Text

Safety Evaluation Supporting Amends 142 & 121 to Licenses DPR-70 & DPR-75,respectively
	ML20056F025
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Site:	Salem
Issue date:	08/04/1993
From:	; Office of Nuclear Reactor Regulation
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I UNITED STATES t

! gi M f j NUCLEAR REGULATORY COMMISSION i

'g WASHINGTON, D.C. 20555 4001

%, N -..... si SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 142 AND 121 TO FACILITY OPERATING L

LICENSE NOS. DPR-70 AND DPR-75 PUBLIC SERVICE ELECTRIC & GAS COMPANY PHILADELPHIA ELECTRIC COMPANY DELMARVA POWER AND LIGHT COMPANY ATLANTIC CITY ELECTRIC COMPANY SALEM NUCLEAR GENERATING STATION. UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311

1.0 INTRODUCTION

By letter dated May 11, 1992, and supplemented by letters dated July 16, 1992, i

February 2,1993, and July 2,1993, Public Service Electric and Gas Company (PSE&G) (the licensee) submitted a request for changes to the Salem Nuclear Generating Station, Unit Nos. I and 2, Technical Specifications (TS).

The requested changes allow longer surveillance test intervals (STIs) and allowed outage times (A0Ts) for the reactor trip system (RTS) and engineered safety features actuation system (ESFAS) instrumentation.

This modification to the TS will minimize the potential number of inadvertent ESFAS actuation and reactor trips during surveillance testing, increase operational effectiveness of plant personnel, and allow resources to be used for other tasks such as preventive maintenance.

In addition, the increased A0Ts will result in fewer human errors since more time will be allowed to perform test and maintenance actions.

The supplemental letters provide clarifying information that does not change the initial proposed no significant hazards consideration determination.

2.0 BACKGROUND

Operating utilities have become increasingly awa e of the effects of current surveillance test intervals (STI) and maintenance requirements on plant operation.

Inadvertent reactor trips have occurred that can be attributed to human errors during performance of these activities. Human errors were found to be directly proportional to the frequency of surveillance tests (STs) and inversely proportional to the time allowed for an inoperable channel to remain in a bypassed condition before repairs could be made. Thus, a greater frequency of STs and shorter A0Ts were, in part, responsible for inadvertent trips and challenges to safety systems.

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To resolve the above concerns, the Westinghouse Owners Group (WOG) initiated a program to evaluate the effect of such undesirable events and proposed TS 1

changes to increase STIs and A0Ts as remedial actions to preclude inadvertent j

trips and challenges to the safety systems while maintaining the benefits of routine tests and maintenance activities to ensure the reliability of the RTS and ESFAS instruments.

t 3.0 PRE-APPROVED REVISIONS AND ASSOCIATED CONDITIONS The WOG published results of its study and proposals for remedial actions in 1983 in the original WCAP-10271.

This document was later revised several times in response to NRC's comments and the current version of WCAP-10271, i

Supplement 2, Revision 1, was published on May 12, 1987. The staff reviewed all versions of WCAP-10271 including WOG's responses to staff's questions on these submittals. During this review, the NRC staff engaged the services of Brookhaven National Laboratory (BNL) to evaluate the approach used and the analyses performed in the WOG reports.

BNL determined the adequacy of W0G's methodology to establish technical bases for unavailability data, reliability calculations, and proposed STI/A0T extensions. After the NRC staff and BNL staff had completed their review the NRC issued three safety evaluation reports (SERs): RTS SER on February 21, 1985, ESFAS SER on February 22, 1989, i

and a supplemental SER (SSER) on April 30, 1990. These SERs approved various TS changes relating to extending STIs, test / maintenance A0Ts, and bypass time for instrument channels in RTS, ESFAS, and the logic cabinets for these systems.

In the SERs, the NRC staff approved extensions to STIs/A0Ts as well as to the time during which the instrument channels could be bypassed.

1 However, the staff stipulated certain conditions that licensees must meet to include these pre-approved changes in plant-specific TSs.

The pre-approved i

changes and associated conditions are addressed below.

