ML18102A802

Application for Amends to Licenses DPR-70 & DPR-75, Requesting Rev to TS Re Containment Systems Air Temp to Ensure Representative Average Air Temp Is Measured

ML18102A802
Person / Time
Site:	Salem
Issue date:	01/31/1997
From:	Eric Simpson Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102A803	List: ML18102A802 ML18102A804
References
LCR-S95-09, LCR-S95-9, LR-N97052, NUDOCS 9702070064
Download: ML18102A802 (11)

Text

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• Public Service i Electric and Gas

' Company E. C. Simpson Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1700 Senior Vice President - Nuclear Engineering JAN 311997 LR-N97052 LCR S95-09 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS CONTAINMENT AVERAGE AIR TEMPERATURE SALEM GENERATING STATION 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 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 TS changes contained herein represent changes to the Containment Systems Air Temperature TS to ensure that a representative average air temperature is measured. The proposed change eliminates the present wording which could allow for measurements which are not indicative of actual containment average temperature. This change is consistent with the Standard Technical Specifications Westinghouse Plants, NUREG 1431.

This request satisfies the long term corrective action discussed in Licensee Event Report 272/95-004-00 pertaining to this topic.

The proposed changes have been evaluated in accordance with 10CFR50.91(a) (1), using the criteria in 10CFR50.92(c), and PSE&G has concluded that this request involves no significant hazards considerations.

The basis for the requested change is provided in Attachment 1.

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 Attachment 3. "\ ')

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• 'JAN 311997 Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities.

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

Affidavit Attachments (3)

C Mr. H. J. Miller, 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 95-4933

Document Control Desk

• JAN 311997 LR-N97052 SRM/mrh BC Senior Vice President - Nuclear Engineering (Nl9)

General Manager - Salem Operations (S05)

Director - QA/NSR (XOl)

Manager - Joint Owners/Ext Aff Interface (N28)

Manager - Salem Operations (SOl)

Manager - System Engineering - Salem (S02)

Manager - Nuclear Safety Review (N38)

Manager - Licensing & Regulation (X09)

Principal Engineer [Salem] Operational Licensing (X09)

Onsite Safety Review Engineer - Salem (X15)

J. Curham S. Makam J. Giessner G. Siefert General Solicitor, E. Selover (Newark, 5G)

Mark J. Wetterhahn, Esq.

Records Management (N21)

Microfilm Copy Files Nos. 1.2.1 (Salem), 2.3 (LCR S95-09)

REF: LR-N97052 LCR S95-09 STATE OF NEW JERSEY SS.

COUNTY OF SALEM E. C. Simpson, being duly sworn according to law deposes and says:

I am Senior Vice President - Nuclear Engineering for the Nuclear Business Unit, 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.

this J day of h

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Subscribed and Sworn to before me 3 1997

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EUZABIDi J. KIDD NOTARY PUBLIC OF NEW JERSEY My Commission Explras April 25, 2000 My Commission expires on

Document Control D .

e LR-N97052 LCR S95-09 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 CONTAINMENT AVERAGE AIR TEMPERATURE BASIS FOR REQUESTED CHANGE REQUESTED CHANGE AND PURPOSE The proposed Technical Specification (TS) changes contained herein represent changes to Specification 4.6.1.5 pertaining to the daily surveillance requirement for measuring Containment average air temperature. The proposed change will delete the existing requirement of averaging the temperatures at any five of the ten listed locations within Containment and replace it with the requirement to verify that the temperature is within the limit, (i.e., ~120°F), at least once per twenty-four hours.

In support of the change to the surveillance requirement, PSE&G is also proposing to add supplemental information to the applicable Bases section stating that an average is calculated using measurements taken at locations within Containment selected to provide a representative sample of the overall Containment atmosphere.

The proposed change is being submitted to eliminate the potential for applying the existing requirements in an unconservative manner.

BACKGROUND Limitations on containment average air temperature ensure that the overall containment average air temperature does not exceed the initial temperature condition assumed in the accident analysis for a Loss of Coolant Accident or Steamline Break inside Containment. The resulting DBA temperature limits are used to establish the environmental qualification envelope for safety-related electrical equipment inside containment. For the Salem Units, the surveillance requirement which ensures that this accident assumption is not exceeded during normal operation currently states that the Containment average temperature shall be the arithmetic average of the temperatures at any five of ten referenced locations within Containment.

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Document Control LR-N97052 LCR S95-09 Prior to March of 1995, PSE&G had used all ten locations to determine the average temperature. Though the use of ten points resulted in a more accurate representation of Containment average air temperature, it was determined that this practice was not in compliance with the surveillance requirement of using only five points. This was reported to the NRC via Licensee Event Report (LER) 272/95-004-00 on May 18, 1995.

Consequently, it was recognized that using only five points could permit the selection of locations that do not provide a representative indication of the overall containment atmosphere and could result in an unconservative containment average temperature being calculated. It was also noted that several of the locations listed in the table were inaccurate. Salem subsequently revised procedures to ensure that the arithmetic average temperature is calculated using five representative temperature detectors.

