ML18096B024
| ML18096B024 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/30/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18096B025 | List: |
| References | |
| GL-86-10, GL-88-12, NLR-N92107, NUDOCS 9210080168 | |
| Download: ML18096B024 (7) | |
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 SEP 3 0 1992 NLR-N92107 Q.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 Gentlemen:
SUPPLEMENT TO REQUEST FOR AMENDMENT SALEM GENERATING STATION, UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311
Reference:
LCR 90-15 On June 30, 1992, Mr. T. Storey, a contractor employed by the Nuclear Regulatory Commission conducted an on-site review of documentation supporting PSE&G's amendment request which was submitted in response to NRC Generic Letter 86-10.
Based upon that review, Public Service Electric and Gas Company (PSE&G) hereby transmits clarifications and corrections, identified during the review,, to supplement our original submittal.
This supplemental information does not materially change our original amendment request.and the corrections and clarifications provided have no significant impact on our original justification.
For continuity, the attachments contained in this letter are copies of the corresponding sections in our original request with the clarifications and corrections identified by marginal marks. contains our original requested changes with the proposed License Condition reworded to be more consistent with that suggested in the Generic Letter. contains the inserts and marked-up pages to accomplish the requested changes.
Included are a typographical correction, the reworded License Condition and a marked-up Technical Specification (TS) page which was inadvertantly omitted from Enclosure 1, for Unit 1, in our original submittal. provides several more detailed justifications for fire protection TS relaxations and for deviations from the.
Westinghouse Standard Technical Specifications (STS) which are being requested in the Salem station amendment.
Additionally, a reference to the Westinghouse STS, Revision 5, in our amendment 9210080 i',68." 920930 PDR. ADOCK '*05000272 P
-/,'
'11' Document Control Desk NLR-N92107 2 -
SEP 3 0 1992 description is corrected to Revision 4.
The entire original is enclosed with revisions identified by marginal bars.
Finally, in response to specific reviewer questions on the subject, our review and position regarding control functions accomplished from the Hot Shutdown Panel are discussed in.
Pursuant to the requirements of 10CFR50.9l(b) (1), PSE&G has provided a copy of this amendment request to the state of New Jersey.
Should you have any questions regarding this supplemental information, we will be pleased to discuss them with you.
Attachments Affidavit Sincerely, c
Mr. T. T. Martin, Administrator USNRC Region I Mr. J. C. Stone USNRC Licensing Senior Project Manager Mr. T. P. Johnson USNRC Senior Resident Inspector Mr. K. Tosch, Chief, Bureau of Nuclear Engineering New Jersey Department of Environmental Protection
I e
REF: NLR-N92107 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 the above referenced letter, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscribe~fnd Sworn to before me this.BD\\ft"J day of ;&IJ~{)e)), 1992 Notary
,ii.
- MY Commission expires on I I r
.'~
/ (
SHERRY L. CAGLE NOTARY PUBLIC OF NEW JERSEY My Commission Exoires March 5,.1997
Ref:
LCR 90-15 ATTACHMENT 1 PROPOSED CHANGES TO FACILITY OPERATING LICENSE DPR-70 AND DPR-75 FOR SALEM GENERATING STATION, UNIT NOS.1 AND 2
- moKSED rnANGES F2\\CILITY OPERATING LICENSE NOO. DPR.-70 AND DPR-75 SAUM GE2mRA.TING STATION UNIT NOO 1 AND 2 rxx:KEI' NOO. 50-272 AND 50-311 Pursuant to the guidance of Generic Letters 86-10 and 88-12, add the following as replacements for the entire current License Condition 2.C. (5) to the Salem Unit No. 1 Facility Operating license and License condition 2.C. (10) of the Salem Unit No. 2 Facility Operating License:
"PSE&G shall inlplement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report, and as approved in the NRC Safety Evaluation Report dated November 20, 1979, and in its supplements, subject to the following provision:
PSE&G may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
From both Salem Units' Technical Specifications (TS), remove, in their entirety, Sections 3/4.3.3.6 (Fire Detection Instn.nnentation), Table 3.3-10 (Fire Detection Instruments), 3/4.7.10 (Fire Suppression systems), 3/4.7.11 (Penetration Fire Barriers), Specification 6.2.2.e and the reference to Fire Brigade in associated Footnote"#" (Facility Staff), Specification 6.4.2 (Training), Bases Sections B3/4.3.3.6, B3/4.7.10, and B3/4.7.11, and Index page references to the.foregoing sections.