3.1 Pre-aporoved Chances As mentioned above, the NRC staff stipulated certain conditions to be met before the approved TS changes to the RTS and ESFAS and to the logic cabinets of these systems could be made in any plant-specific TS. The pre-approved TS changes are described below and the associated conditions are described in Section 3.2 of this report.

PSE&G's specific TS changes for Salem, Units 1 and 2, and their response to the NRC staff's conditions and are evaluated in Section 4 of this report.

3.1.1.

SER issued on February 21, 1985 (RTS SER).

In this SER the staff approved the following TS changes relating to RTS instruments.

(1)

STI for RTS analog channel operational testing may be increased from once a month 10 once per quarter.

(2) The duration for which an inoperable RTS analog channel may be maintained in an untripped condition may be increased from I hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

(3) The duration for which an inoperable RTS channel may be bypassed to allow testing of another channel in the same function may be increased from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

l 4

l o -

1 Also, the channel test may be done in the bypass mode, leaving the inoperable channel in a tripped condition.

(4)

Testing of RTS analog channels in a bypassed condition instead of a tripped condition wi.ll be allowed.

3.1.2.

SER issued on February 22, 1989 (ESFAS SER).

In this SER, the staff approved the following TS changes relating to ESFAS instruments:

(1)

The STIs for the analog channels may be increased from once a month to once a quarter.

l l

(2)

The A0Ts for testing of analog channels may be increased from 2 l

hours to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for both relay and solid state systems.

(3) The A0Ts for testing all components may be up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in solid l

state systems.

1 (4)

In relay systems, the A0Ts for testing of the logic trains and master relays could be increased to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and for the slave relays to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(5)

The A0Ts for maintenance on all components may be extended to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for both relay and solid state systems. All components except the analog channels could be in the bypass mode during maintenance A0T, with an analog channel tripped after spending 6 r

hours in the bypass mode.

Therefore, the maximum duration for 1

which an inoperable ESFAS analog channel could be in an untripped condition is 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

(6)

Staggered testing is not required for analog channels in the ESFAS and this requirement may be removed for analog channels in RTS.

i 3.1.3.

SER issued on April 30, 1990 (SSER).

The staff's approval of the proposed STI/A0T extensions for the logic cabinets and reactor trip breakers for the RTS system was based on its evaluation of Appendix D to the WCAP-10271, Supplement 2, Revision 1.

The RTS and ESFAS share some common instrumentation; therefore it was necessary to consider STI/A0T extensions for RPS logic cabinets.

The staff's conclusions are given below.

(1) The A0T extensions for the RPS logic cabinets as presented in Appendix D are acceptable.

These are 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for testing and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for maintenance instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months respectively.

(2)

The STI/A0T extensions (covered by the ESFAS SER) for ESFAS functions associated with the Safety Injection, Steam Line Isolation, Main feedwater Isolation, and Auxiliary Feedwater Pump Start Signals are acceptable.

(3)

The STI/A0T extensions proposed in Appendix D are not acceptable for reactor trip breakers because the extensions would reduce availability of these breakers.

3.2 Associated Conditions for ADoroval 3.2.1 For the RTS SER Changes:

(1)

Performance of testing shall be done on a staggered basis, (This condition was later removed by the ESFAS SER.)

(2)

Procedures should be implemented to evaluate test-failures for common cause effects and additional testing should be performed if necessary.

(3) Approval of channel testing (items 3.1.1.(3) and (4) above) in a bypassed condition assumes that the plant design allows such testing without lifting any leads or installing temporary jumpers.

(4) The approved revisions to TS as described above in items 3.1.l(1) through (4), also apply to the reactor coolant pump undervoltage and underfrequency functional units.

(5)

For RTS channels which provide duel inputs to other safety-related systems such as ESFAS, the approval of items 3.1.l(1) through (4) above applies only to RTS functions.

(6)

Increased STI would change the margin for analog channel setpoint, therefore, approval of increased STI is contingent on confirmation by the licensee that their setpoint methodology includes sufficient margin to offset the drift anticipated as a result of less frequent surveillance.

