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Application for Amend to License DPR-70,modifying Pressure Isolation Valve Lco,Lco Action Statement,Surveillance Requirement & Table 4.4-4 to Be Consistent W/Salem Unit 2
	ML18102B618
Person / Time
Site:	Salem
Issue date:	10/14/1997
From:	Eric Simpson; Public Service Enterprise Group
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102B619	List: ML18102B618; ML18102B620;
References
	LCR-S96-10, LR-N970619, NUDOCS 9710210020
	Download: ML18102B618 (14)
	v • d • e

Public Service

. 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 OCT 141997 LR-N970619 LCR S96-10 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. *20555 REQUEST FOR LICENSE AMENDMENT REACTOR COOLANT SYSTEM SALEM GENERATING STATION UNIT 1 FACILITY OPERATING LICENSE NOS. DPR-70 DOCKET NO. 50-272 Gentlemen:

In accordance with the requirements of 10CFR50.90, Public Service Electric and Gas Company (PSE&G) hereby requests a revision to the Technical Specification (TS) for the Salem Generating Station Unit No. 1. In accordance with 10CFR50.91(b) (1), a copy of this

submittal has been sent to the State of New Jersey.

This proposed change will modify the Salem Unit 1 Technical Specification (T.S.) 3.4.6.3 "Primary Coolant system Pressure tsolation Valves Limiting Condition for Operation." The proposed change .will modify the Pressure Isolation Valve (PIV) Limiting condition for Operation (LCO), LCO Action Statement (A/S),

Surveillance Requirement (SR), and Table 4.4-4 to be consistent with Salem Unit 2.

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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OCT 14199l Document control Desk LR-N970619 Upon NRC approval of the proposed change, PSE&G requests that the amendment be made effective upon issuance, but allow 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.

Sincerely, Affidavit Attachments ( 3) 95-4933

0 Document control Desk

OCT t 41997 LR-N970619 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 Ms. M. Evans (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-N970619 LCR S96-10 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 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, Unit 1, are true to the best of my knowledge, information and belief.

Subscribed and Sworn~~bef ore me this / '-/ -fh day of fJhlo!J.vL. , 1997 KIMBERLY JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission expires on My Commission Expires April 21, 1998

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Document Control Desk LR-N970619 Attachment 1 LCR S96-10 REQUESTED CHANGE AND PURPOSE This proposed change will modify Technical Specification (TS) 3.4.6.3 "Primary Coolant System Pressure Isolation Valves Limiting Condition for Operation," to make it consistent with the Salem Unit 2 Technical Specifications requirements. The proposed changes are as follows:

1. To Limiting Condition for Operation (LCO) 3.4.6.3

a. Adds the phrase "specified in Table 4.4-4" to the LCO 3.4.6.3, and replaces the word operational with OPERABLE.

b. Deletes parts "a" and "b" of LCO 3.4.6.3 and the associated note (a) at the bottom of page 3/4 4-16a.

c. Rewords the LCO Action as indicated in Insert A.

2. To Surveillance Requirement 4.4.6.3

a. Rewords, deletes and reformats Surveillance Requirement (SR) 4.4.6.3 as follows:

1. Reduces the conditional surveillance testing frequency of SR 4.4.6.3a2 from 12 months to 9 months.

2. Deletes SR 4.4.6.3b.

3. Adds a new SR to test the valves within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following their actuation.

4. Deletes note (b) at the bottom of page 3/4 4-16a

5. Rewords and reformats the SR 4.4.6.3 to be consistent with the Unit 2 SR 4.4.7.2.2 See insert B for proposed changes 2al through 2a5.

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Document Control Desk LR-N970619 LCR S96-10

3. To Table 4.4-4

a. Reformats and adds eleven (11) valves to Table 4.4-4 to be consistent with the Unit 2 Table 3.4-1.

