ML18106A835
| ML18106A835 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/12/1998 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18106A836 | List: |
| References | |
| LCR-S98-03, LCR-S98-3, LR-N980350, NUDOCS 9808270127 | |
| Download: ML18106A835 (11) | |
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 AUG 12 1998 LR-N980350 LCR S98-03 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlehlen:
REQUEST FOR AMENDMENT CONTAINMENT AIRLOCKS, SALEM GENERA TING STATION UNIT NOS. 1 & 2 DOCKET NOS. 50-272 AND 50-311 In accordance with the requirements of 10CFR50.90, Public Service Electric & Gas Company (PSE&G) hereby transmits a request for amendment to Facility Operating
. Licenses DPR-70 and DPR-75 for Salem Generating Station, Unit Nos. 1 & 2 respectively. Pursuant to the requirements of 10CFR50.91(b)(1), a copy of this request has been sent to the State of New Jersey .
. The proposed amendment modifies the Technical Specification for Containment Air Locks for Salem Units 1 and 2. The Salem 1 Technical Specification will be modified to allow continued operation with an inoperable air lock door provided that the operable door is closed and locked. This is currently allowed by the Salem Unit 2 Technical .
Specifications. The change will also provide requirements for an inoperable Containment Airlock interlock mechanism. For Salem Unit 2, the modification will make the requirements for an inoperable air lock door consistent with those of Salem Unit 1; and will provide requirements for an inqperable Containment Airlock interlock mechanism. This change will also correct an editorial error in the Salem Unit 2 /((
Technical Specification Bases 3/4.6.1.2, Containment Leakage.
The proposed changes are consistent with NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 1, dated April 1995. The changes have been evaluated in accordance with 10CFR50.91 (a)(1 ), using the criteria in ftfO J 10CFR50.92(c), and it has been determined that this request involves no significant /V hazards considerations.
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Document* Control DeskAUG 1 2 1998 LR-N980350 A description of the requested amendment, the reason for the changes and the justification for the changes are provided as Attachment 1. The basis for a no significant hazard consideration determination is provided in Attachment 2. The Technical Specification pages affected by the proposed changes are provided in Attachment 3.
PSE&G requests an implementation period of 60 days after amendment approval.
Should you have any questions regarding this request, please contact Brooke Knieriem, Salem Licensing, at (609) 339-1782.
Sincerely,
/rbk 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 Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-493~
Dm;;ument Control Desk LR-N980350 AUG12 1998 BC Senior Vice President - Nuclear Engineering (Nl9)
General Manager - Salem Operations (S05)
Director - QA/Nuclear Training/Emergency Planning (N120)
Director - Licensing & Regulation and Fuels (N21)
Manager - Business Planning & Co-Owners Affairs (N18)
Manager - Salem Operations (S01)
Manager - System Engineering - Salem (S02)
Project manager - NRB (N38)
J. Keenan, Esq. (X09)
Records Management (N21)
Microfilm Copy Files No. 1.2.1 (Salem), 2.3 (LCR S98-03), and 5.93
REF: LR-N980350 LCR S98-03 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 for the Public Service Electric & Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem Generating Station, Units Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscribed and Sworn to before me thi~ll~:-dayof~ 1998
- **. *~~?L("~c;,.,,
.,f.2!LL .~:i* ,j}__ ttrlz:e/JA.
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.'Notary P*u61i~1dfNew Jersey
.. DELORIS D. HADDEN N~tarv Public of New J_ersey MY eommission Expire&
03.29.2000 My Commission expires o n - - - - - - - - - - - - - -
Doct1ment Control Des8 LR-N980350 ATTACHMENT 1 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS I. DESCRIPTION OF THE PROPOSED CHANGES This proposed change modifies Technical Specification 3.6.1.3, Containment Systems, Containment Air Locks, for Salem Unit 1 and Unit 2. The change will replace the Technical Specification Action with the requirements contained in Insert 1 of Attachment 3. The change will also replace the Technical Specification Bases with the revised bases contained in Insert 2 of Attachment 3.
Additionally, the proposed change corrects an editorial error in Salem Unit 2 Technical Specification Bases 3/4.6.1.2, Containment Leakage, that occurred during the issuance of Technical Specification Amendment No. 188.
II. REASON FOR THE CHANGES Salem Unit 1 and Unit 2 Technical Specifications for Containment Air Locks (3:6.1.3) require that each containment air lock must be operable in Modes 1 through 4. The Unit 1 Technical Specification requires that with an air lock inoperable, the air lock must be restored to an operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the unit must be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The Unit 2 Technical Specification contains the same requirements for an inoperable air lock. In addition, the Unit 2 Technical Specification provides action requirements for an inoperable air lock door that permit continued operation if those actions are carried out. Neither Technical Specification provides action requirements that consider an inoperable air lock door interlock mechanism as is the case in the "Standard Technical Specifications -Westinghouse Plants".
