ML18102A452

Application for Amends to Licenses DPR-70 & DPR-75,revising TSs 3/4.7.1.5, Msivs, & 3/4.3.2, ESFAS Instrumentation Which Provide Necessary Means to Accommodate Entry Into Mode 3 & 2 Prior to Performing MSIV Closure Time Testing

ML18102A452
Person / Time
Site:	Salem
Issue date:	10/01/1996
From:	STORZ L F Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102A453	List: ML18102A452 ML18102A454
References
LCR-S96-12, LR-N96285, NUDOCS 9610110154
Download: ML18102A452 (12)

Text

Public Service Electric and Gas Company

• Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President

-Nuclear Operations OCT Ol 1995 LR-N96285 LCR S96-12 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS MAIN STEAMLINE ISOLATION VALVE TESTING SALEM GENERATING STATION NpS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Gentlemen:

In accordance with 10CFR50.90, Public Service Electric & Gas {PSE&G) Company requests a revision to the Technical Specifications

{TS) for the Salem Generating Station Unit Nos. 1 and 2. In accordance with 10CFR50.9l{b)

(1), a copy of this submittal has been sent to the State of New Jersey. \ The proposed TS changes contained herein represent changes to Specifications 3 / 4. 7 .1. 5, "Main Steam Line Isolation Valves {MSIVs)," and 3/4.3.2, "Engineered Safety Feature Actuation System Instrumentation." These changes provide the necessary means to accommodate entry into Modes 3 and 2 prior to performing MSIV' closure time testing in Mode 2, by adding an exclusion to the provisions of Specification

4.0.4. Other

changes are proposed to allow for the repair and testing of inoperable MSIVs in certain operating Modes. This request also changes the low steam line pressure trip setpoint value specified for safety injection to make it consistent with the previously approved value for steam line isolation.

This request satisfies commitments in Licensee Event Report 272/96-023 pertaining to testing of the MSIVs. 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.

The basis for the requested change is provided in Attachment

1. A 10CFR50.92 evaluation with a determination of no significant hazards consideration is provided in Attachment

2. The marked TS pages affected by the proposed changes are provided in Attachment

3. --t_.:t ------------9610110154 961001 PDR ADOCK 05000272 p PDR Printedon Recycled Paper up --l

• Document control Desk LR-N96285

• OCT Ol 199s Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but provide for implementation prior to entry into Mode 3 from the current outages for Units 1 and 2, respectively.

Because this change was identified recently and is needed prior to entry into Mode 3 on Salem Unit 2, PSE&G is requesting an expedited review. Should you have any questions regarding this request, we will be pleased to discuss them with you. Affidavit Attachments (3) Sincerely, c Mr. H. J. Miller, Administrator

-Region I u. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. Olshan, Licensing Project Manager -Salem U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. c. Marschall (X24) USNRC Senior Resident Inspector

-Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 41-5 Trenton, NJ 08625

• OCT 011996 Document control Desk LR-N96285 SRM/pfr BC Senior Vice President

-Nuclear Engineering

{N19) General Manager -Salem Operations

{S05) Director -QA/NSR (XOl) Manager -Joint owners/Ext Aff Interface

{N28) Manager -Salem Operations

{SOl) Manager -System Engineering

-Salem {S02) Manager -Nuclear Safety Review {N38) Manager -Licensing

& Regulation (X09) Principal Engineer (Salem] Operational Licensing (X09) Onsite Safety Review Engineer -Salem {Xl5) Station Licensing Engineer -Salem {X09) J. O'Conner D. Hassler D. Rothrock J. Pehush J. Giessner T. Wescott General Solicitor, R. Fryling, Jr. (Newark, 5G) Mark J. Wetterhahn, Esq. Records Management

{N21) Microfilm Copy Files Nos. 1.2.1 {Salem), 2.3 {LCR S96-12)

STATE OF NEW JERSEY COUNTY OF SALEM SS. REF: LR-N96285 LCR S96-12 L. F. Storz, being duly sworn according to law deposes and says: I am Senior Vice President

-Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Salem Generating Station, Units 1 and 2, are true to the best of my knowledge, information and belief. Subscribed and Sworl.©obefore me this * /.-0 t day of hnL. , 19 9 6 My Commission expires on KIMBERLY JO BROWN . NOTARY_

OF NEW JERSEY My Commrssron Expires April 21, 1998 Document Control .k Attachment 1 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 MAIN STEAMLINE ISOLATION VALVE TESTING BASIS FOR REQUESTED CHANGE REQUESTED CHANGE AND PURPOSE LR-N96285 LCR S96-12 The proposed Technical Specification (TS) changes contained herein represent changes to Specifications 3/4.7.1.5, "Main Steam Line Isolation Valves (MSIVs)," and 3/4.3.2, "Engineered Safety Feature Actuation system (ESFAS) Instrumentation." The change adds a statement to the MSIV surveillance requirement 4.7.1.5 and to the Response Time Test surveillance 4.3.2.1.3 and adds a footnote to the mode applicability in TS 4.3.2.1.1, Table 4.3-2, Item 4.a for the manual steam line isolation surveillance requirement.

