherence to these action statement requirements assures that the assumptions of the safety analyses remain valid. It is therefore concluded that action (c) provides an acceptable level of safety to permit the application of the proposed change to TS 3.0.4, and no additional restriction on mode changes is required.

TS 3.1.3.2 Position Indication Systems - Operating (Modes 1 & 2)

Proposed TS 3.0.4 does not place restrictions on mode changes.

  • The actions do not require shutdown and do allow continued operation as long as remedial measures are taken. Shutdown and control rod operability and alignment are directly related to power distribution.and.shutdown margin, which are initial conditions assumed in.safety analyses. The position of the rod*

can still be determined by use of the in-core movable detectors in the event that one digital rod position indicator channel per group fails. If the operator chooses, a reduction of the Thermal Power to less than or equal.to 50% of RTP may be performed as an option because it puts the core into a condition where rod position is not significantly affecting core peaking factors.

When one demand position indicator per bank is inoperable, the rod position may be determined by the Digital Rod Position Indication System. Verification that the rods in a bank are within plus or minus 12 steps every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is adequate to ensure that the assumptions of the safety analyses are still met.

Adherence to these action statement requirements assures that the assumptions of the safety analyses remain valid. It is therefore concluded that the action statements provide an acceptable level of safety to permit the application of the proposed change of TS 3.0.4 and no additional restriction on mode changes is required.

TS 3.1.3.4 Position Indication System - Shutdown (Modes 1 & 2)

The action of this TS refers to TS 3.1.3.1. As a result, the evaluation of TS 3.1.3.1 applies here.

TS 3.2.1 Axial Flux Difference (Mode 1, above 50% of RTP)

Proposed TS 3.0.4 does not place restrictions on mode changes.

Page 4 of 12 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 The actions do not require shutdown and do allow continued operation as long as the following remedial measures are taken:

(1) restoring, within 15 minutes, the indicated Axial Flux Difference (AFD) to within the target band limits or reduce Thermal Power below 90% of RTP and (2) reducing the cumulative penalty deviation time below 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> before increasing THERMAL POWER above 50% of RTP.

The purpose of the limits on the values of AFD is to limit the amount of axial power distribution skewing to the top or bottom of the core. By limiting the amount of power distribution skewing, the core peaking factors, F 0 (z) in particular, are maintained within safety analysis assumptions.

With AFD outside the target band while Thermal Power is ~ 90% of RTP, assumptions of accident analysis may be violated.

Therefore, the action requires immediate (within 15 minutes) reduction of Thermal Power to <90% of RTP. The action statements for Thermal Power between 50% and 90% allow a maximum of 1-hour cumulative penalty deviation time limit beyond which Thermal Power must be reduced. During rapid Thermal Power reductions, control bank motion may cause the AFD to deviate outside of the target band at reduced Thermal Power levels. Limiting the duration of the AFD deviation prevents the xenon redistribution from changing the envelope of peaking factors which may be reached on a subsequent return to RTP (with the AFD within the target band). The action limiting the cumulative penalty deviation time prevents unanalyzed xenon and power distribution and assures operation consistent with the accident analysis.

It is therefore concluded that the action statements provide an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

TS 3.3.1 Reactor Trip System Instrumentation No additional restrictions are required for any Functional Unit as a result of the revision to TS 3.0.4. Adherence to the action statement requirements assures that the assumptions of the safety analyses remain valid. It is therefore concluded that the action statement provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

TS 3.3.2 ESFAS Instrumentation No additional restrictions are required for any Functional Unit as a result of the revision to TS 3.0.4. Adherence to the action Page 5 of 12

Attachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

  • statement requirements assures that the assumptions of the safety analyses remain valid. It is therefore concluded that the action statement provides an acceptable level of safety to permit the use *of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

U2 TS 3.3.4 Turbine overspeed Protection (Modes 1, 2, and 3)

Proposed TS 3.0.4_ does not place restrictions on mode changes.

The actions do not require shutdown and do allow continued operation as long as remedial measures are taken. Action (a) requires isolation of the turbine from the steam supply if inoperable valve(s) cannot be either restored to operable status or isolated by at least one other valve. Action (b) also requires isolation of the turbine from the steam supply if the Turbine overspeed Protection System becomes inoperable due to reasons other than those described in Action (a) The intent of this TS is to prevent turbine overspeed and subsequent turbine missiles. By taking the turbine off line or closing one valve in the affected steam line, safety is maintained. It is therefore*

concluded that the action statements provide an acceptable level of safety to permit the application of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

TS 3.4.1.4 RCS - Cold Shutdown (Mode 5)

Proposed TS 3.0.4 does not place restrictions on mode changes.