The reason for the proposed changes to Technical Specification 3.6.1.3 is to provide Salem Units 1 and 2 with the ability to continue operation if an air lock door or air lock interlock mechanism becomes inoperable. This will assure that operators are not challenged by unnecessary plant shutdowns. At the same time, these changes will ensure that the units are not operated with the containment air locks in a condition in which they would be unable to support containment integrity. These changes will also make the containment air lock technical specifications identical for both Salem units. The changes are consistent with the content of "Standard Technical Specifications -Westinghouse Plants", Technical Specification 3.6.2, Containment Air Locks, but have been incorporated into the format of the Salem Technical Specifications.
- Document Control Desk e
LR-N980350 ATTACHMENT 1 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS Ill. JUSTIFICATION FOR CHANGES Containment Air Locks serve as part of the containment pressure boundary and provide a means for personnel access during all modes of operation. Each air lock (two per Salem unit) is a right circular cylinder with a door at each end. The doors are interlocked to prevent simultaneous opening. Each air lock door is designed and tested to certify its ability to withstand a pressure in excess of the maximum expected following a Design Basis Accident (OBA) inside containment. . As such, closure of a single door supports containment operability. Each of the doors is pressure seated and contains double gasketed seals. Local leakage rate testing capability is provided to ensure that pressure integrity is maintained. Failure to maintain air lock integrity or leak tightness could result in a leakage rate in excess of that assumed in the units' safety analyses.
In order for a Containment Air Lock to carry out its design function, the air lock interlock mechanism must be operable, air lock leakage must be in compliance with the Type B air lock leakage test, and at least one air lock door must be operable. The interlock mechanism allows only one air lock door to be opened at a time. This ensures that a gross breach of containment does not exist when containment is required to be operable. Compliance with the Type B leakage test and the closure of '.
a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. However, both air lock doors are kept closed when the air lock is not being used for normal entry or exit of the containment.
The proposed Technical Specifications will ensure that conditions necessary for an air lock to be operable will be met. The ACTIONS and their completion times will provide clear guidance in the event of an inoperable air lock door, an inoperable air lock interlock mechanism, or an air lock that is inoperable for other reasons. The proposed change will also ensure that containment integrity is maintained, while allowing access so that repairs to affected components can be performed. In the event that t~e required ACTIONS and their completion times cannot be met, the proposed ACTIONS will require that the unit be placed in a condition in which containment integrity is no longer required to mitigate a OBA.
The proposed ACTIONS are modified by four notes. Note (1) allows entry and exit to perform repairs on the affected air lock component. If the outer door is inoperable, then it may easily be accessed for repair. If the inner door is *inoperable, a short time will exist when the containment boundary is not intact (during access through the outer door). The allowance to open the operable outer door with the inner door inoperable, even if it means that the containment boundary is temporarily breached, is acceptable because of the low p.robability that an event that could pressurize the
Document Control Des9 LR-N980350 ATTACHMENT 1 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS containment would occur while the door is open. After each entry or exit the operable door will be immediately closed. If ALARA conditions permit, entry and exit will be through an operable air lock.
Note (2) has been added to provide clarification that, for this Limiting Condition For Operation (LCO), separate condition entry is allowed for each air lock.
Notes (3) and (4) ensure that only the required ACTIONS and associated completion times of ACTION c. (an airlock that is inoperable for a reason other than an inoperable air lock door or air lock interlock) are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required ACTIONS c.1 and c.2 are the appropriate remedial actions. The exception of these Notes does not affect tracking the Completion Time from the initial entry into Condition a., only the requirement to comply with the required ACTIONS.
ACTION a. addresses a single inoperable containment air lock door. ACTIONS, a.1, a.2, and a.3 ensure that the operable air lock door is closed, locked closed, and maintained locked closed. If unable to complete the ACTIONS required by a.1, a.2, and a.3, ACTION d. requires that the unit be placed in an Operational Mode in which the Technical Specification is no longer applicable.
ACTION a.3 also allows the use of the air lock for entry and exit for 7 days under administrative controls if both air locks have an inoperable door. This restriction begins when the second air lock is discovered to be inoperable. Containment entry may be required on a periodic basis to perform Technical Specification Surveillance's and required ACTIONS, as well as other activities on equipment inside containment that are required by Technical Specifications, or activities on equipment that support Technical Specification required equipment. This Note is not intended to preclude performing other activities (i.e. non-TS required activities) if the containment is entered using the inoperable air lock to perform an allowed activity listed above. This allowance is acceptable due to the low probability of an event that could pressurize the containment during the short time that the operable door is expected to be open.
Because of ALARA considerations, ACTION a.3 also allows doors located in High Radiation Areas to be verified locked closed by the use of administrative means.
Allowing verification by administrative means is considered to be acceptable since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position is small.
- Document Control Desk e
LR-N980350 ATTACHMENT 1 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS ACTION b. addresses an inoperable containment air lock Interlock mechanism.
ACTIONS b.1, b.2, and b.3 ensure that an operable air lock door is closed, locked closed, and maintained locked closed. If unable to complete the ACTIONS required by b.1, b.2, and b.3, ACTION d. requires that the unit be placed in an Operational Mode in which the Technical Specification is no longer applicable.
