ML18101A620
| ML18101A620 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/30/1995 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18101A621 | List: |
| References | |
| LCR-94-45, LR-N94216, NUDOCS 9504110061 | |
| Download: ML18101A620 (10) | |
Text
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 MAR 3 0 1995 LR-N94216 LCR 94-45 United States.Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
LICENSE CHANGE REQUEST SALEM GENERATING STATION UNITS 1 AND 2 FACILITY OPERATI,NG 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.
The proposed change: eliminates the defined term CONTROLLED LEAKAGE, removes Controlled Leakage flow from the Reactor Coolant System Operational Leakage Limiting Condition for Operation (LCO), and establishes a new Seal Injection Flow LCO.
Attachment A contains further discussion and justification for the proposed change.
Attachment B contains a markup of the existing Unit 1 Technical Specifications to reflect the requested changes.
Attachment c*contains a markup of the existing Unit 2 Technical Specifications to reflect the requested changes.
Updated Unit 1 and Unit 2 Bases are included for information.
PSE&G has reviewed the implementation requirements for the proposed amendments and requests a 60 day period from amendment approval to implementation.
Should you have any questions on this transmittal, please contact us.
(
1lOG69 9504110061 950330. ----~
PDR ADOCK 05000272 P
Document Control Desk LR-N94216 Affidavit Attachments (3) 2 c
Mr. T. T. Martin, Administrator Region I U.S. Nuclear-Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan Licensing Project Manager -
Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr* c. s. Marshall (S09)
USNRC Senior Resident Inspector Salem Generating Station Mr. Kent Tosch, Manager, VI N.J. Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 MAR 301995
e REF:
NLR-N94216 STATE OF NEW JERSEY
)
)
SS.
COUNTY OF SALEM 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 Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscrib~~nd Sworn t3~
this JibjJJ_
day of ~
, 1995
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/NOtary PtJ.1ic of ~ey SHERRY L CAGl~.... ~,
NOTARY PUBLIC OF NEW JER§H My commission expires on ____
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PROPOSED LICENSE CHANGE SALEM GENERATING STATION UNIT NOS. 1 AND 2 ATTACHMENT A
- FACILITY OPERATING LICENSE NOS.
DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 LCR 94-45 I. Description of the Change This amendment request eliminates the defined term CONTROLLED LEAKAGE, removes Controlled leakage from the Reactor Coolant System (RCS) Operational Leakage Limiting Condition for Operation (LCO), and establishes a new Seal Injection Flow LCO.
II. Reason for the Proposed Change Recent discussions between PSE&G and Westinghouse concluded that the Salem Technical Specification definition of CONTROLLED LEAKAGE, the associated LCO (RCS Operational Leakage), and Basis should be revised to clearly reflect all accident analysis assumptions related to Emergency Core Cooling System (ECCS) operation.
NRC Inspection Report Nos. 50-272/94-19 and 50-311/94-19 also raised a concern regarding the definition and application of Controlled Leakage at Salem.
PSE&G committed in a letter dated 12/27/94 (NLR-N94215) to process a license change to address this issue.
This amendment request satisfies that commitment.
The proposed new Seal Injection Flow LCO places the requirement, which is actually a verification of emergency core cooling capabilities, in the Technical Specification Chapter that pertains to the ECCS.
III. Justification for the Proposed Changes The existing Technical Specification states that CONTROLLED LEAKAGE shall be that seal water flow from the RCP seals.
The Technical Specification Bases section indicates that by restricting total seal water flow from the RCP seals at normal operating pressures, ECCS flow will not be less than assumed in the accident analysis.
PSE&G previously worked with Westinghouse's Licensing Group, to develop and evaluate Technical Specification flow limits for the high-head ECCS subsystems.
These evaluations included flows during the injection and recirculation modes of operation.
The Controlled Leakage definition was discussed and determined to be correct in that context. Subsequent discussions between PSE&G and Westinghouse's Thermal Hydraulics Group, resulted in a re-evaluation of the Salem Controlled Leakage definition and Technical Specification LCO.