From a human factors point of view, the rewording and reformatting of the Unit 1 LCO significantly improves the LCO quality. The purpose of the proposed change is to have consistency between Salem Units 1 and 2 Technical Specifications. The proposed changes are also consistent with NUREG 1431, Rev 1 (April 1995) Standard Technical Specifications Westinghouse Plants.

JUSTIFICATION OF REQUESTED CHANGES The overall purpose of these pressure isolation valves is to ensure the integrity of the Reactor Coolant System (RCS). These valves separate the high pressure RCS from piping systems rated at a lower pressure. Ensuring the operability of these valves minimizes the probability of an inter-system loss of coolant.

Justification la. Adding the phrase "specified in Table 4.4-4 11 to the LCO 3.4.6.3, and replacing the word operational with OPERABLE.

The proposed change adds the phrase "specified in Table 4.4-4" following the word Valves to indicate in the LCO itself (1) what valves are to be tested, and (2) their acceptance criteria. This requirement is presently contained in part "a" of the LCO, which states " The integrity of all pressure isolation valves listed in Table 4.4-4 .... ~Valve leakage shall not exceed the amounts indicated." Replacing the word operational with OPERABLE brings consistency with the rest of Technical Specification by using a defined Technical Specification term to define operability.

The proposed change is editorial in nature. The only substantive changes are the replacement of the words "listed" and "operational by the words "specified" and "OPERABLE."

2

Document Control Desk LR-N970619 LCR S96-10 lb. Deleting parts "a" and "b" of LCO 3.4.6.3 and the associated note (a) at the bottom of page 3/4 4-16a.

Deleting part "a" of LCO 3.4.6.3 is justified by incorporating its requirements into the LCO statement as indicated in number 1 above.

Deleting part "b" of LCO 3.4.6.3 is justified by including its requirement into the Action Statement(Insert A). Part "b" of the LCO, as presently written, contains actions. Action requirements are more appropriately placed in the Action section of the Technical Specifications rather than the LCO section. Therefore, deleting part "b" and incorporating these requirements into a new action statement is a human factor improvement. The improvement is achieved by having the compensatory measures needed to be performed when the LCO is not met included in the Action portion of the LCO, consistent with the rest of the Technical Specifications. The proposed change is editorial in nature and provides for consistency between the Salem Units~

le. Rewording the Action as indicated in Insert A.

As stated in lb above, the requirement of part "a" is included in the LCO, and the requirements of part "b" are incorporated in the new Action Statement (AS) as stated in Insert A. The shutdown requirement and the allowed outage times contained in the original AS are maintained in the new proposed AS.

The proposed changes (la through le) are editorial in nature.

The changes improve the quality of the Technical Specification from a human factor point of view, by reformatting and rewording the LCO and Action statement. The proposed changes also provide consistency between the Salem Units, and is consistent with NUREG 1431, Rev 1 (April 1995) standard Technical Specifications Westinghouse Plants.

2a. Rewording, and reformatting Surveillance Requirement (SR) 4.4.6.3 as follows:

2al. Rewording SR 4.4.6.3al, and reducing the surveillance testing frequency of SR 4.4.G.3a2 from 12 months to 9 months.

3

Document Control Desk LR-N970619 LCR S96-10 SR 4.4.6.3al is being reworded to read at least once per 18 months. The proposed change clarifies that the testing frequency is that of an 18 month refueling outage schedule. The proposed change is consistent with the Salem Unit 2 Technical Specification wording.

Relative to SR 4.4.6.3a2 requirement, the proposed change will increase the surveillance frequency requirement by reducing the allowed testing frequency from 12 to 9 months and constitutes a conservative change to the Technical Specifications. This change is consistent with the present Salem Unit 2 Technical Specification requirements.

2a2. Deleting SR 4.4.6.3b.

This SR is deleted. This SR provides actions to be taken when the LCO is not met. The new proposed Action, as stated in Insert A, contains equivalent requirements as the requirements deleted by the proposed change.

