ML18101B334

Application for Amends to Licenses DPR-70 & DPR-75,modifying Frequency of Type a Containment ILRT

ML18101B334
Person / Time
Site:	Salem
Issue date:	04/22/1996
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18101B335	List: ML18101B334 ML18101B336
References
LCR-S96-04, LCR-S96-4, LR-N96071, NUDOCS 9604290184
Download: ML18101B334 (10)

Text

Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations APR 2 2 1996 LR-N96071 LCR S96-04 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS INCORPORATION OF 10CFR50 APPENDIX J OPTION B SALEM GENERATING STATION UNITS NOS. 1 AND 2

• FACILITY OPERATING LICENSES DPR-70 *AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Gentlemen:

In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company hereby requests a revision to the Technical Specifications (TS) for the Salem Generating Station, Unit Nos. 1 and 2. In accordance with 10CFR50.91 (b) (1), a copy of this submittal has been sent to the State of New Jersey.

The proposed changes are necessary to implement 10CFR50, Appendix J, Option B, as delineated in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program." The proposed TS changes affect 3/4.6.1 "Primary Containment." Specifically, the proposed changes modify the frequency of Type A containment integrated leakrate tests (ILRT). Appendix J provides for a reduced test frequency for qualified containments in Option B.

Salem Unit 1 and Unit 2 containments have had acceptable ILRT performance in the past and qualify for the reduced test frequency specified in Option B.

The proposed changes incorporate only the provisions of Option B that apply to Type A containment (ILRT) testing. Changes to implement the Type B and C reduced frequency testing provisions of Option B will require additional Appendix J implementation changes and will be submitted at a later date. Adopting the requirements of Option B for a specific category of tests is consistent with Section 3.0 of Nuclear Energy Institute (NEI) 94-01 "Industry Guideline For Implementing Performance-Based Option of 10CFR50, Appendix J," Revision 0.

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APR 2 2 1996 Document Control Desk LR-N96071 The last Type A test was performed on Unit 2 containment March 24, 1992. By taking advantage of Option B at this time, performance of a Type A test will not be necessary during the present Unit 2 outage. PSE&G requests that this amendment be approved no later than July 1, 1996, in order to permit establishment of containment integrity as required by the current Unit 2 startup schedule.

Similar requests for implementation of Option B have been approved by the NRC for River Bend (Amendment 84), Brunswick (Amendment 181/213), and Vogtle 1/2 (Amendment 93/71).

The proposed changes have been evaluated in accordance with 10CFR50.9l(a) (1), using the criteria in 10CFR50.92(c), and PSE&G has concluded that this request involves no significant hazards consideration.

The basis for the requested change is provided in Attachment L A 10CFR50.92 evaluation with a determination of no significant hazards consideration is provided in Attachment 2. The marked up TS pages affected by the proposed changes are provided in .

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

Sincerely, I

Affidavit Attachments (3)

APR 2 2 1996 Document Control Desk LR-N96071 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 (X24)

USNRC Senior Resident Inspector - Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625

REF: LR-N96071 LCR S96-04 STATE OF NEW JERSEY SS.

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

I am Senior 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 Salem Generating Station, Units 1 and 2, are true to the best of my knowledge, information and belief.

Subscribed and Swor~re me thi.s ~md day of i0._L , 1996 l<IMBERLY JO BROWN NOTARY PUBLIC: OF NEW JERSEY My Commission expires on My Commission Expires April 21, 1998

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e Document Control Desk LR-N96071 LCR S96-04 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS INCORPORATION OF 10CFR50 APPENDIX J OPTION B BASIS FOR REQUESTED CHANGE REQUESTED CHANGE AND PURPOSE The Technical Specification (TS) changes included in Attachment 3 will implement the revision to 10CFR50, Appendix J, which became effective on October 26, 1995 with respect to Type A Containment Integrated Leakrate Tests (ILRT). The revision to the regulation represents a shift away from prescriptive testing requirements in Appendix J {Option A) to a performance-based approach (Option B) .