ACTION b.3 also allows entry into and exit from containment under the control of a dedicated individual stationed at the air lock to ensure that only one door is opened at a time. In this case the individual performs the function of the interlock.
Because of ALARA considerations, ACTION b.3 also allows doors located in High Radiation Areas to be verified locked closed by the use of administrative means.
Allowing verification by administrative means is considered to be acceptable since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position is small.
ACTION c. requires that with one or more air locks inoperable for reasons other than those described in ACTION a. orb., an evaluation of previous combined leakage rates using current air lock test results must be performed within one hour. This evaluation is performed to determine if the overall containment leakage rate of LCO 3.6.1.2, Containment Leakage, has been exceeded. If the overall containment leakage rate limits of LCO 3.6.1.2 have been exceeded, the applicability of LCO 3.6.1.1, Containment Integrity, must be evaluated to determine the operability of the containment. The ACTION time of one hour is acceptable because the evaluation must be performed within the one hour ACTION time of LCO 3.6.1.1.
Required ACTION c.2 requires that one door in the affected containment air lock must be verified to be closed within the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> completion time. This specified time period is consistent with the ACTIONS of LCO 3.6.1.1, which requires that containment be restored to an operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Additionally; the affected air lock(s) must be restored to operable status within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time. The specified time period is considered reasonable for restoring an inoperable air lock to operable status, assuming that at least one door is maintained closed in each affected air lock.
ACTION d. requires that if an inoperable containment air lock cannot be restored to operable status within the required completion time, the plant must be brought to a mode in which the LCO does not apply. To achieve this, the plant must be brought to at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to Cold Shutdown within the following 30
Document Control Des.
- LR-N980350 ATTACHMENT 1 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS hours. The-allowed completion times are reasonable, based upon operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
- Document Control Desk e
LR-N980350 ATTACHMENT 2 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS IV. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10CFR50.92, Public Service Electric & Gas (PSE&G) has reviewed the proposed changes and has concluded that these changes do not involve a significant hazards consideration.
The proposed changes will modify the Salem Unit 1 Containment Air Lock Technical Specification action requirements to allow continued operation with an inoperable air lock door; and will make the Salem Unit 1 Technical Specification action for an inoperable air lock door consistent with the Unit 2 actions. The proposed change will also provide action requirements for both units in the event of an inoperable containment air lock interlock mechanism; and will revise the action requirements for an inoperable air lock. Finally, the Technical Specification Bases are being modified to provide a more detailed explanation of the action requirements. These changes are consistent with the requirements contained in the "Standard Technical Specifications -Westinghouse Plants", Revision 1, dated April 1995.
PSE&G has concluded that the proposed changes do not involve a significant hazards consideration because the changes:
- 1. Will not involve a significant increase in the probability or consequences of an ..
accident previously evaluated.
The reactor containment serves to mitigate the consequences of a Design Basis Accident (OBA). That is, the containment is designed to provide a barrier to ensure that in the event of a OBA, a release of radioactive material will not result in the radiation dose.to the general public exceeding the limits of 10CFR100.
Each unit's containment has been provided with two air locks. These air locks permit personnel to access components and systems within the containment boundary without compromising the containment's ability to carry out its design function. In this capacity, the air locks serve as part of the containment boundary and as such are not considered as a contributor to the probability of an accident.
To carry.out their design function, the air locks are designed and tested to certify their ability to withstand a pressure in excess of the maximum expected following a OBA. Each door is individually tested to verify that leakage will remain below design values with the containment at design pressure. An interlock is provided to ensure that containment integrity is maintained during personnel passage by allowing only one air lock door to be open at a time. This interlock is also periodically tested to verify its functionality.
Document Control Desa LR-N980350 ATTACHMENT 2 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS The proposed changes will allow continued operation with one air lock door inoperable or with the air lock door interlock mechanism disabled but will specify the actions necessary under those conditions to assure that containment integrity is not compromised. This will ensure that the consequences of an accident previously evaluated are not significantly increased. Additionally, the proposed changes specify that in the event that an air lock is inoperable for a reason other than an inoperable air lock door, or air lock interlock mechanism, the unit must be placed in a condition in which the analyzed accident could not occur.
Based upon the above, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Create the possibility of a new or different kind of accident.
The proposed changes to the Containment Air Lock Technical Specifications do not affect the ability of the containment to carry out its design function. The changes also do not introduce any riew equipment; nor do they result in the operation of the plant in a manner contrary to the safety analysis. Therefore, the proposed changes will not increase the probability of a new or different kind of accident from any accident previously identified.
- 3. Will not involve a significant reduction in a margin of safety.
The proposed changes do not affect any design or functional requirements of the Containment or the Containment Air Locks. Additionally, the proposed changes do not affect any of the conditions or assumptions of the applicable safety analyses. Containment Air Lock leakage rates are determined based upon containment leakage at design pressure. The proposed changes will not affect containment design pressure nor will they affect the peak containment pressures expected for analyzed accidents.
Based upon the above, the proposed changes will not involve a significant reduction in a margin of safety.
V. CONCLUSIONS Based on the above, Public Service Electric & Gas has determined that the proposed changes do not involve a significant hazards consideration.