The additions to these sections will denote that the provisions of Specification 4.0.4 are not applicable.

This will allow the plant to enter into operational Modes 3 and 2 .to perform the required MSIV stroke time tests, which can only be performed in the higher modes, when appropriate plant conditions exist. Also, changes are proposed to the Action statements for Limiting Condition for Operation (LCO) 3.7.1.5 to allow the plant to proceed to Mode 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if an inoperable MSIV cannot be closed within four hours, and changes to the Modes 2 and 3 Action statement are proposed to account for more than one inoperable MSIV and to eliminate the reference to operation in Mode 1 with MSIVs closed. This change also eliminates notes that were added to the Unit 1 and Unit 2 TS Table 3.3-5 and surveillance 4.7.6.1.5 as a result of a temporary MSIV stroke time extension to eight seconds. These notes expired after the restart from the tenth and sixth refueling outages for Units 1 and 2 and are no longer applicable.

This change also corrects the high steam flow coincident with low steam line pressure setpoint for safety injection in Table 3.3-4, Item 1.f, from a trip setpoint of psig and an allowable value of psig to a trip setpoint of psig and an allowable value of psig. These values are being changed to be consistent with the values specified for the same initiating signal, (high steam flow coincident with low steam pressure), that is also an input into steam line isolation, Item 4.d, which *---was-cna:ngea-vta-:Amendments-121*-and-l:O

t.---*----Page 1 of 5 Do9ument Control Attachment 1 BACKGROUND LR-N96285 LCR S96-12 While reviewing main steam line isolation and response time testing procedures for Salem, it was recently discovered that the TS did not account for the stroke time testing of the MSIVs

• normally performed when the plant is in Mode 2. The stroke time testing is performed to satisfy the surveillance requirements of 4.7.1.5 and is also used in part to demonstrate operability of the manual initiation of main steam line isolation and to satisfy the requirements for ESFAS response time testing of main steam line isolation on high-high Containment pressure.

The closure time test is performed in Mode 2 at least every eighteen months when returning to power following a refueling outage, if not completed in the prior 92 days. The MSIVs are not tested at power since even a part stroke exercise increases the risk of a valve closure when the unit is generating power. Since the MSIVs cannot be tested at power, they are exempt from the ASME Code Section XI requirements during operation in Mode 1. The current TS requirements for testing do not account for lengthy operating cycles or outages in which the valid surveillance period can be exceeded.

Nor do the requirements account for instances when outage maintenance activities may impact the operability of the valve(s) or circuitry.

Unless exception is taken to TS 4.0.4, there is no means to demonstrate operability of the MSIVs, (i.e., perform the stroke time test), as appropriate conditions for testing do not exist until the plant is in higher operational modes. In addition, the present LCO actions for an inoperable MSIV in Mode 1 do not adequately provide for the closure and repair of the valve in Mode 2, when isolation of a steam line can be performed without challenging plant safety systems, (i.e., causing an unwarranted safety injection signal). Currently, if closure of an inoperable valve cannot be accomplished within the stated four hours, the plant must proceed to Mode 4 within the next twelve hours in accordance with the Action Statement.

In many instances, entry into Mode 4 may be unnecessary if the valve is closed, in its safe position, prior to the specified twelve hours. The present TS also does not account for more than one

• inoperable MSIV in Modes 2 and 3 which could exist prior to the testing if outage activities impacted more than one valve as described previously.

