ML18096B301
| ML18096B301 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/23/1993 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18096B302 | List: |
| References | |
| NLR-N93022, NUDOCS 9303020468 | |
| Download: ML18096B301 (7) | |
Text
Public Service Electric and Gas Company Stanley LaBruna.
Public Service Electric and Gas Company P.O. Bcix *236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations FEB 2.-3 *1993 NLR-N93022 United.States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
- REQUEST FOR AMENDMENT 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) is transmitting a request to amend 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.
The proposed changes revise the provisions of Technical.
Specifications 3.3.3.7 Action 3, Post Accident Monitoring System, for both Salem Units.
As discussed in Attachment 1 to this letter, PSE&G's conclusion is that granting this request would not involve a significant hazards consideration.
contains the Technical Specifications marked-up pages.
Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, and to be implemented within sixty (60) days to provide sufficient time for associated administrative activities.
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PDR ADOCK 05000272 P
PDR Sincerely,
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Document Control Desk NLR-N93022 Attachment c
Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Chief 2
New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 FEB 2 3 *1993
REF: NLR-N93022 STATE OF NEW JERSEY
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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.
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Kifv'iBERL Y A Hll L NOTARY. P~BUC OF NEW-JERSEY My Comm1ss1on Expires March 9, 199?
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NLR-N93022 ATTACHMENT 1 I.
DESCRIPI'ION OF THE PROPOSED CHANGES The following is the proposed change to Technical Specification 3.3.3.7 Action 3 for both Salem Unit 1 and 2.
ACTION:
With the number of OPERABLE channels one less than the Required Number of Channels shown in Table 3.3-11, operation may proceed provided that the Boric Acid Tank associated with the remaining OPERABLE channel satisfies all requirements of Specification 3.1.2.8.a., otherwise comply with the requirements of 3.1.2.8 action a.
(3.1.2.6. action a. for Salem 2)
The marked-up Technical Specifications (TS) pages are included in.
II. REASON FOR THE PROPOSED CHANGES Technical Specification (T.S) 3.3.3.7 requires the post accident instrumentation listed in table 3.3-11 be operable (available to operators to assess and monitor plant conditions following an accident).
Specifically, two Boric Acid storage Tank (BAST)
Level indicators are required to be operable (one per tank) with a minimum of one available.
The Limiting Condition for Operation (LCO) is applicable in Modes 1, 2, and 3.
Presently, Salem Unit 1 and 2 Technical Specifications 3.3.3.7 Action (#3) states:
ACTION: With the number of OPERABLE channels one less than the Required Number of Channels shown in Table 3.3-11, operation may proceed provided that the Boric Acid Tank associated with the remaining OPERABLE channel satisfies all requirements of Specification 3.1.2.8.a."
NOTE: Action #3 for Salem Unit 2 should read as stated in section I above since there is no section 3.1.2.8.a.
The action statement as presently written is more restrictive than other Technical Speci!ications dealing with Borated Water Sources.
Specifically, the Borated Water Sources within the Technical Specification Reactivity section; which would apply to an inoperable BAST.
The BAST Technical Specification requires only one BAST to be operable.
The operability is determined by establishing a specified volume, temperature, and boron concentration.
The action statement associated with this LCO allows 72 Hrs to restore the BAST to operable status.
Note that this LCO operability and associated allowable outage time is associated with actual measurable physical parameters.
Page 1 of 4
As presently written (Technical Specification 3.3.3.7 Action Statement #3 [T.S. A.S 3.3.3.7]) the loss of level indication in the operable BAST will automatically place the Unit in T.S.A.S 3.0.3.
T.S.A.S 3.0.3 requires, in part, that; within one hour action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in: 1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and 3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Although T.S 3.0.3 has provisions such that if corrective measures are completed (that permit operation under the action requirements) then the power reduction and shutdown may be avoided.
However, the provisions.do not necessarily avoid the challenge that may have been placed to the facility by an unnecessary shutdown transient due to an overly restrictive and/or inconsistent action requirement.
III. JUSTIFICATION AND EVALUATION OF THE SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES OF THE REQUEST The BAST (with the transfer pumps) are part of the boration subsystem of the Chemical and Volume Control System (CVCS).
This subsystem provides a means to meet one of the functional requirements of the eves, which is the control of boron (neutron absorber) in the Reactor Coolant System (RCS).
The boration system is not assumed to be operable to mitigate the consequences of a Design Basis Accident (DBA) or transient.
In case of a malfunction of the eves, which causes a boron dilution event, the automatic response is for the operator to close the appropriate valves in the reactor make-up system.
The boration subsystem (BAST) is not assumed to mitigate this event.
The BAST level instrumentation is not instrumentation installed or used to detect and indicate a significant degradation of the RCS in the control room.
The Post-Accident Monitoring Instrumentation Limiting Condition for Operation ensures the operability of appropriate instrumentation so that the control room operating personnel can:
Perform the Procedures.
actions for and SGTR.
diagnosis specified in the Emergency Operating These variables are restricted to pre-planned DBA such as LOCA, Steam Breaks, Feedwater Breaks, Take the specified pre-planned manual actions for which no automatic action is available, that are required of the safety systems to perform their safety function.
Reach and maintain safe shutdown conditions.
Page 2 of 4
The instrumentation listed in table 3.3-11 is (intended to be)
Reg. Guide 1.97 instrumentation, and is accordingly defined as Type A through E depending on the plant variable they monitor and Category 1 through 3 depending upon the importance of the variable monitored.
As stated earlier the BAST is not part of a system assumed to mitigate the consequences of a OBA; therefore the level instrumentation has been defined as a Type B Category 3 variable.
The restrictiveness of this LCO seems to be limited to the Salem Technical Specifications.
The Standard Technical Specifications for Westinghouse Pressurized Water Reactors (Rev.4), allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the inoperable level instrumentation to operable.
The Salem unit 1 and 2 technical specification improvement program (MERITS) eliminates the BAST level indication from table 3.3-11 as a line item (one of the required post accident monitoring instrumentation).
MERITS only includes instrumentation that has been defined as a Type A Category 1 variables as intended by the above stated purpose of the LCO.
Additionally, there are a number of (Salem) Technical Specifications which deal with the operability of the BAST and/or Boric Acid flow paths (from the BAST).
In all cases the allowed outage time to retu'rn the required BAST or the* flow path to operable is 72 Hrs.
The proposed T.S change, to allow a 72 hr restoration time, for the level detector, is consistent with other Boric Acid system Technical Specifications.
Therefore, PSE&G believes that the proposed change is administrative in nature and does not affect the health and safety of the public.
IV. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION This proposed Amendment request:
- 1.
Does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The request is only administrative in nature and does not involve a system that was assumed to function in any of the design/licensing basis analysis, and therefore the probability or consequences of an accident previously evaluated are not increased.
- 2.
Does not create* the possibility of a new or different kind of
' accident from any accident previously evaluated.
The proposed change does not introduce any design or physical configuration changes to the facility which could create new accident scenarios.
Page 3 of 4
- 3.
Does not involve a significant reduction in a margin of safety.
As stated in response to question number 1 above, the proposed change does not affect a system that was taken credit for or assumed to function under any of the design/licensing basis analysis.
Consequently, there is no reduction in any margin of safety.
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