ML18107A458

Application for Amends to Licenses DPR-70 & DPR-75 to Change TS Surveillance Requirement 4.8.1.1.2 D 7 by Removing Restriction to Perform Test Every 18 Months During Shutdown

ML18107A458
Person / Time
Site:	Salem
Issue date:	07/23/1999
From:	Bezilla M Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18107A459	List: ML18107A458 ML18107A460
References
LCR-S98-13, LR-N990253, NUDOCS 9907300104
Download: ML18107A458 (28)

Text

-~**** .e PS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit UUL B3 -1999 .

LR-N990253 LCR S98-13 United States Nuclear Regulatory Commission*

Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS 3/4.8.1 A. C. SOURCES SALEM GENERATING STATION NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 c Gentlemen:

. I In accordance with 1 OCFR50.90:, Public Service Electric & Gas (PSE&G) Company hereby requests a revision to the Technical Specifications (TS) for the Salem Generating Station Unit Nos. 1 and 2. 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 changesTS surveillance requirement 4.8.1.1.2 d 7 by removing the restriction to perform the test every 18 months during shutdown. PSE&G recognizes that the NRC Staff has concerns relative to performing the 24-hour Emergency Diesel Generator (EOG) load test paralleled to the offsite power while in Modes 1 and 2. Specifically, the NRC is concerned that if a fault or power disturbance were to occur while an EOG is paralleled with the offsite power system, the availability of the EOG for subsequent emergency operation *could be

.adversely affected. This concern is based on potential for common-mode vulnerability of the offsite and onsite sources during testing, which led to restricting the performance of the test during periods when the reactor was shutdown (i.e., Mode 3, 4 or 5).

Notwithstanding these concerns, NRC has recently approved several licensees' requests (e.g., Pennsylvania Power & Light, Niagara Mohawk Power, Tennessee Valley Authority, Entergy, and PSE&G's Hope Creek Station) to eliminate the sl:lutdown restriction for the 24-hour endurance run. These approvals were granted on the existence of unique EOG design features and/or special provisions that ensured that paralleled operation of the EOG with offsite sources would not prevent the EOG from performing its assumed safety functions. Approval of this amendment has a potential

• for significant cost savings of outage critical path time, and dollars.

The power is in your hands.

95-2168 REV. 6/94

Document Control Desk 2

. LR-N990253 In Attachment 1 to this letter, PSE&G provides similar justification to eliminate the shutdown restriction for the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> EOG load test for the Salem Nuclear Generating Stations.

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. 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.

Should you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely,

~;SA-I{_

Marks. sezi1;a7~

Vice President - Operations Affidavit Attachments (3)

,)

Document Control Desk

• 3 LR-N990253 C Mr. H.J. Miller, Administrator - Region 1 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

REF: LR-N990253 LCR S98-13 STATE OF NEW JERSEY

) SS.

COUNTY OF SALEM Mark B. Bezilla, being duly sworn according to law deposes and says:

I am Vice President - 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 Station, Units 1 and 2, are true to the best of my knowledge.

Subscribed and Sworn jJl&efore me this ~3 day of~ y ,1999 cmw*LRllQWAY NOTARY PUm.IC OF NEW JERSEY My Commission expires on ___My-"-C_om_;m_J$$1_1t11""-""""'&plres~_UO'J_.

. 28-'-';a.=*o_oo_

ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 REQUESTED CHANGE AND PURPOSE This proposed License Change Request (LCR) modifies Technical Specification Surveillance Requirement 4.8.1.1.2.d.7 (24-hour endurance run test) by eliminating the restriction to perform the test during shutdown conditions. Specifically, sub item 7 (24-hour endurance test) under item d (At least once per 18 months during shutdown .. ) is deleted and its requirements moved to a new surveillance item G (see insert A) to be performed once every 18 months as described in Insert A. For Salem Unit 1 only the asterisk (***) associated with this surveillance is also eliminated. The asterisk (***) is defined at the bottom of page 3/4 8-5a. It is associated with a one time extension of this surveillance during cycle 13, and its deletion is purely administrative since it no longer applies.

The purpose of this proposed change is to provide PSE&G with greater flexibility in optimizing its outage schedule and the use of its resources, while still protecting the health and safety of the public and station personnel. While the performance of this surveillance in the past years has not significantly impacted outage critical path, its continued non-impact cannot be assured. Performance of the 24-hour endurance run test surveillance places a significant burden to the operations department and station personnel due to its personnel intensive requirements at a time when resources are most limited.

BASIS FOR REQUESTED CHANGE BACKGROUND The following paragraphs provide a brief description of the applicable systems, and system interactions that are pertinent to this submittal. These systems are:

The Offsite Power System (Grid)

The Onsite Power System 4160-V Vital Buses Emergency Diesel Generators (EOG)

Safeguards Equipment Controller (SEC)

The purpose of this brief presentation is to:

Page 1 of 17

ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERA TING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 Provide the NRG staff a basic description relative to the Salem electrical power systems, their interaction and specific design features incorporated to assure the separation and independence of the Offsite and Onsite power systems, and Demonstrate to the NRG staff how these features will maintain the separation and independence during on line testing of the EDGs, thus assurance of the EDGs continued ability to perform their design safety function.

