ML18101A867

Application for Amends to Licenses DPR-70 & DPR-75,deleting Previous Amends 72 & 46,respectively Re RHR Operation in Modes 5 & 6

ML18101A867
Person / Time
Site:	Salem
Issue date:	06/22/1995
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18101A868	List: ML18101A867 ML18101A869
References
LCR-85-18, LCR-95-08, LCR-95-8, LR-N95081, NUDOCS 9508080394
Download: ML18101A867 (10)

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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 LR-N95081 Vice President - Nuclear Operations LCR 95-08 JUN 2 21995 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

LICENSE AMENDMENT APPLICATION SALEM GENERATING STATION - UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 In accordance with_lOCFR50.90, PSE&G submits an application to amend Facility Operating Licenses DPR-70 and DPR-75 for Salem Generating St~tion, Unit Nos. 1 ~nd 2.

This amendment application effectively deletes two previous amendments, Amendment No. 72 (DPR-70) and Amendment No. 46 (DPR-75), regarding residual heat removal (RHR) operation in MODES 5 and 6.

Attachment 1 contains a description, justification and significant hazards consideration evaluation. The Technical Specification pages affected by this amendment are marked up in Attachment 2.

This issue affects operation in Modes 5 and 6. Since PSE&G has revised Salem outage schedules and is*commencing the Unit 1 refueling outage as part of the current shutdown, your timely review and approval of this request would be appreciated.

In accordance with 10CFR50.91, PSE&G has provided a copy of this application to the State of New Jersey.

Sincerely,

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Attachments (2)

Affidavit r---95osoeo394 950622 - - -----------,

PDR ADOCK 05000272 P PDR

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Document Control Desk 2 LR-N95081 C Mr. T. T. Martin, Administrator - Region I U. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. 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 (S09)

USNRC Senior Resident Inspector Salem Generating Station Mr. K. Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 95-4933

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REF: LR-N95081 LCR 95-08 STATE OF NEW JERSEY SS.

COUNTY OF SALEM )

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 Nos. 1 and 2, are true to the best of my knowledge, information and belief.

Subscribed and Sworn to before me this ZZ day of JvnL 1995 SJ.u1 h d WI.~

Notary Public of New Jersey My Commission expires on ~-1~2"""-*-~-==~*___.9~~,__~~~~~~~

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Attachment 1 REF: LR-N95081 LCR 95-08 LICENSE AMENDMENT APPLICATION LCR 85-18 SALEM GENERATING STATION - UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 I. DESCRIPTION OF CHANGES Revise Specifications 3.4.1.4 and 3.9.8.2 by deleting footnotes and associated information regarding Service Water (SW) header operation to allow RHR operation to be consistent with current regulations and the Standard Technical Specifications (STS)/Westinghouse Plants (NUREG 1431). This effectively deletes previous Amendments No. 72 (DPR-70) and No. 46 (DPR-75)

(Reference LCR 85-18). The revisions are identified on the attached marked-up pages.

II. REASON FOR THE CHANGE In order to perform comprehensive SW header inspections (i.e.,

tagging the system in and out only one time during an outage),

Amendments Nos. 72 and 46 were implemented as an added precaution due to the excessive number of SW piping leaks in the mid 1980's.

This concern about system piping integrity prompted a conservative interpretation of what was required for SW to perform it's RHR support function. The amendments listed equipment (Table 3.4-3) that were required prior to header outage in MODES 5 & 6. This included equipment to ensure component redundancy in RHR, SW, and Component Cooling (CC); and equipment for Decay Heat Removal (DHR), based on a postulated complete loss of SW. Since the mid 1980's, the reliability of the SW piping has been significantly improved, with a large percentage of the pipe upgraded/replaced. Consequently, the integrity and reliability of the SW system is significantly higher. Operating experience and reduced failures support this conclusion. This was recently validated by the Service Water* System Operation Performance Inspection (SWSOPI) performed in 1994; the first strength identified was the upgraded piping.

PSE&G will continue to conduct detailed inspections of the service water system, for both Units 1 and 2, during refueling outages. Each Unit has two Service Water headers. In order to perform these inspections one header will be out of service, for a period of time during Modes 5 and 6, when two loops of RHR are required.

The requirements/proposed configurations added by the 1985 Amendments are no longer required for the following reasons:

LR-N95081 2 LCR 95-08 LCR 85-18

1. As stated above, the integrity and reliability of the system piping has been significantly upgraded.

2. The interpretation made regarding requirements for SW to perform it's RHR support function was excessively conservative, based on a failure mode that is not credible.

