ML18102B673

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Application for Amends to Licenses DPR-70 & DPR-75, Correcting Editorial & Administrative Errors in Ts,Which Existed Since Initial Issuance
ML18102B673
Person / Time
Site: Salem  PSEG icon.png
Issue date: 11/14/1997
From: Storz L
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102B674 List:
References
LCR-S97-08, LCR-S97-8, LR-N970150, NUDOCS 9711210120
Download: ML18102B673 (22)
v • d • e


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 Preside~i - NuCie_ar Operat.ions "l.W-rJ9~o~

LCR S97-08 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS ADMINISTRATIVE CHANGES AND EDITORIAL CORRECTIONS SALEM GENERATING STATION UNIT 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 administrative and editorial changes to the Salem Unit 1 and Unit 2 TS. PSE&G requests these changes to correct the editorial and administrative errors in the TS that have existed since the initial issuance of the TS or were introduced during previous changes to the TS. These changes to the TS include the editorial and administrative changes described in PSE&G's submittals of December 12, 1996 and May 14, 1997. An editorial change is a change to correct a typographical error. An administrative change includes corrections to the specifications beyond a typographical error which do not reduce the current TS requirements for any structure, system or component (SSC). The surveillance requirements added by these changes are also considered administrative changes since these changes were previously reviewed under previous TS Amendments and should have been incorporated within the TS as part of the approved Amendment.

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 bases for the requested changes are 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.

Upon NRC approval of the proposed changes, 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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Document Control Desk NOV 14 1997 LR-N970150 Should you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely, 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 P. 0. Box415 Trenton, NJ 08625

REF: LR-N970150 LCR S97-08 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.

  • I Subscribed and Sworn to before me this I Lf day of N6 ve libkY, 1997 JJ~a (/vfud Notary Public of New Jersey BARBARA A. POWELL NOTARY PUBLIC OF NEW JERSEY My Commission Expires Dec. 2, 1998 ID II 2160323 My Commission expires o n - - - - - - - - - - - - - -

Document Control Desk LR-N970150 Attachment 1 LCR S97-08 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 ADMINISTRATIVE AND EDITORIAL CORRECTIONS BASIS FOR REQUESTED CHANGE REQUESTED CHANGE AND PURPOSE The below listed changes are being proposed to correct editorial inconsistencies identified in the Salem Unit 1 and 2 Technical Specifications (TS) that have either existed since the initial issuance of the TS or have been introduced during previous changes to the TS. The proposed changes in items e through m and o through w stated below address the corrections to the TS that were described in letters LR-N96411, dated December 12, 1996, and letter LR-N970298, dated May 14, 1997. The proposed changes to the TS are identified below:

a. Revise the Unit 1 and Unit 2 indexes as identified in Attachment 3 to reflect current TS section titles and appropriate page numbers.
b. Revise the Unit 1 and Unit 2 TS 3/4.1.3.4 title from "Position Indication System Shutdown" to "Shutdown Rod Insertion Limit" and the title of TS 3/4.1.3.5 from "Position Indication System Shutdown" to "Control Rod Insertion Limits" .
  • c. For Unit 1 TS 3/4.9.8, insert the main title of "3/4.9.8 Residual Heat Removal and Coolant Circulation" and for TS 3/4.9.8.1 insert the subtitle of "All Water Levels", which will make the Unit 1 titles consistent the index and the Unit 2 TS.

For Unit 2 TS 3.4.9.8 revise the main title from "Residual Heat Removal Coolant Circulation" to "Residual Heat Removal and Coolant Circulation".

d. Revise the Unit 1 and Unit 2 Bases section 5.4.1 title from "Design Feature and Temperature" to "Design Pressure and Temperature".
e. Revise Unit 2 definition 1.7.1.b to correct the reference from "... Specification 3.6.3.1." to "... Specification 3.6.3." Also revise Unit 2 surveillance requirement 4.6.1.1.a last sentence from "... as permitted by Specification 3.6.3.1, ... " to "... as permitted by Specification 3.6.3, ... ".
f. Revise Unit 1 LCO 3.1.1.4 Action a.1 and Unit 2 LCO 3.1.1.3 Action a.1 last sentence from "... Specification 3.1.3.6." to "... Specification 3.1.3.5." Also revise Unit 2 Bases section 3/4.10.3 "Physics Tests" last sentence from" ... various control rods at heights which may not be allowed by Specification 3.1.3.6 which ... " to "various control rods at heights which may not be allowed by Specification 3.1.3.5 which ... ".
g. Revise Unit 1 and Unit 2 Surveillance Requirement 4.1.1.1.1.b from" .... verifying that control bank withdrawal is within the limits of Specification 3.1.3.5." to

"... verifying that control banks are within the limits of Specification 3.1.3.5."

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Document Control Desk LR-N970150 LCR S97-08

h. Revise Unit 1 and Unit 2 Table 2.2-1, Item 18 functional unit description from "Safety Injection Input from SSPS" to Safety Injection Input from ESF.
i. Revise Unit 1 and Unit 2 Table 4.3-1, item 20 mode applicability from "N.A." to mode 1. Also revise Unit 2 Table 4.3-1 items 18a and 18b mode applicability from "N.A." to modes 1 and 2.
j. Revise Unit 1 and Unit 2 Surveillance Requirement 4.3.3. 7 to add the performance of CHANNEL FUNCTIONAL TESTs to demonstrate the operability of certain accident monitoring instrumentation as described in TS Table 4.3-11.
k. Unit 1 and 2 TS Table 4.3-12, "#"footnote should be revised from "... constitutes a CHANNEL CHECK. .. " to "... constitutes a SOURCE CHECK".

