ML18100A586
| ML18100A586 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/30/1993 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18100A587 | List: |
| References | |
| LCR-91-04, LCR-91-4, NLR-N93082, NUDOCS 9309090126 | |
| Download: ML18100A586 (8) | |
Text
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Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations AUG 3 0 1993 NLR-N93082 LCR 91-04 United States Nuclear Regulatory Commission Document Control Desk.
Washington, D.C.
20555 Gentlemen:
LICENSE CHANGE REQUEST SALEM GENERATING STATION UNIT NO. 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 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 License DPR-75 for Salem Generating Station (SGS), Unit No. 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.
The proposed change replaces the main feedwater control and control bypass valves with the main feedwater stop check valves for the Containment Isolation Funct-ion.
Attachment A contains further discussion and justification for the proposed change.
Attachment B contains a markup of the.<'-
.existing Unit 2 Technical Specifications to reflect the requesteq changes.
PSE&G has reviewed the implementation requirements for the proposed amendment and requests a 60 day period from amendment approval to implementation.
Should you have any questions on this transmittal, please contact us.
Sincerely,
Documeht Control Desk NLR-N93082 2
Affidavit Attachments (2)
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. s. T. Barr (S09}
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 AUG 3 0 1993
REF: NLR-N93082 STATE OF NEW JERSEY COUNTY OF SALEM
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J. J. Hagan, 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 No. 2, are true to the best of my knowledge, information and belief.
Subscribed and Sworn ~:efore me t~.y,Jo-th.
day of_,.Jdf'J Ab=.
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Ncltary Publ 7c~ New Jersey My Commission expires KIMBERLY JO BROWN NOTARY PtlBUC OF NEW JERSEY My Commission Expires April 21, 1998
PROPOSED LICENSE CHANGE SALEM GENERATING STATION UNIT NO. 2 ATTACHMENT A FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 I.
Description of the Change LCR 91-04 This amendment request replaces the main feedwater control.
(BF-19s) and main feedwater control bypass valves (BF-40s) with the main feedwater stop check valves (BF-22s) for the main feedwater Containment Isolation Function.
Salem Unit 2 Technical Specification Surveillance 4.6.3.2c is deleted and marked NOT USED. *Technical Specification 3.6.3 Table 3.6-1, is revised to delete the reference to Feedwater Isolation (BF-19s and BF-40s).
The BF-22s are added to Table 3.6-1 under the heading Check for the main f eedwater Containment Isolation Function.
An Administrative change moves the information on Page 3/4 6-20 to Page 3/4 6-19.
Page 3/4 6-20 is marked "This page intentionally blank."
The word "supply" is added to the valve 22CA360 function.
Note 1 is deleted.
II.
Reason for the Proposed Change The main feedwater control (BF-19) and main feedwater control bypass valves (BF-40s) are used to control main feedwater flow during power operation, and to isolate main feedwater (Feedwater Tsolation) in response* to a steamline/feedline break accident.
Main feedwater isolation signals are generated by Reactor Trip and/or Engineered Safety Feature actuations *. These valves were not intended for Containment Isolation;.to prevent-or limit the escape of fission products resulting from p6stulated accidents.
The main feedwater stop check valves (BF-22s) were designed as the main feedwater Containment Isolation valve.
The NRC Staff reviewed the BF-22s during initial plant licensing, and concluded that these valves were unacceptable for Containment Isolation at that time.
However, subsequent modifications have eliminated the previous identified deficiencies.
Using the BF-22s for Containment Isolation returns the plant to the originally intended arrangement.
The administrative change lists all the valves in Table
- 3.6-1, Section Hon one page for clarity.
The word "supply" is added to the va+ve 22CA360 function for completeness and consistency with 21CA360.
Note 1 is deleted since the BF-19s and BF-40s are no longer used for containment isolation.
I
III. Justification for the Proposed Changes In letters dated September 27, 1979 and November 9, 1979, the NRC staff defined a set of "short-term" requirements resulting from their investigation of the Three Mile Island accident.
The Staff position on Containment Isolation included: compliance with the requirements of the Standard Review Plan (SRP) Section 6.2.4 and identification of essential and non-essential systems.
Salem Unit 2 was involved in the Operating License process at that time.
PSE&G responded to the Staff position on Containment Isolation in a letter dated January 4, 1980.
PSE&G reviewed the. Salem Containment Isolation System design for conformance to SRP Section 6.2.4.
Systems penetrating Containment were classified as essential or non-essential.
The Salem main f eedwater system was designated a non-essential system.
All non-essential systems at Salem are automatically isolated upon a Containment Isolation signal, or provided with non-return check valves, or closed during power operations and under administrative control.
