ML18106A427

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Application for Amend to License DPR-70,changing Applicability Statement from Mode 3 to Modes 1 & 2
ML18106A427
Person / Time
Site: Salem PSEG icon.png
Issue date: 03/26/1998
From: Storz L
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18106A428 List:
References
RTR-NUREG-1431 LCR-S97-24, LR-N980125, NUDOCS 9804070141
Download: ML18106A427 (7)
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 President - Nuclear Operations LR-N980125 LCR S97-24 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS REACTIVITY CONTROL SYSTEMS - ROD DROP TIME SALEM GENERATING STATION NO 1 FACILITY OPERATING LICENSE DPR-70 DOCKET NOS. 50-272 Gentlemen:

In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company requests a revision to the Technical Specifications (TS) for 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.

The proposed TS changes contained herein represent changes to Technical Specification Limiting Condition for Operations 3.1.3.3 "Rod Drop Time." The proposed change involves a change to the APPLICABILITY Statement from Mode 3 to Modes 1 and 2. The proposed will: 1) Bring consistency with the Salem Unit 2 Technical Specification, 2) Bring consistency with the NUREG 1431 Vol 1, Rev 1 "Standard Technical Specifications Westinghouse Plants," and 3) Implement a corrective action committed in Licensee Event Report (LER) 272/96-005-10.

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.

9804070141 980326 PDR ADOCK 05000272 p POR II\. Printed on

~ Recycled Paper

Document Control Desk

  • MAR 281998 LR-N980125 Upon NRC approval of this proposed'change, PSE&G requests that the amendment be made effective on the date of issuance, and provide for an implementation of sixty days.

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. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris (X24)

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

) 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, Unit 1, are true to the best of my knowledge, information and belief.

Subscr!bed and Sw~me this c??u day of ~. 1998 l<IMBEALV JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission expires on ____M_~_tll_m1_nls_slo_n_Ex_pir_es_A_pri_12_1._1_ss_s_ _

Do.cument Control

,sk

  • LR-N980125 LCR S97-24 I. REQUESTED CHANGE AND PURPOSE The proposed Technical Specification (TS) changes contained herein represent a change to Technical Specification Limiting Condition for Operation 3.1.3.3 "Rod Drop Time." The Technical Specifications are changed as follows:

The Limiting Condition for Operation (LCO) applicability statement is changed from:

APPLICABILITY: MODE 3.,

to APPLICABILITY: MODES 1 & 2.

The purpose of the proposed change is to provide for consistency: 1) Between the Salem Units, 2) With NUREG 1431 Vol 1, Rev 1 "Standard Technical Specifications Westinghouse Plants," and 3) Implement a corrective action committed in Licensee Event Report (LER) 272/96-005-10. Specifically, LER 272/96-005-10 committed to a license change request (LCR) to change the unit 1 Technical Specification Mode applicability to Modes 1 and 2. In addition, the proposed change will bring consistency within the Salem Unit 1 Limiting Condition for Operation (LCO) 3.1.3.3 and its surveillance requirement.

II. JUSTIFICATION OF REQUESTED CHANGES BACKGROUND On July 7, 1997, a Technical Specification Surveillance Improvement Project (TSSIP) review determined that prior to 1991 Technical Specification (TS) 3.1.3.3 (applicable in Mode 3), for Unit 1 was not complied with. Technical Specification Surveillance 4.1.3.3 was not performed prior to entry into Mode 3 (Tave greater than 350 deg. F). In 1991 an Amendment to the Salem Technical Specification (TS) modified the T.S. to allow entry into an Operational Mode that requires the system or component to be operable by relying on the LCO action statement provided the action statement did not contain a shutd_own requirement. Although continued operation under TS 3.0.4 would be acceptable from a regulatory point of view, PSE&G would like to amend the T.S. to bring the consistency described above, and remove any ambiguity from the requirements.