I. Revise Unit 1 and 2 Surveillance Requirements Table 4.3-13 second column title from "CHANNELS OPERABLE" to "CHANNEL CHECK.

m. Revise Unit 1 Specification 3.4.8 and Unit 2 Specification 3.4.9, Action a, pertaining to Modes 1-5, from "... requirements of item 4a of Table 4.4-2 .... " to

"... requirements of item 4a of Table 4.4-4 ... ".

n. Revise Unit 1Specification3.4.10.1 LCO from "... in accordance with Specification 4.4.10. 1." to "... in accordance with Specification 4.4.10.1.1."
o. Revise Unit 2 Specification 3.4.11.1 LCO from "... in accordance with Specification 4.4.10.1" to "... in accordance with Specification 4.4.11.1."
p. Revise Unit 1 and Unit 2 LCO 3.5.5.a to include the units of gallons.
q. Revise Unit 2 surveillance requirement 4.6.1.1.c from "... pursuant to Specification 4.6.1.2d ... " to "... pursuant to Specification 4.6.1.2.b ... ". Also revise Unit 1 surveillance requirement 4.6.3.1.5 and Unit 2 surveillance requirement 4.6.3.5 from "... pursuant to Specification 4.6.1.2d ... " to "... pursuant to Specification 4.6.1.2.b ... ".
r. Revise Unit 1 and Unit 2 surveillance requirement 4.7.9.f from "... as required by Specification 6.10.2.1." to "... as required by Specification 6.10.2.m.".
s. Revise Action b of LCO 3.9.8.2, for Unit 1 and 2, from "The provisions of Specification 3.0.3 are to applicable." to "The provision of Specification 3.0.3 are not applicable."
t. Delete Unit 1 and Unit 2 TS Table 3.3-11 Action 5.
u. Revise Unit 1 and Unit 2 TS Table 4.3-11 Item 10 (Auxiliary Feedwater Flow Rate) channel check frequency from "SU#" to "S/U#".
v. Revise Unit 1 and Unit 2 LCO 3.6.1.6 from " ... with the acceptance criteria in Specification 4.6.1.6." to " ... with the acceptance criteria in Specification 4.6.1.6.1."

2

Document Control Desk LR-N970150 Attachment 1 LCR S97-08

  • w.

X.

Revise Unit 2 surveillance requirement 4.6.2.1.c.2 to delete the redundant "each".

Revise Unit 1 and Unit 2 Specification 3.5.3, Action b, from "Within no ECCS subsystem ... " to "With no ECCS subsystem ... ".

y. Revise Unit 2 LCO 3.6.1.2.b to delete reference to TS Table 3.6-1.
z. Revise Unit 1 and Unit 2 surveillance requirement 4.9.8.1.b from "... equal to 140 F." to " ... equal to 140°F."

aa. Revise Unit 1 and Unit 2 TS Table 4.11-2 table notation "a" from "... The LLD is defined in Table 4.11.1." to "The LLD is defined in Table 4.11-1."

bb. Revise Unit 1 and Unit 2 TS Table 4.3-11 Item 15 (Containment Pressure -

Narrow Range) channel calibration requirement from "NA" to "R".

CC. Revise Unit 1 and Unit 2 TS Table 3.3-6 Item 3.a, Control Room Air Intake -

Radiation Level, from one action statement containing the actions for having one or no channels operable to two separate action statement numbers. The first action statement number would apply to having one channel less than the minimum channels required and the second action statement number would apply to having no channels operable. For Unit 1, this would add an additional

  • dd.

action statement number 25 to item 3.a. For Unit 2, this would add an additional action statement number 28 to item 3. a.

Revise Unit 1 surveillance requirement 4.4.9.3.1.a to add the requirement to perform a channel functional test at least once every 31 days when the Pressurizer Overpressure Protection System (POPS) is required operable.

ee. Revise Unit 2 LCO 3.8.2.1 to add the"*" footnote after line items for the 2A, 28, and 2C vital instrument buses and inverters.

ff. Revise Unit 2 TS Table 3.3-1 description of permissive P-7 as identified in the attached page 3/4 3-7.

gg. Revise Unit 2 LCO 3.4.1.3 footnotes"*" and"**" to remove the extraneous periods identified in the attached mark-up pages.

hh. Change Unit 1 and Unit 2 TS Table 4.3-11 surveillance frequencies that are marked "NA" to the TS defined term of "N.A."

ii. Revise Unit 2 action statement associated with specification 2.2.1 from,

" ... requirement of Specification 3.3.1 until the channel. .. " to "... requirement of Specification 3.3.1.1 until the channel. .. ".

1 jj. Revise Unit 1 TS Table 2.2-1, note 1, to add the units of "Sec- " for the Laplace transform operator "S" .

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Document Control Desk LR-N970150 Attachment 1 LCR S97-08

  • kk.

II.

Revise Unit 1 Bases page B2-2 second paragraph, first sentence; from

" .... control rods FULLY WITHDRAWN the maximum allowable ... " to " .... control rods FULLY WITHDRAWN to the maximum allowable ... ".

Revise Unit 2 TS 3.0.4 to delete the word "shall" at the end of the first sentence.

mm. Revise Unit 1 LCO 3.1.2.6.a.2 reference from figure 3.1.2 to figure 3.1-2.

nn. Revise Unit 1 and Unit 2 action statement 3.1.3.1 c.2 and LCO 3.1.3.5 from referencing figure 3.1-2 to reference figure 3. 1-3. Renumber figure 3. 1-2 concerning control rod insertion limits for three loop operation to figure 3.1-3.

00. Revise Unit 1 surveillance requirement 4.2.1.4 to change the word "measumed" to "measured".

pp. Revise Unit 1 and Unit 2 specification 3.2.1, Action b, to revise the reference from action "2.a) 1 )"to "a.2.a) 1)".

qq. Revise Unit 1 and Unit 2 TS Table 4.3-1, third column heading from "CALIBRATION" to "CHANNEL CALIBRATION".

rr. Revise Unit 1 Table 3.3-3 Action 23 from "... HOT STANDBY within the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ... " to " ... HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ... " .

SS. Revise Unit 1 Table 4.3-2 Notation (2) to change " ... staggered basis." to

" ... STAGGERED TEST BASIS."

tt. Revise Unit 1 and Unit 2 surveillance requirement 4.3.3.1, Unit 1 surveillance requirement 4.4.6.1.a, and Unit 2 surveillance requirement 4.4.7.1.a to include the requirement of performing a "SOURCE CHECK".

