ML18096A659

Application for Amends to Licenses DPR-70 & DPR-75,revising Surveillance Requirements 4.5.2.f & 4.5.2.h of TS 3/4.5.2 Re ECCS Surveillance Test Acceptance Criteria

ML18096A659
Person / Time
Site:	Salem
Issue date:	04/24/1992
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18096A660	List: ML18096A659 ML18096A661
References
LCR-91-03, LCR-91-3, NLR-N91025, NUDOCS 9205040073
Download: ML18096A659 (18)

Text

. I ,.

• Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038. 609-339-1200 Vice President - Nuclear Operations APR 2 4 1992 NLR-N91025 LCR 91-03 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LICENSE AMENDMENT APPLICATION ECCS SURVEILLANCE RELAXATIONS SALEM GENERATING STATION FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 This letter submits an application for amendment to Appendix A of Facility Operating Licenses DPR-70 and DPR-75 for the Salem Generating, Station Unit Nos. 1 and*2 and is being filed in accordance with the provisions of 10CFR50.90. This amendment application proposes revised ECCS surveillance test acceptance criteria. Specifically, changes are being proposed to Surveillance Requirements 4.5.2.f and 4.5.2.h of* Technical Specification 3/4.5.2, "ECCS Subsystems - T ~ 350°F." \

Appropriate modifications are also proposeda~g the. associated Bases. Paramount among' the proposed changes are allowances for a reduction in the required.minimum safety injection flows,. an increase in the allowed maximum runout .flows, and modification of the acceptance criteria for ECCS pump performance. These proposed changes would facilitate testing of the subject ECCS subsystems by providing additional margin between the minimum and maximum pump flow requirements. The changes would also allow flow measurement uncertainties to be directly. applied to flow measurements and remove the need to account for uncertainties implicitly through analysis.

A detailed description of and justification for the proposed changes is provided in Attachment 1 along with our 10CFR50.92 analysis of significant hazards. An evaluation has been performed by the Westinghouse Electric Corporation to support the proposed changes to the ECCS performance criteria. This evaluation is discussed in detail in Section III of Attachment 1.

Marked up Technical Specification pages showing the proposed changes are included as Attachment 2.

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9205040073 920424 PDR ADOCK 05000272 l \

P PDR

Document Control Desk 2

• APR 2 4 1992 NLR-N91025 Changes similar to those being proposed in this license amendment application have been issued by the NRC for Trojan, Donald c.

Cook, Sequoya, McGuire, Vogtle, and most recently for Diablo Canyon (September 5, 1991).

In accordance with 10CFR50.91(b) (1), a copy of this request has been sent to the State of New Jersey as indicated below. Upon NRC approval, please issue a License Amendment which will be effective immediately upon issuance and shall be implemented prior to restart following the subsequent refueling outage.

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

Sincerely, 0;.o~

I><:' r' '

• *s. :" La Bruna Vice President -

Nuclear Operations CEM Affidavit Attachments (2)

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-N91025 LCR 91-03 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"~uch, I find the matters set

- * -..

• forth*-.in. our>.letter-'dated.:*::'.'/~!.;"",2 4 19Q2 , concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.

and Sworn me this of 1992 ELliABETH J. KIDD Notary Public of New Jersey My Commission expires on My Commission Expires April 25, 1995

ATmCHMENl' 1 PROIOOED Cll1\NGES 'ID 'IIIE TEXllNICAL SPEX!IFICATIONS Licms.E ~ APPLICATICfi Exn:> SC1RV.EillANCE RErAXATIONS SAUM GmERATING S'm'l'ICfi

~ OPERATING LICENSES Dffi-70 AND Dffi-75 NIR-N91025

oocKEl' Na>. 50-272 AND 50-311 rm 91-03 I. Description of Proposed Cllarges

'!his amendment application proposes to mcxlify the emergency core cooling system (ECCS) surveillance test acceptance criteria contained in SUrveillance Requirement 4.5.2.f and 4.5.2.h to facilitate ECCS flow testing. '!he specific changes are discussed below. Unless othei:wise noted, the changes apply to both Units 1 and 2.

1) 'Ihe phrase "differential pressure" has been changed to the phrase "Total Dynamic Head (TIE)" in Specification 4.5.2.f.

2) '!he acceptance criteria for pressure testing of the centrifugal charging purrps (CCPs) is changed from~ 2400 psig discharge pressure to~ 2338 psi Total Dynamic Head (TIE).

3) 'Ihe acceptance criteria for pressure testing of the intennediate head safety injection purrps (IHSIPs) is changed from~

1425 psig discharge pressure to ~ 1369 psi TIE.

4) '!he acceptance criteria for pressure *testing of the residual heat removal (RHR) pumps is changed from ~ 195 psig discharge pressure to ~ 165 psi TIE for Unit 1 and from ~ 165 psig discharge pressure to ~ 165 psi TIE for Unit 2.