2a3. Adds a new SR to test the valves within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following their actuation.

The proposed change is consistent with the present Salem Unit 2 Technical Specification requirements. It adds the requirement to test the*hot and cold leg injection valves and accumulator valves listed in Table 4.4-4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following valve actuation.

This new surveillance requirement ensures that the system integrity and operability of the affected systems is demonstrated after valve actuation, and does not rely on the test performed during the last refueling outage.

2a4. Deletes note (b) at the bottom of page 3/4 4-16a The surveillance procedures used to demonstrate acceptability of results are approved Technical Specification surveillance procedures supported by computation. The requirement to have an approved procedure is covered under Technical Specification Section 6.8 "Procedures and Programs." Therefore., this note, which is not contained in the Salem Unit 2 Technical Specification, is redundant to the Section 6.8 requirement.

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Document Control Desk LR-N970619 LCR S96-10 2a5. Rewording and reformatting the SR 4.4.6.3 to be consistent with the Unit 2 SR 4.4.7.2.2 (see insert B).

The proposed changes discussed above (2al through 2a5) are clearly stated in Insert B. Overall, the proposed changes are conservative since they increase the testing requirements by adding a new SR and shortens the frequency of another.

3. Reformatting and adding eleven (11) valves to Table 4.4-4 to be consistent with the Unit 2 Table 3.4-1.

The proposed change adds eleven valves to the Unit 1 Technical Specifications. These valve are pressure isolation valves and are included in the Inservice Test Program. These valves have been tested at the same frequency of a pressure isolation valve.

Adding these valves into Table 4.4-4 is administrative in nature and will bring consistency between Salem Unit 1 and 2 Technical Specifications, and the IST program.

CONCLUSIONS In summary, from a human factors point of view, the proposed changes.described above, significantly enhance the Unit 1 Limiting Condition for Operation and its Surveillance Requirements. The changes also provide consistency between the Salem Unit 1 and 2 Technical Specifications.

This submittal enhances the present Unit 1 Technical Specifications by the proposed changes in word and format. _The changes provide consistency between the units by incorporating additional pressure isolation valves into the Unit 1 Technical Specification Limiting Condition for Operation. The substantive proposed changes will bring the Unit 1 Limiting Condition for Operation in agreement with the Unit 2 Technicai Specification, and w.:Lll establish the operability and testing requirements of the pressure isolation valves.

This proposed change is also consistent~with the intent of the "Standard Technical Specifications Westinghouse Plants" NUREG 1431, Revision 1.

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Document Control Desk LR-N970619 LCR S96-10 SALEM GENERATING STATION UNIT NO. 1 FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-272 CHANGE TO TECHNICAL SPECIFICATIONS (TS) 3.4.6.3 AND TABLE 4.4-4 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 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 changes are as follows:

1. To Limiting Condition for Operation (LCO) 3.4.6.3

a. Adds the phrase "specified in Table 4.4-4" to the LCO 3.4.6.3, and replaces the word operational with OPERABLE.

b. Deletes parts "a 11 and "b" of LCO 3. 4. 6. 3 and the associated note (a) at the bottom of page 3/4 4-16a.

c. Rewords the LCO Action as indicated in Insert A.

2. To surveillance Requirement 4.4.6.3

a. Rewords, deletes and reformats Surveillance Requirement (SR) 4.4.6.3 as follows:

1. Reduces the conditional surveillance testing frequency of SR 4.4.6.3a2 from 12 months to 9 months.

2. Deletes SR 4.4.6.3b.

3. Adds a new SR to test the valves within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following their actuation.

1

'Document Control Desk LR-N970619 Attachment 2 LCR S96-10

4. Deletes note (b) at the bottom of page 3/4 4-16a

5. Rewords and reformats the SR 4.4.6.3 to be consistent with the Unit 2 SR 4.4.7.2.2 See insert B for proposed changes 2al through 2a5.