LIU. Revise Unit 1 and Unit 2 TS Table 3.3-6 and Unit 1 TS Table 4.3-3 footnote"**"

to use the defined term of CORE ALTERATIONS.

vv. Revise Unit 2 TS Table 3.3-11 Item 7 to eliminate the extra"/" as indicated on the attached revised page 3/4 3-51.

WW. Revise Unit 1 TS Table 3.3-11 Action 4 to correct the reference from Table 3.3.11 to Table 3.3-11.

XX. Revise Unit 1 and Unit 2 surveillance requirement 4.3.4.3.b from "At least one per 40 months ... " to "At least once per 40 months ... ".

yy. Revise Unit 1 TS 3.4.1.4 footnote "t#f." from " ... 92% of level ... " to " ... 93.2% of level ... ".

ZZ. Revise Unit 1 surveillance requirement 4.4.5.3.a to add the word "degradation" after the word "additional" in the last sentence .

  • 4

Document Control Desk LR-N970150 Attachment 1 LCR S97-08 aaa. Renumber Unit 1 TS Table 4.4-4 concerning Reactor Coolant System Pressure Isolation Valves to TS Table 4.4-3. Also correct the references in specification 3/4.4.6.3 to reference the new table number.

bbb. In Unit 1 TS surveillance requirement 4.6.1.1.a.1, delete the extraneous period after reference to specification 3.6.3.1.

ccc. Revise Unit 2 TS surveillance requirement 4.6.1.1.a from, " ... except for valves that may be opened ... " to "... except for valves that are opened ... ".

ddd. Revise Unit 1 TS surveillance requirement 4.6.1.2 from "... shall be demonstrated at the follows: ... " to "... shall be demonstrated as follows: ... "

Also revise the word "convormance" to "conformance" in Unit 1 surveillance requirement 4.6.1.2.c.

eee. Revise Unit 1 surveillance requirement 4.6.2.2.a to delete the extraneous word "also" after "... at least 31 days ... ".

fff. Revise Unit 2 surveillance requirement 4.7.1.5 to correct the spelling of the word "Specificaiton" to "Specification" in the last sentence.

ggg. Correct Unit 1 LCO 3.8.2.3 concerning "Train 1C" to revise the word "charge" to "charger".

hhh. Revise Unit 2 surveillance requirement 4.8.2.5.2.b.2 to insert the word "and" after "1.200".

111. Revise Unit 1 and Unit 2 surveillance requirement 4.9.7 from "... at least one per 7 days ... " to "... at least once per 7 days ... ".

JJJ. Revise Unit 1 LCO 3.9.10 to delete the extraneous comma.

kkk. Revise Unit 1 LCO 3.10.1 to delete the word "and" at the end of the sentence.

Ill. Revise Unit 1 Bases 3/4.4.8 and Unit 2 Bases 3/4.4.9 second paragraph, first sentence, to include the word "occur" after "steam generator tube rupture".

mmm. Revise Unit 1 Bases 3/4.4.9 item 1) b) to correct the typographical error of "nondoctile" to "nonductile".

nnn. Revise Unit 2 Bases page B 3/4 4-12 last paragraph, first sentence, from "... RCS cold lets ... " to "... RCS cold legs ... ".

000. Revise Unit 1 Bases 3/4.7.9 third paragraph, third sentence, to change the word "not" to "new".

ppp. Revise Unit 1 specification 6.12.2 third sentence, to change the word "reasonable" to "reasonably" .

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Document Control Desk LR-N970150 Attachment 1 LCR S97-08

  • qqq. Revise Unit 1 and Unit 2 specification 3/4.7.10 to capitalize the defined terms in accordancewith TS 1.0.

JUSTIFICATION OF REQUESTED CHANGES The following information provides the justification for the proposed changes identified in the previous section.

a. The changes described in item a above are editorial changes to the Unit 1 and 2 indexes to revise the index to reflect the current TS section titles and page numbers. These errors have either existed since the issuance of the TS or have been introduced into the TS as a result of changes made to the TS.
b. The revision to the titles of specifications 3/4.1.3.4 and 3/4.1.3.5 are editorial changes to align the specification titles with the index and better reflect the actual subject of the specification.

C. The revision to the Unit 1 and Unit .2 specification 3/4.9.8 title and the Unit 1 specification 3/4.9.8.1 title are editorial changes .to align the specification titles with the index.

d. The revision to the Unit 1 and Unit 2 Bases section 5.4.1 title is an editorial change to align the Bases section title with the index.
e. In Unit 2 definition 1.7.1.b and surveillance requirement 4.6.1.1.c, pertaining to containment integrity, reference is made to specification 3.6.3.1, which does not exist. The correct reference should be specification 3.6.3 for containment isolation valves. This erroneous reference has existed since the initial TS were issued. This change is considered an administrative change that does not currently impact the ability to comply with the technical specifications.
f. Unit 1 LCO 3.1.1.4 and Unit 2 LCO 3.1.1.3 are the LCOs associated with the moderator temperature coefficient (MTC). Action a.1 of these LCOs and Unit 2 Bases section 3/4.10.3 refer to the Rod Insertion Limits contained in specification 3.1.3.6 which does not exist. The correct reference for the Rod Insertion Limits is specification 3.1.3.5. Specification 3.1.3.5 is the only specification that provides insertion limits. This erroneous reference has existed since the original issuance of the TS and specification 3.1.3.6 has never existed.

The change to specification 3.1.3.5 is considered an administrative change that does not currently impact the ability to comply with the technical specifications.

g. Surveillance Requirement 4.1.1.1.b states the control bank withdrawal is to be verified within the limits of specification 3.1.3.5; however, the terminology used in specification 3.1.3.5 is control bank insertion. Bank withdrawal and bank insertion are reciprocal terms that refer to bank position. The use of either term does not create a compliance concern to the limits specified. Revising the surveillance requirement to state that control banks are to be verified within the limits of specification 3.1.3.5 is an administrative enhancement to avoid the use of two different terms, with the same meaning, and does not affect technical requirements of the surveillance .