5) 'Ihe phrase "on recirculation flOVl is removed from the pump pressure testing surveillance requirement and replaced with the phrase "at the test flow point." 'Ihe "test flow point" is the flowrate which corresponds to the TIE acceptance value criteria.

6) 'Ihe :minllnum required injection flow for the CCPs is reduced from 346 gpm to 306 gpm.

7) 'Ihe :minllnum required injection flow for the IHSIPs is reduced from 463 gpm to 453 gpm for Unit 2 only (Unit 1 is already at 453 gpm).

8) '!he maximum allowed :runout flow for the CCPs is increased from 550 gpm to 560 gpm.

9) '!he maximum allowed :runout flow for the IHSIPs is increased from 650 gpm to 675 gpm.

Page 1 of 15

Attachment 1 LCR 91-03 ECCS surveillance Relaxations NLR-N91025

10) A requirement on total flow rate through all four injection lines is added for the C'CPs and IlJSIPs. '!he acceptance criteria is 5 444 gpm for the C'CPs and 5 647 gpm for the IlJSIPs. 'Ihese criteria ensure that the system resistance assumptions in the analyses are met.

11) A requirement on flow imbalance (i.e., the difference between the branch line with the highest flow and the branch line with the lowest flow) is added for the CCPs and IlJSIPs. '!he acceptance criteria is 5 10.5 gpm for the CCPs and 5 12.0 gpm for the IlJSIPs.

12) '!he

• and ** footnotes for Unit 2 are being deleted.

13) '!he Bases for ECCS subsystems are changed to reflect the changes made to the ECCS sm:veillance requirements.

14) '!he Bases for various contairnnent specifications have been updated to correct errors discovered during review. '!he changes are unrelated to the changes proposed for ECCS flavs and pressures. . '!he Contairnnent Bases are also being modified to delete the calculated value for the maximum expected peak contairnnent pressure. '!he specific value is being replaced by a statement that pressure will remain below the maximum contairnnent design pressure of 47 psig.

PSE&G contracted with Westinghouse Electric Corporation (Westinghouse) to evaluate ECCS perfonnance using the revised acceptance criteria. '!he results of this evaluation are discussed in section III below.

II. Reason for Pnl!JOSE'd Qiames PUinp perfonnance is measured in developed head. '!his is the differential pressure across the pump calculated by subtracting the :meaSured suction pressure from the pump discharge pressure. '!his is the "total dynamic head" term which is a more accurate tenn than discharge pressure. All acceptance criteria are now expressed in TIH.

'!he proposed changes to the pressure requirements of SUrveillance 4.5.2.f are intended to provide greater operational flexibility.

'!he proposed changes to the :maximum allowed and miniinum. required flavs of SUrveillance 4.5.2.h are intended to facilitate flow testing and allow flow measurement uncertainties to be directly applied to flow measurements.

'!he existing limits on minllm.nn and naximum flow in SUrveillance Requirement 4.5.2.h provide a narrow band within 'Which the flavs must be adjusted. '!he design Bases for ECCS injection and core thennal response were evaluated to reduce the miniinum. injection flow rate. In addition, the maximum pump runout flow rates were increased without adverse effects on electrical loading or pump integrity. '!his combined analysis resulted in a larger acceptance window between the minllnum ECCS flow required to mitigate accident scenarios and the naximum flow allowed for stable pump Page 2 of 15

Attachment 1 ECCS surveillance Relaxations

• LCR 91-03 NLR-N91025 operation. '!he new acceptance criteria would reduce maintenance expenditures and operational manipulations to achieve unnecessary precision. The increased acceptance band will also allow system resistance requirements and instnnnent inaccuracies to be included.

PSE&G does not currently apply instrument uncertainties directly to the measured sw:veillance test results collected during ECCS flow balancing.

Instrument uncertainty is currently addressed inplicitly through analysis with a resulting PC!' penalty incurred. '!he proposed changes would provide sufficient margin to ensure that recorded values remain within the acceptance criteria after direct application of instrument uncertainties.

'!he pump perfonnance requirements for the RHR pumps were changed to agree with the assumptions in the existing accident analysis.

'!he deletion of the phrase "on recirculation flow" is intended to make the Technical Specification sw:veillance requirement more flexible. '!he CCP recirculation lfnes at Salem are not equipped with flow measuring instrumentation. '!he testing of the CCPs is accomplished by setting the pumps to inject into the RCS at a specified flowrate and recording the developed pressure. '!he intent of specifying the recirculation flow path is to ensure that each sw:veillance test is perfo:rmed under the same fixed conditions as the previous sm:veillance test. Specifying that the test be conducted at a specified test flow point ensures consistency from

, one test to the next and maintains trending capability.

'!he

• and ** footnotes are no longer applicable and will be deleted.

New sm:veillance requirements are being proposed to require that flow imbalances and total flow through all four loops are within specified acceptance criteria. 'lhese new requirements are necessru:y to ensure that the assumptions in licensing basis safety analyses are being met.