SRP Section 6.2.4 requirements are satisfied by any of these conditions.
SRP Section 6.2.4 states that a simple check valve is not normally an acceptable automatic isolation valve for the Containment Isolation function.
The Salem main feedwater system contains stop check valves that PSE&G intended to use as the Containment Isolation valve.
On December 10, 1980, PSE&G submitted an exemption request to the requirements of 10CFR50, Appendix A, General Design Criteria (GDC) 57 for the main feedwater system.
PSE&G justified this request on the basis that a stop check valve automatically and positively i~olates the*l~ne, and is not considered a simpl~ check. valve.
The Staff issued Salem SER Supplement 5 in January, 1981.
This document identified ~ concern with PSE&G's previous request for GDC 57 :exemption.
stop ch~ck valves do permit positive closure and are not considered a simple check valve.
Thus, a stop check valve satisfies the requirements of GDC 57.
However, the main feedwater stop check valves at Salem had local-manual operators.
In the event of an accident, environmental and/or radiological conditions could preclude operator accessibility to the valve local-manual operators.
If the valves are not accessible to effect positive closure, they only function as a simple check valve, which does not satisfy GDC 57.
The Staff requested that PSE&G demonstrate that the existing Containment Isolation provisions complied with GDC 57 requirements under all postulated accident conditions, or propose a design change to achieve compliance.
The staff stated that an acceptable approach would be to add motor operators to the
stop check valves, that permit remote-manual actuation from the main control room.
Interim acceptance of the stop check valves was based on redundant isolation features (i.e.,
Feedwater Isolation).
PSE&G responded to the Staff request in a letter dated August 18, 1981.
We elected to add motor operators to the existing stop check valves and provide remote-manual
- isolation capability.
The staff documented their acceptance of PSE&G's proposal in a letter dated September 30, 1981.
Motor operators were installed on all main feedwater stop check valv~s of both Salem Units.
In April of 1990, PSE&G submitted an amendment request to increase the isolation times of the main feedwater control valves.
The NRR Project Manager for Salem suggested that we consider using the main feedwater stop check valves for Containment Isolation, in lieu of increasing the.main feedwater control valve isolation times.
PSE&G evaluated the conformance of the* modified (motor operators added) main feedwater stop check valves to the GDC 57 requirements.
We concluded that the remote-manual closure feature utilized non-safety related controls in the main control.room and thus did not satisfy GDC 5i requirements.
Des;i.gn modifications were completed during the 7th refueling outage to upgrade the controls to a safety related status.
Since the main feedwater stop check valves now satisfy GDC 57 requirements, and were originally intended for Containment Isolation, we propose to change the Technical Specifications to use these valves for the Containment Isolation Feature.
The administrative.changes relocate existing information, add the word "supply" to the valve 22CA360 function, and delete Note 1.
These changes do not affect the Containment Isolation Function.
Note 1 is removed since the identified valves (BF-19s and BF-40s) are no longer used for the containment isolation function.
IV.
Significant Hazards Analysis Consideration The proposed Technical Specification changes:
- 1.
Do not involve a significant increase in the probability or consequence of an accident previously evaluated.
The main feedwater stop check valves provide the same isolation function presently accomplished by the main feedwater control and control bypass valves, without reliance on an actuation signal.
Positive closure is assured during all postulated accident scenarios, through remote-manual controls in the main control room.
These valves satisfy the requirements of GDC 57 for Containment Isolation.
Therefore, it may be concluded that the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Do not create the possibility of a new or different kind of accident from any accident previously evaluated.
The main'feedwater stop check valves were originally intended to perform the Containment Isolation function.
The only changes to the original plant design were the addition of motor operators and the upgrading of controls to safety related.
These changes bring the stop check valves into compliance with GDC 57 requirements, and ensure positive valve closure during all postulated accident scenarios.
Therefore, no new or different accidents from those previously evaluated will be created.
- 3.
Do not involve a significant reduction in a margin of safety.
Check valves provide inherent isolation from reverse flow conditions.
Stop check valves provided increased safety due to the positive closure feature.
Motor operators with remote-manual closure capability, allow positive closure from the.main control room during all postulated accident scenarios.
These features ensure an adequate margin of safety is maintained.
Additionally, Feedwater Isolation, utilizing the main teedwater control and control bypass valves, occurs through Reactor Trip and/or Engineered Safety Features actuation.
This feature is redundant to the stop check valves for Containment Isolation Feature.
Therefore, it may be concluded that the proposed change does not involve a significant reduction in a margin of safety.
- v.
Conclusions Based on the information presented above, PSE&G has concluded that the proposed changes satisfy the criteria for a no significant hazards consideration.
ATTACHMENT B