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Document Control Desk LR-N970150 Attachment 1 LCR S97-08

h. Revision of Unit 1 and Unit 2 TS Table 2.2-1, Item 18 function description for "Safety Injection Input from SSPS" to "Safety Injection from ESF" does not impact the performance of the equipment or affect the surveillance testing being performed to demonstrate the operability of this function. This change aligns the function description in Table 2.2-1 with the function description in Table 3.3-1, item 19 and the description of the reactor trip feature provided in Bases section 2.2.1. This discrepancy has .existed since the initial issuance of the TS. This change is considered an administrative change to the TS.
i. Revision to Unit 1 and Unit 2 TS Table 4.3-1, item 20, mode applicability from

. "N.A." (not applicable) to mode 1 is an administrative change to make the surveillance requirement mode applicability consistent with the mode applicability of the LCO. TS Table 3.3-1 item 20 has the applicable mode listed as mode 1. This change will provide additional assurance that a valid surveillance would be required to be performed prior to entry into Mode 1.

Current surveillance testing procedures and surveillance testing scheduling controls ensure that the Reactor Coolant Pump Breaker Position Trip (item 20) is tested prior to entry into mode 1. This change is an administrative change to the TS.

Revision to Unit 2 TS Table 4.3-1, Items 18a and 18b (pertaining to Turbine Trip) surveillance requirement mode applicability from "N.A." to modes 1 and 2 will make the Unit 2 table consistent with Unit 1 TS Table 4.3-1. TS Table 4.3-1 Items 18a and 18b currently have a requirement to perform a channel functional test prior to reactor startup. Reactor startup is defined in the TS as Mode 2.

Current surveillance testing procedures and surveillance testing controls ensure that the Turbine Trip functions specified in TS Table 4.3-1 Item 18 are tested prior to entry into Mode 2. Revising the surveillance requirement mode applicability is considered an administrative change to the TS to provide additional assurance that a valid surveillance test would be required to be performed prior to entry into Mode 2.

J. Channel functional tests are currently required for some of the accident monitoring channels included in Unit 1 and Unit 2 TS Table 4.3-11. Surveillance Requirement 4.3.3.7, however, does not specify that channel functional tests are to be performed. The wording of Surveillance Requirement 4.3.3. 7 is being revised to include the reference to CHANNEL FUNCTIONAL TEST for consistency and is considered an administrative change to the TS. Channel functional testing is performed as required by TS table 4.3-11 .

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Document Control Desk LR-N970150 Attachment 1 LCR S97-08

  • k. The"#" symbol is denoted in Unit 1 and Unit 2 TS table 4.3-12, Item 1.a, as applying to the source check of the liquid effluent monitor; however, the note's description refers to the note applying to the channel check. The note is applicable to the source check since the note addresses high background counts that may be present. The magnitude of most sources are not high enough to cause a distinguishable deflection needed for an acceptable test.

The channel check is accomplished by a reasonable inservice reading since there are no other channels to compare against. The current wording has not been changed by any amendments since the inclusion of the radioactive liquid effluent monitoring instrumentation in the Unit 1 and 2 TS under amendments 59 and 28, respectively. The error in the TS footnote is considered a typographical error. This change is considered an editorial change to the TS.

I. Revising the Unit 1 and Unit 2 TS Table 4.3-13 second column heading from "CHANNELS OPERABLE" to "CHANNEL CHECK" makes the column headings consistent with the surveillance requirements listed in TS 4.3.3.9. The information contained in this column in Table 4.3-13 are defined frequencies for completing surveillance test requirements. The required number of channels to be operable is defined in TS Table 3.3-13. This change is considered an administrative change to the TS.

m. Unit 1 LCO 3.4.8 and Unit 2 LCO 3.4.9 are the equivalent LCOs for the reactor coolant system specific activity. In Action a, pertaining to Modes 1-5, reference is made to TS Table 4.4-2. The action statement requires sampling and analysis to be performed on the reactor coolant in accordance with item 4a of Table 4.4-
2. TS Table 4.4-2 pertains to steam generator tube inspections and does not contain an item 4a. The correct table that should be referred to in this action is TS Table 4.4-4 titled, "Primary Coolant Specific Activity Sample and Analysis Program." TS Table 4.4-4 is also referred to in surveillance requirement 4.4.8 (Unit 1) and 4.4.9 (Unit 2) for verifying primary coolant specific activity. This change is considered an administrative change to the TS.
n. Unit 1 LCO 3.4.1 O refers to specification 4.4.10.1. The more specific reference for this LCO is specification 4.4.10.1.1. This is considered an administrative change to the TS.
0. Unit 2 LCO 3.4.11 refers to specification 4.4.10.1. Specification 4.4.10.1 does not exist in the Unit 2 TS and the inconsistency appears to have been a result of the adoption of the Standard Westinghouse Specifications, NUREG-0452 Rev.
2. Specification 3/4.4.11.1 is for the structural integrity for ASME code Class 1,
  • 2, and 3 components. NUREG-0452, Rev. 2, had identified this specification as 3/4.4.10.1. The reference to specification 4.4.10.1 in the Unit 2 TS was not corrected to reflect the change in specification number during the original issuance of the TS. The correct specification reference in LCO 3.4.11 is 4.4.11.1. This change is considered an editorial change to the TS .
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Document Control Desk LR-N970150 Attachment 1 LCR S97-08

  • p. The Unit 1 and Unit 2 LCO 3.5.5.a currently does not specify the units, gallons, for the contained volume limits. Most volume references are in gallons which is the correct volume unit for this specification as well. Refueling water storage tank volume calculations also provide the reference to gallons as the correct unit for this parameter. The change is considered an administrative change to the TS.
q. Type B and C leakrate testing requirements were revised in Amendments 184 and 166, for Unit 1 and Unit 2 respectively. These amendments renumbered surveillance requirement 4.6.1.2.d to 4.6.1.2.b. Unit 1 surveillance requirement 4.6.3.1.5 and Unit 2 surveillance requirements 4.6.1.1.c and 4.6.3.5 were not revised to reflect the change in numbering of surveillance requirement 4.6.1.2.d.

This change to ~he TS surveillance requirements is considered an administrative change to the TS.

r. The Unit 1 and Unit 2 surveillance requirement 4.7.9.f references the snubber service life monitoring records retention requirement as specification 6.10.2.1.

