ML18095B016
| ML18095B016 | |
| Person / Time | |
|---|---|
| Issue date: | 03/27/1989 |
| From: | Shum E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Gray R Battelle Memorial Institute, PACIFIC NORTHWEST NATION |
| References | |
| REF-WM-3 NUDOCS 8904040200 | |
| Download: ML18095B016 (7) | |
Text
Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer March 23, 1989 NLR-N89056 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR AMENDMENT FACILITY OPERATING LICENSE DPR-70 AND DPR-75 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 In accordance with the Atomic Energy Act of 1954, as amended, and the regulations thereunder, Public Service Electric and Gas Company (PSE&G) hereby transmits a request for amendment of Facility Operating License DPR-70 and DPR-75 for Salem Generating Station (SGS), Unit Nos. 1 and 2.
Pursuant to the requirements of 10CFR50.90(b) (1), a copy of this request has been sent to the State of New Jersey as indicated below.
The attached proposed changes request deletion of Table 3.8-1 from the Unit 2 Technical Specifications similar to the guidance provided in Generic Letter 84-13 and as approved on several other dockets.
The deleted information will be incorporated into the next revision of the UFSAR and be controlled via the 10CFR50.59 process.
The proposed changes also request incorporation of identical operability and surveillance requirements into the Unit 1 Technical Specifications.
The proposed changes are considered to be administrative in nature in that 1) one of the proposed changes is similar to guidance provided in Generic Letter 84-13 and has been reviewed and approved on other dockets and 2) the other change is requested to make the two Technical Specifications identical.
Since the proposed changes are administrative, specialized technical review effort should not be required.
Therefore, PSE&G believes that the proposed changes can be classified as a Category 2 change.
\\
r Document Control Desk NLR-N89056 2
03-23-89 contains further discussion and justification for the proposed revisions. is a markup of the existing Technical Specifications to reflect the as requested version of the specifications. is a retype of the Technical Specifications to represent the revised version of these pages.
At a meeting held May 26, 1988 at Region I, PSE&G agreed to update and submit the Unit 2 Technical Specification Table 3.8-1 to reflect the proper values for the penetration overcurrent protection devices after all modifications to the Unit 2 devices were completed.
These modifications have since been completed and the correct penetration overcurrent protective devices have been installed in Unit 2.
However, based on discussions with the NRR Salem Licensing Project Manager, it was agreed that since a License Change Request (LCR) was being submitted to delete the subject tables from the Technical Specifications, it was not necessary to formally modify Table 3.8-1 prior to deletion.
Table 3.8-1 has been modified with the correct protective device values and is provided as Attachment 4.
However, this table is being submitted for information only and is not part of the LCR.
It will be included in the next update of the Salem UFSAR as committed to in the LCR.
This submittal includes one (1) signed original, including affidavit, and thirty-seven (37) copies pursuant to 10CFR50.4(b) (2) (ii).
Should you have any questions on the subject transmittal, please do not hesitate to contact us.
Sincerely, Attachment
f Document Control Desk NLR-N89056 3
C Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson, Acting 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 03-23-89
STATE OF NEW JERSEY
)
REF: LCR-88-08 NLR-N89056
)
SS.
COUNTY OF SALEM
)
Steven E. Miltenberger, being duly sworn according to law deposes and says:
I am Vice President and Chief Nuclear Officer of Public Service Electric and Gas Company, and as such, I find the matters set forth *in our letter dated March 23, 1989
, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscribed. a.nd sworn
_th~/" __ ::.~ day of
, 1989 Etl.EEN 1\\1. OCHS NOTARY PUBLIC OF NE'.W JERSEY My Commission expires on ~Commission Expires July 16, 1992
PROPOSED LICENSE CHANGE SALEM GENERATING STATION UNIT NOS. 1 AND 2 Description of Change ATTACHMENT A
~CR 88-08 Page 1 of 3 NLR-N89056 This license change request (LCR) proposes to modify the Salem Unit 2 Technical Specifications by deleting Technical Specification (TS) Table 3.8-1, "Containment Penetration Conductor Overcurrent Protective Devices," and to modify Bases 3/4.8.3 to require controls for maintaining the list of protective devices similar to those required for snubbers as described in Generic Letter 84-13, dated May 3, 1984.
