ML18107A422

Application for Amends to Licenses DPR-70 & DPR-75 to Relocate TS 3/4.3.4 Lco,Surveillance Requirements & Bases from TS to Ufsar,Iaw GL 95-10

ML18107A422
Person / Time
Site:	Salem
Issue date:	07/02/1999
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18107A423	List: ML18107A422 ML18107A424
References
GL-95-10, LR-N990248, NUDOCS 9907120214
Download: ML18107A422 (10)

Text

Public Service Electric and Gas Company Louis F. Storz Public SeNice Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations LR-N990248 - 11999 LCS 98-02 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR AMENDMENT INSTRUMENTATION - TURBINE OVERSPEED PROTECTION 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 will relocate Technical Specification 3/4.3.4, Instrumentation, Turbine Overspeed Protection limiting conditions for operation (LCO), surveillance requirements, and bases from the Technical Specifications to the Salem Updated Final Safety Analysis Report (UFSAR) in accordance with NRC Generic Letter 95-10.

Relocation of these requirements from the Technical Specifications to the Salem UFSAR will reduce costs for PSE&G and the burden on the NRC staff by allowing changes to be made to these requirements without amending the Operating License.

The proposed changes are consistent with NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 1, dated April 1995, and have 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.

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

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~ 21999 hazards consideration determination are provided in Attachment 2. The Technical Specification pages affected by the proposed changes are provided in Attachment 3.

PSE&G has reviewed the proposed License Amendment Request (LCR) 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. The postulated post accident doses do not increase as a result of operations under the benefit of this request. Based on the foregoing, PSE&G concludes that the proposed change meets t.he criteria delineated in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

• Amendments allowing the relocation of Turbine Overspeed Protection Technical Specification requirements were approved for Duke Power Company's McGuire Nuclear Station Units No. 1 and 2 (Docket Nos. 50-369 and 50-370, dated August 2, 1995),

Wisconsin Electric Power Company's Point Beach Nuclear Plant Units No. 1 and 2 (Docket Nos. 50-266 and 50-301, dated August 6, 1995), and Wisconsin Public Service Corporation's Kewaunee Nuclear Power Plant (Docket No. 50-305, August 31, 1995).

PSE&G requests a 60 day implementation period after amendment approval.

Should you have any questions regarding this request, please contact Brooke Knieriem, Salem Licensing, at (609) 339-1782.

/rbk Affidavit Attachments (3) 95-4933

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.

~Lcs&J Subscribed and Sworn to before me thisdwd day of 0u/L/ '1999

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Notary PubliG of New Jersey DELORIS O. HADDEN Notary Public o! New ~ersey My Commission Exptrea 03-29-2000 My Commission expires on _ _ _ _ _ _ _ _ _ _ _ _ __

Document Control Des-LR-N990248 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 08B 1 Rockville, MD 20852 Mr. S. Morris (X24)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. 0. Box 415 Trenton, NJ 08625

ATIACHMENT 1 Document Control Desk LR-N990248 INSTRUMENTATION - TURBINE OVERSPEED PROTECTION I. DESCRIPTION OF THE PROPOSED CHANGES The proposed amendment will relocate Salem Unit 1 and 2 Technical Specification 3/4.3.4, Instrumentation, Turbine Overspeed Protection, limiting conditions for operation (LCO), surveillance requirements, and bases from the Technical Specifications to the Salem UFSAR in accordance with NRC Generic.

Letter 95-10.

II. REASON FOR THE CHANGE The requested license amendment will relocate the Technical Specification 3/4.3.4, Instrumentation, Turbine Overspeed Protection requirements from the Technical Specifications to the UFSAR. The relocation of these requirements to the UFSAR will allow changes to be made under 10CFR50.59, avoiding the expenditure of PSE&G and NRC resources in the development and review of license amendment requests. This action is consistent with the intent of NRC Generic Letter 95-10, which encouraged licensees to relocate certain instrument-related Technical Specifications to licensee-controlled documents or programs.

Ill. JUSTIFICATION FOR CHANGES Salem Technical Specification 3/4.3.4, Instrumentation, Turbine Overspeed Protection, provides LCO and surveillance requirements for the Turbine Overspeed Protection system. Specifically, the requirements for operability and surveillance of the turbine stop valves and turbine control valves and their controls. The Turbine Overspeed Protection system serves to provide turbine speed control during normal operation and to prevent turbine damage and subsequent generation of turbine missiles in the event of an overspeed condition.