3. Compensatory actions for loss of RHR have been evaluated in accordance with Generic Letter (GL) 88-17 (issued subsequent to the 1985 Amendments). The precautions and compensatory actions added by the 1985 Amendments are not consistent with the requirements implemented by GL 88-17.

4. As currently configured, Salem Technical Specifications do not conform to NUREG 1431, regarding specific identification of support system requirements (e.g., SW) and, consequently, system operation is not consistent with industry practice.

Each of these items is discussed in detail in the following Section.

III. JUSTIFICATION FOR THE CHANGES Salem Technical Specifications require residual heat removal loops to be available in Modes 5 and 6 as follows:

Mode 5 Two RHR loops are required to be operable if no steam generators are available.

Mode 6 Two RHR loops are required to be operable if the water level in the refueling cavity is less than 23 feet above the reactor vessel flange.

Since service water supplies the ultimate heat sink for the RHR system, Amendments 72 and 46 added the precautions of Table 3.4-3, listing equipment required for a SW header outage. This included equipment necessary to ensure two RHR loops are available and equipment required for DHR should all RHR be lost, based on a postulated complete loss of SW, due to a catastrophic piping failure. The short term DHR methods discussed in the Amendments were use of the Refueling Water Storage Tank (RWST) and Spent Fuel Pool (SPF) as heat sinks. The long term DHR method discussed was a make-up and boil-off process, including potential venting of the containment. In addition, the Amendments discussed loss of offsite power, in conjunction with a complete loss of SW, noting the availability of the gas turbine generating unit as a back-up source of power.

LR N95081 3 LCR 95-08 LCR 85-18 The premise on which Amendments 72 and 46 were based was the excessive number of piping leaks of the SW system in the mid-1980 's. This resulted in the listing of required equipment (Table 3.4-3) and the conservative interpretation that both passive loops of SW were required to have both loops of RHR.

This premise no longer exists; the reliability of SW has been significantly improved. This is further reinforced by the fact that SW is a moderate energy system; complete catastrophic failure is not a credible failure scenario. Regulatory guidance (Branch Technical Position 3-1) for moderate energy systems does not require postulating pipe breaks. Plant and industry operating experience documents that passive failures (leaks) can cause soine system degradation, but not loss of system function.

Plant operating experience and the recent SWSOPI document and validate the improved reliability. Consistent with industry practice, active component redundancy on a single passive SW loop adequately supports RHR during all phases of operation in Modes 5

& 6.(i.e., one piping path is adequate providing it supports both RHR loops)

Based on the preceding, it is not necessary or appropriate to establish compensatory OHR actions based on a non-credible failure. Therefore, the OHR compensatory actions established by Amendments 72 and 46, including the 45 day limit and gas turbine provision contained in the Bases, will be deleted from the Technical Specifications.

To ensure active component redundancy and eliminate single failure points, several compensatory actions have been taken.

Single failure point valves will be either disabled or locked open, with the exception of air operated temperature/flow control valves of the CCW heat exchangers. These valves fail in the safe position, on loss of air. The operators will closely monitor the critical temperature and pressure readings in order to detect any problem that may develop and take appropriate corrective action.

An existing procedure identifies the requirements that must be met before entering into the desired configuration (i.e., one service water loop. out for maintenance in Modes 5 and 6). The procedure includes the following:

• A requirement that two RHR, two cc, and two SW pumps, powered from two different vital buses be kept operable

• A listing of valves to be locked open or disabled Since Amendments 72 and 46 were implemented in 1985, loss of RHR has been extensively evaluated in accordance with GL 88-17.

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LR N95081 4 LCR 95-08 Attachment 1 LCR 85-18 Procedural guidance to ensure adequate DHR capability exists have been developed. Loss of RHR is addressed by procedure Sl.OP.AB.RHR-0001, which is based on guidance provided by Westinghouse Owners Group Abnormal Operating Procedure (WOG-ARG-1), Loss of RHR while Operating at Mid-Loop. Actions postulated by Amendments 72 and 46 (regarding short and long term DHR, including containment venting) are based on a non-credible failure (catastrophic failure of SW) and are not consistent with actions taken to address GL 88-17.

The current Technical Specification configuration is not consistent with industry approaches and differs from NUREG 1431.

NUREG 1431 does not include specific identification of support system requirements. This proposed change will conform to NUREG 1431, with regard to support systems (e.g., SW), and will permit operation consistent with industry practices, while ensuring necessary precautions and compensatory actions are in place.

