ML18106B062

Application for Amends to Licenses DPR-70 & DPR-75, Respectively.Proposed Amend Modifies ECCS Subsystems Surveillance Requirement 4.5.3.2.b by Adding Option of Providing Necessary Isolation Function When Testing

ML18106B062
Person / Time
Site:	Salem
Issue date:	02/08/1999
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18106B063	List: ML18106B062 ML18106B064
References
LCR-S98-16, LR-N990069, NUDOCS 9902190239
Download: ML18106B062 (10)

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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-N990069 LCR S98-16 FEB 8 1999 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY CORE COOLING SYSTEMS Tavg<350 F SALEM GENERATING STATION UNIT NOS. 1 AND 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 and 2 respectively. Pursuant to the requirements of 10CFR50.91(b)(1), a copy of this request for amendment has been sent to the State of New Jersey.

The proposed amendment modifies Emergency Core Cooling System, ECCS subsystems Tavg<350 °F Surveillance Requirement 4.5.3.2.b by adding the option of providing the necessary isolation function when performing testing using disabled automatic valves as an alternative to the currently specified manual pump discharge valves. The proposed changes are consistent with NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 1, dated April 1995.

The proposed change has been evaluated in accordance with 10CFR50.91 (a)(1 ), using the criteria in 10CFR50.92(c), and it has been determined that this request involves no significant hazards considerations. \h 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 no significant hazards consideration determination are provided in Attachment 2. The Technical Specification pages affected by the proposed changes are provided in Attachment 3.

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FEB 8 1999 Document Control Desk LR-N990069 PSE&G requests a 60 day implementation period after amendment approval. Approval of this change is requested by June 11, 1999.

Should you have any questions regarding this request, please contact John Nagle, Salem Licensing, at (609) 339-3171.

Sincerely,

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Affidavit Attachments (2)

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 95-4933

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REF: LR-N990069 LCR S98-16 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 this  ?'.h;' day of\..le fa , 199.$"9 AMAJ;~

Notary, Publi:c of New Jersey

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' . ;* ,_ I ,,-, .- , -- * * ~*' ,-: ~... DELORIS D. HADDEN Noterv Public of New Jersey

• My Commission Expires My Commission expires on _ _ _ _03_-2_9-_2000 _ _ _ _ _ _ __

FEB 8 1999 Document Control Desk LB.-N990069 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 S97-21), and 5.93

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.Document Control Des.

ATTACHMENT 1 LR-N990069 LCR S98-16 SALEM GENERA TING STATION UNIT NOS. 1AND2 FACILITY OPERATING LICENSES DPR- 70 AND DPR - 75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY CORE COOLING SYSTEMS Tavg < 350F DESCRIPTION OF THE PROPOSED CHANGES The proposed changes will revise the surveillance requirement contained in Section 4.5.3.2.b to add the use of disabled automatic valves as an alternative means of providing safety injection and charging pump isolation during testing when in Mode 4 with RCS cold leg temperature is less than 312 °F or in Modes 5 or 6 with the head in place.

REASON FOR THE CHANGES Salem Technical Specifications require that a maximum of one safety injection pump or charging pump be operable in modes 4, 5 or 6 under certain configurations in order to protect against low temperature over pressurization conditions which could result from the addition of excess masses of emergency cooling water. Associated surveillance requirements specify assuring the inoperable pumps are indeed inoperable by verifying that the electrical circuit breakers for the pumps are open. An exception is provided for testing of the pumps with the additional requirement that the pump being tested is in recirculation mode with the pump discharge valve closed. Specifying that the manual discharge valve is closed is unnecessarily prescriptive and limits the ability to test the pumps and associated check valves to the operating modes in which low temperature over pressurization is not an issue. The proposed change would allow testing using alternate means of assuring that the injection pathway is blocked thus permitting the associated testing in mode 4 with RCS cold leg temperature less than 312 °F or in Modes 5 or 6 with the head in place.

NUREG-1431, Standard Technical Specifications - Westinghouse Plants, contains a requirement in section 3.4.12 "Low Temperature Over Pressurization (LTOP) Protection", in that case, however, the requirement is stated in general terms of pump with the "capability to inject" rather than prescriptive definition of how to achieve the goal.

The requested Technical Specification changes will provide increased operational flexibility.

