ML19327B783

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Rev 1 to 890911 Application for Amends to Licenses DPR-70 & DPR-75,modifying Operation of RHR Sys to Allow for More Flexibility & Retaining Min RHR Flow Rate within Tech Specs Value of 1,000 Gpm
ML19327B783
Person / Time
Site: Salem  PSEG icon.png
Issue date: 11/06/1989
From: Miltenberger S
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19327B784 List:
References
NLR-N89224, NUDOCS 8911130296
Download: ML19327B783 (11)
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. ' Steven E. Miltenberget Public Sorvice Electric and Gas Company P.0, Box 236, Hancocks Bridge, NJ 08038 609-339-4199 (hce Recent aM CtM Nuckw Othcot F

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NLR-N89224 j

c LUnited States Nuclear Regulatory Commission'

. Document Control' Desk

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Washington, DC 20555 Gentlemen:-

REQUEST FOR AMENDMENT, REVISION 1 SALEM GENERATING STATION UNIT NOS. 1-AND'2-FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272.AND 50-311 In'accordance with the requirements of 10CFR50.90, Public Service Electric and Gas. Company (PSE&G) hereby transmits a request for amendment.of Facility Operating Licenses DPR-70 and DPR-75 for Salem' Generating Station, Unit Nos. 1 and 2, respectively.

In accordance with 10CFR50.91(b) (1) requirements, a copy of this request has been sent.to-the State of New Jersey.

On September 11, 1989, PSE&G submitted a proposed amendment

' request *to modify the operation of the. Residual Heat Removal (RHR) system, to allow for more flexibility.

The change would have removed the required minimum flow rate from the Technical I

specifications, and allowed procedural control of required flow rate based on existing decay heat rate and plant conditions.

Based on discussions with Mr. J.

Stone, the NRC Project Manager, J'

for Salem Generating Station, we are' transmitting Revision 1 to this request.

This revision retains the minimum required RHR L

flow 1 rate within the Technical Specifications, at a value of 1000

.9Pm.

PSE&G believes'that sufficient technical justification is j

'provided to demonstrate that the proposed changes do not involve i

a'significant hazards consideration, and'that this LCR does not 1

require'a significant amount of technical review and should be i

processed as a Category 2 change. includes a description, justification and significant hazards analysis for the proposed changes.

! contains the Technical Specification pages revised with pen and ink changes. contains the Technical Specification pages with the changes incorporated.

contains the revised bases.

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NLR-N89224' i

This submittal includes one (1) signed original, including affidavit, and thirty-seven (37) copies to pursuant to 10CFR50. 4 (b) (2) (ii).

Should you have any questions regarding this transmittal, please feel free.to contact us.

Sincerely, LtA.s

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Attachment C

Mr. J.

C.

Stone Licensing Project Manager Ms.

K. Halvey Gibson Senior Resident Inspector Mr.

W. T. Russell, Administrator Region I Mr. Kent Tosch, Chief

-New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 s

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COUNTY OF SALEM

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S.- Miltenberger, being duly sworn according to law deposes and says:

I am Vice President'and Chief Nuclear officer of Public Service l

Electric and Gas Company, and as such, I find the matters set forth in our letter dated November 6, 1989 concerning the Salem Generating. Station, Unit Nos. 1 and 2, are true to the best

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of'my knowledge, information and belief.

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. Subscribed and Sworn to before me this. NN7 day of NdW/VKlh(A/,1989

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Jid Notary.Public of NON Jersey yp.;;tu to, IV.RSHAll

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9;cy,rty mud Op p JEW My Commissi:n Expires IAay 6,1993 My-Commission expires on b

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NLR-N89224

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ATTACHMENT 1 LCR 88-10 l

PROPOSED LICENSE CRANGE SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 l

DOCKET NOS. 50-272 AND 50-311 r

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Descrintion of Chanae Delete Salem Unit 1 Technical Specification LCO 3.1.1.3. Revise Salem Unit 1 Technical Specification Surveillance 4.9.8 and Salem Unit 2 Technical Specification Surveillance 4.9.8.1 to replace i

q the 3000 gpm minimum flow requirement with a value of 1000 gpm.

j The proposed change would revise the numbering of the Unit 1 LCO a

and Surveillance Requirements from 3.9.8 and 4.9.8 to 3.9.8.1 and l

4.9.8.1 respectively. This numbering scheme is consistent with Salem Unit 2 and the Westinghouse Standard Technical l

Specifications.

l II.

Reason for the chance NRC Generic Letters 87-12 and 88-17 requested licensees to l

evaluate operation of the Residual Heat Removal (RHR) system, when the Reactor Coolant System (RCS) is partially filled.

PSE&G performed an evaluation of Salem's RHR system.

This evaluation revealed that the reliability of the RHR pumps could be increased

-by reducing the flow rate below the present Technical f

Specification limit.

Reduced RHR flow rates provide a greater margin against vortexing and preclude an inadvertent loss of

-decay heat removal capability, due to air entrainment and

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cavitation'of the RHR pumps.

In our response to GL 88-17, PSE&G committed to process a l

Technical Specification change to the required RHR flow rate.

We i

are requasting a reduction of the present 3000 gpm minimum flow L

limit to 1000 gpm, with further flow limitations specified within 1

0 plant procedures.