Specification 6.10.2.1 does not exist. The correct reference for snubber service life monitoring record retention requirement is specification 6.10.2.m. This reference has been incorrect since specification 4. 7.9.f was added to the Unit 1 TS and the since the initial. issuance of the Unit 2 TS. This change is .considered an editorial change to the TS.

S. Action b of LCO 3.9.8.2 states that the provisions of Specification 3.0.3 are "to"

  • applicable rather than "not" applicable. This error was introduced into the TS during Amendment 72 for Unit 1 and Amendment 46 for Unit 2. Prior to these amendments, the TS stated that the provisions of specification 3.0.3 are not applicable. This change is considered an editorial change to the TS.
t. Action 5 of TS Table 3.3-11 refers to alternate means of calculating the RCS subcooling margin. During Unit 1 Amendment 117 and Unit 2 Amendment 95, the action requirements for the subcooling margin monitor were revised from Action 5 to Actions 1 and 2. This change made under these amendments however did not delete the action description contained under action 5. Since no other parameter in TS Table 3.3-11 refers to Action 5, the description under action 5 should be deleted. This is considered an administrative change to the TS.
u. In Unit 1 and Unit 2 TS Table 4.3-11, Item 1O pertaining to Auxiliary Feedwater Flow Rate states that the channel check is "SU" rather than "S/U". The footnote associated with this channel check states that the Auxiliary Feedwater System is used on each startup and flow rate is verified at that time. The term "S/U" is the only defined term for the frequency of startup (see TS Table 1.2). This is an editorial change to the TS.
v. The Unit 1 and Unit 2 containment structural integrity LCO 3.6.1.6 refers to the acceptance criteria of Specification 4.6.1.6. The more specific reference for the actual acceptance criteria is Specification 4.6.1.6.1. This change is considered an administrative change to the TS .
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Document Control Desk LR-N970150 Attachment 1 LCR S97-08

w. In Unit 2 surveillance requirement 4.6.2.1.c.2 there is a redundant use of the word "each" when referring to the Containment Spray pump start test. The second "each" should be deleted. This is considered an editorial change to the TS.

X. Revising Unit 1 and Unit 2 Action b, for Specification 3.5.3, from Within no ECCS subsystem ... " to "With no ECCS subsystem .... ", corrects a typographical error that was introduced during Unit 1 Amendment 94 and Unit 2 Amendment 130. This change is considered an editorial change to the TS.

y. TS Table 3.6-1, which listed the containment isolation valves, was removed from the TS during Unit 1 Amendment 189 and Unit 2 Amendment 172. LCO 3.6.1.2.b was revised for Unit 1 during this amendment to reflect the removal of TS Table 3.6-1; however, the corresponding Unit 2 LCO 3.6.1.2.b was not revised. Revising Unit 2 LCO 3.6.1.2.b to delete the reference to TS Table 3.6-1 does not preclude compliance with the existing LCO and makes the Unit 2 LCO consistent with Unit 1. This change is considered an administrative change to the TS.
z. Revising Unit 1 and Unit 2 surveillance requirement 4.9.8.1.b to include the degree symbol is an editorial change to the TS.

aa. Unit 1 and Unit 2 TS Table 4.11-2 table notation a incorrectly references TS Table 4.11.1. There is not Table 4.11.1 in the TS. The lower limits of detection referred to in notation "a" of Table 4.11-2 are described in TS Table 4.11-1. This change is considered an editorial change to the TS.

bb. Unit 1 and Unit 2 TS Table 4.3-11 was revised in Amendments 79 and 53, respectively, to include the wide range containment pressure parameter. The changes made under these amendments were to incorporate the TS changes outlined in Generic Letter (GL) 83-37, "NUREG-0737 Technical Specifications."

GL 83-37 identified that the channel calibration frequency for containment pressure post accident monitoring instrumentation should be performed on a refueling interval. When PSE&G proposed the changes to TS Table 4.3-11, the containment pressure parameter was broken into two parts, narrow range and wide range. The containment pressure wide range channels were correctly identified to include a calibration frequency of every refueling; however, the containment pressure narrow range channels were identified that the channel calibration was "not applicable." This error is believed to be a typographical error in the original license change request since PSE&G did not take exception to the calibration frequency requirements for containment pressure proposed in GL 83-37. Channel calibrations of the containment pressure narrow range channels have been and are currently being performed on a refueling interval although the TS Table 4.3-11 indicates the requirement to perform the channel calibration is "not applicable." Revising the channel calibration frequency requirement from "not applicable" to performance on a refueling interval is considered an administrative change to the TS .

  • 10

Document Control Desk LR-N970150 Attachment 1 LCR S97-08

  • cc. TS Table 3.3-6 Item 3.a was added during Amendments 190 and 173 to the Unit 1 and Unit 2 TS, respectively. This LCO was added to provide the necessary action requirements for the radiation monitoring instrumentation used to initiate the emergency features of the Control Room Emergency Air Conditioning System (CREACS). The change to the Unit 1 and Unit 2 TS added a single action statement number to address the following two conditions: 1) having the number of operable radiation monitor channels one less than the minimum number required, and 2) having no radiation monitor channels in the Control Room intake operable. To avoid confusion in regards to the reason that the single action statement was entered, PSE&G proposes to separate the currently combined actions into two separate action statement numbers. The addition of the second action statement number is not changing the current requirement of the action statements but will assist the Operating shift in allowing them to better track the actual condition (one or no channels operable) that caused entry into the action statement. Unit 1 TS Table 3.3-6 action 24 will be separated into action 24 for having one channel less than minimum channels required and action 25 for having no channels inoperable. Unit 2 TS Table 3.3-6 action 27 will be separated into action 27 for having one channel less than minimum channels required and action 28 for having no channels operable. The change is considered an administrative change to the TS.

dd. On June 29, 1978, and clarified by a subsequent submittal on September 27, 1979, PSE&G proposed changes to Unit 1 specification 3/4.9.3 for Pressurizer Overpressure Protections Systems (POPS) to be consistent with the Unit 2 TS and the Standard Technical Specifications. In the September 27, 1979 submittal, surveillance requirement 4.4.9.3.1.a was proposed to be revised as follows:

"Performance of a CHANNEL FUNCTIONAL TEST on the POPS actuation channel, but excluding valve operation, within 31 days prior to entering a condition in which the POPS is required OPERABLE and at least once per 31 days thereafter when the POPS is required OPERABLE."