PSE&G has determined it more suitable to propose changes to the surveillance requirement that are consistent with NUREG-1431, "Standard Technical Specifications - Westinghouse Plants,"

Rev. 1, dated April 7, 1995 rather than specifying the selected detectors to be used in the surveillance requirement (as was previously stated in the corrective actions of the LER.)

JUSTIFICATION OF REQUESTED CHANGES Salem's existing TSs were based upon NUREG-0542, "Standard Technical Specifications For Westinghouse PWRs," which stated that any five of ten temperature locations were to be used for the surveillance and was typical of industry practices in measuring the Containment average air temperature. Locations of the detectors by elevation and position within Containment are specified in the surveillance for reference.

PSE&G has performed a temperature profile study to determine the locations that best represent actual containment conditions.

This review resulted in establishing five locations, from various elevations, to calculate the average, and identified back-up locations should any of the primary locations be unavailable.

This methodology is controlled by procedure. Any changes that may be necessary as a result of revised surveillance methodology or plant changes, such as the installation of additional detectors, relocated detectors, etc., would be performed using appropriate administrative controls as required.

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Document Control

• LR-N97052 LCR S95-09 The changes that are proposed by PSE&G maintain the intent of the surveillance in the TSs and are consistent with the surveillance requirements for specification 3.6.5A, "Containment Air Temperature (Atmospheric and Dual)" of NUREG-1431. PSE&G has reviewed the entire specification contained in NUREG-1431 and has determined that Salem's existing TS is consistent with or more limiting than the requirements delineated in the specification.

Therefore, no other changes to Salem's TS 3.6.1.5 are being proposed.

As stated previously, it was noted that the Salem Unit 1 list of detector locations contained an error. There are three locations at the 136' elevation and no detectors at the 78' elevation.

This is considered editorial in nature and does not impact the requested change since the list of detectors is to be deleted.

CONCLUSIONS The changes submitted by this request provide the means to ensure that the surveillance for Containment average air temperature is a representative measurement. The proposal does not change the intent of the surveillance which is currently performed in accordance with the Salem TSs and is consistent with industry practices.

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Document Control

• LR-N97052 LCR S95-09 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 CONTAINMENT AVERAGE AIR TEMPERATURE 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 proposed Technical Specification (TS) changes contained herein represent changes to Specification 4.6.1.5 pertaining to

_the daily surveillance requirement for measuring Containment average air temperature. The proposed change will delete the existing requirement of averaging the temperatures at any five of the ten listed locations within Containment and replace it with the requirement to verify that the temperature is within the limit, (i.e., ~120°F), at least once per twenty-four hours.

Supplemental information is also being added to the applicable Bases section stating that an average is calculated using measurements taken at locations within Containment selected to provide a representative sample of the overall Containment atmosphere.

BASIS

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

Limitations on containment average air temperature ensure that the overall containment average air temperature does not exceed the initial temperature condition assumed in the accident analysis for a Loss of Coolant Accident or Steamline Break inside Containment. The resulting DBA temperature limits are used to establish the environmental qualification envelope for safety-related electrical equipment inside containment.

Page 1 of 3

Document Control

• LR-N97052 LCR S95-09 The measurement of Containment average air temperature is a means to ensure that the design temperature normal operating limit is not exceeded. The probability of an accident is not impacted by the surveillance of normal temperature as it is a measurement which involves permanently installed, static equipment. The consequences of an accident are not impacted since the method of measurement ensures that the design basis temperatures are maintained and the intent of the existing surveillance specification is not changed. The proposed change does not impact the actual containment temperature, but specifies an acceptably accurate method for its determination.

Therefore, the probability of and consequences of an accident previously evaluated are not significantly increased.

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

The proposed changes do not involve any modifications to existing plant equipment, do not alter the function of any plant systems within Containment, do not introduce any new operating configurations or new modes of plant operation, nor change the safety analyses. The proposed change is consistent with NUREG-1431 and provides a methodology to ensure that calculated temperature is accurately determined.

The proposed changes will, therefore, not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

The proposed change results in an acceptably accurate determination of the containment average air temperature, therefore, compliance with the TS surveillance and its associated basis is assured. The present margin of safety is not affected since operating parameters and conditions are unchanged.

All changes are consistent with the intent of Salem's current TS and with the surveillance specified in NUREG-1431, Revision 1.

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Document Control D I LR-N97052 Attachment 2 LCR 895-09 CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

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1 Document Control D . LR-N97052 LCR S95-09 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 CONTAINMENT AVERAGE AIR TEMPERATURE TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Facility Operating License No. DPR-70 are affected by this supplement:

Technical Specification 4.6.1.5 3/4 6-7 3/4.6.1.5 Bases B 3/4 6-2 The following Technical Specifications for Facility Operating License No. DPR-75 are affected by this supplement:

Technical Specification 4.6.1.5 3/4 6-7 3/4.6.1.5 Bases B 3/4 6-2 Page 1 of 5