Option B also provides for test interval extensions for Type B and C testing; however, these changes are not being requested at this time. Adopting the requirements of Option B for a specific category of tests is consistent with Section 3.0 of Nuclear Energy Institute (NEI) 94-01 "Industry Guideline For Implementing Performance-Based Option of 10CFR50, Appendix J," Revision 0.

Surveillance Requirement (SR) 4.6.1.2 is being revised to refer to the requirement in 10CFR50.54(o) that containment testing be performed pursuant to Appendix J. The reference to Appendix J that currently exists in SR 4.6.1.2 will now refer to Option B of Appendix J and include a reference to Regulatory Guide (RG) 1.163 "Performance-Based Containment Leak-Test Program", September, 1995. RG 1.163 is the implementation document for Option B.

Existing SRs 4.6.1.2. a, b, c and f are deleted, since they are redundant and/or outdated by the reference to RG 1.163. The existing 4.6.1.2.d and e are retained, since Type Band C test frequencies are not changed by this request and are renumbered a and b, respectively. SR 4.6.1.2.g in Unit 2 is also being deleted, since the schedule for testing is contained in the referenced documents and variation to TS 4.0.2 is no longer appropriate. The test schedule will be determined based upon the criteria of the implementing documents.

The proposed changes will allow PSE&G to adopt cost-effective, industry standard methods for complying with regulatory requirements related to Type A testing.

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Document Controltsk LR-N96071 LCR S96-04 BACKGROUND Compliance with Appendix J provides assurance that the primary containment, including those systems and components which penetrate the primary containment, do not exceed the allowable leakage rates specified in the TS. The allowable leakage rate is determined so that the leakage assumed in the safety analysis is not exceeded.

Salem Unit 1 and Unit 2 containments have, historically, had acceptable performance with Type A testing. Of the seven ILRTs performed on the two Salem Units, none have resulted in a leakage rate exceeding the criteria. The last tests were performed on Unit 1 in April 1991 and on Unit 2 in March 1992. Based on Amendment 171, the ILRT for Unit 1 is due during Refueling Outage 13 (no later than June 1997).

Option B of Appendix J permits the Type A test interval to be up to 10 years provided two consecutive successful tests have been performed (NEI 94-01, Section 9.2.3). Since both Unit 1 and Unit 2 have had more than two consecutive successful Type A tests, the next Type A test would not be required until April 5, 2001 for Unit 1 and March 24, 2002 for Unit 2.

JUSTIFICATION OF REQUESTED CHANGES The proposed changes are based on approved guidance documents from the NRC and NEI, including RG 1.163 and NEI 94-01. These proposed changes are consistent with TS changes, relative to Type A testing, that have been approved by the NRC for other facilities. In RG 1.163, the NRC has determined that the industry guideline (NEI 94-01), with some exceptions, is an acceptable means of demonstrating compliance with the requirements of Option B.

PSE&G intends to comply with the provisions of the NEI document, except as modified by the RG 1.163.

Section 9. 2. 3 of NEI 94-01 spec*ifies that Type A testing shall be performed during a period of reactor shutdown at a frequency of at least once per 10 years based on acceptable performance history.

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e Document Control Desk LR-N96071 LCR S96-04 Acceptable performance history is defined, in NEI 94-01, as completion of two consecutive periodic Type A tests where the calculated performance leakage rate was less than 1.0 La. Salem Units 1 and 2 meet the specified acceptable performance history as noted in the following table.

SALEM TYPE A (ILRT) TEST RESULTS Unit 1 Unit 2 Date Fraction of Date Fraction of 1.0 La 1.0 La 4/91 0.314 La 3/92 0.224 La 12/87 0.430 La 11/86 0.430 La 8/84 0.410 La 5/83 0.540 La 8/79 0.620 La The acceptance criterion for Type A tests as specified in TS 3.6.1.2 is not being changed nor is the requirement that the containment leakage be less than or equal to 0.75 La before entering a mode in which containment integrity is required.

Containment inspections, currently done with Type A tests, will have a modified schedule that will ensure the frequency for the containment inspections is approximately three in ten years.