'!he Bases changes for the ECCS subsystems are intended to reflect the changes to the ECCS licensing basis resulting from the new analyses with the revised acceptance criteria. '!he changes to the contairnnent systems Bases are unrelated to the ECCS changes. 'lhese Bases changes are intended to provide a more accurate description of the contairnnent system bases.

m. SUimary of Evaluation Using revised perfonnance assumptions, Westingh6use has evaluated ECCS perfonnance and the resulting impact on the Salem licensing basis safety analyses. '!he results of the Westinghouse evaluation are discussed below.

A. Analysis Asstmtptions

'!he maximum and minimum pump curves used in the analysis are sham below *

. Page 3 of 15

• .l Attachment 1 ECCS Surveillance Relaxations

• LCR 91-03 NLR-N91025 Centrifugal Charging Pumps Flow MaxiIIn.nn ijead Minimum ijead - 7%

(G:EM) (Ft/Psi) (Ft/Psi) 0 6200/2682 5414/2342 100 6155/2663 5394/2334 200 5811/2514 5094/2204 300 5000/2163 4284/1853 400 3910/1692 3194/1382 425 3610/1562 2884/1248 450 3250/1406 2559/1107 500 2470/1069 1794/776 525 2070/896 1464/633 550 1640/710 1014/439 560 1495/647 704/305 Intennediate Head Safety Injection Pumps Flow Maximum Head Minimum ijead - 10%

(GIM) (Ft/Psi)* (Ft/Psi) 0 3560/1540 3200/1384 100 3450/1493 3070/1328 200 3385/1464 3000/1298 300 3165/1369 2835/1227 400 2855/1235 2520/1090 500 2455/1062 2100/909 525 2355/1019 1985/859 550 2270/982 1870/809 575 2150/930 1755/759 600 2025/876 1635/707 650 1785/772 1400/606 675 1645/712 1260/545

• '!he tables provided in the Westinghouse evaluation contained only pump head values in feet; since values in psi were used throughout the remainder of the doa.nnent, for convenience, PSE&G converted the head ~ues in psi using the density of water at 70°F (62.3 lbf/ft ) .

'!he final colunm in each table represents the pump design curve degraded by 7% for the CCPs and 10% for the IHSIPs. '!he vendor curve is bounded by these values.

Additional assumptions used in the engineering evaluation are as follows:

1) '!he flow llnbalance between branch lines will not exceed 10.5 gpm in the centrifugal charging subsystem (i.e. , the imbalance is the difference between the branch line with the highest flow and the branch line with the lowest flow). '!he previous analyses assmned a flow imbalance of 5. o gpm between loops.

Page 4 of 15

.~

Attachment 1 ti ECCS Surveillance Relaxations

• LCR 91-03 NLR-N91025

2) '!he flow imbalance between branch lines will not exceed 12. o gpm in the intennediate head safety injection subsystem. '!he previous analyses assumed a flow imbalance of 5.0 gpm between loops.

3) '!he maxllm.nn header flCIW for the centrifugal charging subsystem is 444 gpm.

4) The maxllm.nn header flCIW for the intermediate head safety injection subsystem is 647 gpm.

5) The Till for the centrifugal charging subsystem is ~ 2338 psi at 60 gpm or ~ 2328 psi at 105 gpm.

6) The Till for the intennediate head safety injection subsystem is ~

1369 psi at 30 gpm or ~ 1320 psi at 130 gpm.

7) Reactor coolant pump (RCP) seal flow during sw:veillance testing is limited to a range of 76 gpm - 82 gpm.

8) The centrifugal charging recirculation miniflow range is 15 gpm to 34 gpm.

9) The intennecliate head safety injection recirculation miniflow range is 10 gpm to 28 gpm.

10) The centrifugal charging recirculation valves (SJ-139 and SJ-140) are conservatively assumed open in all mi.niinum ECCS cases and closed for all the maxinrum ECCS cases.

11) The minimum injection flow for the C'CPs is 306 gpm.

12) The minimum injection flow for the IHSIPs is 453 gpm.

13) The maxllm.nn runout flCIW for the C'CPs is 560 gpm.

14) The maxllm.nn runout flow for the IHSIPs is 675 gpm.

B. Evaluation of Impact on* Systems and Components The proposed changes were reviewed to evaluate their inlpact on the operability of the ECCS and its associated pumps. cavitation and motor horsepower capability are the two major concen1S which must be addressed "When increasing the pump runout operating conditions. An evaluation of pump perfo:rmance was conducted by the pump vendor, Dresser Purrp Division (Pacific Pumps). 'Based on this evaluation, the following conclusions were reached: *

1) The :miniinum Till of 2338 psi for the C'CPs and 1369 psi for the IHSIPs is within their design basis and does not represent a challenge to their operability.