Sections 7.0 and 8.0 of the Salem Updated Final Safety Analysis Report (UFSAR) contains detailed information relative to these systems.

Offsite Power System Each Salem unit generates electric power at 25 Kilo-Volts (kV). This power is fed through an isolated phase bus to the main transformer bank where voltage is stepped up to 500 kV and delivered to the switching station. The 500-KV switching station design incorporates a breaker-and-a-half scheme for high reliability, and is connected to three 500-KV transmission lines. Two transmission lines go north, via separate right-of-way, to two of Public Service Electric & Gas (PSE&G) major switching stations. The third transmission line serves as a tie line to the adjacent Hope Creek 500-KV switchyard. These lines are also integrated into the Pennsylvania I New Jersey I Maryland (PJM) 500-KV interconnected system.

Some of the reliability considerations taken into account by PSE&G to minimize the possibility of power failure due to faults in the network interconnections and the associated switching are as follows:

Each of the three transmission lines takes a separate route to its destination.

The breaker-and-a-half switching scheme in the 500-kV switching station.

Primary and backup relaying systems have been provided for each circuit along with circuit breaker failure protection.

In addition system network performance has been analyzed and evaluated on a computer model for critical three-phase faults cleared by primary relay protection. The Salem nuclear units are stable for the following postulated conditions:

Loss of One Salem Nuclear Unit Page 2 of 17

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• ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 Loss of Largest Generating Unit on the Grid Loss of the Most Critical Transmission Line System Stability Studies performed for unexpected operating conditions such as Hope Creek - Keeney 500-KV or Salem - Deans 500-KV line having an extensive outage, have indicated that the most critical condition is the disconnection of the Salem - Deans or the Hope Creek - Kenney 500-KV line respectively. In such a situation to maintain System Stability, the tripping of one of the Salem Units is required. The relay protection circuitry was modified to incorporate this change.

In summary, these considerations demonstrate that PSE&G has taken significant steps to achieve electrical stability of the Salem Generating Station(s), and stability of its offsite power sources by minimizing the possibility of loss of more than one offsite power source.

Onsite Power System The Salem station(s) has been designed to be capable of being safely shut down from full power in the event of the loss of all offsite power sources. Redundant and independent onsite power sources are provided to ensure the availability of the necessary power for shutdown systems. Onsite Electrical Systems and components vital to station safety, including the emergency diesel generators, are designed so that system integrity is not impaired by a design basis earthquake, high winds, floods, or disturbances on the Electrical System. Total loss of all onsite and offsite ac power is not a design basis event.

The Onsite Power System for each Salem unit consists of the main generator, the auxiliary power and station power transformers, the diesel generators, the group, vital

• and circulating water bus sections and related distribution systems. Station power transformers served by the 13-kV south bus sections energize the 4160-V vital buses.

The 4160-V vital buses feeds safeguard equipment. Preferred power is supplied to the 13-kV bus south sections by two independent AC sources from the switchyard. A single 40-MW gas turbine-generator is also located on-site.

The safeguard loads are divided among the 4160-V vital buses in three independent load groups (Vital Buses A, B, and C). Each of these load groups is provided with an Page 3 of 17

• ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 emergency diesel generator, which serves as a standby power supply in the event that the preferred source is unavailable.

4160-Volt Vital Bus System (4-KV vital)

The vital buses are fed directly from 13 - 4 kV station power transformer (SPT). During normal operation, two of the three vital buses are supplied from one 13 - 4 KV SPT and the third from the other 13 - 4 KV SPT. The in-feed breakers on each vital bus from the two station power transformers are electrically interlocked to prevent paralleling both sources through a vital bus. This ability to supply power to the vital buses from either of two SPTs provides the capability for transferring between sources in the event of an interruption of power from one source.

In the event all offsite power is lost, the EOG are automatically started and the normal in-feed breakers to each 4-kV vital bus are opened. When the diesel generator is up to speed and voltage, its generator breaker is automatically closed to energize the affected 4-kV vital bus. Interlock from the diesel generator breaker prevents closure of either in-feed breaker to that bus, thereby preventing any interconnection between redundant 4-kV vital buses or paralleling to the grid in an out-of-phase condition.

Undervoltage protection on the 4160-V vital buses is provided in two levels as described below.

The first level uses undervoltage relays to sense the loss of offsite power. These relays monitor the 4160-V vital buses. When the voltage on these buses drops below 70 percent of its rated voltage, the undervoltage relays drop out. The dropout action of the relays isolates the buses from the offsite sources, and initiates the Safeguards Equipment Controller (SEC) to accomplish safeguards loading.

The Second Level Undervoltage Protection System (SLUPS) is comprised of three under voltage and time delay relays per vital bus. These relays react after the voltage at the vital bus drops below its predetermined setpoint of rated voltage and does not recover to the relay reset setpoint for a period of 13 seconds.