3.2.2 For the ESFAS SER Changes:

(1) The licensee must confirm the applicability of the generic analyses to the plant.

(2)

The licensee must confirm that any increase in instrument drift due to the extended STIs is properly accounted for in the setpoint calculation methodology.

3.2.3 For the SSER changes:

(1) Acceptance of item 3.1.3.(1) is contingent on including a separate new action statement for modes 1 and 2 for RPS Automatic Trip and Interlock Logic Functional Units The model Action Statement given below is in the format of Westinghouse Standard Technical Specifications, Revision 4, Table 3.3-1.

ACTION 12 - Vith the number of OPERABLE Charnels (analog channels and trip logic) one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.1.1, provided the other channel is OPERABLE.

3.2.4 Expeditious Review: In the letters tiansmitting the ESFAS SER and SSER, the staff indicated that a licensee's request for the proposed changes to the plant-specific TS will be expeditiously reviewed by the staff provided the licensee:

(1) Ccnfirms the applicability of the generic analyses of WCAP-10271, Supplement 2, Ravision 0 and Revision 1, to its plant.

(2) Confiras tnat any increase in instrument drift as a result of the extecYed ST's has been properly accounted for in setpoint calculatior methodology.

(3) Confirms that the proposed TS changes are consistent with those approved by the staff in the SERs.

4.0 EVALUATION The staff evaluated PSE&G's proposed Salem Units 1 and 2 TS changes to verify that they are consistent with the pre-approved changes and that PSE&G has met all the conditions associated with those changes.

4.1 Verification that Proposed Chances are consistent with the Pre-aporoved Chanaes 4.1.1 Limiting Condition for Operation 3.3.1.1 A.

Table 3.3-1 i

1.

Proposed change:

(Units 1 and 2) Functional Units 12 through 15 and 18

~

(two places).

Change applicable ACTION from 7 to 6.

Evaluation:

For RTi functional units 12 (Loss of Flow - Single Loop),13 (Loss of Flow - Two Loops), 14 (Steam Generator Water Level Low-Low), 15 (Steam /feedwater Flow Mismatch and Low Steam Generator Water Level) and 18 (Turbine Trip - Low Autostop Oil Pressure and Turbine Stop Valve Closure),

in a condition with the number of operable channels one less than the p

required minimum operable channels, the existing ACTION 7 allows startup and/or power operation to proceed until performance of the next required CHANNEL FUNCTIONAL TEST, provided the inoperable channel is placed in the tripped position within I hour.

The revised ACTION 6 requires the inoperable channel be placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and, if the requirement for the minimum operable channels is met, the inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels per Specification 4.3.1.1.1.

Thus the time for putting the inoperable channel in the tripped condition is extended from I hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and bypassing the inoperable channel for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is allowed while the other channels are being tested.

The above change is acceptable because it is consistent with the pre-approved change as described in Sections 3.1.1.(2) and 3.1.1.(3) of this evaluation.

2.

Proposed change:

(Units 1 and 2) Functional Units 19 and 22.

Change applicable ACTION from 1 to 10. ACTION 10 is added to implement a 12-hour 7aintenance and 4-hour surveillance A0T for the appropriate functions.

Evaluation:

For Functional Units 19 (Safety Injection Input from ESF) and 22 (Automatic Trip logic), if the number of operable channels is one less than the minimum operable required, the existing Action I requ'res the plant "to be in H0T STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , however, one channril may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other channel is OPERABLE."

The new ACTION 10 allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the inoperable channel to OPERABLE status before requiring shutdown to HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and allows bypassing one channel up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , for surveillance testing per Specification 4.3.1.1.1 provided the other channel is OPERABLE.

The above change is acceptable because it is consistent with the pre-approved change as described in Section 3.2.3.(1) of this evaluation.

3.

Proposed change:

(Units 1 and 2) ACTION 2.

Change the time an inoperable channel may be maintained in an untripped condition from 1 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Allow placing the inoperable channel in bypass while testing another channel in the same function, instead of placing the tested channel in bypass.

