ML18101A710

Application for Amend to License DPR-70,revising TS 3/4.6.1.2, Containment Leakage to Request Extension Until Next Refueling Outage,Scheduled to Start in Sept 1995 to Facilitate Testing During Refueling Outage

ML18101A710
Person / Time
Site:	Salem
Issue date:	05/04/1995
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18101A711	List: ML18101A710 ML18101A712
References
LCR-95-06, LCR-95-6, LR-N95056, NUDOCS 9505220180
Download: ML18101A710 (8)

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 MAY 041995 LR-N95056 LCR 95-06 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen: ,,_

LICENSE AMENDMENT APPLICATION ONE-TIME EXTENSION OF SURVEILLANCE REQUIREMENT INTERVAL SALEM GENERATING STATION UNIT NO. 1 FACILITY OPERATING LICENSE DPR-70 DOCKET NO. 50-272 This letter submits an application for amendment to Appendix A of Facility Operating License DPR-70 for the Salem Generating Station Unit No. 1. The application for amendment is being filed in accordance with 10CFR50. 90. Pursuant to the requirements of 10CFR50.91(b) (1), a copy of this request for amendment has been sent to the State of New Jersey.

The proposed Technical Specification change contained herein repre-sents a one-time change to Specification 3/4.6.1.2 "Containment Leakage. " Public Service is requesting an extension for this surveillance requirement until the end of the next refueling out-age, currently scheduled to start in September 1995, to facilitate testing during a refueling outage.

Typically, an eighteen month surveillance interval, with the 25%

extension allowed by Technical Specification 4.0.2 is sufficient to accommodate normal variations in the length of an operating cycle.

However, Salem Unit 1 entered a forced outage on April 7, 1994 during the 12th fuel cycle. This outage lasted approximately 2 months until June 4, 1994 when Salem Unit 1 resumed power opera-tion. With usable fuel remaining in the current core, Public Service has rescheduled the April 1995 refueling outage to September 1995 to support the summertime peak period. Public Service, therefore, requests that this application for amendment be processed by July 1, 1995 since the surveillance, including the 25%

allowance, will become overdue shortly thereafter.

If a forced outage occurs prior to the scheduled refueling outage, Public Service will perform the surveillance, time permitting, but will not prolong the forced outage for that purpose.

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MAY 041995 Document Control Desk LR-N95056 The proposed change has been evaluated in accordance with 10CFR50.9l(a) (1), using the criteria in 10CFR50.92(c), and it has been determined that this request involves no significant hazards considerations.

A description of the requested amendment, supporting information and analysis for the change, and the basis for a no significant hazards consideration determination are provided in Attachment 1.

The Technical Specification page affected by the proposed change is provided in Attachment 2 with pen and ink changes.

Should you have any questions regarding this request, we will be pleased to discuss them with you.

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. L. 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. Marschall (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 95-4933

REF: LR-N95056 LCR 95-06 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 for the 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 1, are true to the best of my knowledge, information and belief.

Subscribed and Sworn to before me this Lj+h ot-fn~ , 1995 u

.. _~!~BERL YJO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission expires on ____M_,v'-*B_t!tl1"""1ll~is""~'='on"-"E=xp=ir=es'-'A=o,,..,ril_,,,2....,J._.J""99.,.a.____ __

ATTACHMENT 1 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS LICENSE AMENDMENT APPLICATION ONE-TIME EXTENSION OF SURVEILLANCE REQUIREMENT INTERVAL SALEM GENERATING STATION UNIT NO. 1 FACILITY OPERATING LICENSE DPR-70 LR-N95056

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DOCKET NO. 50-272 LCR 95-06 I. DESCRIPTION OF THE PROPOSED CHANGE This amendment extends the surveillance interval for Surveillance Requirement 4. 6 .1. 2. a which would expire prior to the rescheduled refueling outage for Salem Unit 1 in September 1995. The* specification is revised by replacing the existing footnote with the following:

"The fifth inservice Integrated Leak Rate Test shall be performed prior tO or during the twelfth refueling outage, but no later than November 30, 1995. II II. REASONS FOR THE CHANGE Under normal circumstances, an eighteen month surveillance interval, with the 25% extension allowed by Technical Specification 4.0.2 is sufficient to accommodate minor varia-tions in the length of an operating cycle. However, due to a two month forced outage during the 12th fuel cycle, Salem Unit 1 retained usable fuel in the current core. Given the availability of the fuel and the approaching summertime peak period, Public Service has rescheduled the April 1995 refueling outage to September 1995.

III. JUSTIFICATION FOR CHANGE The containment leakage specification is intended to provide assurance that the total containment leakage volume will re-main within the limit assumed in the accident analyses at the peak accident pressure. In this regard, the Technical Speci-fication limit is conservatively set at 75% of the accident parameter to account for the possibility of degradation of containment leakage barriers between leakage tests.

These leakage tests are categorized as Type A tests, Type B and Type C. The Type A tests are defined in 10CFR50, Appendix J, Section II.Fas"* .. tests intended to measure the primary reactor containment overall integrated leakage rate. 11 Similar definitions identify the Type B tests as local leakage detec-tion of various containment penetrations (e.g., piping

ATTACHMENT 1 ONE-TIME EXTENSION OF SURVEILLANCE LR-N95056 REQUIREMENT INTERVAL LCR 95-06 penetrations, air lock door seals, etc.) and the Type C tests as determination of containment isolation valve leakage rates.

The current surveillance interval for the Type A Test, and the associated containment liner surveillance (§4.6.1.6.1), is 40 months +/-10 (see 10CFR50, Appendix J, Section III.D.l(a)) and is further clarified by 10CFR50, Appendix J, Section III.D.l(b) as to when the Type A test shall be performed.