The changes to specification 3/4.4.9.3 were approved by the NRC in Amendment 24 to the Unit 1 TS. However, the revised TS pages provided by the NRC for surveillance requirement 4.4.9.3.1.a did not contain the requirement to perform the channel functional test of POPS every 31 days when POPS was required to be operable. The safety evaluation report (SER) for Amendment 24 (page 9) states that :

  • the Unit 1 TS for POPS are the identical wording of the Salem Unit 2 TS, and
  • The POPS must be tested on a periodic basis consistent with the need for its use.

The Unit 2 TS contains the additional requirement to perform the channel function test when POPS is required to be operable and has not been revised since issuance of the Unit 2 TS. Based on the statements from the SER for Amendment 24, the NRC approved the change to the Unit 1 specification based 11

Document Control Desk LR-N970150 LCR S97-08 on the periodic performance of the channel functional test when POPS is required to be operable.

The missing requirement to perform the channel functional test every 31 days when POPS is required to be operable is attributed to an editorial oversight when the revised TS pages were issued with Amendment 24.

PSE&G has been and is currently performing the channel functional test every 31 days when POPS is operable. Revising Unit 1 surveillance requirement 4.4.9.3.a to include the requirement to perform the channel functional test every 31 days when POPS is required to be operable is considered an administrative change to the TS.

ee. Unit 2 LCO 3.8.2.1 contains a "*" footnote that applies to disconnecting the DC power source of an inverter for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the purpose of performing an equalizing charge on the associated battery bank. This footnote was incorporated into the original issuance of the Unit 2 TS but due to an editorial error was not placed after the LCO listings for the 2A, 28, and 2C 115 volt vital instrument buses and inverters. The placement of the "*" footnote after these entries in the LCO is consistent with Revision 4 of the Westinghouse Standard Technical Specifications and an editorial enhancement to LCO 3.8.2.1. This change is considered an editorial change to the TS.

ff. During the issuance of Amendment 113 for Salem Unit 2, an editorial error was introduced to the description of the P-7 permissive listed in Table 3.3-1. Prior to Amendment 113, the description contained in the column titled, "Condition and Setpoint," was as follows:

"With 2 of 4 Power Range Neutron Flux Channels~ 11 % .... "

Although the description of permissive P-7 was not revised in Amendment 113, when the revised TS pages were issued, the word "flux" in the above description was inadvertently moved to the end of the next column in the table. This proposed change corrects the editorial error introduced during Amendment 113.

gg. The changes to the footnotes associated with Unit 2 LCO 3.4.1.3 remove the extraneous periods and are considered an editorial correction that does not impact the compliance with the LCO.

hh. The proposed changes identified in the section above are editorial changes to use the correct notation for surveillance requirements that are "not applicable" as defined in TS Table 1.2. TS Table 1.2 defines the correct notation for a surveillance requirement that is "not applicable" as "N.A.".

ii. During Unit 2 Amendment 113, the number for TS 3.3.1 was revised to TS 3.3.1.1; however, the reference to TS 3.3.1 in specification 2.2.1 was not revised to reflect this change. This change is considered an editorial change to the TS.

12

Document Control Desk LR-N970150 Attachment 1 LCR S97-08

  • jj. The unit of measurement for Laplace transform operator, "S", in the Unit 1 overtemperature delta temperature (OTAT) equation were never listed in TS Table 2.2-1 note 1 since the original issuance of the Unit 1 TS. The unit for the Laplace transform operator, "S", is Sec-1 . This unit of measurement is consistent with the unit listed for the Unit 1 overpower delta temperature (OPAT) Laplace transform operator on page 2-8 and is also consistent with the units listed in Unit 2 TS Table 2-2-1 for OTAT and OPAT. This change is considered an editorial change to the TS.

kk. During Unit 1 Amendment 91, PSE&G requested a change to Bases Page 2-2 to capitalize the term "fully withdrawn" due to the proposed change in the definition of fully withdrawn in this amendment. However, the corrected pages included with the "Request for Amendment," dated January 3, 1989, inadvertently deleted the word "to" following "fully withdrawn" in the second paragraph. The proposed change is to re-insert the word "to" following "FULLY WITHDRAWN". This change is considered an editorial change to the TS.

II. During Unit 2 Amendment 110, PSE&G requested changes to specification 3.0.4. During the generation of the revised TS pages included with Amendment 110, the word "shall" was inadvertently added to the end of the first sentence of specification 3.0.4 contrary to the mark-up pages contained with PSE&G's "Request for Amendment," dated February 20, 1991. The addition of the word "shall" to this sentence does not affect the content or use of TS 3.0.4. PSE&G proposes to correct this first sentence in TS 3.0.4 to delete the word "shall" to be consistent with the original "Request for Amendment," and the wording of TS 3.0.4 contained in the Unit 1 TS. This change is considered an editorial change to the TS.

mm. Unit 1 LCO 3.1.2.6.a.2 references figure 3.1.2 for boi"ic acid storage tank boron concentration. The correct reference is figure 3.1-2. This was an editorial error that was introduced during Amendment 169 to the Unit 1 TS. This change 'is considered an editorial change to the TS.

nn. Unit 1 and Unit 2 Action statement 3.1.3.1.c.2 and LCO 3, 1.3.5 refer to figures 3.1-1 and 3.1-2 for control rod insertion limits. Figure 3.1-1 provides the control rod insertion limits for four loop operation. However, there currently exists two figures with the reference of 3. 1-2. The first figure 3.1-2 contains the graph for the Boric Acid Contents. The second figure 3.1-2 contains the title of "Rod Bank Insertion Limits versus Thermal Power for Three Loop Operation," but was intentionally left blank. Figure 3.1-2 for Boric Acid Contents was added to the Unit 1 and Unit 2 TS during Amendments 145 and 133, respectively. During the proposal of these amendments, the existing figure 3.1-2 for control rod insertion for three loop operation was not revised. The proposed change is to revise the current figure 3.1-2 for control rod insertion limits for three loop operation to figure 3.1-3 and to revise Action statement 3.1.3.1.c.2 and LCO 3.1.3.5 to reference figure 3.1-3. This change is considered an administrative change to the TS.