Westinghouse ECCS hydraulic flow
calculations assumed RCP seal injection flow path resistance values. The existing Technical Specification, which sets limits on seal leakoff flow, could result in seal injection flow path resistance values that are slightly lower, impacting the Salem Large Break Loss of Coolant Accident (LOCA) analyses.
- Thus, PSE&G and Westinghouse concluded that the Salem Technical Specification Controlled Leakage definition and associated LCO should be revised to restrict seal injection flow rather than seal leakoff flow.
This enhancement clarifies the assumptions made in the Salem accident analysis.
The Mode applicability for the new Seal Injection LCO is 1,2 and
- 3. The seal injection flow limit is not required for Mode 4 and lower, because of lower initial RCS pressures and reduced decay heat removal requirements.
The proposed changes are consistent with the wording in the Westinghouse Standard Technical Specification (NUREG-1431, Rev. O)
- IV. Significant Hazards Analysis Consideration The proposed Technical Specification changes:
- 1. Do not involve a significant increase in the probability or consequenc~ of an accident previously evaluated.
Changing the Technical Specification to limit seal injection flow instead of seal leakoff flow does not affect the probability of any accident previously evaluated.
Maintaining adequate Emergency Core Cooling System (ECCS) flow during Loss of Coolant Accident (LOCA) ensures that the consequences of these accidents are unaffected.
The existing Technical Specification allows seal injection throttle valve positioning that could result in seal injection flow path resistance values below those used in the Salem ECCS hydraulic flow analyses.
Reduced line resistances could result in inadequate ECCS flow to the reactor core.
Revising the Technical Specification to limit RCP seal injection flow ensures that the accident analysis assumptions are maintained, and the previously evaluated accident consequences remain unchanged.
Therefore, it may be concluded that the proposed changes do not increase the probability o*r 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 proposed changes do not involve any hardware modifications or result in any functional changes to system operation.
RCP seal injection flow is used as a limiting parameter in-place of RCP seal leakoff flow.
r --
Since design requirements continue to be met and the RCS pressure boundary is not challenged, no new failure mode is created.
Thus, an accident different from any already evaluated is not created by this change.
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.
- 3. Do not involve a significant reduction in a margin of safety.
The proposed changes do not alter the manner in which Safety Limits or Limiting Safety System Setpoints are determined.
Controlled Leakage (RCP seal leakoff)is removed from the Reactor Coolant System Leakage Limiting Condition for Operation (LCO),
and a new seal injection LCO is established.
The new LCO continues to limit seal injection flow during accident conditions.
The limiting parameter is changed from RCP"seal leakoff flow to RCP seal injection flow.
These changes ensure that the accident analysis assumptions and existing margins of safety are maintained.
The seal injection flow specification limit is not applicable in Mode 4 and lower, because high seal injection flow is less critical due to lower R_eactor Coolant System (RCS) pressure and decay heat removal requirements in these modes.
Reactor coolant pump seal injection flow must be limited in Modes 1, 2, and 3 to ensure adequate Emergency Core Cooling System Flow.
Therefore, it may be concluded that the proposed changes do 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 Technical Specification changes satisfy the criteria for a no significant hazards consideratior:i.
ATTACHMENT B INSERT 1:
EMERGENCY CORE COOLING SYSTEMS SEAL INJECTION FLOW LIMITING CONDITION FOR OPERATION 3.5.4 Reactor coolant pump seal injection flow shall be ~ 40 gpm with centrifugal charging pump discharge header pressure ~ 2430 psig and the charging flow control valve full open.
APPLICABILITY: MODES 1, 2, and 3 ACTION:
With seal injection flow not within the limit, adjust manual seal injection throttle valves to give a flow within the limit with the charging pump discharge pressure ~ 2430 psig and the charging flow control valve full open within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or be in 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 /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
SURVEILLANCE REQUIREMENTS 4.5.4 At least once per 31 days, verify manual seal injection throttle valves are adjusted to give a flow within the limit with centrifugal charging pump discharge header pressure ~ 2430 psig, and the charging flow control valve full open.
