ML18096B246

Rev 1 to License Change Request 89-06 to Licenses DPR-70 & DPR-75,revising RTS & ESFAS Instrumentation Sections & Associated Bases for Surveillance Test Intervals & Allowed Outage Times

ML18096B246
Person / Time
Site:	Salem
Issue date:	02/02/1993
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18096B247	List: ML18096B246 ML18096B249
References
NRL-N92172, NUDOCS 9302110170
Download: ML18096B246 (14)

Text

Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations FEBO 2 1993 NLR-N92172 LCR 89-06 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

REQUEST FOR AMENDMENT, REVISION 1 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 In accordance with the requirements of 10CFR50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits a request for amendment of Facility Operating Licenses 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.

On May 11, 1992, PSE&G submitted a proposed amendment request to revise the Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) Instrumentation Sections and associated Bases, for Surveillance Test Intervals (STI) and Allowed Outage Times (AOT).

Upon further review, a number of minor discrepancies were identified in that submittal.

We are transmitting Revision 1 to that request to correct those discrepancies.

Additionally, we have included several administrative Technical Specification changes that were not identified in our original submittal.

Based on discussions with Mr. J. Stone, the NRC.Project Manager for Salem Generating Station, we are also providing justification for an Action Statement change and clarification of surveillance testing in bypass.

Due to the number of changes and impact of Technical Specification amendments approved since the original submittal, we are forwarding a complete Description of Changes section and marked-up pages to reflect all requested changes. 'The previously submitted Description of Changes and marked-up pages are hereby superseded.

The previously submitted Justification for Proposed Changes, Response to Safety Evaluation Report Imposed Conditions,

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Document Control Desk NLR-N92172 2

FEB 0 2 1993 Significant Hazards Analysis Consideration, and Conclusions are included for convenience of review and remain unchanged.

Attachment A contains a complete Description of Changes section, justification for Functional Unit 9.b Action Statement change, and clarification of surveillance testing in bypass.

Attachment B is a markup of the existing Unit 1 Technical Specifications to reflect the requested changes.

Attachment C is a markup of the existing Unit 2 Technical Specifications to reflect the requested changes.

Should you have any questions on this transmittal, please contact us.

Affidavit Attachments (3)

Sincerely, c

Mr. T. T. Martin, Administrator - Region I

u. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. J. c. Stone, Licensing Project Manager -

Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. T. P. Johnson (S09)

USNRC Senior Resident Inspector Mr. K. Tosch, Chief NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

REF: NLR-N92172 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.

Subscribed and Sworn to before me this cJ.. ncl day of1{Jrrv.1LX~, 1993 15£~~ E N:f!!:ey KIMBERLY A. HILL NOTARY PUBLIC OF NEW JERSEY My Commission Expires March 9, 1997 My Commission expires on ~~~~~~~~~~~~~~~

ATTACHMENT A LCR 89-06 I.

Description of Changes This amendment request proposes to revise Salem Unit 1 and 2 Technical Specification Sections 3/4.3.1 (RTS) and 3/4.3.2 (ESFAS) as follows:

1.

Limiting* Condition for Operation 3.3.1.1 A.

Table 3.3-1

1)

(Units 1 and 2) Functional Units 12 thru 15 and 18.

Change applicable ACTION from 7 to

6.

2)

(Units 1 and 2) Functional Units 19 and 22.

Change applicable ACTION from 1 to 10.

ACTION 10 is added to implement a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> maintenance and 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> surveillance AOT for the appropriate functions.

3)

(Units 1 and 2) ACTION 2.

Change the time an inoperable channel may be maintained in an untripped condition from 1 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Allow placing the inoperable channel in bypass while testing another channel in the same function, instead of placing the tested channel in bypass.

Change the time an inoperable channel may remain in bypass to support testing another channel in the same function from 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Add the words "of other channels."

Adding the words "of other channels" is an administrative change to clarify and provide consistency between Units 1 and 2.

4)

(Units 1 and 2) ACTION 7.