Each SLUPS relay operates an auxiliary relay, which provides an input to the undervoltage relays associated with the vital bus SEC. The SEC utilizes this input to provide a two-out-of-three relay intelligence to separate the vital bus from the offsite power source and load it onto its associated emergency diesel generator. One of these SLUPS relays will also operate the vital bus 70-percent auxiliary relays (one for each Page 4 of 17

• ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 SEC) to provide a two-out-of-three bus undervoltage intelligence similar to the 70-percent blackout protection scheme.

This configuration eliminates the possibility of vital bus flip-flopping, provides for separation of the vital buses from the preferred source, on an individual basis only, and satisfies GDC-17 relative to maintaining the connection between the offsite source and the onsite distribution system. This undervoltage protection of the 4160-V vital buses is required by the Salem Station Technical Specification 3.3.2.1 Functional Units 7 a and b, and are required to be operable in Modes 1, 2, and 3.

Standby Power Supplies (Emergency Diesel Generators)

The standby ac power source consists of three automatically starting EDGs per unit.

Each diesel generator set supplies power to one 4160-V vital bus (A, B, and C) in the event of a loss of offsite power.

The nameplate continuous rating of the diesel generator units is 2600 kW, 900 rpm, 4160-V, 3 phase, 60 cycles. The units are sized to handle the loads necessary for a design basis LOCA coincident with the loss of all offsite power. The diesel generators are designed to be ready to accept load within 10 seconds after receipt of a signal to start.

Each diesel generator unit is rated as follows:

TIME KW PF KVAR KVA 0.5 Hours <3100 0.8 2325 3875 2.0 Hours <2860 0.8 2145 3575 2000 Hours <2750 0.8 2063 3438 Continuous <2600 0.8 1950 3250 The diesel generator units are located in the Auxiliary Building at Elevation 100 feet.

Within the building the diesel-generators are isolated from each other and from other equipment in the area by firewalls and fire doors. An Automatic Fire Protection System is installed.

Any two of the three diesel generators and their associated vital buses can supply sufficient power for operation of the required safeguard equipment for a design basis LOCA coincident with a loss of offsite power. Sufficient redundancy is provided in the Page 5 of 17 J

• ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 safety features and their assignment to the vital buses so that failure to energize any one vital bus does not prevent operation of the required minimum safety equipment.

Additional information relative to the offsite and onsite power distributions can be found on Section 8.0 of the Salem UFSAR.

Safeguards Equipment Controller (SEC)

There are three-SEC cabinets associated with each of the three-diesel generator vital bus combination. The SECs are completely independent of each other. Each SEC contains two independent sequencers used to load the EOG in an ordered manner. To make this determination, the SEC is provided with input from both Solid State Protection System (SSPS) and each vital bus undervoltage relay. The SSPS test cabinets are used to provide independent output signals from both SSPS trains to the three-SEC units. Buffer relays are used on each vital bus undervoltage sensor to supply independent signals to each SEC unit. Thus, complete channel independence is maintained.

The SEC units are completely redundant. Because both SSPS trains feed each SEC; a failure of an SSPS train will not negate safeguards operation. Failure of a bus undervoltage relay to operate will not negate safeguards operation since a 2-out-of undervoltage logic is used to sense blackout conditions. If only one bus experiences undervoltage, and the sensor on that bus fails to recognize the condition, only that bus will not be loaded; the remaining buses will supply power to the required amount of safeguards equipment. The SEC can operate in any one of the following modes:

MODE I - Safety injection (SI) only (accident only)

MODE II - Loss of all outside power (blackout)

MODE Ill - Safety injection coincident with loss of all outside power MODE IV - Safety injection coincident with undervoltage on the one 4-KV vital bus For the purpose of the SEC loading an "undervoltage" is defined as a bus voltage equal to or less than 70% of nominal and "blackout" loading signal is defined as an "undervoltage" condition in 2 out of three 4 KV vital buses.

Page 6 of 17

-i.'

• ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 All equipment required to keep the plant in a safe condition during the occurrences of safety injection, blackout, or both of these conditions, can be powered by the three EDGs. The safety related equipment is arranged such that safe shutdown can be achieved under all postulated abnormal conditions coincident with the loss of one emergency diesel generator. Each SEC unit has a separate and independent electrical system to provide power for Engineered Safeguards Systems.

Each emergency diesel generator is provided with an independent loading Control System, which initiates the startup and/or loading of the diesel generators during any of the modes of operations described above. During conditions of automatic startup and/or loading for all modes, the following criteria have been met in the Control System design:

Each vital bus control is independent of the other two.

Manual control of equipment is locked out until the automatic load sequencing is complete.

Safeguard actuation signals cannot be interrupted by any automatic device.

Following the completion of the automatic load sequencing and its reset, manual initiation of the loading sequence is available to the operator.

Off-normal diesel conditions are alarmed in the Control Room.

Safety injection conditions take precedence over all other operating modes.

Diesels operating in a "test" mode at the occurrences of a blackout and/or safety injection are automatically separated from the bus (breaker trip) and reloaded according to prevailing conditions.