The actions do not require shutdown (to be placed in a lower mode) and do allow continued operation as long as remedial measures are taken. These remedial measures include the immediate initiation of corrective actions to restore operability with less than two RHR*loops operable and the suspension of all operations involving a reduction in the boron concentration of the RCS with no loop in operation. RCS circulation, provided by the RHR loop, is considered in the determination of the time available for the mitigation of the accidental boron dilution accident. In order to move from Mode 5 loops filled to Mode 4 assurance must exist that a combination two RHR/RCS loops are available for heat removal. Although the actions of TS 3.4.1.4 do not provide that assurance, the actions of TS 3.4.1.3 which do provide that assurance must be satisfied before the mode change is allowed. In order to move from Mode 5 with RC loops not filled to Mode 6, other TS requirements (3.9.8.1 and 3.9.8.2) must be satisfied. It is therefore concluded that the action statements do provide an acceptable level of safety to permit the use of proposed TS 3.0.4 and no additional restriction on mode changes is required.

Page 6 of 12

Attachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

Proposed TS 3.0.4 does not place restrictions on mode changes.

Continued operation is allowed as long as remedial measures are taken. The relaxation would only allow mode changes without positive reactivity changes, while the RHR system is operating in the shutdown cooling mode (for RCS overpressure protection).

During low temperature operation (one or more RCS cold leg 5 312 deg F), the Pressurizer Overpressure Protection System (POPS) is required to be operable to provide overpressure protection. A mode change from 6 to 3 involving a positive reactivity addition and would be prevented by the action statement. It is therefore concluded that the existing TS provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

Ul TS 3.4.6.2 Operational Leakage (Modes 1, 2, 3, & 4)

U2 TS 3.4.7.2 Proposed TS 3.0.4 does maintain restrictions on mode changes for Actions (a) and (b). However, proposed TS 3.0.4 does not place restrictions on mode changes for action (c) of Unit 2. Continued operation is permitted as long as remedial measures are taken.

The remedial measures include the isolation of the high pressure portion of the affected system from the low pressure portion (i.e., isolation of the leakage path). It is therefore concluded that the action requirements provide an acceptable level of safety and no additional restrictions on mode changes are required.

Ul TS 3.4.7 Chemistry (At all times)

U2 TS 3.4.8 In Modes 1, 2, 3, and 4 proposed TS 3.0.4 does maintain restrictions on mode changes.

In Modes 5 and 6, proposed TS 3.0.4 does not place restrictions on mode Changes. The actions do not require shutdown (to be placed in a lower mode) and would allow changes from Mode 5 to 6 and from Mode 6 to 5. The remedial actions consist of reducing pressurizer pressure to less than or equal to 500 psig, performing an engineering evaluation to determine the effects of the out-of-limit condition of the RCS integrity, and a determining that.the RCS remains acceptable for continued operation prior to increasing the pressurizer pressure above 500 psig and proceeding to Mode 4. The limitations on RCS chemistry minimize corrosion and help to assure the structural integrity of the RCS. The effects of an out-of-limit condition Page 7 of 12

Attachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

  • on RCS integrity are time dependant. While there is no specified time limit in Modes 5 and 6, out-of-limit time is an input to the engineering evaluation required by the action statement, and engineering judgement dictates that the chemistry parameters be brought to within their limits in a timely manner. It is therefore concluded that the action statement provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes for Modes 5 and 6 is required.

Ul TS 3.4.9.1 RCS Pressure/Temperature Limits (At all times)

U2 TS 3.4.10.1 In Modes 1, 2, 3, and 4, the revised LCO 3.0.4 does maintain restrictions on mode changes.

In Modes 5 and 6, the revised TS 3.0.4 does not place restrictions on mode changes. The actions do not require shutdown (a mode reduction) and do allow continued operation as long as remedial measures are taken. Those remedial measures include the restoration of the temperature and/or pressure to within limits, the performance of an engineering evaluation to determine the effects of the out-of-limit condition on the structural integrity of the RCS, and the determination that the

  • RCS remains acceptable for continued operation.

The P/T limits are not derived from design bases accident events presented in the FSAR, but are requirements to be used during normal operation to avoid encountering pressure, temperature, and temperature rate-of-change conditions which might cause undetected flaws to propagate, resulting in non-ductile failure of the Reactor Coolant Pressure Boundary. The action statement is consistent with this guide since the pressure and temperature reduction requirements are "to less than 200 F and 500 psig, respectively." It is therefore concluded that the action statement does provide an acceptable level of safety to permit the use of the proposed change to LCO 3.0.4 and no additional restriction on mode changes for Modes 5 and 6 is required.

Ul TS 3.4.9.2 Pressurizer (At all times)

U2 TS 3.4.10.2 In Modes 1 and 2, the revised LCO 3.0.4 does maintain restrictions on mode changes.