Delete and mark NOT USED.

5)

(Units 1 and 2) ACTION 10.

Change NOT USED to See Insert.

6)

(Units 1 and 2) ACTION 11.

Change the time an inoperable channel may be maintained in an untripped condition from 1 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

1

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7)

(Units 1 and 2) ACTIONS 1, 2 and 6.

Change identified specification number to 4.3.1.1.1.

This is an administrative change to identify the correct specification.

B.

Table 4.3-1

1)

(Units 1 and 2) Functional Units 2, 3, 4, 6, 7, 8, 9, 10, 12, 14, 15, 16, 17.

Change CHANNEL FUNCTIONAL TEST frequencies from monthly to quarterly.

2)

(Units 1 and 2)

Notation (1) is changed from 7 to 31 days.

2.

Limiting Condition for Operation 3.3.2.1 A.

Table 3.3-3

1)

(Units 1 and 2) Functional Units 1.c, 1.d, 1.e, 1.f (three places), 4.d (three places),

5.a, 8.c.i, and 8.c.ii.

Change the applicable ACTION from 14 to 19.

2)

(Units 1 and 2) ACTION 13.

Change to include a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> maintenance AOT.

Change the time a channel may be bypassed to support surveillance testing from 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

(Unit 1 only) ACTION 13.

Add the words "provided the other channel is operable."

Adding the words "provided the other channel is operable" is an administrative change to clarify and provide consistency between Units 1 and 2.

3)

(Units 1 and 2) ACTION 16.

Change the time an inoperable channel may be maintained in an unbypassed condition from 1 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Increase the time that another channel in the same function may be bypassed to allow surveillance testing from 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

(Unit 1 only) ACTION 16.

Add the words "by CHANNEL CHECK."

Adding the words "by CHANNEL CHECK" is an administrative change to clarify and provide consistency between Units 1 and 2.

2

4)

5)

(Units 1 and 2) ACTION 19.

Change the time an inoperable channel may be maintained in an untripped condition from 1 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Allow placing the inoperable channel in bypass while testing another channel in the same function, instead of placing the tested channel in bypass.

Change the time an inoperable channel may remain in bypass to support testing another channel in the same function from 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Add the words "of other channels."

Adding the words "of other channels" is an administrative change to clarify and provide consistency between Unit 1 and 2. *

(Units 1 and 2) ACTION 20. Change to include a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> maintenance AOT.

Change the time a channel may be bypassed to support surveillance testing from 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Add the words "per.specification 4.3.2.1.1.

Adding the words "per specification

4. 3. 2.1.1 11 is an administrative change to clarify and provide consistency between Units 1 and 2.

6)

(Unit 2 only)

Functional Unit 9.b.

Change applicable ACTION from 13 to 20.

This change corrects an existing*. Technical Specification error.

ESFAS Action Statements associated with Automatic Actuation Logic take the plant to a mode below the specified "Applicable Mode."

Functional Unit 9.b is applicable in Modes 1-3, thus the appropriate Action Statement is 20, which requires placing the plant in HOT SHUTDOWN (Mode 4).

This is an administrative change.

B.

Table 4.3-2

1)

(Units 1 and 2) Functional Unit 1.c, 1.d, 1.e, 1.f, 2.c, 3.b.3, 4.c, 4.d, 5.a, and 8.c.

Change CHANNEL FUNCTIONAL TEST frequency from monthly to quarterly.

2)

(Units 1 and 2) Functional Unit 8.d.

Change CHANNEL FUNCTIONAL TEST frequency from monthly staggered (Unit 1) and monthly (Unit

2) to quarterly.

3

3)

(Unit 2 only) Functional Unit 9.a.

Change CHANNEL FUNCTIONAL TEST from monthly to quarterly.

II.

Clarification of Surveillance Testing in Bypass

1.

In addition to the Westinghouse TOPS Program (WCAP-10271 and its supplements) proposed changes, we previously requested changes to ACTION 2 and 6 of Table 3.3-1 and ACTION 19 of Table 3.3-3, to allow bypassing an inoperable channel for surveillance testing of other channels.