Also, the Action Statement for Modes 2 and 3 refer to subsequent operation in Mode 1 if the isolation valve is maintained closed. Since operation in Mode 1 with this configuration is limited and not desirable, this reference is being deleted. Page 2 of 5

. I Do9ument Control Attachment 1 LR-N96285 LCR S96-12 Amendments 112 and 124 for Salem Unit 1 and Amendment 91 for Salem Unit 2 added footnotes to allow an eight second closure time until modifications and testing could be performed on the MSIVs during specific refueling outages. Since these actions have been.performed and refueling outages completed, the surveillance requirements have returned to the originally specified times, based on a five second MSIV closure time. Therefore, the notes are no longer applicable and are being deleted. By letter NLR-N90052, dated September 4, 1990, PSE&G submitted a request to amend Table 3.3-4 to incorporate a revised trip setpoint for low steam line pressure to account for transmitter inaccuracy due to harsh environment effects. Though the submittal pertained to the high steam flow coincident with low steam line pressure signal, which inputs into both the safety injection and steamline isolation protection functions, only the steam line isolation function was included in the proposed revision to the Salem TS pages. Thus, when Amendments 121 and 101 were issued, the increased setpoint and allowable values for the safety injection function remained at the previously specified values. By meeting the more conservative TS requirements for the steam line isolation function, (i.e., higher specified setpoint), the TS requirements for the safety injection function were met. JUSTIFICATION OF REQUESTED CHANGES The safety function of the MSIVs is to close automatically in the event of a main steam line break or a malfunction that results in a secondary system depressurization.

Rapid closure prevents steam flow in the downstream direction, if the break is downstream of the valves, or in the reverse direction, if the break is upstream of the valves. When the TS surveillance test requirements for the MSIVs are met, (i.e., closure time five seconds) and overall ESFAS response time is equal to or less than seven seconds, then assurance is provided that the MSIVs will isolate for steam line ruptures that generate an automatic isolation signal. Testing of the valves must be done in the higher modes due to the design of the MSIVs. Emergency close actuation of the valves is accomplished by creating a differential pressure initiated by venting steam off the top of the valve's actuator piston-. The steam pressure of the Main Steam System acts on the piston and assists valve closure within the specified time. Therefore, conditions of sufficient system steam pressure, which are generated in the higher operational modes, must be present to perform the time test, which is with conditions under which the acceptance criterion were generated.

Page 3 of 5 Do9ument Control Attachment 1 LR-N96285 LCR S96-12 Testing is performed prior to the opening of the MSIVs for power operation.

During testing, only one valve is opened at a time, with the other three valves remaining closed, already in the safe position.

Should the tested time exceed the specified five second closure time, the valve would be declared inoperable and the isolation valve closed in accordance with the TS action statement.

During testing, automatic isolation capability is maintained.

A postulated failure of the tested valve in the open position would result in the blowdown of a single steam generator since the remaining three MSIVs are closed. Failure of a single MSIV to

• close is consistent with the accident assumptions presented in the Updated Final Safety Analaysis Report (UFSAR) Section 15.4.2, "Major Secondary System Pipe Rupture," for Condition IV events. Therefore, allowing a Mode change and testing with inoperable MSIVs, (as a result of exceeding the closure time test surveillance interval during previous testing or due to outage maintenance on the isolation circuitry for example), is acceptable and within the previously reviewed plant safety analyses.

The need to take exception to Specification 4.0.4 for testing is common in the industry.

Catawba Units 1 & 2, Comanche Peak Units 1 & 2, D. c. Cook Units 1 & 2, Vogtle Units 1 & 2, Shearon Harris Unit 1, Millstone Unit 3, and Wolf Creek Unit 1 currently have provisions in their TS Surveillance Requirements for taking exception to Specification 4.0.4 for the MSIV closure time test. With one MSIV inoperable in Mode 1, action must be taken to restore the valve to an operable status within four hours. Some repairs to the MSIV can be made with the unit at power. If the MSIV cannot be restored to an operable status within four hours, the unit must be placed in a Mode in which the LCO does not apply. To achieve this, it is proposed that the unit be placed in Mode 2 within six hours which is considered a reasonable amount of time, based on operating experience, to reach Mode 2 and to close the MSIV(s) in an orderly manner and without challenging plant systems*.

Since the MSIVs are required to be operable in Modes 2 and 3, the inoperable MSIVs may either be restored to an operable status or closed. When closed, the MSIVs are already in the position required by the assumptions in the safety analysis.

Opening of a single MSIV for subsequent testing is necessary, however, and is also bounded by the safety analysis as discussed previously.

Eliminating the reference to subsequent operation in Mode 1 with an MSIV closed is being proposed since operation in that configuration is not desirable and could challenge the plants' safety systems. Page 4 of 5 Do9ument Control Attachment 1 LR-N96285 LCR S96-12 Changes to the LCO Action Statements are consistent with that provided in NUREG-1431, "Standard Technical Specifications Westinghouse Plants." The change to the high steam flow coincident with low steam line pressure setpoint for safety injection from a setpoint of psig and allowable value of psig to values of psig and psig, respectively, remain bounded by the values assumeq in the safety analyses.