13

Document Control Desk LR-N970150 LCR S97-08

00. The change to Unit 1 surveillance requirement 4.2.1.4 corrects a typographical error with the word "measumed". This word should be changed to "measured".

This change is considered an editorial change to the TS.

pp. Revising Unit 1 and Unit 2 specification 3.2.1, Action b, reference from Action "2.a) 1)" to "a.2.a) 1)" incorporates a more specific reference to the correct action statement. For specification 3.2.1, the only action "2.a) 1)"that exists is contained under Action a. This change is considered an administrative change to the TS.

qq. Revising Unit 1 and Unit 2 TS Table 4.3-1 third column heading from "CALIBRATION" to "CHANNEL CALIBRATION" makes the title consistent with surveillance requirement 4.3.1.1.1 titles. The missing word "CHANNEL" in the title does not impact the ability to comply with the surveillance requirements.

This change is considered an editorial change to the TS.

rr. During Amendment 138 to the Salem Unit 1 TS, Action 23 was added to TS Table 3.3-3. The mark-up pages provided in the "Request for Amendment" dated August 14, 1992, did not include the word "the" in the statement "... be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ... ". However, when revised TS pages were included in Amendment 138, an additional "the" was inserted before "6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />".

Removing the "the" from Action 23 is considered an editorial change to the TS.

SS. This change to Unit 1 TS Table 4.3-2 revises Notation (2) to use the defined term for staggered testing as identified in TS 1.32. This change also makes Unit 1 consistent with the Unit 2 TS (which uses the defined term). This change is considered an editorial change to the TS.

tt. Unit 1 surveillance requirement 4.4.6.1, Unit 2 surveillance requirement 4.4. 7.1, and Unit 1 and Unit 2 surveillance requirement 4.3.3.1 refer to Table 4.3-3 for the performance of the necessary surveillances for the radiation monitors.

SOURCE CHECKS are currently required to be performed on radiation monitors in accordance with TS Table 4.3-3. The above listed surveillance requirements are being revised for consistency to add the reference to the performance of SOURCE CHECKS. This change is considered an administrative change the TS.

uu. Revising the"**" footnote in Unit 1 and Unit 2 TS Table 3.3-6 and Unit 1 TS Table 4.3-2 to use the defined term for CORE ALTERATIONS corrects an editorial error. This footnote was added during Amendments 190 and 173 for Unit 1 and Unit 2, respectively, and should have capitalized this term consistent with TS definition 1.9. This change is considered an editorial change to the TS.

vv. Deleting the extra"/" in Unit 2 TS Table 3.3-11 item 7 is an editorial correction that makes item 7 consistent with the other items in the table. This change does not affect the compliance with the LCO.

WW. This change corrects a typographical error in TS Table 3.3-11 Action 4. TS Table 3.3.11 does not exist and the correct reference should be to TS Table 3.3-

11. This is considered an editorial change to the TS.

14

Document Control Desk LR-N970150 Attachment 1 LCR S97-08

Although the current surveillance requirement states, "At least one per 40 months ... ", this surveillance requirement is actually referring to a frequency of, "At least once per 40 months ... ". This change is considered an editorial change to the TS.

yy. This proposed change is an administrative change to correct footnote"##" to reference the value of "93.2%" of level" which was incorporated into this footnote during Unit 1 Amendment 34. During Amendment 72, Unit 1 TS 3.4.1.4 footnote

"##"was inadvertently changed from "... (equivalent to approximately 93.2% of level) ... " to "... (equivalent to approximately 92% of level) ... ". This footnote was not part of the changes proposed to the TS during Amendment 72. However the footnote was inadvertently changed when the revised pages for Amendment 72 were generated. This change is considered an administrative change to the TS.

zz. During Unit 1 Amendment 118, which made changes to surveillance requirements 4.4.5.2.c and 4.4.5.3.b, the word "degradation" was inadvertently deleted after the word "additional" in surveillance requirement 4.4.5.3.a.

Surveillance requirement 4.4.5.3.a was not changed during Unit 1 Amendment 118. Adding the word "degradation" to surveillance requirement 4.4.5.3.a is considered an administrative change to the TS.

aaa. There exist two separate Unit TS Tables 4.4-4. The first TS Table 4.4-4 is a listing of the Reactor Coolant System Pressure Isolation Valves. This TS Table 4.4-4 is referenced in specification 3/4.4.6.3. The second TS Table 4.4-4 is for the primary coolant specific activity sample and analysis program. This TS Table 4.4-4 is referenced in specification 3/4.4.8. This change proposes to renumber TS Table 4.4-4 concerning the Pressure Isolation Valves to TS Table 4.4-3 and correct the references in specification 3/4.4.6.3 to reflect this new number. This change is considered an administrative change to the TS.

bbb. This proposed change is deleting an extraneous "period" contained in surveillance requirement 4.6.1.1.a.1 and does not affect the compliance with the requirements of the surveillance. This change is considered an editorial change to the TS.

ccc. Unit 2 TS surveillance requirement 4.6.1.1.a was revised by Amendment 172.

The proposed changes to this surveillance requirement submitted to the NRC in "Request for Amendment" dated September 25, 1996, proposed to add the words, "... except for valves that are opened under administrative control. .. ".

However, due to an editorial oversight, the revised page for surveillance requirement 4.6.1.1.a contained the words, "... except for valves that may be opened under administrative controls ... ". This proposed change corrects the wording of the surveillance requirement 4.6.1.1.a to agree with the wording proposed in the September 25, 1996, "Request for Amendment." This change is considered an administrative change to the TS.