Based on the preceding, the DHR methods and loss of offsite power scenario postulated in Amendments 72 and 46 do not need to be considered since they were based on a non-credible failure mode, and are not consistent with regulatory guidance. Therefore the Amendments should be deleted.

IV. SIGNIFICANT HAZARDS CONSIDERATION EVALUATION The proposed changes to the Technical Specifications:

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

Even though one service water loop will be out for maintenance, both loops of residual heat removal (RHR) will be kept operable, consistent with the requirements of STS (NUREG 1431). A minimum of two RHR, two component cooling (CC), and two service water (SW) pumps, powered from two different vital busses, will be kept operable.

Only one component cooling heat exchanger will be operable since only one service water loop is operable. The CC heat exchangers for both Units 1 and 2 have a very high reliability.

The primary heat transfer surfaces of the heat exchangers are made of titanium; no material problems have been experienced in ten years of service.

The remaining active components that, through misoperation, could

LR-N95081 5 LCR 95-08 LCR 85-18 potentially defeat RHR capability are, (1) the motor operated valves in RHR or SW that could develop a "hot short" and subsequently close and (2) the air operated temperature/flow control valves of the CC heat exchangers. Additional actions will be taken to effectively eliminate the possibility of these single point valves from failing and defeating RHR capability.

The motor operator breakers will be tagged open during MODES 5 and 6, except for flooding the cavity, when the RHR suction valves must be closed. The CC Heat Exchanger air operated temperature/flow control valves fail open, or as is, on loss of air which is the safe position. Operators will monitor critical temperatures; this equipment is accessible if any corrective action is required. Thus, with one service water header out of service, the intent of the technical specifications as defined in the bases section (to have a single failure proof RHR system) is met with the proposed system configuration. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

The catastrophic failure of a moderate energy Class 3 piping system is not a credible event, based on the upgraded reliability of the system, the redundancy of active components, the elimination of single failure points, and on the industry and regulatory positions established for this type of system. Since SW is a Class 3 moderate energy system, the only postulated passive failure mode is a leakage crack. . In accordance with Generic Letter (GL) 91-18 and GL 90-05, a leak in the SW system, following acceptable evaluation, does not constitute a failure that causes the loss of capabiiity to perform it's intended safety function. A moderate energy Class 3 piping leak does not cause the system to be declared inoperable. Therefore, the proposed changes do not create the possibility of a new or different type of accident from any previously evaluated.

3. Do not involve a significant reduction in a margin of safety RHR redundancy is maintained; no credible single failure point exists that could cause a nonrecoverable loss of SW. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

V. CONCLUSION As discussed above, the proposed changes do not involve a

LR-N95081 6 LCR 95-08 LCR 85-18 significant hazards consideration since the changes: (i) do not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) do not create the possibility of a new or different kind of accident previously evaluated, and (iii) do not involve a significant reduction in a margin of safety.

In addition, proposed technical specification changes will result in an alignment of Salem Technical Specifications with NUREG 1431, inspection practices consistent with the industry, and an overall improvement in plant safety due to several factors discussed below.

The postulated failure mode of Amendments 72 and 46 is no longer credible, consistent with current regulatory guidance.

Additionally, the premise which prompted the earlier Amendments no longer exists; the reliability of the SW piping has been significantly improved. By deleting Amendments 72 and 46, Salem will be consistent with industry practices. The efficiency associated with a single outage for each SW header (i.e., tagged in and out of service only once) will permit the implementation of a comprehensive inspection and maintenance program.

The compensatory actions to disable the motor operated valves in RHR and SW (except when flooding the cavity when the RHR suction valves must be closed), eliminate active failure points that could interrupt flow. These actions, combined with the other actions taken, ensure there are no credible single failures that could cause a nonrecoverable loss of SW.

LR-N95081 7 LCR 95-08 LCR 85-18 REFERENCES

1. December 19, 1985 Letter, McNeil! (PSE&G) to Varga (NRC):

Request for Additional Information - Service Water Header Outage

2. NUREG 1431, Standard Technical Specifications, Westinghouse Plants

3. Salem Generating Station, Units 1 and 2 Updated Final Safety Analysis Report. *

4. GL 88-17, Loss of Decay Heat

5. BTP 3-1, Protection Against Postulated Piping Failures In Fluid Systems Outside Containment

6. GL 91-18, Information to Licenses Regarding Two NRC Inspection Manual Sections On Resolution of Degraded and Nonconforming Conditions and on Operability

7. GL 90-05, Guidance For Performing Temporary Non-Code Repairs Of ASME'Code Class 1, 2 and 3 Piping

8. Standard Review Plan, Section 9.2.1, Station Service Water