ML18101B025

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Application for Amend to License DPR-70,representing one- Time Extension to Spec 3/4.8.1.2 Electric Power Sys - AC Sources - Shutdown
ML18101B025
Person / Time
Site: Salem PSEG icon.png
Issue date: 09/28/1995
From: Storz L
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18101B026 List:
References
LCR-95-12, LR-N95150, NUDOCS 9510050111
Download: ML18101B025 (9)


Text

Public Service Electric and Gas

  • Company Louis F. Storz Public SeNice Electric and Gas CompSEP ~rs* fggs36, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations LR-N95150 LCR 95-12 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LICENSE AMENDMENT APPLICATION ONE-TIME EXTENSION OF TECHNICAL SPECIFICATIONS SURVEILLANCE REQUIREMENT 4.8.1.2 FOR ELECTRICAL POWER SYSTEMS - SHUTDOWN 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 10CFR50.9l(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 represents a one-time extension to Specification 3/4.8.1.2 Electrical Power Systems - AC Sources - Shutdown. Public Service Electric & Gas Company (PSE&G) is requesting a test interval extension for the diesel generator 18 month surveillance requirements. The change will require the specified surveillance tests to be completed prior to entering Mode 4 from the current self-imposed maintenance/refueling outage, but not on the normal 18 month frequency.

The proposed change has been evaluated in accordance with 10CFR50.91(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 the basis for a no significant hazards consideration determination are provided in Attachment 1. The Technical Specification pages affected by the proposed changes are provided in Attachment 2.

Printed on 9510050111 6§865~72 Recycled Paper ~DR ADOCK PDR

Document Control Desk LR-N85150

  • SEP 2 8 1995 LCR 95-12 Should you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely,

~---

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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

COUNTY OF SALEM L. F. Storz, being duly sworn according to law deposes and says:

I am Senior Vice President - Nuclear Operations for the Public Service Electric & 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.

Subscribed and Sworn to before me this 6/8-1.:;f\ day o~liml:J..vL 1995 KIMBERl YJO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission expires on My Commission Expires April 21, 1998

ATTACHMENT 1 LR-N95150 LCR 95-12 I. DESCRIPTION-OF THE PROPOSED CHANGE A one time extension to surveillance requirement 4.8.1.2 is requested. This extension is requested from time of NRC issuance, but not later than November 22, 1995, until the 18 month surveillance requirements can be performed prior to entering Mode 4 from the current maintenance/refueling outage - 1R12.

Specifically, Specification 4.8.1.2 is revised by adding a modifying Note identified as Insert 1, which is shown below and on the marked-up pages of Attachment 2.

Insert 1 Note The following surveillances: 4.8.1.1.1.b, 4.8.1.1.2.d.2, 4.8.1.1.2.d.3, 4.8.1.1.2.d.4, 4.8.1.1.2.d.6, 4.8.1.1.2.d.7, 4.8.1.1.2.d.9, and 4.8.1.1.2.f, are being extended, on a one time only basis, to prior to entering Mode 4 from the current refueling outage (1Rl2) .

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 variations in the length of an operating cycle. However, due to the extended maintenance/refueling outage for Salem Unit No. 1, performance of AC Sources 18 month surveillance requirements is not practicable.

These surveillances were originally intended to be performed during the Unit shutdown. This would have corresponded to the normal Technical Specification frequency and would have provided sufficient time to perform all critical work with the reactor defueled. A number of issues associated with plant equipment resulted in improper scheduling of these surveillances until after the core was unloaded.

' ATTACHMENT 1 2 LCR 95-12 LR-N95150 Plant operating procedures written to comply with these technical specifications surveillances, assume that fuel is loaded into the reactor vessel. In addition, equipment availability to perform these surveillances requires that the reactor be assembled (i.e., reactor vessel head installed with all its supporting ventilation equipment) .