No sequential loading can occur until the diesel generator ACB is closed onto the bus Inadvertent tripping of the diesel generator output breaker is precluded by locking out the shutdown relay when a safeguard initiation signal is present.

The following paragraph will provide a brief description/listing of the major sequence (steps) of how the SEC responds in the different modes of operation.

Page 7 of 17

• ATTACHMENT 1 LR-N990253 SALEM GENERA TING 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 (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 MODE I - Accident mode - Safety Injection Only (there is no LOOP)

(Both trains of) The SSPS send a SI signal to each SEC Cabinet.

The SEC trips the EOG breaker and the EOG automatically switches out of test mode if one was operating; the EOG control circuits change from "Droop" mode to "Isochronous" mode, and the EOG output breaker is confirmed open.

All required safety-related loads are simultaneously started on the vital buses, except for the Containment Fan Cooling Units (CFCUs). The SEC assumes that the CFCUs were running in High Speed and a trip signal is generated. The SEC will restart the CFCUs in the Low Speed mode following a 20-second time delay.

Manual control of required safety-related loads is locked out until SEC is reset. Any pumps in Auto will remain in Auto, but will be locked Out until SEC is reset.

MODE II - Blackout Only Each SEC receives inputs from each Vital Buses Blackout (70%) and Sustained Degraded UV Relays. If at least 2 of 3 Vital Buses indicate a UV/Blackout condition exists, either by operation of the specific Sustained Degraded voltage relays or the Undervoltage relays, all three SEC Cabinets will initiate a Mode II Loading Sequence.

The SEC trips all 4160VAC Vital Bus and 460VAC breakers except the breakers that feed the transformers for the 460/230V Vital Buses.

The SEC trips the breaker and switches the EOG out of test mode (if operating), and starts the EDGs.

When the EOG output breaker is closed (the signal maintained until SEC is reset),

loads required for Blackout are sequenced onto the Vital Buses.

SEC locks out "Manual Control" of all bus loads until Auto Loading Sequence is complete and the SEC is reset. Any pumps in Auto will swap to Man.

MODE Ill - Safety Injection (LOCA) Plus Blackout (LOOP)

Page 8 of 17

ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERA TING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 If Mode I and Mode II conditions exist simultaneously, the SEC will initiate a Mode Ill Loading Sequence. The sequence involves the same equipment that is loaded under a Mode I actuation except that the EDGs are automatically connected to the 4kV Vital Buses, and the loads are applied in discrete steps to prevent stalling of the EOG.

The loading Sequence is predicated on the times required for starting Emergency Core Cooling system equipment and other equipment required for a LOCA, and the operator is prevented from taking control of the safety loads until the SEC has finished the loading sequence and the SEC is reset.

MODE IV - Safety Injection Plus One 4-KV Vital Bus Undervoltage As far as the individual SEC Cabinets are concerned, Mode Ill and Mode IV loading sequences are the same. Uses the same sequencer for both Modes Ill and IV Only difference is the number of Vital Buses that are loading at the same time.

The two Vital Buses that do not have a UV/Blackout go through Mode I sequence (simultaneous loading). The Vital Bus that has the UV/Blackout condition or degraded voltage goes through the Mode Ill sequence (sequential loading).

A single Vital Bus undervoltage (with no safety injection) can be defined as a Mode II*,

and it will have the same loading sequence as Mode II actuation, involving only that Vital Bus.

SEC MODE CHANGES Once a Mode of operation is established, the SEC will remain in that mode of operation until the SEC is reset or the input criteria changes. If changes in input require a mode change, SEC automatically shifts to the new mode, and will remain in the new mode until reset. Automatic mode changes are restricted and only certain Mode of operation changes can occur. These are:

Mode I to Mode Ill Mode I to Mode IV Mode II to Mode Ill No other mode changes can occur until SEC is reset The following general steps describe/list what occurs when mode change is called for:

Page 9 of 17

ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERA TING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7

1. SEC stops where it is

2. Sequencer currently in use is reset (by the SEC)

3. All loads previously started are shed

4. New loading sequence is initiated For a Mode II to Mode Ill If a Mode II (blackout) signal occurs, followed by a Mode I (accident) signal, the SEC will reset to Mode Ill and go through the proper sequence. All existing output signals are removed except the Manual Lockout signals. Lockout signals are maintained during a Mode change. The SEC strips and reloads the bus. The SEC generates trip signals for the loads. The trip signal is maintained for 5 seconds, and then the loads are re-sequenced on the bus.

The sequence is:

SEC goes to Mode Ill due to a Mode I signal causing all three EOG output breakers to open.

SEC now sees an SI, and as soon as 2/3 Vital Bus UV relays operate (due to the EOG breaker trip) a Blackout (Mode Ill) signal is generated.

SEC now sees an SI plus Blackout condition (Mode Ill).