JUSTIFICATION LCO 3.1.3.3 requires that the full length control rods achieve a minimum rod drop time of::::; 2.7 seconds (from fully withdrawn) from begining of decay of stationary gripper coil voltage to dashpot entry given a set of specific initial conditions. The initial conditions Page 1 of 2

Document Control Desk

  • LR-N980125 LCR 597-24 specified for the rod drop test in TS 3.1.3.3 are that 1) the average temperature of the reactor coolant system be greater than 541 deg. F, and 2) all reactor coolant pumps be in operation. These requirements, and specifically the temperature requirement, cannot be attained prior to Mode 3. Mode 3 is a defined term in the Technical Specifications, and one of the variables used to define Mode 3 is the average temperature of the Reactor Coolant System being greater than 350 deg F. Therefore, the initial conditions imposed by the Technical Specifications LCO cannot be achieved without entering Mode 3, inconsistent with the Applicability statement.

This inconsistency is further exposed by LCO 3.1.3.3 surveillance requirement 4.1.3.3.

T.S. surveillance 4.1.3.3 states "The rod drop time of full length rods shall be demonstrated through measurement prior to reactor criticality:" This statement clearly states that Mode 2 (reactor criticality) is when the rod drop time surveillance needs to be completed. The basis for having the rod drop time test performed with all reactor coolant pumps in operations and the average temperature of the reactor coolant system at :::: 541 deg F is consistent with the assumptions made in the accident analysis. Specifically, that the measured rod drop times will be representative of the insertion time expected during a reactor trip from normal operating conditions.

As stated above, the proposed change will bring consistency within the Unit 1 LCO and its surveillance requirement, as well as bringing consistency between Salem 1 and 2 Technical Specifications. Although, the current Unit 1 Technical Specification allows entry into the Mode 3, in accordance with the ACTION requirements, it is PSE&G's intention to provide accurate and consistent Technical Specifications to its personnel.

Page 2 of 2

Document Control Desk Attachment 2

  • LR-N980125 LCR S97-24 SALEM GENERATING STATION UNIT NO. 1 FACILITY OPERATING LICENSE DPR-70 DOCKET NO. 50-272 CHANGE TO TECHNICAL SPECIFICATIONS MOVABLE CONTROL ASSEMBLIES AND POSITION INDICATION SYSTEMS 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Salem Generating Station Unit No. 1 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 a change to Technical Specification Limiting Condition for Operation 3.1.3.3 "Rod Drop Time." The Technical Specifications are changed as follows:

The Limiting Condition for Operation (LCO) applicability statement is changed from:

APPLICABILITY: MODE 3.,

to APPLICABILITY: MODES 1 & 2.

The purpose of the proposed change is to provide for consistency: 1) Between the Salem Units, 2) With NUREG 1431 Vol 1, Rev 1 "Standard Technical Specifications Westinghouse Plants," and 3) Implement a corrective action committed in Licensee Event Report (LER) 272/96-005-10. Specifically, LER 272/96-005-1 O committed to a license change request (LCR) to change the unit 1 Technical Specification Mode applicability to Modes 1 and 2. In addition, the proposed change will bring consistency within the Salem Unit 1 Limiting Condition for Operation (LCO) 3.1.3.3 itself.

BASIS

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

The proposed change to the Technical Specification Mode applicability provides consistency between the testing requirements as stated in the surveillance requirement of the Technical Sepcifications and intended by the initial conditions specified in the limiting condition for operations. The proposed change does not introduce any physical changes to the plant or equipment already in place in the plant, the proposed change ensures that testing of the rod drop times is performed in a manner that is Page 1 of 2

, D~cument Attachment 2 Control , s k

  • LR-N980125 LCR 597-24 consistent with the Technical Specifications and the assumptions made in the Salem accident analysis.

Therefore, the proposed amendment does not increase the probability or consequences of any 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 does not introduce a new component or changes the manner in which the facility is operated, maintained or tested. Thus no new accident scenarios, failure mechanisms or limiting single failures are introduced as a result of the proposed change to the facility.

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

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

As stated in question number 2 above, the proposed change does not introduce a new component or changes the manner in which the facility is operated. Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in the margin of safety. The Technical Specifications remain the same, as the input, or initial conditions, of the safety analysis have not changed. Therefore, there is no reduction in the margin to 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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