Page 5 of 15

Attachment 1 ECCS Surveillance Relaxations

• LCR 91-03 NLR-N91025

2) '!he system provides ample net positive suction head (NPSH) to operate the CCPs at a nmout flow of 560 gpm and the IHSIPs at a runout flow of 675 gpm.

3) '!he increased :runout flows would have no effect on the long tenn mechanical and hydraulic perfonnance of the pumps.

4) Basd on* review of the horsepower cw:ves, operation at the proposed runout flows is within the horsepower capability of the pump motors.

5) '!he p.mps will not cavitate and the motors will not overheat during extended operation under the identified conditions.

6) The motor horsepower requirements at the increased pump runout flows were evaluated. since the Salem CCPs and IHSIPs have falling head characteristics that cause the pump brake horsepower cw:ves to became flat at high flow rates, the motor horsepower required to operate the pumps at the proposed runout limits does not exceed the horsepower required to operate the pumps at the original runout limit. '!he increased runout flows would therefore not cause an increase in the electrical power required to operate the pump assemblies and would not negatively impact the emergency diesel generator by increasing loads beyond their applicable capabilities and ratings. Furth.ennore, horsepower requirements at the increased flows remain within the rated limits of the motors (including sel'.Vice factor).

The Westinghouse evaluation concluded that the operability of the EC'CS and its associated pumps would not be challenged by any of the pressures or flow rates being proposed in this amendment application.

c. Evaluation of Impact on Accident Analyses

'!he accident scenarios which are potentially affected by changes in EC'CS flows are listed below. The impact of the proposed changes on each analysis is discussed.

Non-I.OCA Analyses The Salem Units 1 and 2 licensing basis non-I.OCA analyses which rely upon safety injection flow for accident mitigation include the steam line break analysis to detennine the core response (i.e.

margin to departure from nucleate boiling) , the steam line break mass and energy release inside contaimnent analysis for the detennination of the contairnnent pressure and temperature response, and the steam line break outside contairnnent analysis for equipment qualification. 'lhese analyses are perfonned assuming minimum safety injection flows which account for the limiting single failure of a safeguards train. None of the other Salem Units 1 and 2 non-I.OCA safety analyses rely upon minilnum safety injection flow for mitigation of the accident consequences and hence are not adversely affected by a reduction in the safety injection flow delivered by the Centrifugal Charging Pumps or the High Head Safety Injection Pumps.

Page 6 of 15

Attachment 1 LCR 91-03 ECCS Surveillance Relaxations NLR-N91025 One non-IDCA analysis is inpacted by the maxi.mum safety injection perfonnance. '!his event is the Spurious Operation of the Safety Injection System at Power which assumes the inadvertent actuation of the ECCS safety injection purrps during full power operation. In this event, all purrps are assumed to be available to deliver flow to the RCS, and therefore, safety injection flow assumptions during this event conservatively :maxiinize the pump perfo:nnance.

Safety injection flow ClllVes which reflect both the minil1lum and maximum safeguards safety injection flow for Salem Units 1 and 2 have been evaluated against the non-IJX'A licensing basis analyses and evaluations for Salem Units 1 and 2. The results of this evaluation show that the minil1lum safety injection flows assumed in previous SI reduction evaluations are more conservative for RCS pressures greater than 875 psia.

For pressures less than 875 psia, the difference in the SI flO'WS is slight and evaluation of the steam line break core response transient has shown that the existing licensing basis analysis is bounding. For the maximum SI cases, the maxi.mum safety injection flow rates using the revised Technical Specification acceptance criteria remain lower than the maximum SI flow rates which have been previously evaluated.

Based upon the results of these evaluations, it is concluded that, with the modified SI pump perfo:nnance, the existing Salem Units 1 and 2 non-IDCA licensing basis safety analyses remain valid and that the SI pump perfo:nnance, as presented in the changes to the Technical Specification ECCS smveillance test ranges, are bounded by the existing analyses.

Steam Generator Tube Rupture (SGIR) A SGIR results in a decrease in pressurizer pressure due to the loss of reactor coolant inventory. In addition, reactor trip and safety injection (SI) actuation were assumed to occur silllultaneously at the low pressurizer pressure SI setpoint for the Salem Units 1 and 2 analysis. After the reactor trip and SI actuation, the RCS pressure was assumed to reach equilibrium at the point at which the incoming SI flow rate equals the outgoing break flow rate. 'lhe equilibrium pressure and break flow rate were assumed to persist until 30 minutes after the accident. The :maximum. SI flow rates were assumed for the SGl'R analysis in order to maximize the equilibrium flow rate and therefore maximize the offsite radiological consequences.

In order to perfonn an assessment of the effect of revised Technical Specification safety injection flows with respect to the Salem Units 1 and 2 SGl'R analysis of record, the revised maxi.mum SI flow rates were compared with the maxi.mum SI flow rates used for the Salem Unit 1 and 2 SGl'R analysis of record. The results of the maxi.mum SI flow comparison indicate that for the RCS pressure range of interest in the Salem Unit 1 and 2 SGl'R analysis, the revised :maximum. SI flows are less than the maximum SI flow rates utilized for the Salem Units 1 and 2 SGl'R analysis of record. The conclusion in the Salem Units 1 and 2 FSAR that the offsite doses for a SGIR event would be within the 10CFRlOO guidelines remains valid for a SGIR event with the revised ECCS Technical Specification acceptance criteria.