A specification for surveillances of fuses is being added to reflect the use of those fuses as overcurrent protective devices.
Additionally, an identical specification would be added to the Unit 1 Technical Specifications for consistency between units.
Changes to the Technical Specifications of Operating License Nos. DPR-70 and DPR-75 are noted in the marked-up copy of the applicable Technical Specifications (Attachment B).
Also attached (Attachment C) is a retyped version of the Technical Specification to reflect the as requested condition.
Reason for Change Currently the list of containment penetration conductor overcurrent protective devices and their setpoints are controlled by Table 3.8-1 in the Unit 2 Technical Specifications.
Changes to these breakers and their setpoints require a license amendment, even if the change is in the conservative direction.
This requirement places an undue burden on the plant staff and NRC staff in preparing and reviewing these changes.
Justification for Change Deleting Table 3.8-1 from the Technical Specifications and requiring administrative controls for the protective devices is similar to the requirements for snubbers as described in Generic Letter 84-13 and does not deg~ade compliance with TS 3.8.3.1.
Technical Specification 3.8.3.1 will continue to require that the containment penetration conductor overcurrent protective devices be operable.
The currently required surveillances will continue to be performed and the required corrective actions will be taken if the devic~s are found to be inoperable.
~CR 88-08 Page 2 of 3 The list of containment penetration overcurrent protective devices and setpoints will be incorporated into a future revision to the UFSAR.
Additionally, the setpoints for the subject devices will be incorporated into plant maintenance procedures and plant drawings which are controlled plant documents.
Changes to the setpoints and devices are made through this controlled system in accordance with the PSE&G Quality Assurance Program and within the guidance of 10CFR50.59.-
Performing and documenting setpoint changes via the 50.59 process and including them in FSAR updates gives the staff adequate opportunity to review changes to the setpoint list.
Maintaining the list of containment penetration conductor overcurrent protective devices in appropriate controlled plant systems and drawings provides additional flexibility for making changes based on 10CFR50.59 evaluations.
It is also consistent with the NRC and industry efforts to simplify the Technical Specifications, as evidenced by th~ NRC granting a similar Technical Specification change for the Callaway Plant, Unit 1, on November 19, 1985.
In the Callaway amendment, the NRC Staff's position was that the overcurrent protective device inspection and maintenance should be performed through the QA program and appropriate plant procedures.
This change was also granted to Diablo Canyon on September 3, 1987.
Addition of an identical requirement to the Unit 1 Technical Specifications is being requested as part of PSE&G's ongoing program to achieve consistency between the Unit 1 and Unit 2 specifications.
Significant Hazards Consideration PSE&G has evaluated the hazards considerations involved with the proposed amendment, focusing on the three standards set forth in 10CFR50.92(c) as quoted below:
"The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment to an operating license for a facility licensed under paragraph 50.2l(b) or paragraph 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new of different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety."
LCR 88-08 Page 3 of 3 The following evaluation is provided for the significant hazards consideration standards.
- 1.
Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed changes provide for the list of *containment penetration conductor overcurrent protective devices to be maintained and controlled at the plant rather than in the Technical Specifications.
The removal of the containment penetration conductor overcurrent protective device listing does not degrade the existing Technical Specification protective device operability and surveillance requirements nor does it affect the accident analysis.
Therefore, this license amendment request does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the change create the possibility of a new of different kind of accident from any accident previously evaluated?
The proposed changes do not make any physical changes to the plant or changes in parameters governing normal plant operation.
Therefore, the changes do not create the possibility of a new or different kind of accident from any previously evaluated.
- 3.
Does the change involve a significant reduction in a margin of safety?
As discussed above, the proposed changes do not degrade the existing protective devices' operability and surveillance requirements, nor do they effect the accident analysis.
Therefore, changes do not involve a significant reduction in a margin of safety.
==
Conclusion:==
Based on the above safety evaluation, PSE&G concludes that the activities associated with this license amendment request satisfy the significant hazards consideration standards of 10CFR50.92(c).
Accordingly, a no significant hazard consideration finding is justified.