Change the time an inoperable channel may remain in bypass to support testing another channel in the same function from 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Add the words, "of other channels."

Evaluation: With the number of operable channels one less than the total number of channels, ACTION 2 of the existing TS allows startup and/or power operation to proceed provided the inoperable channel is placed in

t

i the tripped condition within I hour, and, if the requirement for the minimum channels operable is met, one additional channel may be bypassed l

up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing.

t The revision to the action statements allows up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , instead of 1 l

hour, for putting a channel in the tripped conditier, and allows for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , for the inoperable channe', instead of an additional channel, to be placed in a bypassed status for surveillance testing "of other channels" per Specification 4.3.1.1.1.

The above change is acceptable because it is consistent with the pre-approved changes described in Sections 3.1.1.(2) and 3.1.1.(3) of this e

evaluation.

The addition of the words, "of other channels" is an administrative change and is acceptable to the staff.

4.

Proposed change:

(Units 1 and 2) ACTION 7.

Delete and mark NOT USED.

Evaluation: Action statement of ACTION 7 has been replaced by ACTION 6 as described above for item 1.

Therefore, this ACTION can be deleted. This is an editorial change and is acceptable to the staff.

5.

Proposed change:

(Units 1 and 2) ACTION 10. The existing TS Table has a "NOT USED" status.

This is revised by deleting the words "NOT USED" and adding the description of insert 1, which reads as follows:

" ACTION 10 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to 3

OPERABLE status within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or be in at least HOT STANDBY in the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.1.1.1 provided the other channel is OPERABLE."

Evaluation:

The description of ACTION 10 is acceptable to the staff as described in item 2 above. Adding the above text to the ACTION 10 statement is an administrative change and is acceptable to the staff.

6.

Proposed change:

(Units 1 and 2) ACTION 11.

Change the time an inoperable channel may be maintained in an untripped condition from 1 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

4 Evaluation: With the number of operable channels one less than the minimum number of channels OPERABLE, ACTION 11 of the existing TS allows operation to continue provided the inoperable channel is placed in the tripped condition within I hour.

The revision to the action statement allows up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , instead of 1.

hour, before putting the inoperable channel in the tripped condition.

This change is acceptable because it is consistent with the pre-approved changes described in Sections 3.1.1.(2) of this evaluation.

7.

Proposed change:

(Units 1 and 2) ACTIONS 1, 2 and 6.

Change identified specification number to 4.3.1.1.1.

Evaluation:

This change is an administrative change which identifies the correct specification.

This change is acceptable to the staff.

B. Table 4.3-1 1.

Proposed change:

(Units 1 and 2) functional Units 2,3,4,6,7,8,9, 10, 12, 14, 15, 16, and 17.

Change CHANNEL FUNCTIONAL TEST frequencies from monthly to quarterly.

Evaluation:

The existing STI for the RTS Functional Units of TS Table 4.3-1 is monthly. The revision to the Table 4.3-1 changes the STI for these Functional Units from monthly to quarterly.

The above change is acceptable because it is consistent with the pre-approved changes described in Section 3.1.1.(1) of this evaluation.

2.

Proposed change:

(Units I and 2) Notation (1) is changed from 7 to 31 days.

Evaluation: These Functional Units are used only during start up.

Changing the STI from 7 to 31 days would be acceptable only if the 31-day drift is included in the loop error calculations of the instrument loop of the affected Functional Unit (s). The licensee has committed to address all changes in drift values due to increased STIs.

Therefore, this change is acceptable to the staff.

l 4.1.2 Limiting Condition for Operation 3.3.2.1 A.

Table 3.3-3 l.

Proposed change:

(Units 1 and 2) Functional Units 1.c, l.d, l.e, l.f (three places), 4.d (three places), 5.a, 8.c.i, and 8.c.ii.

Change the i

applicable ACTION from 14 to 19.