The provisions of Specification 4.0.4 are not applicable for entry into Mode 3.
This exemption is allowed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the Reactor Coolant System pressure stabilizes at 2235 +/- 20 psig.
INSERT 2:
3/4.5.4 SEAL INJECTION FLOW The Reactor Coolant Pump (RCP) seal injection flow restriction limits the amount of ECCS flow that would be diverted from the injection path following an ECCS actuation.
This limit is based on safety analysis assumptions, since RCP seal injection flow is not isolated during Safety Injection (SI).
The LCO is not strictly a flow limit, but rather a flow limit based on a flow line resistance.
Line pressure and flow must be known to establish the proper line resistance.
Flow line resistance is determined by*assuming that the RCS pressure is at normal operating pressure, and that the centrifugal charging pump discharge pressure is greater than or equal to 2430 psig.
Charging pump header pressure is used instead of RCS pressure, since it is more representative of flow diversion during an accident.
The additional LCO modifier, charging flow control valve full open, is required since the valve is designed to fail open.
With the LCO specified discharge pressure and control valve position, a flow limit is established.
This flow limit is used in the accident analysis.
A provision has been added to exempt surveillance requirement 4.0.4 for entry into MODE 3, since the surveillance cannot be performed in a lower mode.
The exemption is permitted for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the RCS pressure has stabilized within +/- 20 psig of normal operating pressure.
The RCS pressure requirement produces the conditions necessary to correctly set the manual throttle valves.
The exemption is limited to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to ensure timely surveillance completion once the necessary conditions are established.
ATTACHMENT C INSERT 1:
EMERGENCY CORE COOLING SYSTEMS SEAL INJECTION FLOW LIMITING CONDITION FOR OPERATION 3.5.4 Reactor coolant pump seal injection flow shall be 5 40 gpm with centrifugal charging pump discharge header pressure > 2430 psig and the charging flow control valve full open.
APPLICABILITY: MODES 1, 2, and 3 ACTION:
With seal injection flow not within the limit, adjust manual seal injection throttle valves to give a flow within the limit with the charging pump discharge pressure ~ 2430 psig and the charging flow control valve full open within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or be in 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 /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
SURVEILLANCE REQUIREMENTS 4.5.4 At least once per 31 days, verify manual seal injection throttle valves are adjusted to give a flow within the limit with centrifugal charging pump discharge header pressure ~ 2430 psig, and the charging flow control valve full open.
The provisions of Specification 4.0.4 are not applicable for entry into Mode 3. This exemption is allowed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the Reactor Coolant System pressure stabilizes at 2235 +/- 20 psig.
INSERT 2:
3/4.5.4 SEAL INJECTION FLOW The Reactor Coolant Pump (RCP) seal injection flow restriction limits the amount of ECCS flow that would be diverted from the injection path following an ECCS actuation.
This limit is based on safety analysis assumptions, since RCP seal injection flow is not isolated during Safety Injection (SI).
The LCO is not strictly a flow limit, but rather a flow limit based on a flow line resistance.
Line pressure and flow must be known to establish the proper line resistance.
Flow line resistance is determined by assuming that the RCS pressure is at normal operating pressure, and that the centrifugal charging pump discharge pressure is greater than or equal to 2430 psig.
Charging pump header pressure is used instead of RCS pressure, since it is more representative of flow diversion during an accident.
The additional LCO modifier, charging flow control valve full open, is required since the valve is designed to fail open.
With the LCO specified discharge pressure and control valve position, a flow limit is established.
This flow limit is used in the accident analysis.
A provision has been added to exempt surveillance requirement 4.0.4 for entry into MODE 3, since the surveillance cannot be performed in a lower mode.
The exemption is permitted for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the RCS pressure has stabilized within+/- 20_psig of normal operating pressure.
The RCS pressure requirement produces the conditions necessary to correctly set the manual throttle valves.
The exemption is limited to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to ensure timely surveillance completion once the necessary conditions are established.