ML18101A200

Application for Amends to Licenses DPR-70 & DPR-75,adding New Action Statement (B) to TS 3.1.3.2.1 Re Position Indication Sys - Operating for Both Units

ML18101A200
Person / Time
Site:	Salem
Issue date:	08/19/1994
From:	Hagan J Public Service Electric & Gas Co, of New Jersey
To:	NRC/IRM
Shared Package
ML18101A201	List: ML18101A200 ML20072K834
References
LCR-94-30, NLR-N94150, NUDOCS 9408300319
Download: ML18101A200 (10)

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 1 9 1994 NLR-N94150 LCR 94-30 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 2055'5 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 The proposed change requests the addition of a new action statement to Technical Specifications 3.1.3.2.i, Position Indicaton Systems - Operating 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 t~

be implemented within sixty (60) days to provide sufficient time for associated administrative activities.

---*---**-*'--l_::L.:_~------- -------~

9408300319 940819 PDR ADOCK 05000272 P

PDR Sincerely,

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Document Control Desk NLR-N94150 Attachment (2) 2 C

Mr. J. c. Stone, Licensing Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. s. Marschall (S09)

USNRC Senior Resident Inspector Mr. T. T.* Martin, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Kent Tosch, Manager, VI New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 I

i AUG 191994

NLR-N94150 LCR 94-30 STATE OF NEW JERSEY COUNTY OF SALEM SS.

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. 1, are true to the best of my knowledge, information and belief.

My Commission expires on 1994 KIMBERLY JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission Expires A'1ril 2 l, 1998

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NLR-N94150 LCR 94-30

• ATTACHMENT 1 I.

DESCRIPTION OF THE PROPOSED CHANGES IA Proposed change adds a new action statement (b) to Limiting Condition for Operation (LCO) 3.1.3.2.1 for both Salem Units.

The new action (b) will read; With two or more analog rod position indicators per bank inoperable, within one hour restore the inoperable rod position indicator(s) to OPERABLE status or be in 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 />.

A maximum of one rod position indicator per bank may remain inoperable following the hour, with Action (a) above being applicable from the original entry time into the LCO.

IB, As a result of the above proposed change the presently existing action statement (b) should be changed to (c).

II. REASON FOR THE PROPOSED CHANGES IIA The proposed change adds a new Action Statement to the LCO.

Thus eliminating the need to enter Technical Specification (T.S.)

3.0.3 whenever two or more individual rod position indications (IRPis) are lost during adjustment.

IIB The proposed change is an editorial change to accomodate the addition of the new action statement requirement.

III. JUSTIFICATION AND EVALUATION OF THE SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES OF THE REQUEST IIIA The analog rod position indication system is designed to provide actual individual rod position indication (IRPI) to the control board Dixon modules, the SPDS computer, the P-250 computer, and locally at the IRPI rack via the Digital Multi Meter (DMM).

Due to electronic drift IRPis occasionally need to be adjusted.

Components that require adjustment/recalibration are the Dixon modules and the Signal Conditioning Modules (SCM).

Each Dixon module provides indication for two rods, dual channels.

This arrangement provides for a better utilization of space in the control room, and facilitates performance of the required rod control system technical specification surveillances.

To adjust an IRPI the Dixon module must be removed from service and placed in an extender card.

Because of the duality of the Dixon module, whenever one is removed for single !RPI adjustment two IRPI indications are lost.

NLR-N94150 LCR 94-30

• ATTACHMENT 1 The loss of indication lasts approximately 30 seconds, the time it takes to remove the Dixon from the control board and place it in the extender card.

Following the adjustment evolution, which normally takes a few minutes, indication is again lost in returning the Dixon back to the control board.

The Westinghouse analog rod position indication design is such that the SCM ground wire for each of the 13 VDC power supplies is daisy-chained.

Electronic drift that involves adjustment of the SCM also requires placing the SCM in an extender card.

This evolution has a high potential of shorting out the main DC power supplies.

Failure of either the main or auxiliary power supplies could result in the total loss of IRPI indication and a potentially complex corrective maintenance activity depending on the number of power supplies affected.

To prevent this situation the power supplies fuse is removed.

Removal of this fuse causes a total loss of indication; however, this temporary loss of indication only lasts approximately 30 seconds, which is the time necessary to remove/replace the SCM.

However, since in both cases more than one analog position indication is lost and the present technical specification does not provide for an action statement within the confines of the LCO, entry into technical specification 3.0.3 is required.

Technical Specification 3.0.3 requires, in part, that; When a Limiting Condition for Operation is not met as provided in the associated ACTION requirements, 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 />.

Entry into T.S. 3.0.3 is reportable via the License Event Report (LER) as a condition prohited by T.S.

The proposed change would eliminate this unnecessary reporting.

The proposed change does not alter the operator response or operator response time.

The proposed change incorporates, into the applicable LCO, the action requirements already established in technical specification 3.0.3.

NLR-N94150 LCR 94-30

• ATTACHMENT 1 The proposed change is consistent with NUREG 1431 Vol.1 (Standard Technical Specifications Westinghouse Plants) issued November 1992.