This is consistent with RG 1.163.

Eliminating the details of the test program from the TS, and providing a reference to the guidance document (RG 1.163) is consistent with the requirements of Appendix J, Option B.

Adopting the requirements of Option B for a specific category of tests is consistent with Section 3.0 of NEI 94-01, Revision 0.

PSE&G's implementation of Option B will include conformance to the test frequencies and methodologies specified in RG 1.163 and will provide an on-going review of test performance to ensure the test frequencies are consistent with the requirements of Option B. Record keeping will be consistent with Section 12 of NEI 94-01, Revision 0.

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e Document Control Desk LR-N96071 LCR S96-04 PSE&G does not refer to a "Primary Containment Leakage Rate Program" in the TS since this request affects only Type A testing, and PSE&G has not adopted the improved Standard Technical Specifications (NUREG 1431). Reference to a separate program will be re-evaluated when implementation of Option B for Type B and C testing occurs. The tenants of a program will be contained in applicable implementing procedures.

For both Salem Units footnote

• at the bottom of page 3/4.6-2, referring to a deferral of Type A testing, is deleted since it has expired and is no longer applicable. For Salem Unit 1, footnote ** is deleted, since it is superseded by the proposed change. Deletion of the footnotes is an administrative change.

CONCLUSIONS The change in the Type A test interval, based on acceptable performance of the containment structure in previous tests, has been determined by the NRC's analysis to have a minimal impact on safety. Salem Units 1 and 2 have achieved acceptable results in the last two consecutive ILRTs. This performance meets the requirements for utilizing Option B of 10CFR50, Appendix J for Type A tests. The proposed changes are consistent with the guidance presented in RG 1.163 and NEI 94-01 and are therefore acceptable.

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Document Control~esk eLR-N96071 LCR S96-04 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS INCORPORATION OF 10CFR50 APPENDIX J OPTION B 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Salem Generating Station Unit Nos. 1 and 2 Technical Specifications {TS) do not involve a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10CFR50 .,92 is provided below.

REQUESTED CHANGE The requested change modifies the frequency of required Type A containment integrated leakrate tests (ILRT). These changes are being proposed in accordance with the recent revision to 10CFR50, Appendix J, which provided for a reduced test frequency for qualified containments in Option B.

BASIS

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Containment leak rate testing is not an initiator of any accident. The proposed changes do not make any physical changes to the containment. The proposed changes do not affect performance of the containment, reactor operations or accident analysis. Therefore, the proposed changes will not involve an increase in the probability of any previously evaluated accident.

Since the allowable leakage rate is not being changed and since the analysis documented in NUREG-1493, "Performance-Based Containment Leak-Test Program" concludes that the impact on public health and safety due to extended intervals is negligible, the proposed changes will not involve an increase in the consequences of any previously evaluated accident.

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Document Control~esk eLR-N96071 LCR S96-04 Therefore, adoption of a performance-based verification of leakage rates for the overall containment boundary will provide an equivalent level of safety and does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed chande makes no physical changes to the plant.

Since no physical changes are involved and since the analysis documented in NUREG-1493 confirms that the performance based schedule continues to maintain a minimal impact on public risk, it can be concluded that the effect of the containment on any accident will not change. The proposed change does not affect normal plant operations or configuration, nor does it affect leak rate test pressure.

Therefore, the proposed amendment will not create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety.

The proposed changes are based on NRC-accepted provisions, and maintain necessary levels of reliability of containment integrity. The performance-based approach to leakage rate testing recognizes that historically good results of containment testing provide appropriate assurance of future containment integrity. This supports the conclusion that the impact on the health and safety of the public as a result of extended test intervals is negligible. Since the analysis documented in NUREG-1493 confirms that the performance based schedule continues to maintain a minimal impact on public risk, it can be concluded that the margin of safety is not significantly affected by the proposed changes.

The test history at Salem Units 1 and 2 (no ILRT failures) provides continued assurance of the leak tightness of the containment structure.

Therefore, the proposed amendment will not involve a significant reduction in a margin of safety.

CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

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