ML18102B629

Application for Amends to Licenses DPR-70 & DPR-75,extending Applicability of Power Range Neutron Flux TS Trip to Require Operability & Surveillance Testing in Mode 3,when Reactor Trip Sys Breakers in Closed Position

ML18102B629
Person / Time
Site:	Salem
Issue date:	10/21/1997
From:	Eric Simpson Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102B631	List: ML18102B629 ML18102B632
References
LCR-S95-19, LR-N97109, NUDOCS 9710270010
Download: ML18102B629 (7)

Text

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 2111997 LR-N97109 LCR S95-19 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS MODE APPLICABILITY OF THE POWER RANGE, NEUTRON FLUX REACTOR TRIP AND SURVEILLANCE REQUIREMENTS 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 will extend the modes when the Reactor Trip System's Power Range Nuclear Instrumentation - low setpoint is required to be operable. The trip instrumentation will be required to be operable in Modes 1, 2 and 3, when the reactor trip system breakers are in the closed position and the control drive system is capable of rod withdrawal. The associated surveillance test applicability is being changed for consistency with the instrumentation mode applicability.

The proposed changes have been evaluated in accordance with 10CFR50.91 (a)(1 ),

using the criteria in 10CFR50.92(c). PSE&G has concluded that this request does not involve a significant hazards consideration.

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 revised TS pages affected by the proposed changes ~re provided in Attachment 3.

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.

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OCT ~l 1997 Document Control Desk 2 LR-N97109 Should you have any questions regarding this request, please contact us.

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 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 95-4933

REF: LR-N97109 LCR S95-19 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, Units 1 and 2, are true to the best of my knowledge, information and belief.

Subscribed and Swo~ b~fore me thiscf?/ si day of Jo~ 1997 ,

KIMBERLY JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission expires on ____M_vc_om_m_is_sio_n_Ex_pir_es_Ap_ri1_2_1._1s_s_a_ _

LR-N97109 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75

. DOCKET NOS. 50-272 AND 50-311 MODE APPLICABILITY OF THE POWER RANGE, NEUTRON FLUX REACTOR TRIP AND SURVEILLANCE REQUIREMENTS BASIS FOR REQUESTED CHANGE REQUESTED CHANGE AND PURPOSE The proposed Technical Specification (TS) changes contained herein represent changes to TS Table 3.3-1, "Reactor Trip System Instrumentation," Applicable Modes for the Power Range, Neutron Flux, and TS Table 4.3-1, "Reactor Trip System Instrumentation Surveillance Requirements." The proposed change will extend the applicability of the Power Range Neutron Flux TS trip to require operability and surveillance testing in Mode 3, when the reactor trip system breakers are in the closed position and the Control Rod Drive system is capable of rod withdrawal. The current TS require the Power Range Neutron Flux - low setpoint reactor trip be operable in Modes 1 and 2 only, and require the surveillance test be performed in Modes 1 and 2, only.

This change is being requested to ensure adequate protection against a rod withdrawal from subcritical event.

BACKGROUND On May 27, 1993, a failure in the rod control system at Salem Unit 2 caused a single rod to withdraw while the operator applied a rod insertion signal. As a result of this event the NRC issued Generic Letter (GL) 93-04, "Rod Control System Failure and Withdrawal of Rod Cluster Assemblies." In response to this event and the GL, PSE&G performed extensive reviews of the relevant accident analyses, the associated Technical Specifications and the procedures that implement the established design bases. During this review, the possibility of a rod withdrawal during Mode 3 that could cause an inadvertent criticality was id~ntifie~~ To address this concern, the start-up procedures were revised to require the Power Range Nuclear Instrumentation - low setpoint reactor trip be operable. This procedure revision has been implemented, and the PSE&G start-up procedures now require both an operable reactor trip for Power Range Neutron Flux trip - low setpoint, and compliance with the surveillance procedures.

JUSTIFICATION OF REQUESTED CHANGES When the rod control drive system is available for rod movement, the power range neutron flux is required to be operable. The accident analysis credits the power range neutron flux trip - low setpoint in mitigating the consequences of the Rod Withdrawal From Subcritical (RWFS) event. Therefore, the TS should require the trip be operable in Mode 3, when the control rods can be withdrawn. Accordingly, this TS change is being requested.

The Salem Updated Final Safety Analysis Report credits the power range neutron flux reactor trip - low setting for mitigation of the consequences of a RWFS event. In the Page 1of2 LR-N97109 analysis of the RWFS event, the reactor trip is assumed to be initiated by power range high neutrbn flux - low setting. The most adverse combination of instrument and setpoint settings, as well as trip signal actuation and RCCA release delays is taken into account. A 10-percent increase is assumed for the power range flux trip setpoint, raising it from the nominal value of 25 percent to the nominal value of 35 percent. In addition, the reactor trip insertion characteristic is based on the assumption that the highest worth RCCA is stuck in its fully withdrawn position. The results of the analysis demonstrate that established safety criteria are satisfied.

CONCLUSIONS The changes submitted by this request provide the means to ensure that the power range neutron trip is operational and in surveillance. The proposal does not change the design bases which are currently implemented by the performance of station procedures, but rather makes the TS consistent with the design bases.

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Page 2of2 LR-N97109 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 MODE APPLICABILITY OF THE POWER RANGE, NEUTRON FLUX REACTOR TRIP AND SURVEILLANCE REQUIREMENTS 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 TS Table 3.3-1 and Table 4.3-1 pertaining to operational and surveillance requirements for the Power Range, Neutron Flux reactor trip function. The proposed change will extend the current operational and surveillance requirements from Modes 1 and 2 to include Mode 3, when the reactor trip system breakers are closed, and the Control Rod Drive system is capable of rod withdrawal.

BASIS

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

The requirement for operability of a trip and the surveillance requirements to ensure the functionality of the trip are independent of the probability of an accident previously evaluated. The accident that this trip is intended to mitigate is the Rod Withdrawal from Subcriticality event. The surveillance procedure and the requirement for the trip to be operational when the Control Rod Drive System is capable of rod movement mitigate the consequences of this event, and do not increase the probability of a rod withdrawal from subcritical.

Therefore, the probability 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, do not introduce any new operating configurations or new modes of plant operation, or change the safety analyses. The proposed change is intended to ensure that the trip function is available and will perform as designed in the event of a previously evaluated event.

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

Page 1 of 2 LR-N97109

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

The proposed change does not reduce the margin of safety, because assurance of the operability of the trip function is increased by the proposed change.

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

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