Page 7 of 15

Attachment 1 ECCS Surveillance Relaxations

• LCR 91-03 NLR-N91025 Small Break I.DC'A (SBIDCA) '!he current SBIDCA licensing basis analysis for Salem Units 1 and 2 was perfonned using the 1975 WFIASH Westinghouse Small Break Evaluation Model. '!he Units 1 and 2 SBIDCA analysis of record is presented in Section 15. 3 of the plant UFSAR. The peak clad temperature (PC!') reported in the Salem UFSAR is 1465. 3 °F. A rnnnber of safety evaluations have been perfonned against the UFSAR analysis which have assigned additional PC!' penalties. These penalties include: 1) 3°F for setpoint uncertainty, 2) 22.3°F for V5JV'Ihi.mble Plugs, 3) 95°F for Auxiliary Feedwater enthalpy delay, 4) 100 °F for assmning the C'CP recirculation valve remains open for 10 minutes follOW'ing a I.OCA, 5) 5°F for degraded pump perfonnance, and 6) 37°F for SBIDCA coding updates.

When these PC!' penalties are added to the original PC!' of 1465.3°F, the resulting net pennanent PC!' is 1728°F {1465.3°F + 3°F + 22.3°F + 95°F +

l00°F + 5°F + 37°F = 1728°F).

The new SI perfonnance data was evaluated with respect to the current SBI.OCA licensing basis. The evaluation was perfonned for the 4 inch break case and for the limiting single failure configuration, which is the loss of one diesel generator with the corresponding loss of one train of SI.

For this configuration, it was detennined that the revised SI perfonnance assumptions resulted in a net degradation to the SI perfonnance assumed in the existing analysis/evaluation sequence. As a result, the following PC!'

penalties were assigned:

1. The assumption that the C'CP recirculation valve is open throughout the transient resulted in a 167°F PC!' penalty. This new PC!' penalty supersedes the l00°F penalty assessed for the recirculation valve being open for only 10 minutes {See No. 4 in the preceding paragraph). '!he net PC!' penalty is 67°F {167°F -

l00°F = 67°F).

2. The SI perfonnance was evaluated in detail using an approach which integrated the SI short fall over the duration of the RCS pressure transient through the ti.me of PC!'. This teclmique was applied for the 4 inch break pressure transient. The PC!'

penalty due to the SI degradation through PC!' t:ilne was then detennined using a sensitivity to SI. The result of this evaluation was an additional 122°F penalty assigned to the 4 inch break case. This 122°F penalty incorporates the previous SI reduction penalty of 5°F {See No. 5 in the preceding paragraph). '!he net PCr penalty is 117°F {122°F - 5°F = 117°F) *.

The pennanent PC!' for the 4" break case is now 1912°F {1728°F + 67°F +

117°F = 1912°F).

The cumulative SBIDCA PC!' is therefore 1912°F. This is below the 2200°F regulatocy limit. The EC'CS perfonnance with the re\rised Technical Specification acceptance criteria is therefore acceptable. SBIDCA PC!'

penalties are summarized below.

Page 8 of 15

Attachment 1

• ECCS Surveillance Relaxations LCR 91-03 NLR-N91025 Salem Units 1 and 2 Small Break IDCA PC!' SUmmary Item PC!' aJANGE NE!' PC!'

Existing PC!' 1728°P SUbsequent Pennanent Safety Evaluations: (SI-Dependent)

Recirc open at all times - +67°P (167°P - l00°P) 1795°P 167°P penalty (SUpersedes the l00°P penalty for the recirc valve being open for 10.minutes)

Additional Net SI Sho:rtfall - +117°P (122°P - 5°P) 1912°P 122°P penalty (SUpersedes the degraded perfonnance penalty of 5°P)

NE!' PERMANENT SBIOCA PC!': 1912°P

'!he cumulative SBI.OCA PC!' is 1912°P.