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Document Control Des.

ATTACHMENT 1 LR-N990069 LCR S98-16 JUSTIFICATION FOR CHANGES The goal of the affected Technical Specifications is to assure that the vessel is protected from Low Temperature Over Pressurization conditions which could result from mass inventory additions in excess of the relief capability of a single over pressure protection relief valve. In order to accomplish this goal, a maximum of one safety injection or charging pump is permitted to be operable in Mode 4 with the RCS cold leg temperature less than 312 °F or in Modes 5 or 6 when the head is on the reactor vessel. Surveillances are included which verify that the motor circuit breakers for the additional pumps are open. In recognition of the need to perform testing, an exemption is included in the surveillance which allows a pump undergoing testing to be operating in the recirculation mode with the manual discharge valve in the closed position. This proposed change would provide an alternate method of assuring the flow path protection necessary during testing by disabling an automatic valve in the pump discharge flow path. The disabling would be effected by closing the valves and either opening the associated circuit breakers (for motor operated valves) or shutting the air supply (for air operated valves) and by controlling the evolution with the appropriate surveillance procedures. The manual valve remains as an option. A disabled closed automatic valve provides the same level of protection and positive control as that provided by a closed manual valve. The proposed automatic valves leakage characteristics are similar to the manual valves for which they will be substituted. The Safety Injection Header Valves (SJ40) have been drilled in order to address the pressure locking I thermal binding issue. The drilling was performed on the upstream (pump) side of the valve disks and, as such, there is no affect on the leakage characteristic in so far as this change request is concerned.

The proposed changes are consistent with the content of NUREG-1431, Standard Technical Specifications Westinghouse Plants.

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. Document Control Des.

ATTACHMENT 2 LR-N990069 LCR-S98-16 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 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Pursuant to 10CFR50.92, PSE&G reviewed the proposed amendment to determine whether our request involves a significant hazards consideration.

PSE&G has determined that operation of Salem Generating Station, Unit Nos. 1 and 2, in accordance with the proposed changes:

1. Will not involve a significant increase in the probability or consequences of an accident previously evaluated.

In Mode 4 with the RCS coolant temperature less than 312 °F or in Modes 5 and 6 there is a potential risk of low temperature overpressurization. Mass additions of coolant by the safety injection and charging pumps could cause such an event to the extent that these pump flows exceed the ability of a single over pressure protection relief valve to protect the system. In order to eliminate this potentiality provisions are made to allow a maximum of one pump to be in service with the other pumps disabled except for testing. Further provisions are made to assure that a pump being tested can not inject into the vessel. The proposed change merely adds an alternate method of providing this assurance in addition to that currently provided by closing the manual discharge valves. The proposed change offers an equivalent means of affording the required protection.

Based upon the above, the proposed change will not increase the probability or consequences of an accident previously analyzed.

2. Will not create the possibility of a new or different kind of accident from any previously evaluated.

The proposed changes do not require any change in the operation of the plant. A minor configuration change is involved in that an disabled automatic valve in the flow path will be used in lieu of the manual valve to provide protection.

Specifically, no new hardware is being added to the plant as part of the proposed change, no existing equipment is being modified, and no significant changes in operations are being introduced. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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.Document Control Des.

ATTACHMENT 2 LR-N990069 LCR-898-16

3. Will not involve a significant reduction in a margin of safety.

The proposed change will not alter any assumptions, initial conditions, or results of any accident analyses. The proposed change maintains the level of protection.

The change will, therefore, not involve a significant reduction in a margin of safety.

CONCLUSIONS Based on the above, Public Service Electric & Gas has determined that the proposed changes do not involve a significant hazards consideration.

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.* Document Control Desk9 ATTACHMENT 3 LR-N990069 LCR S98-16 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 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Facility Operating License No. DPR-70 are affected by this change request:

Technical Specification 4.5.2.3.b 3/4 5-6a The following Technical Specifications for Facility Operating License No. DPR-75 are affected by this change request:

Technical Specification 4.5.2.3.b 3/4 5-8 Page 1

.Document Control Desk9 ATTACHMENT 3 LR-N990069 LCR S98-16 INSERTS AND MARKED UP PAGES INSERTS FOR LCR S98-16 (none)

MARKED UP PAGES FOR LCR S98-16 attached Page2