ML18100A854

Requests Enforcement Discretion from Requirements of TS 3.7.1.2, Auxiliary Feedwater Sys.

ML18100A854
Person / Time
Site:	Salem
Issue date:	01/21/1994
From:	HAGAN J J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N94010, NUDOCS 9402040125
Download: ML18100A854 (9)

Text

' .. .e . . .. " Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President

-Nuclear Operations JAN 211994 NLR-N94010 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR ENFORCEMENT DISCRETION FROM THE REQUIREMENTS OF TECHNICAL SPECIFICATION 3.7.1.2 FACILITY OPERATING LICENSE NO. DPR-70 SALEM GENERATING STATION UNIT 1 DOCKET NO. 50-272 This letter submits an application for enforcement discretion from the requirements of Appendix A of Facility Operating licen9e DPR-70 for the Salem Generating Station Unit 1, and is being filed in accordance with the provisions of 10 CFR 50.90. Specifically PSE&G is requesting enforcement discretion from the requirements of Technical Specification 3.7.1.2, "Auxiliary

• Feedwater System." Specifically, we are requesting a one time, 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> extension of the allowed outage time for an inoperable turbine driven AFW pump, which would otherwise expire at 0310 hours0.00359 days <br />0.0861 hours <br />5.125661e-4 weeks <br />1.17955e-4 months <br /> on January 20, 1994. Attachment 1 includes a detailed description of the proposed change along with PSE&G's conclusions regarding No Significant Hazards Consideration per 10 CFR 50.92. It also provides justification for processing this request on an emergency basis. The attached evaluation has been reviewed and recommended for approval by the Salem Generating station Operations Review Committee (SORC). In accordance with 10 CFR 50.9l(b) (1), a copy of this request has been sent to the State of New Jersey as indicated below. Should you have any questions in regard to this transmittal, please do not hesitate to call. Sincerely, PDR ADOCK 05000272 *t/ I / 9402040125 940121 p PDR -., /(ool '/ /

Document Control Desk NLR-N94010 Attachment (1) 2 c Mr. J. c. Stone, Licensing Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 c. s. Marschall (S09) USNRC Senior Resident Inspector Mr. T. T. Martin, Administrator

-Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Kent Tosch, Manager, IV New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 JAN 2 1 1994 REF: NLR-N94010 STATE OF NEW JERSEY COUNTY OF SALEM , ) ) SS. ) J. J. Hagan, being duly sworn according to law deposes and says: I am 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 the Salem Generating Station, Unit No. 1, are true to the best of my knowledge, information and belief. My Commission expires on l<IMBERL Y JO BROWN NOTARY Pl-JBllG QF NEW JrnSEY My t11mmluion Expires April 21, 1998 NLR-N94010 ATTACHMENT I 1.0 TECHNICAL SPECIFICATION REQUIREMENT FROM WHICH RELIEF IS SOUGHT Technical Specification 3.7.1.2, applicable in MODES 1, 2, and 3, requires: "At least three independent steam generator auxiliary feedwater pumps and associated manual activation switches in the control room shall*be OPERABLE with: a. Two feedwater pumps, each capable. of being powered from separate vital busses, and b. One feedwater pump. capable of .. being powered from an OPERABLE steam supply system." Action (a) requires, "With one auxiliary feedwater pump inoperable, restore the required auxiliary feedwater pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next six hours and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />." The purpose of this request for enforcement discretion is to extend the allowed outage time of Action (a) for an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, on a one time basis. The scope of this request is limited to continued operation in MODE 3 Hot Standby (reactor subcritical, RCS temperature degrees F). 2.0

SUMMARY

OF PRESENT SITUATION Salem Unit 1 is currently in MODE 3. The turbine driven Auxiliary Feedwater pump (13.AFW pump) was declared inoperable at 0310 on January 17, 1994, to allow troubleshooting of the turbine governor.

Both motor driven AFW pumps (11 and 12) are OPERABLE.

On January 10, 1994, unit 1 entered Mode 3 for the first time coming out of the eleventh refueling outage. 13 AFW pump was tested satisfactorily prior to increasing temperature above 350 deg. F, by feeding auxiliary feedwater to all steam generators and observing a level increase.

While in mode 3 and increasing temperature to perform the test required by technical specifications and 4.7.1.2.a.2, unusual pump speed oscillations were noted. Visual inspection of the governor oil indicated the potential for water contamination.