For a Mode I to Mode Ill If a Mode I signal occurs, followed by a Mode II signal, the SEC will reset to Mode Ill and go through the proper sequence. If SI occurs followed by one Vital Bus UV, the SEC for the affected Vital Bus will change from a Mode I to a Mode IV (Sl/1 Vital Bus UV); other two SECs will remain in Mode I If another vital bus then develops an UV condition, that bus's SEC will also change to a Mode IV.

Page 10 of 17

ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERA TING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 If a SI occurs, and is then followed by the simultaneous loss of voltage on 2/3 vital buses, the SECs for all three buses will change from Mode I to Mode Ill (SI plus Blackout).

If the simultaneous loss of voltage on the vital buses occurs after one bus had loaded in a Mode IV sequence, the bus in Mode IV will not restrip and reload. Bus is already loaded in the same manner as a Mode Ill.

SEC Contact Configuration Duration Manual/Operator Lockout exists for 60 seconds and continues until the SEC is reset.

Components cannot be started or stopped from the control room until the SECs are reset When Mode Operation requires stripping components from the vital buses, trip signal is applied simultaneously to all components for 5 seconds Additional information relative to the SEC can be found on Section 7.0 of the Salem UFSAR.

JUSTIFICATION FOR THE PROPOSED CHANGE PSE&G performed an assessment of the risk of an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of diesel generator testing. The unavailability of all three emergency diesel generators was increased in the Probabilistic Safety Analyses (PSA) for both Salem Unit 1 and 2 to correspond to an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per cycle (18 months) out-of-service time. The unavailability was changed from 1.86E-02 to 2.0E-2. The increase in the baseline internal events core damage frequency (CDF) was determined to be 1.6E-07 events/year for both Salem Units 1 and 2. Based on the definition provided in Regulatory Guide 1.174, Paragraph 2.2.4, this increase is considered a very small increase in risk (less than 1.0E-06 events/year).

Notwithstanding the very small increase in the risk to CDF (1.6E-07), PSE&G recognizes the NRC's concerns regarding the performance of the 24-hour endurance run test paralleled to the offsite power grid while in Modes 1 and 2. Based on these concerns, the 24-hour endurance run test was restricted to periods when the reactor was shutdown. Specifically, the NRC is concerned that if a fault or power disturbance were to occur while an EOG is paralleled to the offsite power system, the availability of the EOG for subsequent emergency operation could be adversely affected. This is Page 11 of 17

ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERA TING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 based on the potential for common-mode vulnerability while the EOG is paralleled to the offsite and onsite sources during testing.

PSE&G will address the NRC's concern in light of the design features described in the background section, as well as the proposed administrative controls to be imposed on the on-line performance of the 24-hour endurance run of the EDGs.

The proposed administrative controls are:

1. Only one Emergency Diesel Generator will be tested at a time.

2. On-line performance of the Emergency Diesel Generator 24-hour endurance run will not be performed under severe weather conditions, or the threat of severe weather conditions.

3. The remaining emergency diesel generators will be operable.

4. An operator will continuously attend the EOG during testing.

The concerns of the NRC staff have been raised in Information Notice 84-69, and in response to other industry documents related to similar licensed amendments.

In the following paragraphs PSE&G will address the NRC's concern (in boldface type) followed by the response in regular (non-boldface) type. The stated concerns are paraphrase from other docketed information related to similar licensed amendments.

Finally, the proposed change provides an economic benefit derived from increased operational flexibility in maintenance scheduling. Because the proposed change to Surveillance Requirement 3.8.1.14 would allow the 24-hour endurance test to be conducted in other than shutdown conditions, PSE&G could reduce the number of critical path activities that must take place during the refueling outages and shorten the outage schedule by up to four days. Approval of this amendment has a potential for significant cost savings of outage critical path time, and dollars.

Concern #1:

During operation with the reactor critical, performance of the 24-hour endurance test could cause perturbations to the electrical distributions systems that would challenge continued steady state operation, and as a result, plant safety systems.

Page 12 of 17 J

ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERA TING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7

a. When the EOG is connected to offsite power grid, the emergency power system is not independent of disturbances on the offsite power systems. This condition can adversely affect emergency power availability (a trip may result due to overcurrent or reverse power or a lockout device may be actuated, requiring local operator action to reset the lockout).

PSE&G Response:

Testability of the system (EOG) is required to satisfy General Design Criterion (GDC)

18. The Salem Safety Evaluation Report (SER), dated October 11, 1974, concluded that the onsite power system meets the requirement of GDC 18.

The possibility that performing the 24-hour endurance test.on line could induce an electrical distribution system perturbation is acknowledged. However, the same possibility to induce an electrical disturbance exists today, when the EOG is tested during the monthly 1-hour loaded surveillance test.

The risk of testing the EOG at power was reviewed and found acceptable by the NRC.

This is clearly demonstrated by the existing Salem Technical Specification Surveillance Requirements (Surveillance 4.8.1.1.2 a 2) requiring a monthly 1-hour loaded test (paralleled to the offsite power source). The automatic response of the electrical distribution system to electrical disturbances and/or accidents as described below, including EDGs performance, is the same regardless of the test duration.