Additionally, insert the following Special Report requirement as a new TS Section 6.9.3:
"6.9.3 Violations of the requirements of the fire protection program described in the Updated Final Safety Analysis Report which would have adversely affected the ability to achieve and maintain safe shutdown in the event of a fire shall be submitted to the U. s. Nuclear Regulato:ry Conunission, Docket Control Desk, Washington, DC 20555, with a copy to the Regional Administrators the Regional Off ice of the NRC via the License Event Report System within 30 days."
Generic Letters 86-10 and 88-12 provide guidance to utilities seeking license amendments that recognize approved Fire Protection Programs and that remove SUrveillance/Lirniting Conditions for operation from the TS. 'Ihe purpose of this amendment request is to remove the Fire Protection Program, which satisfies the criteria of the Generic Letters, from the Salem TS (after NRC review and approval of the comprehensive and up-to-date Fire Protection Program that is provided in Attachments 3 and 4)
- PSE&G is making this change request to inlprove the overall Fire Protection Program at Artificial Island.
JUSl'IF'ICATICH FOR '!HE PK>IU3ED rnANGES The enhancements made to TS through this Attachment reflect actual plant conditions. The incorporation of Standard Technical Specification (STS) requirements and approved Hope Creek variations allow a consistent fire protection program to be applied at Artificial Island. By removing inconsistent requirements, the probability of errors in smveillance requirements is reduced. The NRC review and approval of the proposed changes will then satisfy the Criteria of Generic I.etters 86-10 and 88-12 and pennit the removal of the Salem Fire Protection Program (as approved by NRC) from the TS following the guidelines provided by the Generic I.etters. The removal of the Fire Protection Program from the TS has been reviewed by the NRC staff as part of the issuance of the Generic I.etters and been found acceptable provided that the criteria established in the Generic I.etters are met.
SIGNIFICANI' HAZARIE ANAINSIS CXH;IDERATICH The proposed changes to the technical specifications do not involve a significant increase in the probability or consequences of any accident previously evaluated.
Upon NRC approval of the requested changes herein, the FPP requirements currently defined in the TS, in conjunction with these additional proposed changes to those TS and to the SGS Updated Facility Safety Analysis Report (UFSAR) in Attachment 4, would be embodied within a periodic testing and smveillance program described in the SGS UFSAR that would entail shifting of the testing requirements from TS smveillance procedures to periodic test procedures. The Attachment 1-proposed License Condition and additional Special Report requirements in TS Section 6.9.3 would provide adequate administrative control of FPP elements to ensure that station capabilities to achieve and maintain safe shutdown in the event of a fire remain at an equivalent level of fire protection as currently provided with the FPP in the TS.
Since station fire Protection capabilities will remain at an equivalent level with the FPP removed from the TS, it can be concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes to the technical specifications do not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes represent enhancements to existing TS. The majority of significant are to Unit 1 TS to provide consistency with Unit 2. The changes to both units' TS are in accordance with approved generic Westinghouse STS and variations approved for Hope Creek Generating Station. No physical plant modifications or operating configurations result from these changes. The proposed changes do not affect the design or operation of any system or component important to safety. Upon NRC approval of the Fire Protection Program, as modified herein, the removal of the elements of that program from TS and incorporation in the UFSAR in accordance with the provisions and guidelines of Generic I.etters 86-10 and 88-12 will not create any new or different accident from any previously evaluated.
'!he proposed changes to the technical specifications do not involve a significant reduction in a margin of safety.
'!he proposed changes affect the control of periodic testing and smveillances for fire protection systems and components. 'Ihe changes do not affect any analysis of design bases accidents or Appendix R Hazards Consideration. 'Ihe proposed changes provide a consistent approach to assuring operability and availability of existing fire protection systems for safety-related areas at Salem Generating Station.
'!he proposed License condition and requirements placed in TS Section 6.9.3 will ensure that the station fire protection capabilities, following removal of the FPP from the TS, remain at an level equivalent to that level currently in place with the FPP in the TS.
'lherefore, removal of the fire protection program elements from the TS will not involve a significant reduction in a margin of safety.
OJNCIDSION Based on the infonnation provided above, PSE&G has concluded that the proposed changes satisfy the criteria for a no significant hazards consideration.