To satisfy the surveillance requirements of Technical Specification 3/4.3.4, turbine valve testing is performed at a frequency consistent with the methodology presented in WCAP-11525, "Probabilistic Evaluation Of Reduction In Turbine Valve Testing Frequency." WCAP-11525 evaluates the contribution of failure or unavailability of the turbine valve safety function to the probability that the turbine will overspeed and eject a missile. This probability determines the interval between turbine valve functional tests that can be achieved without exceeding the NRC acceptance criteria for the probability of a turbine missile ejection incident.

The proposed amendments will relocate the LCO and surveillance requirements of Technical Specification 3/4.3.4, Instrumentation, Turbine Overspeed Protection, and their Bases to the Salem UFSAR. Turbine valve testing will continue to be

Document Control Desk e ATIACHMENT 1

.. LR-N990248 performed at a frequency consistent with WCAP-11525. Performance of turbine stop valve surveillance testing in acc;;ordance with WCAP-11525 permits PSE&G to enhance safety by optimizing turbine stop valve testing frequencies such that unnecessary testing is not performed; thereby reducing the probability of plant transients.

In Generic Letter 95-10, the NRC referenced the four criteria of 10CFR50.36 for items for which a technical specification limiting condition for operation must be established. The four criteria include:

1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

2. A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

4. A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Based upon these criteria, NRC Generic Letter 95-10 listed the Turbine Overspeed Protection system Technical Specifications among the candidate Technical Specifications for relocation to licensee-controlled documents. Although design basis accidents and transients include a variety of system failures and conditions that might result from turbine overspeed events, the system failures and plant conditions are much more likely to be caused by events other than turbine failures. As a result, assumptions related to the turbine overspeed protection are not part of an initial condition of a design basis accident or transient that either assumes the failure of or challenges the integrity of a fission product barrier. The turbine overspeed protection system is not relied upon in the design basis accident or transient analyses as a primary success path to mitigate such events.

With regard to the criteria of 10CFR50.36, the Salem Unit 1 and 2 Turbine Overspeed Protection systems are not used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure 2

ATTACHMENT 1 Document Control Desk

" LR-N990248 boundary. The Turbine Overspeed Protection system is not considered to be a protection signal with respect to an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Turbine Overspeed Protection system is not a part of the primary success path which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Finally, the Salem Turbine Overspeed Protection system is not a system which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Therefore, the Salem Turbine Overspeed Protection system does not meet the criteria of 10CFR50.36 for inclusion in the Technical Specifications.

The requested change will relocate the Turbine Overspeed Protection Technical Specification LCO and surveillance requirements, as well as their bases, from the Technical Specifications to the Salem UFSAR. Once located in the UFSAR, changes to these requirements will be made in accordance with the requirements of 10CFR50.59. Reporting of such changes to the Commission will be accomplished in accordance with the requirements of 10CFR50.59(b)(2) and 10CFR50.71 (e).

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ATTACHMENT 2

,, Document Control Desk LR-N990248 IV. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The requested amendments will relocate the requirements of Salem Unit 1 and Unit 2 Technical Specification 3/4.3.3, Turbine Overspeed Protection, and its Basis to the Salem Updated Final Safety Analysis Report (UFSAR).

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.

The requested amendments will not involve an increase in the probability or consequences of an accident previously evaluated. Relocation of the affected Technical Specification sections and their Bases to the Salem UFSAR will have no affect on the probability that any accident will occur. Additionally, the consequences of an accident will not be impacted because the Turbine Overspeed Protection system will continue to be utilized in the same manner as before. No impact on the plant response to accidents will be created.

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

The proposed amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated. No new accident causal mechanisms will be created as a result of the relocation of the Turbine Overspeed Protection system Technical Specification requirements and their Bases to the Salem UFSAR. Plant operation will not be affected by the proposed amendments and no new failure modes will be created.

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

The proposed amendments will not involve a reduction in the margin of safety.

Relocation of the affected Technical Specification requirements to the Salem UFSAR is consistent with NUREG 1431, Standard Technical Specifications -

Westinghouse Plants which do not include Technical Specification requirements for the Turbine Overspeed Protection system. The proposed amendments are consistent with the NRG philosophy of encouraging utilities to propose amendments that are consistent with NUREG 1431.

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Document Control Desk e ATTACHMENT 2

'* LR-N990248 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.

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ATTACHMENT 3

.. Docu.r:nent Control Desk LR-N990248 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 Index IV XII

. 3/4.3.4 3/4 3-70 3/4 3-71 BASES 3/4.3.4 B 3/4 3-4 B 3/4 3-5 The following Technical Specifications for Facility Operating License No. DPR-75 are affected by this change request:

Technical Specification Index IV 3/4.3.4 3/4 3-65 3/4 3-66 BASES 3/4.3.4 B 3/4 3-4 B 3/4 3-4a 6