In addition to the tests conducted in the EOG manufacturer's plant, testing has been performed at the station to simulate the various modes of loading and continued to be performed as required Technical Specifications Surveillance test. These tests verify specific design criteria and assure continued operability. For example:

Surveillance 4.8.1.1.2 d 2 requires, in part, that on a load rejection of greater than 820KW, the voltage and frequency are restored to acceptable values within a 4 second time.

This surveillance demonstrates the ability of the EDG's to withstand a loss of load, as it would occur in a normal SEC actuation, without compromising its ability to be ready to accept a new loading sequence and carry out its design safety function.

Page 13 of 17

ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 Surveillance 4.8.1.1.2 d 9 requires, in part, that with the diesel generator operating in a test mode (connected to its bus), a simulated safety injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (2) automatically energizing the emergency loads with offsite power.

This surveillance demonstrates the ability of the EDGs to be disconnected from the grid, if in a test mode, on an accident signal, and be ready to accept a new loading sequence and carry out its design safety function.

Surveillance 4.8.1.1.2 a 2 requires, in part, that every 31 days each diesel generator be demonstrated OPERABLE by synchronizing it to the grid for greater than or equal to 60 minutes.

Note that this proposed amendment request, in its simplest form, is just a request to extend the amount of time the EOG is synchronized to grid from one hour to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> once per cycle.

In addition, the proposed change allows the operator to perform the EOG 24-hour endurance test on a staggered basis. The staggering of the surveillances could reduce the maximum length of time (currently 18 months) since a 24-hour endurance run test was last conducted, and potentially reduce the interval of continued plant operation with a previously undetected common mode failure (e.g., a failure affecting the EOG during the 24-hour test while running at 110% of continuous rating).

Thus, utilizing a staggered test schedule could result in an increase in the level of plant safety. The same bases used for establishing other existing EOG surveillance on a staggered test schedule could also apply for the 24-hour endurance run test.

As stated in the NRC's concern, the disturbance of the offsite power grid may result in the loss of the EOG due to overcurrent or reverse power or a lockout device may be actuated, requiring local operator action to reset the lockout. At Salem station the actuation of the generator differential protection relays will actuate the Diesel Unit Trip Relay (DUTR). Because only one EOG will be operated in parallel to the offsite power grid, only one EOG can be potentially affected by the assumed disturbance.

As described earlier, the EOG protection scheme was designed such that a loss of voltage or sustained degraded voltage condition between the EOG undergoing test and the offsite power system will abort the test by tripping the EOG or opening the EOG output breaker. If a LOOP were to occur and the EOG failed to trip for such a fault, Page 14 of 17

.. + ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 then the associated undervoltage /degraded voltage protection channel for this bus would not respond to a LOOP condition because this channel has not experienced a loss of power. However, the other two channels will respond to the LOOP condition and respond as described earlier. Failing to separate the EOG from the offsite power source under a loss of voltage or degraded voltage condition would require the failure (single active failure) of safety related technical specification item. This undervoltage protection of the 4160-V vital buses is required by the Salem Station Technical Specification 3.3.2.1 Functional Units 7 a and b, and are required to be operable in Modes 1, 2, and 3. This provides additional protection of the EOGs.

In this scenario, the Salem plant will remain within its design basis since safe shutdown can be achieved with the two remaining EOGs. However considering the unlikely failure of the protective system to separate the EOG from the offsite power source, PSE&G proposes to continuously monitor (by an operator) the EOG during the 24~hour endurance run. Resetting of the OUTR relay, which is located in the EOG control room

_can be accomplished in a relative short time. Resetting the OUTR relay will allow the EOG to be started manually or automatically by the SEC, if required.

In summary, the worst case scenario of the electrical disturbance coincident with a Loss of Coolant Accident (LOCA) and the single failure of the protective system to separate the EOG, the Salem plant will remain within its design basis since safe shutdown can be achieved with the two remaining EOGs. Giving the same scenario and considering that an operator will continuously attend the EOG during testing, the OUTR relay can be promptly reset and the EOG started manually or by the SEC, thus restoring full electrical capability.

Concern #2:

The EOG would be more vulnerable to trips that are normally bypassed for emergency starts but are operable for manual starts and during running for test purposes.

PSE&G Response:

Yes. Running the EOG in the test mode (non-SEC mode of operation) exposes the EOG to protective trips that are bypassed during SEC actuation. However the design features incorporated into the offsite and onsite power distributions systems provide a high degree of confidence that the EOG would remain unaffected by any credible fault.

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ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 In addition since an operator will continuously attend the EOG during testing, resetting the DUTR relay, if necessary, can be accomplished in a relative short time. Resetting the DUTR relay will allow the EOG to be started manually or automatically by the SEC.

The plant will remain within its design basis since safe shutdown can be achieved with the two remaining EDGs.

Concern #3:

An accident concurrent with a LOOP and a single failure preventing the opening of the feeder isolation breaker through which the paralleling of the power systems is being accomplished could cause the total loss of power to the safety buses.