These changes provide consistency with the Westinghouse Standard Technical Specifications (STS).

The STS allows bypassing an inoperable channel for surveillance testing of other channels.

Salem Station does not have bypass testing capability on any analog channels, with the exception of.

Containment Pressure High-High.

Inoperable channels are placed in the tripped condition within the limitations of the Action Statement.

If surveillance testing is subsequently initiated on another channel in that functional unit, a valid*actuation signal (Reactor trip or Safeguards) would be generated.

To avoid this situation, a dummy signal is applied to the inoperable channel (referred to as bypass) to simulate an operable condition.

The tested channel is then placed in the tripped condition during surveillance Testing.

These actions functionally change a 2-out-of-4 logic to a l-out-of-2 logic, since a trip condition on either of the remaining operable channels will result in an actuation signal (Reactor Trip or Safeguards).* Upon completion of Surveillance Testing, the tested channel is returned to normal and the inoperable channel is returned to the tripped condition.

These proposed changes are in accordance with the normal testing configuration of the installed equipment and therefore do not represent a significant change.

2.

RTS Action Statement 10 and ESFAS Action Statements 13 and 20 refer to a "bypass" condition.

The associated Functional Units concern Automatic Logic Testing.

Salem does have the capability to conduct Logic Testing with the tested channel in the traditional bypass condition.

4

III. Justification for the Proposed Changes AS INDICATED ON THE COVER LETTER, THIS SECTION IS INCLUDED FOR CONVENIENCE OF REVIEW AND REMAINS UNCHANGED FROM OUR PREVIOUS SUBMITTAL.

Increasing the RTS and ESFAS instrumentation STis minimizes the potential number of inadvertent reactor trips and ESFAS actuations.

Less frequent surveillance testing is estimated to result in 0.5 fewer inadvertent reactor trips per unit, per year.

Increasing the STis enhances the operational effectiveness of plant personnel.

Reducing the amount of time devoted to surveillance testing allows manpower reallocation to tasks such as preventive maintenance.

Increasing AOTs results in fewer human factors errors, since more time is allotted to perform corrective actions.

WCAP-10271 results indicate that the reduction in testing frequency and the increase in maintenance AOTs do not adversely affect public health and safety.

The results of the plant-specific evaluation for Functional Unit 9, Semi-automatic Switchover to the Containment Sump on RWST Low Level, also supports this conclusion.

The proposed changes will reduce the number of inadvertent reactor trips and ESFAS actuations, and support a greater level of managed plant resources.

IV.

Response to Safety Evaluation Report Imposed Conditions AS INDICATED ON THE COVER LETTER, THIS SECTION IS INCLUDED FOR CONVENIENCE OF REVIEW AND REMAINS UNCHANGED FROM OUR PREVIOUS SUBMITTAL.

The Westinghouse owners Group (WOG) evaluated the impact of the proposed STI and AOT changes on Core Damage Frequency (CDF) and public risk in WCAP-10271 and its supplements.

The NRC staff concluded in their review of these documents, that the overall upper bound of the CDF increase is less than 6% for Westinghouse PWR plants.

The Staff expected actual CDF increases for individual plants substantially below 6%.

This CDF increase is small when compared to the range of uncertainty in the CDF analysis, and is therefore acceptable.

The Staff did not require a staggered test strategy for ESFAS channel testing, and eliminated this previous requirement for RTS analog channel testing.

This decision resulted from the relatively small contribution of the analog channels to RTS/ESFAS unavailability, process parameter signal diversity, and normal operational testing sequencing.

5

Our proposed changes are consistent with NRC SERs dated February 21, 1985, February 22, 1989, and April 30, 1990.

These SERs are associated with WCAP-10271 Supplement 1, WCAP-10271 Supplement 2, and WCAP-10271 Supplement 2 Revision 1 respectively.