Since the LCO is only applicable in Modes 1 and 2, the proposed new action only requires to place the unit in HOT STANDBY (Mode 3), which is the first operational mode in which the LCO is no longer applicable.

The proposed change is also*more conservative than NUREG 1431, which allows for either continued (reduced) power operation with one or more rod position indication inoperable or up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to determine the rod(s) position.

IIIB The proposed change is a notation change due to the addition of a new action statement.

No physical changes to the facility are proposed by either change.

IV. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The discussion below applies to both proposed changes.

This proposed Amendment request:

1.

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

The request (both proposed changes) does not change any assumption or parameter 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.

The change, as described in section IB, incorporates into the applicable LCO the action statement which is already taken under technical specification 3.0.3, and does not alter the operator response or response time.

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.

NLR-N94150 LCR 94-30

• ATTACHMENT 1

3.

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

As stated in response to question number 1 above, the change does not change any assumption or parameter assumed to function in any of the design/licensing basis analysis.

No changes to the operator response or operator response time is proposed, only that the response is now taken under the confines of the LCO.

Therefore, there is no reduction in any margin of safety from the proposed changes.

NLR-N94150 LCR 94-30 Insert A ATTACHMENT 2 b)

With two or more analog rod position indicators per bank inoperable, within one hour restore the inoperable rod position indicator(s) to OPERABLE status or be in 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 />.

A maximum of one rod position indicator per bank may remain inoperable following the hour, with Action (a) above being applicable from the original entry time into the LCO.

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REACTIVITY CONTRO.L SYSTEMS POSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITION F-OR OPERATION 3.l.3.2.l The shutdown and control rod position indication systems shall be OPERABLE and capable of determining the actual and demanded.rod positions as follO'llllS:

a.

Analog rod position indicators, within.one houP after rod notion (allowance for thermal soak);

All Shutdown Banks:

+ 12 steps of the gooup demand counters for withdrawal ranges of ~-30 steps and 200-228 steps.

Control Bank A:

..- 12 steps of the group demand counters for

'llllithdrawal ranges-of 0-30 steps and 200-228 steps.

Control Bank 8:

• 12 steps of the group demand counters for withdrawal ranges-of 0-30 steps and 160-228 steps.

Control Banks C and D:

..- 12 steps of the group demand counters for withdrawal range of n"-228 steps.

b.

Group demand counters;.:, 2 steps of the pulsed output of the Slave Cycler Circuit over the withdrawal range of 0-228 steps.

APPLICABILITY: MODES l and 2.

ACTION:

a.

With a maxi111Jm of one analog rod position indicator per bank inoperable either:

l.

Determine tl'te position of the non-indicating rod(s)

• iod1rectly by th* novable 1nc:are detectors at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and within one hour after any notion of the

• nan-indicating rod which exceeds 24 steps in one direction sinc:a tl'te last determination of the rod 1s pos1t1an, or

2.

Reduce THERMAL PO\\IER ta less than soi of RATED THERMAL PO\\CR I irvs.£<l.T Ah-r:---i;1th1n* 8 t'ours.

c J.

With a naxi111Jm of one group demand position indicator per bank inoperable either:

SALEM

• UNIT 2 9408300320 940819 PDR ADDCK 0500027?

P PDR-3/4 1-16 Amendment No. 48

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REACTIVITY CONTROL SYSTEMS POSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITt~N FOR OPERATION 3.l.3.2.l The shutdown and control rod position indication systems shall be OPERABLE and capable of determining the actual and demanded rod positions as fallows:

a.

Analog rod position indicators, within one hour. after rod notion (allowance far thermal soak):

Al 1 Shutdown Banks: + lZ steps of the ~oup demand munters for withdrawal ranges of rr-30 steps and 200-228 steps.

Control Bank A: !. 12 steps of the ~up demand counters far withdrawal ranges of 0-30 steps and 200-228 steps.

Control Bank 8: !. lZ steps of the !J"OUP demand counters for withdrawal ranges of 0-30 steps and l60-2Z8 steps.

Control Banks C and 0:

+ lZ steps of the group demand counters far withdrawal. range of cr-22s steps.

b.

Group demand munters; ! 2 steps of the pulsed output of the Slave Cycler Circuit over the withdrawal range of 0-228 steps.

APPLICABILITY: MODES l and 2.

ACTION:

a.

With a maxinum of one analog rod position indicator per bank inoperable either:

l.

Determine the position of the ran-indicating rod(s) indirectly by the navable incore detectors at least once per

. ~ hours and within one mur after any notion of the

-non-indicating rod which exceeds 24 steps in one direction since the* last determination of the rod's position, or

2.

Reduca THERMAL PO !CR ta 1 ass than soi 0 f RA TEO THERMAL FU !CR within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

c_., 't(.

With a max1111111 of one ~oup demand position indicator per bank inoperable either:

SALEM - UNIT l 3/4 1-19 Amendment No. 73