PSE&G Response:

NUREG-0800 states that an accident concurrent with a LOOP and a single failure preventing the opening of the feeder isolation breaker through which the paralleling of the power systems is being accomplished could cause the total loss of power to the safety buses. During the 24-hour endurance run, the redundant EDGs will be in a standby condition and the vital buses will be connected to the preferred offsite power source. In this configuration, the remaining EDGs will respond to a simultaneous LOOP/LOCA accident (coincident with a single failure described above) appropriately.

In the unlikely event of a LOCA with complete LOOP in conjunction with a failure of the isolation breaker for the diesel under test to trip would not affect the remaining EDGs ability to perform their safety function. The non-tested EDGs and their associated vital buses would respond to a SEC Mode 3 actuation, as described in the background section of this letter. In Mode Ill operation, the SEC will initiate a Mode Ill Loading Sequence. The sequence involves the same equipment that is loaded under a Mode I actuation except that the EDGs is automatically connected to the 4kV Vital Buses, and the loads are applied in discrete steps to prevent stalling of the EOG.

The loading Sequence is predicated on the times required for starting Emergency Core Cooling system equipment and other equipment required for a LOCA, and the operator is prevented from taking control of the safety loads until the SEC has finished the loading sequence and the SEC is reset.

As documented in Enclosure 2, the proposed change does not involve a significant hazards consideration.

Page 16 of 17

ATTACHMENT 1 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 Based on this determination, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, there is no significant increase in individual or cumulative occupational radiation exposure.

Therefore, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9); and pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

CONCLUSIONS The proposed change will provide PSE&G the flexibility necessary to optimize its outage schedules, the utilization of its resources, while still protecting the health and safety of the public and station personnel.

This conclusion is based on:

a) The very small increase in the baseline internal events CDF (1.6E-07), as defined in Regulatory Guide 1.174, Paragraph 2.2.4, b) The design features described above and their response to credible postulated events, and c) The administrative controls to be imposed on the performance of the 24-hour endurance run of the EDGs.

Page 17 of 17

ATTACHMENT 2 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 10CFR50.92 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 10CFRS0.92 is provided below.

REQUESTED CHANGE This proposed License Change Request (LCR) modifies Technical Specification Surveillance Requirement 4.8.1.1.2.d.7 (24-hour endurance run test) by eliminating the restriction to perform the test during shutdown conditions. Specifically, sub item 7 (24-hour endurance test) under item d (At least once per 18 months during shutdown .. ) is deleted and its requirements moved to a new surveillance item G (see insert A) to be performed once every 18 months as described in Insert A. For Salem Unit 1 only the asterisk(***) associated with this surveillance is also eliminated. The asterisk(***) is defined at the bottom of page 3/4 8-Sa. It is associated with a one time extension of this surveillance during cycle 13, and its deletion is purely administrative since it no longer applies.

The purpose of this proposed change is to provide PSE&G with greater flexibility in optimizing its outage schedule and the use of its resources, while still protecting the health and safety of the public and station personnel. While the performance of this surveillance in the past years have not significantly impacted outage critical path, its continued non-impact cannot be assured. Performance of the 24-hour endurance run test surveillance places a significant burden to the operations department and station personnel due to its personnel intensive requirements at a time when resources are most limited.

In support of the proposed amendment, PSE&G will also impose the following administrative controls on-line performance of the 24-hour endurance run of the EDGs.

The proposed administrative controls are:

1. Only one Emergency Diesel Generator will be tested at a time.

2. On-line performance of the Emergency Diesel Generator 24-hour endurance run will not be performed under severe weather conditions, or the threat of severe weather conditions.

Page 1 of 5

ATTACHMENT 2 LR-N990253 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 (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7

3. The remaining emergency diesel generators will be OPERABLE.

4. An operator will continuously attend the EOG during testing.

BASIS

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

In its simple form, this proposed amendment requests the extension of the 31 day surveillance testing that requires synchronization of the Emergency Diesel Generators (EOG) to the off-site power from one hour to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> once per cycle.

Synchronizing the EOG to the off-site power for test could induce an electrical distribution system perturbation. However, the same possibility to induce an electrical disturbance exists today, when the EOG is tested during the monthly 1-hour loaded surveillance test required by Technical Specifications.

The risk of testing the EOG at power was reviewed and found acceptable by the NRC.

This is clearly demonstrated by the existing Salem Technical Specification Surveillance Requirements (Surveillance 4.8.1.1.2 a 2) requiring a monthly 1-hour loaded test (paralleled to the offsite power source).

PSE&G also performed an assessment of the risk of an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of diesel generator testing. The unavailability of all three emergency diesel generators was increased in the Probabilistic Safety Analyses (PSA) for both Salem Unit 1 and 2 to correspond to an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per cycle (18 months) out-of-service time. The unavailability was changed from 1.86E-02 to 2.0E-2. The increase in the baseline internal events core damage frequency (CDF) was determined to be 1.6E-07 events/year for both Salem Units 1 and 2. Based on the definition provided in Regulatory Guide 1.174, Paragraph 2.2.4, this increase is considered a very small increase in risk (less than 1.0E-06 events/year).