Specifically, "* .. when the plant facility is non-operational and secured in the shutdown condition .... " The Type Band C tests are required once per twenty four months. Since the last Type A test was performed at the end of the lRlO refueling outage, April 1991, this surveillance interval, including the 25% grace period, will expire by July 7, 1995.

Performance of the Type A test by November 30, 1995, at the latest, will result in an interval of 54.7 months since the last Type A test.

While this is an increase of approximately 37% beyond the normal 40 month surveillance interval, the following points were noted:

• the purpose of containment leak rate testing is to detect any containment leakage resulting from active or passive failures in the containment isolation boundar-ies. Since the Type B and C tests will not be modified by this submittal, they will continue to effectively detect containment leakage resulting from degradation of active isolation components (e.g., valves) as well as passive barriers (e.g., sealing material within the containment penetrations),

• containment leak rate testing is also used to determine the leakage through the containment shell (i.e.,

liner) . Leakage through the shell can be aggravated by either environmental factors (e.g., pressure, tempera-ture, radiation, chemicals, etc.) or the failure to perform required maintenance which would leave the structure with reduced capability.

Structural degradation from environmental factors is a gradual phenomenon requiring periods of time well in excess of the proposed four month extension. Changes to the existing maintenance program, concerning con-tainment structural integrity, are infrequent and receive extensive review to ensure that containment capabilities are not diminished, and

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ATTACHMENT 1 ONE-TIME EXTENSION OF SURVEILLANCE LR-N95056 REQUIREMENT INTERVAL LCR 95-06

• historically, Salem 1 has not experienced an unaccept-able Type "A" test. A review of the four Type "A" tests performed (see Table 1) substantiate the fact that Salem 1 has a low leakage containment and that the one-time extension will not jeopardize the ability of the containment in performing its intended function.

In light of the aforementioned considerations, Public Service believes that an extension of the Type "A" surveillance to the end of the 1Rl2 refueling outage is justified.

Table 1 - Unit 1 ILRT History Date Results (@ %La Results %La 95% upper corrected for confidence as found data level) seem 8/79 134,075 0.620% N/A N/A 8/84 88,663 0.410% 107,030 0.49%

12/87 92,988 0.430% 135,666 0.63%

4/91 74,548 0.344% 90,338 0.42%

Table 1 Notes As per Specification §3.6.1.2, the leakage limit for an integrated leakage rate test (ILRT) (i.e., Type "A") is 0. 75 La, which is 162, 188 seem (standard cubic centimeters/minute) . As indicated above, there have been no Type A test failures at Salem Generating Station Unit 1. Type A Test results were not corrected for "as found" conditions until 1984. The "as found" corrections are described in NRC Information Notice 85-71.

The Unit Type A test history provides substantial justification for the proposed extension. As can be seen in Table 1, four (4) Type A tests have been performed to date and none have exceeded the 10CFR50 Appendix J acceptance criteria of 1.0 La, where La is equal to 0 .1% per day of containment atmosphere at a peak accident pressure of 47 psig. Also, considerable margin exists between the Type A test results and the Technical Specification limit of 0.75% La. These tests demonstrate that the proposed one-time extension would not jeopardize the ability of the containment to maintain the leakage rate at or below the required Type A limits.

The Type A tests and associated visual examinations have not identified any conditions that would challenge the leak tight integrity of the containment structure or leakage paths that have not been identified by the local leak rate test (Type B and C) program. Corrective action has been taken on penetrations with unacceptable leakage. The penetrations with a history of unacceptable as found leakage are limited to the containment air lock shaft seals.

ATTACHMENT 1 ONE-TIME EXTENSION OF SURVEILLANCE LR-N95056 REQUIREMENT INTERVAL LCR 95-06 IV. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION PSE&G has, pursuant to 10CFRSO. 92, reviewed the proposed amendment to determine whether our request involves a significant hazards consideration. We have determined that operation of Salem Generating Station Unit 1, in accordance with the proposed change:

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

The proposed change involves no hardware changes, no changes to the operation of any systems or components, and no changes to existing structures. This change is tempor-ary, allowing a one-time extension of a specific surveil-lance requirement for cycle 12 to allow surveillance test-ing to coincide with the twelfth refueling outage. The proposed surveillance interval extension is short and will not result in any significant reduction in structural re-liability nor will the extension affect the ability of the structure in performing its intended functions. To pre-clude the possibility of an undetected containment failure/leakage at a valve or penetration seal, Type "B" and "C" tests will continue to be performed as required by the Technical Specifications. Therefore, this change will not involve a significant increase in the probability or consequences of any accidents previously evaluated.

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

Extending the surveillance interval for the performance of specific testing will not create the possibility of any new or different kinds of accident. No changes are required to any system configurations, plant equipment, or analyses. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Will not involve a significant reduction in a margin of safety.

The proposed change will not alter any assumptions, initial conditions, or results of any accident analyses.

The safety limits assumed in the accident analyses and the design function of the structure required to mitigate the consequences of any postulated accidents will not be changed since only the surveillance interval is being extended. Historical performance indicates a high degree

ATTACHMENT 1 ONE-TIME EXTENSION OF SURVEILLANCE LR-N95056 REQUIREMENT INTERVAL LCR 95-06 of reliability, and surveillance testing performed during continued plant operation will verify that Salem 1 will remain within analyzed limits. Consequently, the change does not involve a significant re~uction in a margin of safety.

V. CONCLUSIONS Based on the above, PSE&G has determined that the proposed change does not involve a significant hazards consideration.