An assessment was made to evaluate the possibility of a shift in the limiting break size from the 4 11 break to a smaller break size. Typically, reduced SI flows tend to reduce the limiting break size. A detailed evaluation was completed to detennine if the 3" break size could became more limiting. '!he results of this evaluation concluded that the reduced SI associated with the new assmnptions had a smaller effect on the generic 3 II break than On the 4 11 break. '!he 4 11 break remained limiting by 11 op*

A study was also made to detennine the effect that the SI reduction would have on the zirconitnn water reaction. '!he approximate local and global reactions were estimated by considering the results of the WFIASH analysis for another plant with similar PC!' results. It was concluded that the 10CFR50.46 limits of 17% maximum local zirconium-water cladding oxidation and 1% core wide average zirconium-water reaction are satisfied and continue to be met.

large Break I.OCA '!he Salem IBI.OCA B.1\SH Evaluation Model analysis of record is presented in Section 15.4 of the UFS.AR. '!he PC!' reported in the Salem UFS.AR is 2091 °P for the double ended cold leg guillotine break with a discharge coefficient of % = 0. 4 for th~ :miniinum SI case. A.~ of safety evaluations have been perfonned against the UFS.AR analysis which Page 9 of 15

Attachment 1 LCR 91-03 ECCS surveillance Relaxations NLR-N91025 have assigned additional PCl' penalties. 'Ihese penalties include: 1) 1°F to address a non consei:vative low head safety injection {IHSI) input in the B.l\SH analysis, 2) l0°F to address I.OCBARl' coding updates, and 3) l0°F.

to address SG tube collapse. Consequently, the revised Salem Unit 1 and 2 IBIDCA a.nnulative PCl' is 2112 °F (2091°F + 1°F + l0°F + l0°F = 2112 °F) *

'!here are no IBIDCA PCl' penalties associated with the revised EC'CS perfo:nnance characteristics proposed by this amendment application.

IBIDCA PC!' penalties are summarized below.

Item PCl' CHANGE NEr PC!'

Existing PC!' 2112°F NEr PERMANENT IBIDCA PCl': 2112°F

'!he a.nnulative IBIDCA PCl' is 2112 °F.

'!he IBIDCA SI perfo:rmance data for the proposed EC.'CS flow rates was evaluated with respect to the current IBIDCA basis. '!he mininn.nn and maxinn.nn SI case with '1J = 0.4 and the :mi.nill1um SI cases with CU = 0.6 and 0.8 were considered. *

'!he IBIDCA Evaluation Model limiting single failure is the loss of one IHSI purrp. Conservatively for the Salem analysis, the remaining SI purrps on that train were not credited. It was shown for the B.l\SH transient that, by crediting the second CCP, the net SI perfo:nnance was increased beyond that assumed in the Salem analysis. '!here was no impact to the Salem B.l\SH analysis for all :mi.nill1um SI cases. Consequently, there was no impact to the overall transient for the IHSI failure mininn.nn SI cases presented in the UFSAR.

For the maximum SI case in the UFSAR analysis, it was detennined that the net CCP and IHSIP flow data had increased slightly and the IHSI data remained unchanged. '!he IBLOCA maxinn.nn SI case is not limiting for Salem.

A small increase in PCl' was postulated to occur for the maximum SI case.

'!his increase did not exceed the existing minimum SI PC!'. 'lhus, it was concluded that the maxinn.nn SI case remains non-limiting.

In conclusion, the IBLOCA PCl' for Salem Units 1 and 2 remains below the 2200°F regulato:cy limit in 10CFR50.46 and the EC.'CS pump perfonnance is acceptable.

Page 10 of 15

. i Attachment 1 ECCS surveillance Relaxations

• LCR 91-03 NLR-N91025 IDCA Blowdown Hydraulic Forces Blowdown hydraulic forces are primarily a function of plant geometry, break size, break location and initial RCS conditions (fluid temperatures and pressures). Since the blowdown forces are most limiting early in the event, SI is not modelled in the analysis.

'Iherefore, any SI short fall resulting from the reduced ECCS flows for the C'CPs and lliSIPs does not impact the results of the IDCA Blowdown Hydraulic Forces Analysis.

Post-IDCA I.Dng Tenn cooling SUb-criticality Calculation '!he Westinghouse evaluation model conunitrnent is that the reactor will remain shutdown using borated ECCS water residing in the smnp after a postulated IDCA. Since credit is not taken for the control rods for large break IDCA, the borated ECCS water provided by the aeeumulators and the RWST must have a boron concentration that, when mixed with other water sources, will result in the reactor core remaining subcritical assuming all control rods out.

Since SI performance does not affect the boron concentration assumptions, the SI short fall does not affect the results of the long tenn cooling sub-criticality calculation.

Hot I.eg switch-over to Prevent Potential Boron Precipitation Following a IDCA, there is a possibility that SI delivered flow to the RCS in the cold leg injection mode will not establish full circulation through the core.

Should this occur, the core fluid may stagnate and boiling may occur in the core in a quasi steady state manner leading to an increase in core boron concentration. In o:rder to prevent the boron from ex:c.eeding the solubility limit and leading to subsequent precipitation, the plant realigns the SI system to the hot leg recirculation configuration. '!his precludes the continued increase in boron concentration provided that the hot leg recirculation SI flO'irl is sufficient. '!he time after the IDCA that this switch-over must occur is predicted by analysis.