Functional Unit 9, Semi-automatic Switchover to the Containment Sump on RWST Low Level, is not part of the TOPs generic program.

Westinghouse completed a plant-specific evaluation for PSE&G's Salem Unit 2.

This evaluation determined the change in availability when the generically approved AOT and STI were applied to this function.

The evaluation yielded less than a 12% decrease in automatic function availability.

This corresponds to the lowest value for any Functional Unit in the generic program.

We anticipated these results since this function utilizes a 2 out of 4 configuration, with a minimum of modules in each loop.

The final switchover actions are manually completed.

Emergency Operating Procedures specify automatic action verification.

Thus, the decrease in automatic function has no impact on the ultimate success of the switchover evolution.

Staff approval of the TOPs generic program changes is contingent upon confirmation that certain conditions are met.

Although WCAP-10271 Supplement 2 and WCAP-10271 Supplement 2 Revision 1 specifically apply to ESFAS instrumentation, PSE&G has imposed the conditions described in WCAP-10271 and WCAP-10271 Supplement 1 for RTS instrumentation to the ESFAS, as appropriate.

These conditions also apply to the Functional Unit not covered by the generic program, where appropriate.

PSE&G provides the following responses to the required conditions.

1.

RTS SER Conditions A.

The RTS SER states that approval of an increase in STI from once per month to once per quarter, for analog channel operational tests, is contingent on performance of testing on a staggered test basis.

The ESFAS SER removed this requirement.

PSE&G Response - Neither Salem Unit implemented staggered testing for the RTS function, so this SER condition has no impact.

B.

The RTS SER states that approval of items related to extending STI is contingent on procedures in-place to require failure evaluation for common cause and additional testing, if necessary.

6

PSE&G Response -

Salem Units 1 and 2 will have procedures in-place for common cause failure evaluation and any required additional testing, prior to the requested implementation date.

These procedures will be consistent with the "Westinghouse Owners Group Guidelines for Preparing Submittals Requesting Revision of Reactor Protection System Technical Specifications, Revision 1, 11 which received NRC Staff review and approval.

c.

The RTS SER states that approval to extend STI and AOT for channels that provide dual inputs to other safety related systems, such as ESFAS, only applies to the RTS function.

PSE&G Response -

The extensions generically approved for the ESFAS analog channels are now the same as the RTS channels.

This condition is not applicable to Salem since the relaxations requested are the same for channels shared by the RTS and ESFAS.

D.

The RTS SER states that approval of channel testing in a bypassed condition is contingent on the capability of the RTS design to support such testing without lifting leads or installing temporary jumpers.

PSE&G Response - Salem Units 1 and 2 do not have bypass testing capability for any RTS or ESFAS analog instrumentation, with the exception of the Containment Pressure High-High channels.

Extending bypass testing capability to other channels requires plant modifications.

We do not anticipate installing these modifications in the near term.

Thus, approval for bypass testing is not requested at this time.

E.

The RTS SER states that acceptance is contingent on confirmation that the instrument setpoint methodology includes sufficient margin to offset the drift anticipated as a result of less frequent surveillance.

PSE&G Response -

We have evaluated Salem Units 1 and 2 setpoint drift per "Westinghouse Owners Group Guidelines for Preparing Submittals Requesting Revision of Reactor Protection System Technical Specifications, Revision 1, 11 which received NRC Staff review and approval.

7

PSE&G has determined that the values used in the Salem Unit 1 and 2 setpoint methodology properly account for drift associated with extended STis.

2.

ESFAS SER Conditions A.

The ESFAS SER states that the licensee must confirm generic analysis applicability to their specific plant.

PSE&G Response -

The generic analysis used in WCAP-10271 and Supplements is applicable to Salem Units 1 and 2.

Salem Units 1 and 2 use the Westinghouse 7100 Process Control System and the Westinghouse Solid State Protection System for RTS and ESFAS.

Both of.these systems were specifically modelled iri the generic analyses.

All of the requested ESFAS Functional Unit relaxations are addressed by the generic analysis, with the exception of Functional Unit 9 on Unit 2.