Evaluation:

For ESFAS functional units 1.c (containment pressure high),

l.d (Pressurizer pressure low), l.e (Differential pressure between Steam Lines - High), l.f (Steam Flow in Two Steam Lines-High), 4.d (Steam Flow in Two Lines - High), 5.a (Steam generator Water level High-High), 8.c.i (Start Motor Driven Pumps on Steam Generator Water Level Low-Low) and 8.c.li (Start Turbine Driven Pumps on Steam Generator Water Level Low-Low), in a condition with the number of operable channels one-less than the total number of channels, the existing ACTION 14 allows operation to proceed until performance of the next required CHANNEL FUNCTIONAL TEST, provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

u

. The revised ACTION 19 requires the inoperable channel be placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and, if the requirement for the minimum OPERABLE channels is met, the inoperable channel, instead of an additional channel, may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of j

other channels per Specification 4.3.2.1.1.

Thus the time for putting the inoperable channel in the tripped condition is extended from I hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and bypassing the inoperable channel is allowed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months while the other channels are being tested.

The above change is acceptable because it is consistent with the pre-approved change as described in Sections 3.1.2.(5) and 3.1.2.(2) of this evaluation.

2.

Proposed change:

(Units 1 and 2) ACTION 13.

Change to include a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months maintenance A0T.

Change the time a channel may be bypassed to support surveillance testing from 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

(Unit 1 only) ACTION 13. Add the words "provided the other channel is OPERABLE."

Evaluation: With the number of OPERABLE channels one less than the total i

number of channels, the existing ACTION statement 13 requires the plant to be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , however, one channel may be bypassed up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other channel is operable.

The revised ACTION statement allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable channel to OPERABLE status before requiring shutdown to HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , and increase the allowed bypassed time from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1.4 provided the other channel is operable.

j The above change is acceptable because it is consistent with the pre-approved change as described in Section 3.2.3.(1) of this evaluation.

Adding the words "provided the other channel is operable" is an administrative change which clarifies the statement and provides consistency between Units 1 and 2.

Therefore, this change is acceptable to the staff.

3.

Proposed change:

(Units 1 and 2) ACTION 16.

Change the time an inoperable channel may be maintained in an unbypassed condition from 1 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Increase the time that another channel in the same function may be bypassed to allow testing from 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

(Unit 1 only) ACTION 16. Add the words "by CHANNEL CHECK."

Evaluation: With the number of OPERABLE channels one less than the Total-Number of Channels, the existing ACTION 16 allows operation to proceed provided the inoperable channel is placed in the bypassed condition, and, if the Minimum Channels OPERABLE requirement is demonstrated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , one additional channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1.1.

The revised ACTION statement allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months instead of I hour to keep the inoperable channel bypassed and to demonstrate if the Minimum Channels OPERABLE requirement is met.

If this requirement is demonstrated. it allows one additional channel to be bypassed up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1.1.

The above change is acceptable because it is consistent with the pre-approved change as described in Sections 3.1.2.(5) and 3.1.2.(2) of this evaluation. Adding the words "by CHANNEL CHECK" is an administrative change which clarifies the statement and provides consistency between Units 1 and 2.

Therefore, this change is acceptable to the staff.

4.

Proposed change:

(Units 1 and 2) ACTION 19. Change the time an inoperable channel may be maintained in an untripped condition from 1 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Allow placing the inoperable channel in bypass while testing another channel in the same function, instead of placing the tested channel in bypass.

Change the time an inoperable channel may remain in bypass to support testing another channel in the same function from 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Add the words "of other channels."

Evaluation: With the number of OPERABLE channels one less than the total number of channels, existing ACTION 19 allows Startup and/or Power operation to proceed provided the inoperable channel is placed in the tripped condition within I hour, and, if the minimum channels OPERABLE requirement is met, allows an additional channel to be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Section 4.3.2.1.1.

The revised ACTION 19 requires the inoperable channel be placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and, if the requirement for the minimum l

operable channels is met, the inoperable channel instead of an additional channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels per Specification 4.3.2.1.1.

Thus the time for putting the inoperable channel in the tripped condition is extended from I hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and bypassing the inoperable channel instead of one additional channel for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is allowed while the other channels are being tested.

