LR-N990252, Application for Amends to Licenses DPR-70 & DPR-75,modifying TS 3/4.6.1, Containment Integrity, by Clarifying When Verification of Primary Containment Integrity May Be Performed by Administrative Means
| ML18107A377 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 06/10/1999 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18107A378 | List: |
| References | |
| RTR-NUREG-1431 LCR-S99-02, LCR-S99-2, LR-N990252, NUDOCS 9906220198 | |
| Download: ML18107A377 (9) | |
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-N990252 LCR S99-02 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 REQUEST FOR LICENSE AMENDMENT CONTAINMENT SYSTEM SALEM GENERA TING STATION UNITS 1 AND 2 Dtl 01999 FACILITY OPERA TING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Gentlemen:
In accordance with the requirements of 1 OCFR50.90, Public Service Electric and Gas Company (PSE&G) hereby requests a revision to the Technical Specification (TS) for the Salem Generating Station Units No. 1 and 2. In accordance with 10CFR50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey.
This amendment proposes to modify the Salem Units 1 and 2 Technical Specifications (TS) 3/4.6.1 "Containment Integrity." The proposed change clarifies when verification of Primary Containment Integrity may be performed by administrative means. Specifically, verification by administrative means may be performed for valves; blind flanges and deactivated automatic valves located inside Containment and high radiation areas outside containment. The Technical Specifications Bases is appropriately clarified. This proposed change is in accordance with the guidance and intent provided in NUREG 1431, Rev 1 (April 1995) Standard Technical Specifications Westinghouse Plants.
The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1),
using the criteria in 1 OCFR50.92(c) and PSE&G has concluded that this request involves no significant hazards considerations. PSE&G has also reviewed the proposed TS change against the criteria of 10 CFR 51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the above, PSE&G concludes that the proposed change meets the criteria delineated in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
9906220198 990610 PDR ADOCK 05000272 P
~
Printedon
~
Recycled Paper
___________ f)_ --
11
Document Control Desk LR-N990252
- The marked up TS pages affected by the proposed changes are provided in Attachment 111.
Upon NRC approval of the proposed change, PSE&G requests that the amendment be made effective upon issuance, but allow implementation period of sixty (60) days to provide sufficient time for associated administrative activities.
Should you have any questions regarding this request, we will be pleased to discuss them with you.
Sincerely,
<.__/
dtJi~~
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 Ms. 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 95-4933
REF: LR-N990252 LCR S99-02 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 the Salem Generating Stations are true to the best of my knowledge, information and belief.
Sub. scribed and Swo)Z'~~
me
. this LQ ~~day of
, 1999
<.~~J)L~
- , *
- ~ot~ry~ PMb!!c::~~:f'Jew Jersey DELORIS D. HADDEN
,_* :.*::*,*J..
- Notary Public of New Jersey My Commission Expiru My Commission expires on _____
o_3-_2_s-_2000
ATTACHMENT i PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)
T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990252 REQUESTED CHANGE AND PURPOSE The proposed change revises Technical Specification (TS) Section 3/4.6.1. The proposed change clarifies when verification of Primary Containment Integrity may be performed by administrative means. Specifically, verification by administrative means may be performed for valves, blind flanges and deactivated automatic valves located inside Containment.
The current surveillance requirement (SR) 4.6.1.1.a requires, in part, that at least once per 31 days all penetrations* not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are verified closed by valves, blind flanges, or deactivated automatic valves secured in their positions. The word penetration is modified by an asterisk (*) defined at the bottom of the page as follows:
Except vents, drains, test connections, etc. which are (1) one inch nominal pipe diameter or less, (2) located inside the containment, and (3) locked, sealed, or otherwise secured in the closed position. These penetrations shall be verified closed at least once per 92 days."
The proposed change will amend the definition of this asterisk(*) as indicated in Insert A below.
Except vents, drains, test connections, etc. which are (1) one inch nominal pipe diameter or less, (2) located inside the containment, and (3) locked, sealed, or otherwise secured in the closed position. These penetrations shall be verified closed at least once per 92 days. Administrative means may be used to verify those valves/penetrations inside containment and high radiation areas outside containment."
The purpose of the proposed change is to eliminate unnecessary radiological exposure associated with field verification of valve position for equipment known to be in the proper position by administrative means. Administrative means that may be used to determine proper valve position include; tagging requests, other TS surveillance procedures and/or previously performed valve alignments.
The proposed change is consistent with the guidance and intent of NUREG 1431, Rev 1 (April 1995) Standard Technical Specifications Westinghouse Plants (NUREG 1431).
1
ATTACHMENT I PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)
T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990252 JUSTIFICATION OF REQUESTED CHANGES As stated in the Salem TS Bases, assuring Primary Containment Integrity ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses.
Assuring Primary Containment Integrity assures the 10 CFR Part 100 dose limits will not be exceeded at the site boundary during accident conditions.