In Modes 3, 4, 5, and* 6, the revised LCO 3. O. 4 does not** place restrictions on mode changes. The actions do not require shutdown (to be placed in a lower mode) and do allow continued operation as long as remedial measures are taken. Those measures Page 8 of 12

'Attachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

  • include the restoration of the temperature and/or pressure to within limits, the performance of an engineering evaluation to determine the effects of the out-of-limit condition on the structural integrity of the pressurizer, and the determination that the pressurizer remains acceptable for continued operation.

The P/T limits are not derived from design bases accident events presented in the FSAR, but are requirements to be used during normal operation to avoid encountering pressure, temperature, and temperature rate-of-change conditions which might cause undetected flaws to propagate, resulting in non-ductile failure of the Reactor Coolant Pressure Boundary. It is therefore concluded that the action statement does provide an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes for Modes 3, 4, 5, and 6 is required.

TS 3.5.3 ECCS Subsystems - Tavg < 350 F (Mode 4)

Proposed TS 3.0.4 does maintain restrictions on mode changes for action (a). For action (b), entry into Mode 4 from Mode 5 would be allowed. However, TS 3.4.1.3 requires any combination of at least two RCS and RHR loops to be operable prior to entering Mode

4. It is therefore concluded that action b does provide an
  • acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restrictions on mode changes is required.

Ul TS 3.6.3.1 Containment Isolation Valves (Modes 1, 2, 3, 4)

U2 TS 3.6.3 The proposed TS 3.0.4 does not place restrictions on mode changes as long as compliance with Action (b) or (c) have been met.

Isolating each affected penetration in compliance with Actions (b) or (c) ensures an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restrictions on mode changes is required.

Ul TS 3.7.5.1 Flood Protection (At all times)

U2 TS 3.7.5 Proposed TS 3.0.4 does not place restrictions on mode changes for Action (a), which allows continued operation as long as remedial measures are taken. These measures are to maintain the water level between 10.5 feet and 11.5 feet. Action (b), for a water level above 11.5 feet, will continue to restrict mode changes.

It is therefore concluded that the action statements provide an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

Page 9 of 12

~ttachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1

For Units 1 and 2, Modes 1, 2, 3, and 4, proposed TS 3.0.4 does maintain restrictions on mode changes for actions (a), (b),

and (c). Proposed TS 3.0.4 does not place restrictions on mode changes for action (d), which applies to outside air intake duct.

Remedial measures are to close the damper, thus isolating the affected duct from the control room. This is an acceptable remedial action.

For Unit 2, Modes 5 and 6, proposed TS 3.0.4 does not place restrictions on mode changes for action (a) or (b). Action (a) requires placing the control room ventilation system in recirculation mode with less than the full complement of equipment OPERABLE; action (b) requires suspending positive reactivity changes and core alterations with both fans, the cooling coil, the filter train, or any isolation damper inoperable. Given the remedial actions already in place, no additional restrictions on mode changes (between Modes 5 and 6) are required to assure control room habitability.

TS 3.7.10.1 Fire Suppression Water System (At all times)

  • The present exception to TS 3.0.4 for action (a) is being retained because the action also includes an exception to TS 3.0.3.

Proposed TS 3.0~4 does not place restrictions on mode changes for action (b). The TS has remedial measures which require a backup fire suppression water system to be established within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and a submittal of a Special Report to the Commission, without requiring shutdown. The basis of the Fire Suppression System is to ensure that adequate fire suppression capability exists to minimize potential damage to safety-related equipment. The remedial actions provide for establishment of adequate suppression capability in a timely manner. It is therefore concluded that action (b) provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

TS 3.8.1.2 A.C. Sources (Modes 5 and 6)

Proposed TS 3.0.4 does not place restrictions on mode changes.

The action requires the suspension of all operations involving core alterations or positive reactivity changes until the minimum required A.C. electrical power is restored to operable status.

TS 3.8.1.1 would prevent entry to Mode 4. It is therefore concluded that the action statement provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

Page 10 of 12

,Attachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 TS 3.8.2.2 A.C. Distribution - Shutdown (Modes 5 and 6)

TS 3.8.2.4 125 Volt D.C. Distribution - Shutdown (Modes 5 and 6)

TS 3.8.2.6 28 Volt D.C. Distribution - Shutdown (Modes 5 and 6)

Proposed TS 3.0.4 does not place restrictions on mode changes.