Flow limitations in excess of the 1000 gpm j

specified in the Technical Specifications will be determined i

" based on decay heat rate, as a function of time after shutdown.

This amendment request satisfies that commitment.

1, l

III. Justification for Changa

. Evaluation of Salem's RHR system revealed that, reducing the RHR s

flow rate to <1800 gpm precludes air entrapment and vortex L

formation.

Further review considered the minimum RHR flow rate I

necessary to: (1) remove decay heat (2) preclude boron stratification, and (3) provide an adequate flow rate for boron dilution accident concerns.

Page 1 of 4

N* ?I NLR-N89224 Table 1 (attached) indicates the required RHR flow rate for specified periods of time after shutdown.

Mid-loop operation is not implemented at Salem until at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> aftet shutdown (by procedure).

Adequate decay heat removal can be accomplished with <1500 gpm RHR flow at this time.

The required flow rate decreases further with increased time after shutdown.

This is graphically depicted in Figure 1 (attached).

Westinghouse ovaluated the effect on not positive suction head (NPSH), for flow rates between 1000 and 3000 gpa.

Sufficient RHR I

pump suction head is available at these reduced flow rates.

The potential for boron stratification was evaluated for RHR flow

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rates greater than 1000 gpm.

The basis for preventing boron stratification in the RCS is to minimize the potential for a boron dilution accident.

RHR flow rates greater than 1000 gpm l

ensure that adequate mixing occurs within the RCS.

Thus, there y

is no concern for boron stratification above an RHR flow rate of 1000 gpm.

l Figure 2 (attached) depicts limitations on RHR flow rate for various RCS hot leg water levels.

The data reveals that RHR flow rates should be maintained between 1000 and 1800 gpm when RCS hot leg water level is < 6 inches above canterline.

RHR flow rates can be extended from a maximum of 1800 gpm to 3000 gpm, when RCS hot leg water level is > 6 inches above centerline.

Figures 1 and 2 show that required RHR flow rates vary based on RCS water l

level and the time after shutdown.

More ipportantly, the present l

Technical Specification minimum flow rate (300e gpm) exceeds the maximum flow rate specified for vortexina concerns.

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PSE&G believes that the RHR minimum required flow rate of 3000 is too restrictive and that the minimum required flow rate should be reduced to 1000 gpm.

Due to the many factors influencing RHR flow rate requirements, further limitations on RHR flow rate are more appropriately controlled administratively within plant procedures, with the Design Basis documented in the UFSAR.

These i

changes will allow more flexibility in mid-loop operation and address such factors as actual decay heat, RCS hot leg water level and RHR pump vortexing.

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Salem Unit 1 Technical Specification LCO 3.1.1.3 is not in the Standard Technical Specification (NUREG-0452), nor is it a Salem Unit 2 requirement.

Consequently, its deletion will provide consistency between all of these documents.

Deletion is justified, because operation in Modes 1-3 requires a minimum of at least one Reactor Coolant Pump (RCP) in service.

This t

guarantees that the flow rate is much greater than 3000 gpm.

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NLR-N89224

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I operation in Modes 4-6 will require a minimum flow rate of 1000 gpa.

Further limitationn will be specified within plant I

procedures and will be based ont decay heat, RCS water level,

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F boron stratification and vortexing concerns.

l IV. glanificant Hazards Consideration l

i The proposed changer tc,the Technical Specificationst j

1.

Do not involve a significant increase in the probability or f

consequence of ar, accident previously evaluated.

The Technical Specification requirement to maintain the r

minimum Reactor Coolant Loop in operation will ensure

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adequate RCS flow for Modes 1-4.

The RHR loop OPERABLI LCO will ensurs adequate RHR availability.

The minimum RHR flow i

requirement will be reduced to 1000 gpm in the Technical Specification with further limitations specified in plant l

procedures.

This change will increase the overall reliability of the RHR pumps by addressing vortexing concerns at higher flow rates. Therefore, it may be concluded that the prcposed changes do not involve a i

significant increase in the probability or consequences of an accident previously evaluated.

2.

Do not create the possibility of a new of different kind of i

accident from any accident previously evaluated.

l The proposed change only allows reduced flow rates when the RHR system is in service.

The reduced flow rates are justified by analysis and controlled by the Technical l

Specifications and plant procedures.

Since the RHR system will be maintained at a minimum flow rate of 1000 gpm, per Technical Specifications, no new or different accident from any previously evaluated will be created.

l 3 '.

Do not involve a significant reduction in a margin of safety.

The proposed changes allow a reduction in the minimum RHR flow rate from 3000 gpm to 1000 gpm.

Although this results in a reduced capability to remove decay heat and decreases the amount of mixing in the RCS, the minimum flow specified in the Technical Specifications ensures that adequate margin is maintained, i

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u The flow reduction eliminates the potential for air entrapnent and vortexing of the RHR pumps due to excessive flow rates.

Thereby, increasing the reliability of the RHR i

pumps, while maintaining sufficient flow to ensure the RHR design requirements are net.

Therefore, it may be concluded that the proposed changes do not involve a significant i

reduction in a margin of safety.

i V.

Conclusions j

Based on the information presented above, PSE&G has concluded that the proposed changes satisfy the criteria for a no significant hazards consideration.

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