The above change is acceptable because it is consistent with the pre-approved change as described in Sections 3.1.2.(5), and 3.1.2.(2) of this evaluation. Adding the words "of other channels" is an administrative change which clarifies the statement. Therefore, this change is acceptable to the staff.

j 1

5.

Proposed change:

(Units 1 and 2) ACTION 20.

Change to include a 12-hour maintenance A0T.

Change the time a channel may be bypassed to support surveillance testing from 1 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Add the words "per Specification 4.3.2.1.1."

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. Evaluation: With the number of OPERABLE channels one less than the total number of channels, the existing ACTION statement 20 requires the plant to l

be at least in H0T STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed up to I hour for surveillance testing provided the other channel is OPERABLE.

l The revised ACTION statement allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable l

channel to OPERABLE status or be at least in HOT STANDBY within the same 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months befoie requiring to be in HDT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , I

and it increases the allowed bypassed time for one channel from I hour to l

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1.1, provided the other channel is OPERABLE.

The above change is acceptable because it is consistent with the pre-approved change. described in Section 3.2.3.(1) of this evaluation.

Adding the words

,.er Specification 4.3.2.1.1" is an administrative change which clarifies the statement and provides consistency between Units I and 2.

Therefore, this change is acceptable to the staff.

6.

Proposed change:

(Unit 2 only) Functional Unit 9.b.

Change applicable ACTION from 13 to 20.

i Evaluation:

ACTION 13 was an error in the existing TS. Correction of this error is an administrative change, therefore, this change is acceptable to the staff.

B.

Table 4.3-2 1.

Proposed change:

(Units 1 and 2) Functional Units 1.c, l.d,1.e, l.f, 2.c, 3.b.3, 4.c, 4.d, 5.a, and 8.c.

Change CHANNEL FUNCTIONAL TEST frequency from monthly to quarterly.

l Evaluation: The STI requirement for these ESF instruments per existing TS Table 4.3-2 requirement is monthly.

The revision to Table 4.3-2 changes the STI requirement for inese instruments from monthly to quarterly.

The above change is acceptable because it is consistent with the pre-approved changes described in Section 3.1.2.(1) of this evaluation.

2.

Proposed change:

(Units 1 and 2) Functional Unit 8.d.

Change CHANNEL FUNCTIONAL TEST frequency for Unit 1 from monthly / staggered to quarterly 1

and for Unit 2 from monthly to quarterly, i

Evaluation: The STI requirement for these ESF instruments per existing TS l

Table 4.3-2 of Unit 1 is monthly / staggered and of Unit 2 is monthly. The revision to Table 4.3-2 changes the STI requirement for these instruments from monthly to quarterly.

The above change is acceptable because it is consistent with the pre-approved changes described in Section 3.1.2.(1) of this evaluation. The revision to the TS Table 4.3-2 of Unit I removes the requirement to test

i.

the above channels on a staggered test basis. This change is acceptable because it is consistent with the pre-approved changes described in Section 3.1.2.(6) of this evaluation.

3.

Proposed change:

(Unit 2 only) Functional Unit 9.a.

Change CHANNEL FUNCTIONAL TEST from monthly to quarterly.

Evaluation: The STI requirement for these ESF instruments per existing TS Table 4.3-2 is monthly. The revision to the Table 4.3-2 changes the STI requirement for these instruments from monthly to quarterly.

The above change is acceptable because it is consistent with the pre-approved changes described in Section 3.1.2.(1) of this evaluation.

4.1.3 Bases

The Units 1 and 2 TS bases pages B 3/4 3-1 have been updated to reflect the changes included in this license amendment. These changes are acceptable to the staff.

4.2 Verification of Conditions Through its submittal, PSE&G confirmed that it has met the SER conditions as described below.

(1) Condition 3.2.1.(1):

Performance of testing on a staggered basis was stipulated by the RTS SER but was removed by ESFAS SER.

PSE&G stated that neither Salem Unit implemented staggered testing for RTS functions, therefore, this condition has no impact. This statement is acceptable to the staff.

(2)

Condition 3.2.1.(2):

PSE&G stated that its engineering evaluation confirmed that no common mode failures could be introduced by extended STIs.