That is, the protective functions that occur as a result of this initiating signal already assume a setpoint that is conservative for the revised value. The setpoints for these protection channels were previously changed in the plant as a result of Amendments 121 and 101; therefore, this proposed TS change will not result in any plant changes. CONCLUSIONS PSE&G has determined that the proposed TS changes to take exception to Specification 4.0.4 for MSIV closure time testing and to correct the safety injection setpoint for low steam line pressure will bring the TSs into alignment with the current plant design and are consistent with assumptions in the accident analyses.

Page 5 of 5 Do9ument Control Attachment 2* LR-N96285 LCR S96-12 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 MAIN STEAMLINE ISOLATION VALVE TESTING 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 Technical Specifications (TS) do not involve a significant hazards consideration.

In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below. REQUESTED CHANGE The proposed Technical Specification (TS) changes contained herein represent changes to Specifications 3/4.7.1.5, "Main Steam Line Isolation Valves (MSIVs)," and 3/4.3.2, "Engineered Safety Feature Actuation system (ESFAS) Instrumentation." The change adds a statement to the MSIV TS surveillance, to the response time surveillance for steamline isolation, and to the mode applicability for the instrumentation surveillance table to denote that the provisions of Specification 4.0.4 are not applicable.

Also, changes are proposed to the Action Statements for Limiting Condition for Operation (LCO) 3.7.1.5 to allow the plant to proceed to Mode 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if an inoperable MSIV cannot be closed within four hours and changes to the Modes 2 and 3 Action statement are proposed to account for more than one inoperable MSIV and to eliminate the reference to operation in Mode 1. This change also eliminates notes that were previously added to extend the Unit 1 and Unit 2 MSIV stroke time to eight seconds. This request also changes the stated high steam flow coincident with low steam line pressure setpoint for safety injection from a setpoint of psig and allowable value of psig to values of psig and psig, respectively, to be consistent with the values currently specified for steam line isolation.

Page 1 of 3 D99ument Control .k Attachment 2 BASIS LR-N96285 LCR S96-12 1. The proposed change does not involve a significant increase in the probability or consequences of an accident previ,ously evaluated.

The isolation capability of the MSIVs and the protective functions of the low steam line pressure channels are necessary for accident mitigation and do not impact the probability of an accident.

MSIV testing in the higher modes is necessary to obtain conditions which enable .testing of the MSIVs. These conditions are consistent with the current accident analyses for main steam line breaks and secondary system depressurization.

Failure of a MSIV, which could be encountered during testing, is accounted for in the accident analyses.

Provisions for entering Mode 2 within six hours with an inoperable MSIV allows operators to remove the plant from power generation in a more controlled manner without challenging plant safety systems and is consistent with other plant shutdown TS (i.e., TS 3.0.3). The additional six hours to Hot Shutdown, should MSIV closure be infeasible, does not result in a significant increase in the probability or consequence of an accident since this is a very small incremental time addition.

The values for the low steam line pressure safety injection are higher and are bounded by the present accident analysis.

The elimination of the obsolete stroke time of eight seconds is editorial in nature. As a result, the changes proposed do not involve a significant increase in the probability or consequence 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 changes do not involve any modifications to existing plant equipment, do not alter the function of any plant systems, do not introduce any new operating configurations or new modes of plant operation, nor change the safety analyses.

The proposed changes will, therefore, not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety. MSIV testing in Mode 2 is within the currently analyzed plant operation as discussed in the Updated Final Safety Analaysis Report (UFSAR) Sections 10.3 and 15.4. These Page 2 of 3

Control Attachment 2 LR-N96285 LCR UFSAR sections address performance of the TS surveillance test at or near 1000 psig Steam Generator pressure to assure main steam isolation occurs within the accident conditions, where Steam Generator pressure may be lower during Mode 1 operation.

The test methodology demonstrating MSIV operability is consistent with the accident analysis.

Operation in Modes 2 and 3 with one or more isolation valve ,inoperable and in the closed position does not impact the margin of safety since the valves are already performing the safety function.

The protective functions that occur as a result of the low steam line pressure initiating signal remain bounded by the values assumed in the safety analyses.

That is, the protective functions that occur as a result of this initiating signal already assume a setpoint that is conservative for the revised value. The change to the setpoint eliminates conflicting information in the Therefore, the proposed changes 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.

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