The Salem TS and Bases do not provide any additional guidance or clarification as the purpose of the surveillance requirement. However, NU REG 1431 explicitly states the purpose of this surveillance. As stated in NUREG 1431, the purpose of this 92-day surveillance requirement is not to perform any testing or valve manipulations, but to verify that containment isolation valves capable of being mispositioned are in their proper safety position (closed). Physical verification (hands on verification) that these penetrations (containment isolations valves) are in the proper position is performed prior to entering Mode 4 and documented in the appropriate valve line-up. Thus, NUREG 1431 concludes that allowing the use of administrative means every 92 days to verify compliance with the surveillance requirement for these valves is acceptable based on the limited access to containment in Modes 1 - 4. This approach is consistent with limiting personnel exposure to as low as reasonably achievable (ALARA).
The Salem TS allows the use of administrative means, but restricts its application to specification 3.6.3.1. This proposed license amendment extends the use of administrative means for all valves/penetrations that are inside containment.
PSE&G acknowledges that including valves/penetrations outside containment is not in verbatim agreement with NUREG 1431. However, it is within the spirit and intent of the NUREG, to reduce the personnel exposure to ALARA. The Salem TS Bases are modified, as stated in Insert B, to clarify the intent of the TS.
CONCLUSIONS The proposed change is consistent with NUREG 1431, Rev 1 (April 1995) Standard Technical Specifications Westinghouse Plants, and supports the ALARA principle by eliminating unnecessary exposure of personnel. In summary, NUREG 1431 allows the use of administrative means. Its acceptance is based upon the small probability of misalignment of these valves due to the restricted access to containment in Modes 1 - 4.
Similarly, Salem Technical Specification 3.6.1.1 allows the use of administrative means to satisfy the requirements of surveillance 4.6.1.1 a for containment isolation valves that are open under administrative means.
2
ATTACHMENT II PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)
T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990252 1 OCFRS0.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Salem Generating Station Unit Nos. 1 and 2 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 change revises Salem Units 1 and 2 Technical Specification (TS)
Surveillance Requirement (SR) 4.6.1.1 a. The proposed change will explicitly allow for use of administrative means to verify closed position of valves, blind flanges and deactivated automatic valves located inside Containment, or located in areas that are physically inaccessible during normal plant operation without the use of special equipment.
The proposed change will amend the definition of this asterisk (*) as indicated in Insert A below.
BASIS Except vents, drains, test connections, etc. which are (1) one inch nominal pipe diameter or less, (2) located inside the containment, and (3) locked, sealed, or otherwise secured in the closed position. These penetrations shall be verified closed at least once per 92 days. Administrative means may be used to verify those valves/penetrations inside containment and high radiation areas outside containment."
- 1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The Salem Technical Specifications allows the use of administrative means to verify valve position. The proposed amendment, as described above, does not affect any assumptions made in evaluating the radiological consequences of accidents described in the Safety Analysis Report (SAR). The proposed change to use administrative means continues to ensure that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analysis. The probability of occurrence of any previously evaluated accident is independent of valve position verification. Therefore, the 1
ATTACHMENT II PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)
T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990252 proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated in the SAR.
- 2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed amendment, as described above, does not physically alter the facility or the operation of the facility. The proposed change to use administrative means every 92 days in lieu of field verification continues to ensure that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analysis. The proposed amendment does not affect the response of any systems, structures or components assumed to function in the accident analysis, or creates a new or different accident scenario.
Therefore, the proposed change does not increase the consequences of a malfunction of equipment important to safety previously evaluated in the SAR or creates 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 Technical Specifications margin of safety as defined in the Bases depends upon proper identification of equipment and performance of the proper surveillance requirements to demonstrate equipment operability. The proposed amendment will continue to ensure that the proper valves are identified and tested in accordance with the Technical Specification requirements. The proposed amendment, as described above, does not introduce any new equipment or modifies how the equipment is operated or tested.
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 change does not involve a significant hazards consideration.
2
ATTACHMENT Ill PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)
T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990252 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following TS for Facility Operating License No. DPR 70 are affected by this change request:
Technical Specification 3.6.1.1 3/4.6.1 3/4 6-1 83/4 6-1 The following TS for Facility Operating License No. DPR 75 are affected by this change request:
Technical Specification 3.6.1.1 3/4.6.1 1
3/4 6-1 83/4 6-1
INSERT A ATTACHMENT ill PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)
T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990252 Except vents, drains, test connections, etc. which are (1) one inch nominal pipe diameter or less, (2) located inside the containment, and (3) locked, sealed, or otherwise secured in the closed position. These penetrations shall be verified closed at least once per 92 days. Administrative means may be used to verify those valves/penetrations inside containment and high radiation areas outside containment."
INSERT B (To the TS Basis)
The purpose of this 92-day surveillance requirement (4.6.1.1 a1) is not to perform any testing or valve manipulations, but to verify that containment isolation valves capable of being mispositioned are in their proper safety position (closed).
Physical verification (hands on verification) that these penetrations (containment isolations valves) are in the proper position is performed prior to entering Mode 4 and documented in the appropriate valve line-up. Allowing the use of administrative means every 92 days to verify compliance with the surveillance requirement for these valves is acceptable based* on the limited access to containment in Modes 1 - 4, or to high radiation areas outside containment. This approach is consistent with limiting personnel exposure to as low as reasonably achievable (ALARA).
2