Although, procedures could be modified to perform applicable portions of these surveillances, their performance with limited availability of electrical power could compromise both the offsite power source, as well as, the onsite power sources. Therefore, .PSE&G believes that, as explained in Section III below, there is a significant net safety gain in granting this extension.

III. JUSTIFICATION FOR CHANGE The Class lE AC electrical power distribution system consists of the offsite power sources and the onsite standby DGs. The design of the electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

The Salem onsite Class lE distribution system is divided into three redundant trains, such that, loss of any one train does not prevent the minimum safety functions from being performed. Each train has connections to two offsite power sources and a single DG.

Offsite power is supplied from the switchyard by two electrically and physically separated independent circuits.

The operability of the minimum AC sources during Modes 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods.
b. Sufficient instrumentation and control capability is available for monitoring and maintaining unit status, and
c. Adequate AC electrical power is provided to mitigate events postulated during shutdown.

' ATTACHMENT 1 4 LCR 95-12 LR-N95150

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

The proposed change only extends the surveillance interval.

No component modification, system realignment, or change in operations will occur which could affect the probability of any accident or transient. The surveillance frequency extensions will preclude rendering operable DGs inoperable, and/or preclude de-energizing a required ESF bus or disconnecting a required offsite circuit during performance of the surveillance requirement. The proposed changes do.

not eliminate any testing requirements, but do ensure that the surveillances will be performed prior to entry into Mode

4. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously analyzed.
2. Will not create the possibility of a new or different kind of accident from any previously evaluated.

No component modification, system realignment, or change in operating procedure is required to implement the proposed change. Extending the surveillance test intervals for the performance of specific testing reduces the possibility of a single event impacting the operability of an ESF bus or its DG simultaneously. Therefore, these changes 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 Class lE equipment assumed available in the accident analyses and their designed capability to mitigate the consequences of any postulated accidents will not be changed since only surveillance test intervals are being extended. The short extensions requested for the diesel generator surveillance test intervals will not involve a significant reduction in a margin of safety.

' ATTACHMENT 1 3 LCR 95-12 LR-N95150 Surveillance requirement 4.8.1.2 identifies those surveillances associated with Electrical Power Systems Shutdown. The surveillance requirements of this specification refer to LCO 3.8.1.1, Electrical Power Systems

- Operating to identify the specific testing requirements.

This surveillance requirement is being modified by the new Note to defer the 18 month testing.

The proposed change will defer that testing associated with automatic operation of the DGs and associated breakers following a Design Basis Accident and/or a loss of offsite power. The normal weekly and monthly surveillance testing identified below will ensure that the minimum requirements for AC Sources in Modes 5 and 6 can be met.

To ensure DG operability prior to completing the 18 month testing, surveillance requirements 4.8.1.1.1.a, 4.8.1.1.2.a, 4.8.1.1.2.b, 4.8.1.1.2.c, and 4.8.1.1.3 will be performed at the frequency required by Technical Specifications. These surveilllances include monthly DG operation, breaker alignments, and fuel oil transfer system operation.

The reason for the Note, and basis for granting the extension, is to preclude requiring surveillances to be performed that could compromise both the required offsite circuit and the DG.

This change is consistent with NUREG-1431, Standard Technical Specifications - Westinghouse Plants. PSE&G has submitted a License Change Request to modify Salem Unit Nos.

1 and 2 Technical Specifications (Ref. LR-N95151 dated September XX, 1995) . LR-N95151 would revise the Salem Technical Specification 4.8.1.2, AC Sources - Shutdown, to be consistent with NUREG-1431.

IV. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION PSE&G has, pursuant to 10CFR50.92, reviewed the proposed amendment to determine whether our request involves a significant hazards consideration. We have determined that operation of Salem Generating Station Unit No. 1, in accordance with the proposed change:

ATTACHMENT 1 5 LCR 95-12 LR-N95150 V. CONCLUSIONS Based on the above, Public Service Electric & Gas has determined that the proposed changes do not involve a significant hazards consideration.

~ LR-N95150 LCR 95-12 ATTACHMENT 2