ML18096A126

Responds to NRC Request for Addl Info Re Rev 1 to License Change Request 88-06 on Generic Ltr 87-09 Changes.Info Covers Administrative Controls & Training

ML18096A126
Person / Time
Site:	Salem
Issue date:	07/01/1991
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18096A128	List: ML18096A126 ML18096A129
References
GL-87-09, GL-87-9, NLR-N91094, NUDOCS 9107120208
Download: ML18096A126 (5)

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 JUL O 1 1Q91 *.

NLR-N91094 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION/LCR REVISION LCR 88-06, REVISION 1 - 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 is being submitted by Public Service Electric and Gas Company (PSE&G) in response to the request for additional information (RAI) issued for LCR 88-06, Revision 1. In.addition to responding to the RAI, this letter also submits a revision to the Bases changes proposed in the subject LCR.

LCR 88-06, Revision 1 (NLR-N90121) was submitted on February 20, 1991 and proposed changes to Specifications 3.0.4, 4.0.3, 4.0.4, and the Bases for all 3.0/4.0 Specifications as endorsed by Generic Letter 87-09. On May 17, 1991, the NRC issued an RAI to obtain information relative to the administrative controls and training to be employed by PSE&G in limiting the use of the new 3.0.4 exemptions. The RAI states that the basis for accepting the 3.0.4 changes endorsed by Generic Letter 87-09 is predicated on the assumption that commencement of startup with important safety features inoperable will be.the exception rather than the rule. In order for the NRC staff to conclude that an adequate safety basis exists relative to this assumption, PSE&G was requested to:

1) identify and affirm those administrative controls established to limit the use of any authorized exceptions to Specification 3.0.4 and

2) identify training necessary for ensuring that plant operators are made aware of and instructed to exercise the controls promulgated in limiting the use of such exceptions.

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9107120208 910701 PDR ADOCK 05000272

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JUL o1 1gg1 Document Control Desk

• 2 NLR-N91094 contains information addressing the administrative controls and training which PSE&G intends to employ to ensure that abuse of the 3.0.4 exceptions does not occur. contains a description of a proposed revision to LCR 88-06, Revision 1. Attachment 3 contains a revised page which reflects the proposed revision. This page is intended to replace the corresponding page contained in LCR 88-06, Revision 1 dated February 20, 1991.

Should you have any questions or comments on this transmittal, do not hesitate to contact us.

Sincerely,

/X//6~

s. LaBruna Vice President -

Nuclear Operations Attachments (3) 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

REF: NLR-N91094 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM

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

I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated JUL o t 'ggi , 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 _ _\~ day of

• J0\1 , 1991

• ~ JJ. \/twk}

• Notary Public of New Jersey My Commission expires on ~~~*~--4-\~\5---!-\~-'-4~~~~~~~-

RESRXSE 'IO REOJES'l' FOR AIDITIONAL INFCR4ATIW/ICR REVISIW Im 88-06, REVISIW 1 - GENERIC IEl'lER 87-09 ClIANGES

~ OPERATING LICEmE NOO. Dffi-70 AND Dffi-75 SAllM GmERATING smTIW UNI'IS 1 .AND 2 IX>CKEl' NOO. 50-272 .AND 50-311 NIR-N91094 PSE&G endorses the philosophy that plant startup should normally be initiated only when all required equipment is operable and that startup with inoperable equipment must be the exception rather than the rule. Administrative controls will be developed and personnel training will be conducted to ensure that this philosophy is consistently .inplemented at the Salem Generating Station.

'As noted in previous correspondence (NIR-N90121 dated February 20, 1991), the Salem Integrated Operating Procedures (IOPs) will be revised to include checklists which must be completed prior to entering a higher mode of operation (e.g. , Mode 5 to Mode 4) * '!he checklists will identify all Technical Specification action statements in effect in the current mode and those that will be in effect upon entry into the intended mode of operation.

Approval of the checklist by the Senior Nuclear Shift SUpervisor will be a prerequisite for the mode change. In addition, administrative controls will be instituted requiring that the concurrence of operations management (Operations Manager or Operating Engineer) be obtained prior to changing modes under the new provisions of Specification 3.0.4.

Guidance on changing modes under the new provisions of Specification 3. o. 4 will be developed and dOClilllented. '!his guidance will inco:rporate the philosophy that plant startup with important safety features inoperable must be the exception rather than the rule. '!he guidance will errphasize that reliance on Specification 3.0.4 for plant startups must be limited to those situations that are absolutely necessary and safe for plant operations.

Personnel training will be conducted on the Technical Specification changes and all associated administrative controls and guidance. '!his training will ensure that all appropriate personnel are made aware of and instructed to exercise the controls promulgated to control the use of the new provisions of Specification 3.0.4.

It is believed that the administrative controls and guidance described above will ensure that the consequences of changing modes with inoperable equipment will be adequately evaluated by appropriate levels of utility management and that mode changes with inoperable equipment will be executed only when absolutely necessary and when such mode changes do not affect safe plant operat;i.on.

Due to the training connnitments discussed above, the 60 day .inplementation period requested in I.CR 88-06, Revision 1 (NIR-90121 dated February 20, 1991) may not be adequate. PSE&G therefore requests an extended

.inplementation period to pennit the required training to be conducted prior to

.i.nplementation of the amendment. Upon NRC approval, please issue a license amendment which will be effective upon issuance and shall be .inplemented within 90 days of issuance.

\

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RESKRm 'ID REQJEST FOR AIDITIOOAL JNKR.mTIONfliR REVISION Im 88-06, REVISION 1 - GENERIC IEIT.ER 87-<>9 CHANGES

~OPERATING LICEmE :tm. DFR-70 .AND DFR-75 SAIJ!M GmERATING smTION UNITS 1 .AND 2 JDCKEr :tm. 50-272 AND 50-311 NIR-N91094 I. Description. of Revision ICR 88-06, Revision 1 is being revised to delete the sentence in the proposed Bases Section for Specification 3.0.4 which states, Unless othei:wise noted, the portion of Specification 3.0.4 that is exempted by the remaining 3.0.4 exemptions is that portion stating that entcy into an OPERATIONAL MODE or other specified condition shall not be made when the conditions of the ICO are not met and the asscx::iated ACTION requires a shutdown if they are not met within the specified time intei:val (i.e., Part a)."

II. Reason for Revision It was detennined during NRC review of I.CR 88-06, Revision 1 that the subject Bases sentence could lead to unintended restrictions on mcx;ie changes for specifications that do not allow unlimited continued operation but currently include exemptions from the requirements of Specification 3.0.4.

• III. Justification for the Revision Unintended restrictions such as those that could be created by the subject Bases sentence are contrary to the Generic letter 87-09 guidance. In addressing specifications that do not allow unlimited continued operation but contain existing 3.0.4 exemptions, the generic letter states that it is not the staff's intent that the proposed changes result in more restrictive requirements for individual specifications.

N.

• Significant Hazards Consideration E'Valuation Impact In NIR-N90121 dated February 20, 1991, PSE&G 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. 'lhese conclusions and the basis for making them is unaffected by this revision; the significant hazards analysis submitted in NIR-N90121 remains valid.

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