15

Document Control Desk LR-N970150 Attachment 1 LCR S97-08 ddd. Unit 1 surveillance requirement 4.6.1.2 was inadvertently changed during Amendment 189 from " ... shall be demonstrated as follows: ... " to " .. shall be demonstrated at the follows: ... ". LCO 3.6.1.2.b was the only change to this page proposed under Amendment 189. This change to correct the wording of surveillance requirement 4.6.1.2 is considered an editorial change to the TS.

Also correction of the typographical error in the word "convormance" to "conformance" in Unit 1 surveillance requirement 4.6.1.2.c is also considered an editorial change to the TS.

eee. The word "also" after "... once per 31 days ... " is an extraneous word in Unit 1 surveillance requirement 4.6.2.2.a. Deleting the word "also" will make surveillance requirement 4.6.2.2.a read consistent with the other surveillance requirements throughout the Unit 1 TS. This change is considered an editorial change to the TS.

fff. Correction of the typographical error of the word "Specificaiton" to "Specification" in Unit 2 surveillance requirement 4.7.1.5 is considered an editorial change to the TS.

ggg. Correction of the typographical error of the word "charge" to "charger" in LCO 3.8.2.3 is c9nsidered an editorial change to the TS.

hhh. During Unit 2 Amendment 92, surveillance requirement 4.8.2.5.b.2 was inadvertently changed to delete the word "and" after the value of "1.200".

Amendment 92 only revised surveillance requirement 4.8.2.5.d on this same page; however, surveillance requirement 4.8.2.5.b.2 was not revised as a result of Amendment 92. This change is considered an administrative change to re-insert the word "and" in surveillance requirement 4.8.2.5.b.2.

iii. Revising the word "one" to "once" in Unit 1 and Unit 2 surveillance requirement 4.9.7 corrects a typographical error. This change is considered an editorial change to the TS.

jjj. Revising Unit 1 LCO 3.9.10 to delete the extraneous comma is considered an editorial change to the TS. Removing the comma does not change the requirements of the LCO. This change is considered an editorial change to the TS.

kkk. During Unit 1 Amendment 16, LCO 3.10.1 was revised to eliminate the LCO associated with part length rods. However, this change inadvertently left the word "and" at the end of the LCO. The word "and" at the end of the LCO would imply that another requirement exists in the LCO, but this requirement was deleted during Amendment 16. Deleting the word "and" from LCO 3.10.1 is considered an administrative change to the TS.

16

Document Control Desk LR-N970150 LCR S97-08 Ill. Revising the first sentence of the second paragraph of the Unit 1 Bases section 3/4.4.8 and Unit 2 Bases section 3/4.4.9 to include the word "occur" after "steam generator tube rupture" corrects an editorial error to this Bases section. This change is considered an administrative change to the TS.

mmm. Revising Unit 1 Bases 3/4.4.9 to change the word "nondoctile" to "nonductile" in Item 1) b) corrects a typographical error. This change is considered an editorial change to the TS.

nnn. Revising Unit 2 Bases page B 3/4 4-12 last paragraph, first sentence, from

"... RCS cold lets ... " to "... RCS cold legs ... " corrects a typographical error. This change is considered an editorial change to the TS.

ooo. Revising Unit 1 Bases section 3/4.7.9 to change the word "now to "new in the third paragraph, corrects a typographical error. This change is considered an editorial change to the TS.

ppp. Revising Unit 1 Section 6.12.2 to change the word "reasonable" to "reasonably" corrects a typographical error. This change is considered an editorial change to the TS.

qqq. The proposed changes to Unit 1 and Unit 2 TS 3/4.7.10 capitalize the defined terms contained in this specification in accordance with definition section 1.0.

This specification was added during Amendment 199 for Unit 1 and Amendment 182 for Unit 2. The proposed pages for the addition of specification 3/4. 7 .10 did not capitalize each defined term in the specification due to an administrative error. This change to capitalize the defined terms is considered an editorial change to the TS.

CONCLUSIONS Based on the above discussions and the no significant hazards consideration determination presented in Attachment 2, PSE&G has determined that the proposed changes do not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard and are therefore acceptable.

17

Document Control Desk LR-N970150 LCR S97-08 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 ADMINISTRATIVE AND EDITORIAL CORRECTIONS 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 10CFRS0.92 is provided below.

REQUESTED CHANGE The proposed changes to the Unit 1 and Unit 2 Technical Specifications (TS) are described in detail in Attachment 1. These changes are being made to correct editorial inconsistencies in the TS that resulted from previous TS changes or have existed from the initial issuance of the TS. These proposed changes also include the editorial and administrative changes described in PSE&G's submittals of December 12, 1996, and May 14, 1997.

BASIS

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

The proposed changes to the TS are administrative or editorial changes to the TS and do not involve any physical changes to the plant. The administrative changes and editorial changes do not delete any existing surveillance requirements or delete any requirements from the Limiting Condition for Operations (LCOs) or Action Statements and therefore do not reduce the actions that are currently taken in the TS to demonstrate operability of plant structures, systems, or components (SSCs). The additional surveillance requirements that are being added to the TS including the new surveillances correct past administrative errors and should have been incorporated within the TS as part of the approved Amendments to the TS. These changes will provide additional assurance that SSCs perform their intended safety functions. Surveillance testing has been and is currently being performed for the surveillance _

requirements that should have been incorporated and are now administratively being added to the TS. Since these changes do not modify any SSCs or reduce the current requirements for demonstrating operability of these SSCs, the proposed changes to the TS do not involve a significant increase in the probability or consequences of an accident previously evaluated.

  • 1

Document Control Desk LR-N970150 Attachment 2 LCR S97-08

  • 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 to the TS are administrative and editorial corrections to the TS that do not affect the ability of the plant systems to meet their current TS requirements or design basis functions. There is no reduction in the current surveillance requirements required to demonstrate the operability of plant SSCs.

These changes also do not involve any physical changes to plant SSCs.

Therefore 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 proposed changes are administrative and editorial corrections to the TS that do not affect the ability of plant SSCs to perform their design basis accident functions. There is no reduction in the current surveillance requirements required to demonstrate the operability of plant SSCs. Therefore, 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.

2

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