'!he Salem analysis for the prediction of the time to switch-over to hot leg recirculation uses inputs such as RCS and ECCS volumes and initial boron concentrations. SI is not modelled in the analysis. '!he 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> result is therefore not affected and the existing minimum hot leg recirculation SI flow requirement remains in place. It was verified that the new SI short fall perfonnance exceeds the existing rn.ini1m.nn hot leg recirculation SI flow requirement. '!here is therefore no impact on the analysis and the rn.ini1m.nn recirculation SI capability remains at or above the required value.

IDCA and SGI'R Conclusions Westinghouse has evaluated the revised safety injection purrp perfonnance data for Salem Units 1 and 2. Based upon the results of the preceding I.DC.A and SGI'R evaluations, it can be concluded that:

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. l Attachment 1 ECCS surveillance Relaxations

• LCR 91-03 NLR-N91025

1) '!he Salem Units 1 and 2 licensing basis SBI.OCA and IB1DCA results meet 10CFR.50. 46 requirements after consideration of the revised safety injection perfo:rmance and inclusion of all other current sources of I.OCA margin consumption.

2) '!he remaining Salem Units 1 and 2 I.OCA events and the SGl'R analysis remain bounded by existing licensing basis safety analysis requirements after consideration of the revised safety injection ptmp perfo:rmance.

Contairnnent Integrity '!he irrpact of the revised ECCS flow rates on various contaimnent integrity issues were evaluated. 'Ihese issues were evaluated as follows:

1) 'Ihe first contairnnent issues evaluated were the short tenn IOCA mass and energy releases and the subcomparbnent pressure analysis.

Ille to the short duration of the transient (less than 3 seconds) used for subcompartment analyses, change in safety injection flows have no effect on contairnnent subcompartment pressure analyses.

2) '!he second contairnnent issue evaluated was the long tenn mass and energy release. An evaluation of the irrpact of the revised safety injection flows on the contairnnent integrity analysis was perfonned.

'!he evaluation results show that the current UFSAR design basis analysis peak pressure for long tenn IOCA would be negligibly increased (<0.05 psi).

3) '!he third contairnnent issue evaluated was the steam line break contairnnent response. Since the mass and energy values do not change, there is no irrpact on the steam line break contaimnent response.

In stnmnacy, the effects of the reduction in safety injection flow have been evaluated from a contairnnent integrity perspective. Based on this evaluation, it is concluded that the operation of Salem Units 1 and 2 with the reduced safety injection flows is bounded by the current licensing basis safety analyses.

D. SUmmary of Conclusions

'Ihe following conclusions are dra"WJl*as a result of the Westinghouse analyses:

1. Non-IOCA Conclusions It is concluded that, with the* modified SI purrp perfo:rmance, the existing Salem Units 1 and 2 non-IOCA licensing basis safety analyses remain valid and that the SI ptmp perfomance, as presented in the changes to the Technical Specification ECCS sw::veillance test ranges, are bounded by the existing analyses.

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• J

• Attachment 1 LCR 91-03 ECCS Surveillance Relaxations NLR-N91025

2. SGI'R Conclusions For the RCS pressure range of interest in the Salem Unit 1 and 2 SGIR analysis, the revised maxiinum SI flows are less than the maximum SI flow rates utilized for the Salem Units 1 and 2 SGIR analysis of record. '!he conclusion in the Salem Units 1 and 2 FSAR that the offsite doses for a SGI'R event would be within the 10CFRlOO guidelines remains valid for a SGI'R event with the revised ECCS Technical Specification acceptance criteria.

3. SBIDCA Conclusions '!he PC!' for SBIDCA using the ECCS perfonnance with the revised Technical Specification acceptance criteria is below the 2200°F regulato:cy limit. It has been concluded that the 10CFRS0.46 limits of 17% maxiinum local zirconium-water cladding oxidation and 1% core wide average zirconium-water reaction are satisfied and continue to be met.

4. IBIDC'A Conclusions '!he LBIOCA PC!' for Salem Units 1 and 2 remains below the 2200°F regulato:cy limit in 10CFRS0.46 and the ECCS pump perfonnance is acceptable.

Arr:! SI short fall resulting from the reduced EC'CS flows for the CCPs and IHSIPs does not impact the results of the I.DCA blOINdown hydraulic forces analysis, the post-I.DCA long tenn cooling subcriticality calculation, or the analysis for hot leg switch-over to prevent potential Boron precipitation.

5. Contairnnent Integrity Conclusions Fram a contairnnent integrity perspective, it is concluded that the operation of Salem Units 1 and 2 with the reduced safety injection flows is bounded by the current licensing basis safety analyses.

The SI pump perfonnance, as proposed in the changes to the Technical Specification EC'CS sw::veillance requirements, have been evaluated, and it has been detennined that all applicable safety analysis criteria would continue to be met following inplementation of the proposed changes and that inplementation would not violate any regulato:cy limits or requirements (e.g., 10CFRS0.46).

E. PSE&G Evaluation of Impact on OVei:pressure Protection Systems In their evaluation, Westinghouse placed the responsibility for evaluating the impact of the proposed changes on the low tenperature overpressure protection systems upon PSE&G. '!he results of PSE&G' s evaluation is discussed below.