The TS have remedial actions which require that containment integrity be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if the Limiting Conditions for Operation are not met. This action requires that all penetrations into the containment not capable of being closed by OPERABLE containment isolation valves be closed and secured in that position. The basis of this Technical Specification is to ensure that sufficient power and distribution systems in Modes 5 and 6 are available to maintain the unit in the shutdown or refueling condition, to provide sufficient instrumentation and control capability to monitor and maintain unit status, and to assure adequate power for recovery from a postulated fuel hapdling accident. Entry into Mode 4 would be prohibited by the TS requirements for Distribution systems during Operation. It is therefore concluded that the action statement provides an acceptable level of safety to permit the use of the proposed change to TS 3.0~4 and no additional restriction on mode changes is required.

TS 3.9.2 Instrumentation (Mode 6)

  • Proposed TS 3.0.4 does not place restrictions on mode changes.

The remedial actions include: 1) suspension of core alterations and positive reactivity changes, and 2) verification of boron concentration every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, which is consistent with the TS requirements for Modes 3, 4, and 5 (TS 3.3.1). An acceptable level of safety is provided by the action requirements, and no additional restrictions on mode changes are required.

TS 3.9.7 Crane Travel - Fuel Handling Area (With fuel. assemblies in the storage pool)

Proposed TS 3.0.4 would not place restrictions on mode changes.

The action statement allows continued operation as long as remedial actions are taken. Remedial actions involve placing the crane in a safe condition. The purpose of the nominal weight requirement (5 2200 pounds) of loads for travel over fuel assemblies in the storage pool ensures that in the event the load is dropped: 1) the activity release will be limited to that contained in a single fuel assembly and 2) any possible distortion of fuel in the storage racks will not result in a critical array. This assumption is consistent with the activity release assumed in the FSAR. It is therefore concluded that the action requirements provide an acceptable level of safety, and no additional restrictions on mode changes are required.

Page 11 of 12

'Attachment 4 NLR-N90121 Generic Letter 87-09 Changes LCR 88-06, Rev. 1 TS 3.9.8.l RHR - All Water Levels (Mode 6)

Proposed TS 3.0.4 would not place restrictions on mode changes.

The actions do not require shutdown and do allow continued operation as long as remedial measures are taken.

Adherence to the action statement requirements assures that the assumptions of the accident analyses remain valid. It is therefore concluded that the action statement provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required.

TS 3.9.9 Containment Purge and Pressure-Vacuum Relief Isolation (mode 6)

Proposed TS 3.0.4 does not place restrictions on mode changes.

The containment purge and pressure-vacuum relief isolation system is required to be capable of isolating containment on a high radiation signal in order to prevent the release of radioactive material to the environment. The action requirement to isolate the system when it is inoperable provides an acceptable level of safety and no additional restrictions on mode changes are required .

  • TS 3.9.11 Storage Pool Water Level (Whenever irradiated fuel assemblies are in the storage pool)

Proposed TS 3.0.4 does not place restrictions on mode changes.

The action statement does not require shutdown and does allow continued operation as long as remedial actions are taken. The minimum water level in the fuel storage pool is required to meet the Iodine decontamination factor assumptions following a fuel handling accident. The remedial actions require suspending all movement of fuel assemblies and crane operations with loads in the fuel storage area and restoring water level to within limits.

The suspension of either fuel movement or crane operation shall not prevent the movement of loads to a safe position. The remedial measures effectively preclude the possibility of a spent fuel handling accident. It is therefore concluded that the action statement.provides an acceptable level of safety to permit the use of the proposed change to TS 3.0.4 and no additional restriction on mode changes is required .

  • Page 12 of 12

ATTACHMENT 5 REVISED TECHNICAL SPECIFICATION PAGES GENERIC LETTER 87-09 CHANGES NLR-N90121 LCR 88-06, REV. 1 The following Technical Specifications have been revised to reflect the proposed changes:

Unit 1 Techriical Specification 3.0.4 3/4 0-1 4.0.3 3/4 0-2 4.0.4 3/4 0-2 3.3.1.1 3/4 3-2 3/4 3-3 3/4 3.-4 3.4.3 3/4 4-5.

3.4.9.3 3/4 4-30 3.7.1.1 3/4 7-1 3.7.1.5 3/4 7-10 Bases for Sections B 3/4 0-1 3.0 and 4.0 B 3/4 0-2 B J/4 0-3 B 3/4 0-4 Unit 2

  • Technical Specification 3~0.4 3/4 0-1 4.0.3 3/4 0-2 4.0.4 3/4 0-2 3.3.1.1 3/4 3-2 3/4 3-3 3.4.5 3/4 4-8 3.4.10.3 3/4 4-31 3.7.1.1 3/4 7-1 3.7.1.5 3/4 7-10 3.8.3.1 3/4 8-16 Bases for Sections B 3/4 0-1 3.0 and 4.0 B 3/4 0-2 B 3/4 0-3 B 3/4 0-4
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