Westinghouse addressed Functional Unit 9 on a plant-specific basis for PSE&G.

They determined that this Functional Unit has less than a 12%

decrease in availability.

This value corresponds to the lowest calculated value for any Functional Unit in the generic program.

The generic program determined that an availability decrease of less than 12% was acceptable.

B.

The ESFAS SER states that the licensee must confirm that any increase in instrument drift due to the extended STis is properly accounted for in the setpoint calculation methodology.

PSE&G Response -

same as RTS Condition E above.

V.

Significant Hazards Analysis Consideration AS INDICATED ON THE COVER LETTER, THIS SECTION IS INCLUDED FOR CONVENIENCE OF REVIEW AND REMAINS UNCHANGED FROM OUR PREVIOUS SUBMITTAL.

The proposed Technical Specification changes:

1.

Do not involve a significant increase in the probability or consequences of an accident previously evaluated.

8

L

• SERS issued for WCAP-10271, WCAP-10271 Supplement 1, WCAP-10271 Supplement 2, and WCAP-10271 supplement 2 Revision 1 document the determination that the proposed changes are within acceptable limits.

Implementation of the proposed changes decreases the total Reactor Protection System (RPS) yearly availability, primarily due to less frequent surveillance testing.

Decreased availability causes a higher probability of Anticipated Transient Without Scram (ATWS), with an associated increase in the core melt contribution resulting from an ATWS.

Decreased ESFAS availability slightly increases the CDF.

The proposed changes result in a significant reduction in the core melt probability from inadvertent reactor trips.

This reduction is primarily attributable to less frequent surveillance testing.

The reduction in inadvertent reactor trip core melt frequency is large enough to counter the increase in ATWS core melt probability, resulting in an overall reduction in total core melt probability.

The WOG determined values for the increase in CDF were documented in the WCAP, and independently verified by Brookhaven National Laboratory, as part of an NRC Staff audit and sensitivity analysis.

Based on the small increase in CDF compared to the range of uncertainty, the increase is considered acceptable.

Salem Functional Unit 9, evaluated on a plant-specific basis, falls within the same criteria and is considered acceptable.

Therefore, it may be concluded that the proposed changes do not increase the severity or consequences of an accident previously evaluated.

The proposed changes do affect the probability of RPS failure, but do not alter the manner in which protection is afforded, nor the manner in which limiting criteria are established.

2.

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

The proposed changes do not involve hardware modifications:or result in changes to RPS provided plant protection.

RPS functionally is not altered.

Therefore, it* may be concluded that the proposed changes do. not create the possibility of a new or different kind of accident from any previously evaluated.

9

3.

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

The proposed changes do not alter the manner in which Safety Limits, Limiting Safety System Setpoints, or Limiting Conditions for Operation are determined.

The impact of reduced testing is a longer time interval over which instrument uncertainties (e.g., drift) may act.

Experience indicates that the initial uncertainty assumptions are valid for reduced testing.

Therefore, it may be concluded that the proposed changes do not involve a significant reduction in a margin of safety.

VI.

Conclusions AS INDICATED ON THE COVER LETTER, THIS SECTION IS INCLUDED FOR CONVENIENCE OF REVIEW AND REMAINS UNCHANGED FROM OUR PREVIOUS SUBMITTAL.

Implementation of the proposed changes results in plant safety and resource improvements through:

1.

Reduced number of inadvertent reactor trips and ESFAS actuations, due to less frequent testing.

2.

Improved equipment repairs and reliability, due to longer allowed outage times.

3.

Improved operating staff effectiveness in monitoring and controlling plant operations, due to less frequent operating shift distractions from surveillance testing.

Based on the information presented above, PSE&G has concluded that the proposed Technical Specification changes satisfy the criteria for a no significant hazards consideration.

10

ATTACHMENT Bl Markup of Salem Unit 1 Technical Specification 3/4.3.1 -

Reactor Trip System Instrumentation