The automatic response of the electrical distribution system to electrical disturbances and/or accidents as described below, including EDGs performance, is the same regardless of the test duration.

In addition to the tests conducted in the EDG's manufacturer's plant, testing has been performed at the station to simulate the various modes of loading and continued to be Page 2 of 5

) . . . r..

• ATTACHMENT 2 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 performed as required Technical Specifications Surveillance test. These tests verified specific design criteria and assure continued operability and diesel generator load acceptance criteria have been met. For example:

Surveillance 4.8.1.1.2 d 2 requires, in part, that on a load rejection of greater than 820KW, the voltage and frequency are restored to acceptable values within a 4 second time.

This surveillance demonstrates the ability of the EDG's to withstand a loss of load, as it would occur in a normal SEC actuation, without compromising its ability to be ready to accept a new loading sequence and carry its design safety function.

Surveillance 4.8.1.1.2 d 9 requires, in part, that with the diesel generator operating in a test mode (connected to its bus), a simulated safety injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (2) automatically energizing the emergency loads with offsite power.

This surveillance demonstrates the ability of the EDG's to be disconnected from the grid, if in a test mode, on an accident signal, and be ready to accept a new loading sequence and carry its design safety function.

Surveillance 4.8.1.1.2 a 2 requires, in part, that every 31 days each diesel generator be demonstrated OPERABLE by synchronizing it to the grid for greater than or equal to 60 minutes.

Note that this proposed amendment request, in its simplest form, is just a request to extend the amount of time the EOG is synchronized to grid from one hour to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> once per cycle.

In addition, the proposed change allows the operator to perform the EOG 24-hour endurance test on a staggered basis. Staggered testing could reduce the interval of continued plant operation with a previously undetected common mode failure (e.g., a failure affecting the EOG during the 24-hour test while running at 110% of continuous rating). Thus, utilizing a staggered test schedule could result in an increase in the level of plant safety. The same bases used for establishing other existing EOG surveillance on a staggered test schedule could also apply for the 24-hour endurance run test.

Page 3 of 5

ATTACHMENT 2 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 At Salem station the actuation of the generator differential protection relays will actuate the Diesel Unit Trip Relay (OUTR). Because only one EOG will be operated in parallel to the offsite power grid, only one EOG can be potentially affected by the assumed disturbance. Failing to separate the EOG from the offsite power source under a loss of voltage or degraded voltage condition would require the single active failure of safety related technical specification item. This undervoltage protection of the 4160-V vital buses is required by the Salem Station Technical Specification 3.3.2.1 Functional Units 7 a and b, and are required to be OPERABLE in Modes 1, 2, and 3. Note that this Technical Specification item is not required to be operable in Modes 5 and 6, where the test is presently required to be performed.

However considering the unlikely failure of the protective system to separate the EOG from the offsite power source, PSE&G proposes to continuously monitor (by an operator) the EOG during the 24-hour endurance run. Resetting of the OUTR relay, which is located in the EOG control room can be accomplished in a relative short time.

Resetting the OUTR relay will allow the EOG to be started manually or automatically by the SEC, if required.

Therefore, the proposed amendment, including proposed administrative controls, does not involve a significant increase in the probability or consequences of an 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 amendment as described above does not physically modify the facility, introduce a new failure mode, or proposes a different operational mode of the AC electrical power sources, or Emergency Diesel Generators.

Therefore, the proposed amendment will 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.

The AC Electrical distribution system has been designed to provide sufficient redundancy and reliability to ensure the availability of the EOGs to provide the required safety function under design basis events to protect the power plant, the public and Page 4 of 5

,_,t u ,.,

ATTACHMENT 2 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 plant personnel. Specifically, the ability of the EDGs to separate from the off-site power source has been designed and tested per Technical Specifications requirements.

Performance of the 24-hour endurance run during power operations will not affect the availability of any of the required power sources, nor the capability of the EDGs to perform their intended safety function. Furthermore, performing the test when the undervoltage protection of the 4160-V vital buses required by the Salem Station Technical Specification 3.3.2.1 is operable, provides for an added level of protection to the EOG that is not available while shutdown.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

Page 5 of 5

ATTACHMENT 3 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following TS for Facility Operating License No. DPR-70 are affected by this change request:

Technical Specification 3.8.1.1 3/4 8-5 3/4 8-5a The following TS for Facility Operating License No. DPR-75 are affected by this change request:

Technical Specification 3.8.1.1 3/4 8-5 Page 1 of 2

,. .A ATTACHMENT 3 LR-N990253 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS (TS)

SURVEILLANCE REQUIREMENT 4.8.1.1.2 D 7 INSERT A

g. At least once per 18 months verifying the diesel generator operates for at least 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s*. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generators shall be loaded to 2760-2860 Kw**. During the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be loaded to 2500-2600 Kw**. The steady state voltage and frequency shall be maintained at~ 3910 and ~ 4580 volts and 60 +/- 1.2 Hz during this test.

Page 2 of 2