ML20198S869

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Safety Evaluation Supporting Amends 203 & 185 to Licenses DPR-70 & DPR-75,respectively
ML20198S869
Person / Time
Site: Salem  PSEG icon.png
Issue date: 01/08/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20198S866 List:
References
GL-94-01, GL-94-1, NUDOCS 9801260312
Download: ML20198S869 (4)


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- UNITED STATES '

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NUCLEAR REGULATORY COMMISSION U

I wAsmwovow, o.c. sonas.oooi IAEETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION.

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RELATED TO AMENDMENT N05.203 AND 185 TO FACILITY OPERATING lifMILNQL Df1dD ANQ DfR-li PUBLIC SERVICE ELECTRIC & GAS COMPANY PHILADELPHIA ELECTRIC COMPANY pELMARVA POL'iR AND LIGHT COMPANY ATLANTIC CITY ELECTF.IC COMPANY n

I SALEM NUCLEAR GENERATING STATION. UNIT N05. 1'AND 2 DOCKET NOS. 50-272 AND 50-311 1.0- INTRODUCTION L

By letter dated November 4,1997, the Public Service Electric & Cas Company (the licensee) submitted a request for changes to the Salem Nuclear Generating

. Station, Unit Nos.-1 and 2, Technical Specifications (TSs). The requested.

changes would revise TS 3/4.8.1 on the emergency diesel generators (EDGs) to (1) delete-the 18-month surveillance requirements in TS 4.8.1.1.2.d.1 and (0) eliminate the accelerated testing requirement of Table 4.8-1.

Specifically, L

iS Surveillance Requirement 4.8.1.1.2.d.l.would be changed to allow each diesel generator to be inspected in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service. The manufacturer endorses the performance of major preventive e

maintenance actions on a refueling outagre basis rather than on the prescribed 18-tonth frequency. Additionally, the recommendations of the Nuclear Regulatory Commission's (NRC) Generic. Letter (GL) 94-01, " Removal of l

Accelerated -Testing and Special Reporting Requirements for-Emergency Diesel Generators," would be incorporated.'

'2.0- EVALUATION The licensee's application to amend the TSs notes that NUREG-1431, " Standard Technical Specification, Westinghouse Plants," allows for relocating the EDG

-inspection requirements from the TSs to the-plant-controlled preventiva maintenance program. The Sales Nuclear Generating Station preventive maintenance' program currently includes EDG performance history, engineering -

c analyses,iand manufacturer's. recommendations as' appropriate for determining-iL nspection requirements.

The licensee states that this change will provide

' increased flexibility for performing preventive maintenance based on manufacture's recommendations, and eliminate any potential conflict between

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'4 the manufacturer supported maintenance intervals and the 18-month interval

_ currently--prescribed by the TSs..The licensee states that the EDG manufacturer endorses the performar.ce of major preventive maintenance actions on.a refueling outage. basis rather than on the prescribed 18-month frequency.-

The proposed change is consistent with _NU8tEG-1431.

On May 31, 1994, the NRC issued GL 94-01 to advise licensees.that thev may request amendments to remove-the accelerated testing ~ and special reporting o

requirements for EDGs from the TSs.

When requesting this amendment, licensees must commit to implement within 90 days of the issuance of the

-amendment.a maintenance program for monitoring and maintaining EDG performance

' consistent with the provisions of Section 50.65 of Title.10 of the Code of Federal Reaulations (10 CFR 50.65), " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and the guidance of Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Additionally, GL 94-01 stated that EDG Special Reporting Requirements could be deleted from the TSs since 10 CFR 50.72 and 50.73 address regulatory requirements for licensees to notify NRC and report j

individual EDG failures.

-2.1_ Removal of 18-Month EDG Inspection

. Inspection of EDGs in accordance with the manufa:turers' recommendations-is common industry practice.