3. To Table 4.4-4

a. Reformats and adds eleven (11) valves to Table 4.4-4 to be consistent with the Unit 2 Table 3.4-1.

This submittal enhances the present Unit 1 Technical Specifications by the proposed changes in word and format. The changes provide consistency between the units by incorporating additional pressure isolation valves into the Unit 1 Technical Specification Limiting Condition for Operation. The substantive proposed changes will bring the Unit 1 Limiting Condition for Operation in concert with the Unit 2 Technical Specification to establish the operability and testing requirements of the pressure isolation valves.

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

The majority of the proposed changes, as described above, are editorial in nature. Rewording, and reformatting the Limiting Condition for Operation, including the surveillance requirements do not involve a significant increase to the probability or consequences of an accident.

Those substantive changes involving the addition of (1) new reactor coolant system pressure isolation valves, (2) providing for a shorter test frequency upon entry into Mode 4, and (3) adding a new surveillance test requirement, do not increase the probability or consequences of an accident. These changes ensure that the system and components needed to prevent and minimize the effects of inter-system loss of coolant are properly identified in the Technical Specifications.

2

. Document Control Desk

LR-N970619 Attachment 2 LCR S96-10 Although pressure isolation valves are being added to the Technical Specification table, these valves were already included in the IST program as pressure isolation valves and were being tested as such. The proposed changes do 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 change, as described above, does not physically alter the facility or the operation of the facility. The majority of the changes are editorial in nature and provide for improvement in the human factors of the Technical Specifications, while properly identifying all the pressure isolation valves in the Technical Specifications. The addition of valves into the Technical Specification is an administrative change that improves the quality of the LCO, but does not add components to the facility.

The proposed changes do 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 margin of safety, as defined in the bases for any technical specifications, depend upon proper identification of equipment and performance of the proper surveillance requirements to demonstrate equipment operability. The proposed change will ensure that the proper valves are identified and tested in accordance with the Technical Specification requirements.

The proposed changes do 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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INSERT A ACTION:

a. With any Reactor Coolant System Pressure Isolation Valve leakage greater than the specified limit in Table 4.4-4, isolate the high pressure portion of the affected system from the low pressure portion within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least two closed manual or deactivated automatic valves, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

INSERT B 4.4.6.3 Each Reactor Coolant System Pressure Isolation Valve specified in Table 4.4-4 shall be demonstrated OPERABLE pursuant to Specification 4.0.5, except that in lieu of any leakage testing required by Specification 4.0.5, each valve shall be demonstrated OPERABLE by verifying leakage to be within its limit:

a. At least once per 18 months.

b. Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or more and if leakage testing has not been performed in the previous 9 months.

c. Prior to returning the valve to service following maintenance repair or replacement work on the valve.

d. For the Residual Heat Removal and Safety Injection systems hot and cold leg injection valves and accumulator valves listed in Table 4.4-4 the testing will be done within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following valve actuation due to automatic or manual action or flow through the valve. For all other systems testing will be done once per refueling.

The provisions of specification 4.0.4 are not applicable for entry into MODE 3 or 4.

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INSERT c Safety Injection Accumulators to cold leg loop 11 11SJ55 s 5.0 GPM each valve loop 12 12SJ55 s 5.0 GPM each valve loop 13 13SJ55 s 5.0 GPM each valve loop 14 14SJ55 s 5.0 GPM each valve Safety Injection Boron Injection to cold legs loop 11, cold leg 11SJ17 s 5.0 GPM each valve loop 12, cold leg 12SJ17 s 5.0 GPM each valve loop 13, cold leg 13SJ17 s 5.0 GPM each valve loop 14, cold leg 14SJ17 s 5.0 GPM each valve 1SJ150 s 5.0 GPM each valve RHR suction loop 11 lRHl s 5.0 GPM each valve loop 11 1RH2 s 5.0 GPM each valve 2

ML18102B618

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