Upon confirmation by oil sample and analysis, the system was drained and flushed with fuel oil. Following these activities, the pump was started to adjust the governor valve compensating screw. The pump was brought to speed at 500 rpm inte}'.'Vals up to 4000 rpm. One adjustment of the screw had to be performed

.. Subsequent to the troubleshooting described above the 4.0.5-P was attempted again.

the pump started to oscillate and water in the oil was* once more observed.

At this point Unit 1 cooldown into Mode 4 was initiated in accordance with TS 3.7.1.2. Mode 4 was achieved on Friday January 14, 1994. While in Mode 4 the governor was replaced, the governor linkage and the governor cooler were inspected, and all the cooler's o-rings were replaced.

These activities were conducted with the Terry turbine and Woodward governor vendors on-site. Following these activities 15 system flushes were performed, to reduce the water content in the governor oil. Additionally, while in Mode 4 and with secondary steam pressure at approximately 100 psig, the pump was tested to ensure proper pump operation.

The pump was started, with speed demand set a minimum, and brought to a maximum of 2200 rpm, which was the maximum obtainable speed at about 100 psig steam pressure.

No pump oscillation was observed, and the pump was stopped. The pump. speed demand was set at 80% of 2200 rpm and the associated feed valves (AFlls) were fully opened. The pump was started and allowed to run, as it would under normal conditions, with no pump oscillation detected.

Normally, the pump speed is set at 3450 rpm, which is approximately 80% of rated speed. Based upon the governor replacement, linkage repair, and testing, it was determined that a mode change was appropriate.

In accordance with Integrated Operating Procedure (IOP)-2, the steam generators were fed using the 13 AFW pump satisfactorily, and on January 17, 1994, unit 1 entered mode 3. Upon entry into mode 3, the action statement for the 13AFW pump was re-entered.

This re-entry into the action statement was conservatively made to administratively track the requirement to re-test the pump at 750 psig, using the exception to TS 4.0.4 to allow the Mode 3 entry. On January 17, when secondary system steam pressure reached 750 psig the was twice satifactorily started from normal configuration.

The 4.0.5-P and response time tests were satifactorily performed.

However when the pump was taken out of recirculation to start feeding the steam generators, the pump started to oscillate.

The action statement was not exited. Investigation by system engineering and maintenance personnel appeared to indicate that the pump oscillation may be indicative of .excessive flow at the present conditions.

Under an approved troubleshooting procedure, the following tests were performed.

When the pump was started at idle speed, and slowly brought to 3450 rpm, 13AFW pump successfully fed the steam generators without oscillating.

When the steam generators were attempted to be fed utilizing 13AFW pump with a preset speed, oscillations were observed.

Presently, a number of options are being contemplated by PSE&G engineering to resolve this issue. However, these options require that data be taken to determine the most stable system configuration for pump operation.

In order to obtain this data, it is necessary to maintain the secondary steam pressure at greater than 750 psig (Mode 3 operations) to operate the pump. Based on the results of our corrective actions to date, and the scope of the proposed troubleshooting activities; it is judged that the 13. AFW pump will not be restored to OPERABLE status within the time allowed by the Action statement.

Accorqingly, a one time only exemption from the requirements of Technical Specificatipn (TS) Limiting Condition for Operation (LCO) 3.7.1.2 Act1on (a) is requested.

Specifically, PSE&G would like to extend the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowable outage time by an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The requested duration of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is based on PSE&G's expectation that the oscillation problems will be resolved within this time. Therefore PSE&G requests that Enforcement Discretion be granted until 0310 hours0.00359 days <br />0.0861 hours <br />5.125661e-4 weeks <br />1.17955e-4 months <br /> on January 23, 1994, or until the 13 AFW pump is restored to OPERABLE, whichever is

• 3.0 JUSTIFICATION FOR THE REQUESTED RELIEF-3.1 Benefit of the Requested Relief The requested relief would allow data collection, testing and corrective maintenance to proceed with sufficient steam pressures to obtain meaningful test data. Without the requested relief, corrective maintenance may be performed, but re-entry to MODE 3 (using the exception to TS 4.0.4 in TS 4.7.1.2) would be required .to allow post maintenance operability testing to determine the success of the corrective actions. This would result in* unnecessary mode changes and constrain our ongoing. corrective actions. Furthermore, the relief would allow an expeditious return to service of Unit 1, during a period of time of excessive load demand on the grid caused by severe weather conditions. 3 . 2 Impact***

on _AFW System

• Capability The safety significance of extending-the allowable outage time for the 13 AFW pump is judged to be insignificant.