In the past, the NRC staff has typically included this common industry practice as a requirement in the TSs. However, with the issuance of NUREG-1431, the NRC staff has allowed licensees to relocate EDG inspection requirements from the TSs to plant-controlled preventive maintenance (PM) programs. The licensee has proposed to (a) relocate its EDG inspection requirements from the TSs to the Salem plant-controlled PM program and (b) modify the TSs bases to indicate its intent to continue to perform EDG preventive maintenance under its PM program.in accordance with the manufacturer's recommendations. All other surveillance requirements, which

' demonstrate that the AC electrical power system functions as required, will L

remain unchanged. Any changes to the Salem preventive _ maintenance program, as F

part of the maintenance and inspection activities described in the Updated-Final Safety Analysis Report, will be controlled by the requirements of 10 CFR -

50.59.. Sufficient-surveillance requirements are retained in the TSs to-4 demonstrate the functional capability of the EDGs.

The licensee-stated that the original guidance provided by the EDG manufacturer quoted a frequency of 2920 operating-hours between performance of

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major preventive maintenance activities. The Salem EDGs currently have experienced an-average lifetime operating history of about31326 operating-hours between preventive maintenance performance. Therefore, allowing the

.praventive maintenance. inspections to_be conducted on a refueling outage-basis rather than'on the 18-calendar months' basis should not significantly increase the number of operating-hours between major maintenance inspections nor exceed i

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. manufacturer's guidance. Further, the recent operating history of the EDGs supports thisichange.

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The NRC staff concludes =that the change ~to the inspection provisions can' be controlled by the maintenance prog'Ss.

ram because sufficient surveillance requirements.are retained in the The change is consistent with the Improved Standard Technical-Specifications. The staff finds this change to be acceptable.

I 2.2 Deletion of Accelerated Testing of EDGs and Special. Reporting Requirements-The licensee has proposed to eliminate the accelerated testing of the EDGs from the TSs based or, implementation of the Maintenance Rule for the EDGs.-

The current requirement stated in TS Table 4.8-1-accelerates the EDG test schedule-from monthly to weekly when 2 or more failures are encountered in the e

last 20 valid tests. This test frequency is teintained until 7 consecutive failure-free demands have been performed and the number of failures-in the

,last 20 valid demands has been reduced to 0 or 1.

The licensee has stated that it conforms to the guidance of NRC Regulatory Guide 1.160 Revision l',

" Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," for the EDGs, including the key elements in GL 94-01:

performance criteria for EDG reliability and unavailability, under I

phragraph (a)(2) of 10 CFR 50.65; L

appropriate root cause determination.and corrective action following a l

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single maintenance-preventable failure; and L

goals and EDG performance monitoring under paragraph (a)(1) of 10 CFR 50.65 l

if any performance criterion is not met, or if a second maintenance -

preventable failJre occurs.

I As stated in GL 94-01, the NRC staff has found that it is not necessary to relocate accelerated testing requirements to the maintenance program. The L

staff finds that the proposed TS change is consi:: tent with Enclosure 2, p

" Revisions to TS 4.8.1.1.2," of GL 94-01. The proposed change ensures that the EDGs will perform their-intended functions by prevention of EDG failures through maintenance nd periodic surveillance testing. The proposed changes are consistent with the guidance provided in Enclosures 1 and 2 of GL 94-01.

The NRC staff finds the deletion of the surveillance requirements to be L

acceptable since they are not essential for dete' wining operability or whether the TSs Limiting Conditions for Dperation-have been met. The TS requirements L

that remain-are consistent with current licensing practices, operating i

experience and plant accident and transient analyses. and provide reasonable assurance that theJpublic nealth and safety will be protected.

3.0 GTATE CONSULTATION

-In-accordance with the Commission's regulationst the New Jersey State official was-notified of the_ proposed: issuance of the amendments. The State official

~had no comments.-

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l 4.0 ENVIRONMENTAL CONSIDERATI0i1 The amendmerits change a requirement with respect to installation or use of a facility couponent located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the ameunts, 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 Comission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (62 FR 63992). Accordingly, the amendments meet the eligibility 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.

5.0 CONCLUSION

The Comission 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 defense and security or to the health ud safety of the public.

Principal Contributor:

P.

Milano Date: Januarv 8,1998 l

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