In addition, Salem Units 1 and 2 will have procedures in place for common cause failure evaluation and any required additional testing, prior to implementation of the proposed revisions to the TS. This statement is acceptable to the staff.

(3) Condition 3.2.1.(3):

PSE&G stated that with the exception of

" containment Pressure High-High channels," the Salem Units 1 and 2 design does not provide for testing the RTS and ESFAS analog instrumentation channels in a bypass mode without the lifting of wires or installation of temporary jumpers. Therefore, approval for bypass testing is not requested at this time. This statement is acceptable to the staff.

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\\

(4)

Condition 3.2.1.(5): The RTS SER states that approval to extend STI and A0T for channels that provide duel inputs to other safety-related systems, such as ESFAS, only applies to the RTS function.

PSE&G stated that the extensions generically approved for the ESFAS analog channels are now the same as for the RTS analog channels.

This condition is not applicable to the Salem Units since the relaxations requested are the same for channels shared by the RTS and ESFAS.

This statement is acceptable to the staff.

O f

l (5) Condition 3.2.2.(1): The ESFAS SER states that the licensee must confirm the applicability of the generic analyses to the plant.

PSE&G stated that the generic analysis used in WCAP-10271 and its supplements is applicable to Salem Units 1 and 2.

Salem Units 1 and 2 use the Westinghouse 7100 Process Control System and the Westinghouse Solid State Protection System for RTS and ESFAS. Both of these systems were specifically modelled. in the generic analyses. All of the requested ESFAS Functional Unit relaxations were addressed by the generic analysis, with the exception of functional Unit 9 (SEMIAUTOMATIC TRANSFER TO l

RECIRCULATION) on Unit 2.

Westinghouse addressed Functional Unit 9 of Unit 2 on a plant-specific evaluation " Technical Specification Optimization Program, Semi-Automatic Transfer to Recirculation on RWST

{

Level Low for Salem Generating Station Unit 2".

The Westinghouse evaluation concluded that this Functional Unit has less than a 12%

decrease in availability. This value corresponds to the lowest calculated value for any Functional Unit in the generic program (Supplement 1, Revision 1, to WCAP-10271). The generic program determined that an availability decrease of less than 12% was acceptable. This conclusion is 7

acceptable to the staff.

1 (6) Conditions 3.2.1.(6) and 3.2.2.(2): The RTS SER and ESFAS SER state l

that the license must confirm that any increase in instrument drift due to i

the extended STIs is properly accounted for in the setpoint calculation methodology. PSE&G conducted an in-house evaluation of the performance as stated in the July 2,1993 letter.

The evaluation analyzed the monthly Technical Specification Surveillance as-found/as-left data over a 3-year-period (mid 1989 thru 1992) for the Hagan comparators, delta-T and Tavg comparators, and Nuclear Instrumentation.

In their submittal, PSE&G stated there was no evidence of drift bias, and they observed no time dependency in the drift. Their study concluded that an increase in STIs from monthly to quarterly was supported by Salem instrument performaace, and is expected to have no h servable impact on instrument reliability or performance.

The staff finas this acceptable.

j 4.3 OTHER Table 3.3-3, TABLE NOTATION ***, in the second line, the word " operable" was changed to "0PERABLE". This is now a defined term that requires certain actions (e.g., surveillance) to be performed before the valves can be declared operable. The staff finds this acceptable.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New Jersey State official was notified of the proposed issuance of the amendments. The State official had no comments.

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6.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (57 FR 40220). Accordingly, the amendments meet the eiigibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common j

defense and security or to the health and safety of the public.

l Principal Contributor:

S. V. Athavale Date:

August 4, 1993 I

l

ML20056F025

Contents

Text

1.0 INTRODUCTION

2.0 BACKGROUND

4.1.3 Bases

5.0 STATE CONSULTATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 CONCLUSION

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ML20056F025

Text

1.0 INTRODUCTION

2.0 BACKGROUND

4.1.3 Bases

5.0 STATE CONSULTATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 CONCLUSION

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