. . * . The basis for AFW system operability is to provide sufficient heat removal capability to reduce RCS temperature to less than 350 degrees F. With the reactor subcritical following a refueling outage, the decay heat load is low; it has been conservatively estimated to be less than 2 MWt. Either of the two motor driven AFW pumps (11 or 12) is capable of providing sufficient decay heat removal capability in the event of a loss of normal feedwater.

11 and 12 AFW pumps and their associated Emergency Diesel Generators are OPERABLE.

In addition, in the unlikely event of a loss of offsite power or loss of heat sink, procedures are in place to address and mitigate the consequences of these events. 3.3 PRA Considerations Probabilistic Risk Assessment (PRA) was used to evaluate the incremental change in core damage frequency associated with extending the allowed outage time by 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Because the Salem PRA model applies only to power operation as an initial condition, the evaluation does not directly apply to the present configuration, but is used as a relative measure of safety significance.

The base core damage frequency (cdf) for Salem Unit 1 is 4.45 E-5/yr. The incremental change in cdf associated with extending the turbine driven pump allowed outage time by 72 .hours during power operation is less than 2% of the base cdf (8.78 E-7/yr). This small incremental change, combined with the fact that the core heat load is signi,ficantly lower than the full power operation case in the PRA model, further supports.

the low safety significance of the requested extension.

3.4 Determination

of No Significant Hazards Consideration The request for enforcement discretion:

1) Does not involve a significant increase in the probability or the consequences of an .accident previously evaluated.

Operability of the AFW system is required to ensure the ability to remove decay heat following a transient involving loss of normal feedwater.

The inoperable status of the turbine driven *AFW pump does. not affect the initiation of any such transient.

Therefore, the requested extension of the allowed outage time for the turbine driven AFW pump does not affect the probability of occurrence of any accident.

Salem Unit 1 is in MODE 3, Hot standby, with a decay heat load less than 2 MWt. Both motor driven AFW pumps and their respective Emergency Diesel Generators (EDG's) are operable.

---

---

* Either motor driven pump is capable of providing sufficient decay heat removal given a single failure of the redundant train. Therefore, the proposed request to allow MODE 3 operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> beyond the allowed outage time does not have a significant effect on the consequences of any accident previously evaluated.

The proposed change does not significantly increase the probability or the consequences of any accident previously evaluated.

2) Does not create the possibility of a new or different kind of accident from any previously evaluated.

The proposed change does not introduce any new configuration at the Salem Generating Station. Technical Specifications allow operation of the inoperable AFW pump for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The propos-ed extends the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> by an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. operational Presently, unit with one change only Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3) Does not involve a significant reduction in a margin of safety. The AFW_system is capable of performing its intended function with the turbine driven*pump inoperable in the configuration applicable to the requested--

extension (Mode 3, low decay heat load). Therefore, the request does not significantly reduce any margin of safety .. Based on the above, PSE&G concludes that the requested enforcement discretion will not be a potential detriment to the public health and safety and that a significant hazards consideration is not involved.

3.5 No Adverse Environmental Consequences 10 CFR 51.22 allows a categorical exclusion from environmental assessments for License Amendment Requests provided the following criteria are met: i) The amendment involves no significant hazards consideration.

PSE&G's determination of No Significant Hazard Consideration is presented in Section 3.4.

• ii) There is no significant change in the types and no significant increase in the amounts of effluents that may be released offsite. The proposed change does not impact the offsite dose calculations.

The current analyses for offsite radiological releases maximize the postulated dose resulting from design basis accidents.

The change does not allow for any changes to the amount or types of effluents release offsite. iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The change does not affect the cumulative or occupational radiation exposure.

Therefore, PSE&G has concluded that* the proposed amendment qualifies.for a categorical exclusion

• pursuant to the requirements of 10 CFR 51.22. CONCLUSION As discussed above, PSE&G has determined that the proposed change to the Technical Specification does not involve a Significant Hazards Consideration pursuant to the requirements of 10 CFR 50.92(c).

Accordingly, a one time only extension of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time of Technical Specification (TS) Limiting Condition for Operation (LCO) 3.7.1.2 Action (a), for an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, is requested.

This request for Enforcement Discretion was reviewed and approved by the Salem station Operations Review Committee (SORC) on January 19, 1994.