'!he design basis for the Salem low tenperature overpressure protection (I.JIOP) system is an inadvertent start of an IHSIP. The I.JIOP analysis uses 780 gpm as the worst case mass input. '!his assumption bounds the revised rtmout flow rate of 675 gpm, and therefore, the I.JIOP analysis remains bounding with the proposed revised flows.

Page 13 of 15 LCR 91-03*

ECCS Surveillance Relaxations NLR-N91025 IV. Justification for the Qiarpe A. Cllanqes to EC'CS Flows and Prnnp Pressures '!he purpose of SUrveillance Requirements 4.5.2.f and 4.5.2.h are to verify that the plant configuration is consistent with the assumptions used in the design and safety analyses. '!he new EC'CS perfonnance assumptions being proposed as surveillance test acceptance criteria have been used as new assumptions in the Salem accident analyses. '!he impact of the modified assumptions have been evaluated and it has been detennined that all applicable safety analysis criteria continue to be met. In addition, evaluation has shown that the new assumptions and acceptance criteria do not challenge the operability of the EC'CS system or its associated pumps.

It is noted that changes to EC'CS flows similar to those being proposed in this license amendment application have been issued by the NRC for Trojan, Donald c. Cook, Sequoya, McGuire, Vogtle, and most recently for Diablo Canyon (September 5, 1991)

• B. Deletion of "On Recirculation Flow Testing of the CCPs is accomplished by setting the injection flow into the RCS at a specified value (the test flow point) * '!he requirement that the testing be conducted at the test flow point ensures consistency from one test to the next and thereby maintains trending capability.

c. Changes to Containment Bases '!he changes proposed to the containment Bases are editorial in nature. Deletion of the analysis limit for containment pressure does not eliminate any requirement but simply removes the analytical number to avoid the need to modify the Technical Specification Bases every time the peak containment pressure changes. The parameter of importance is the allowed design pressure of 47 psig, and the Bases still specify that the peak pressure must rema.in below this value.

D. Deletion of Unnecessary Footnote '!he

• and ** footnotes on Unit 2 Page 3/4 5-6a are no longer applicable and their removal from the Technical Specifications would have no impact.

IV. Significant Hazaros Consideration Evaluation

'!he proposed changes to the Salem Generating Station Technical Specifications:

1. Do IXJt involve a significant irc:'ease in the prdJability or cansequen=es of an accident previously evaluated.

The evaluation perfonned by Westinghouse has detenni.ned that the proposed changes will not challenge the operability of the subject pumps nor result in violation of any safety analysis criteria.

Although there would be a relatively minor increase in runout flows, the increased flows would have no effect on the long-term mechanical and hydraulic perfonnance of the purnps.

Since design limitations continue to be met and the integrity of the Page 14 of 15

Attachment 1 LCR 91-03 ECCS Surveillance Relaxations NLR-N91025 reactor coolant system pressure boundary is not challenged, the assumptions employed in the calculation of the offsite radiological doses remain valid.

'Ihe Westinghouse evaluation detennined that all safety analysis acceptance criteria are met when using the revised flOVtT rates. With respect to the IDC'A accidents, the PC!' continues to confo:rm to 10CFR50.46 requirements.

'!he offsite doses for a SGl'R event remain within 10CFRlOO guidelines. '!he evaluation of a main steam line break and IDC'A mass and energy releases demonstrated that the present mass and energy releases are acceptable and that the contai.rnnent responses and all licensing conclusions remain valid.

Since the design limitations continue to be met and the integrity of the reactor coolant system pressure boundary is not challenged, the assunption employed in the calculation of the offsite radiological doses remain valid. '!he consequences of the IDC'A, non-IDC'A, and SGIR. accidents considered. in the Salem Units 1 and 2 licensing basis remain unchanged.

Based on the above info:anation, the proposed changes would not increase the probability or consequences of a previously analyzed accident.

2. lb DX create the possibility of a new or different k:ini of accident fran any accident previrusly evaluated.

'!he relatively minor increase in runout flows would have no effect on the long-te:rm mechanical and hydraulic perfonnance of the pumps. It has been detennined that the respective pump's operability will not be challenged.

No new single failures were discovered nor.were any new accident initiators found. '!he proposed changes will therefore not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. lb DX involve a significant reduction in a margin of safety.

'Ihe evaluation of IDC'A, non-IDC'A, and SGIR. accident analyses perfonned by Westinghouse has verified that with the proposed changes to the Technical Specifications, plant operation would be maintained within the bounds of safe, analyzed conditions as defined in the FSAR and the conclusions presented in the FSAR would remain valid. '!he analysis acceptance criteria would continue to be met with the revised ECCS perfonnance characteristics. '!he proposed changes would therefore not reduce a margin of safety.

V. Conclusion As discussed 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.

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