ML18102A979

Application for Amends to Licenses DPR-70 & DPR-75, Increasing Cw Flow to 2550 Gpm for 31 Day Surveillance Fans Started & Operated in Low Speed

ML18102A979
Person / Time
Site:	Salem
Issue date:	04/11/1997
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102A980	List: ML18102A979 ML18102A981
References
LCR-S95-10, LR-N970149, NUDOCS 9704220137
Download: ML18102A979 (9)

Text

• • Public Service Electric and Gas Company Louis F. Storz Public SeNice Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations APR 111997 LR-N970149 LCR S95-10 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS CONTAINMENT COOLING SYSTEM SALEM GENERATING STATION NOS. 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 hereby requests a revision to the Technical Specifications (TS) for the Salem Generating Station Unit Nos. 1 and 2. In accordance with 10CFR50. 91 (b) ( 1) , a copy of this submittal has been sent to the State of New Jersey.

The proposed Technical Specification changes contained herein represent changes to Specification 3.6.2.3, "Containment Cooling System" and the associated bases. These changes increase the cooling wate~ flow rate to ~ 2550 gpm for the 31 day and 18 month surveillances and specifies that during the 31 day surveillance the fans are started and operated in low speed.

PSE&G requests these changes to ensure that the cooling water flow rate and fan speed being verified is representative of the Containment Fan Cooling Unit (CFCU) post-accident mode of operation.

The proposed changes have been evaluated in accordance with 10CFR50.91(a) (1), using the criteria in 10CFR50.92(c), and it has been determined 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 Technical Specification pages affected by the proposed changes are provided in Attachment 3.

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,Document Control Desk tR-N970149 Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities.

Should you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely, a~~

Affidavit Attachments (3)

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 415 Trenton, NJ 08625

REF: LR-N970149 LCR 895-10 STATE OF NEW JERSEY SS.

COUNTY OF SALEM 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 Sworn}/ ?efore me this //ff\ day of~.JJ__ , 1997 ijbtary KIMBERLY JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission expires on ~~~~~M~v=Co=m=mi=ss=ion~E=xp~ir~es~A~pr_il2_1~,_19_98~~~

Document Control

.k LR-N970149 LCR S95-10 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 CONTAINMENT COOLING SYSTEM BASIS FOR REQUESTED CHANGE REQUESTED CHANGE AND PURPOSE The requested changes to Technical Specification 3.6.2.3, "Containment Cooling System," consist of revising the Surveillance Requirements to reflect the fan speed and cooling water flow rate required during the post-accident mode of operation and adding 50 gpm to the flow rate to account for the motor cooling flow for the Containment Fan Cooling Unit (CFCU).

Bases section 3/4.6.2.3 is being revised to reflect the reason for performing flow verification of CFCUs in the post-accident mode of operation.

Surveillance Requirements 4.6.2.3.a(3) and 4.6.2.3.b(2) are being revised to verify a cooling water flow rate of ~ 2550 gpm to each CFCU. The revised flow rate is based on the flow rate required for the post-accident mode of CFCU operation and includes 50 gpm used for cooling of the CFCU motor.

Surveillance Requirements 4.6.2.3.a(l) and 4.6.2.3.a(2) are also being revised to clarify that each CFCU shall be demonstrated operable by starting and operating each fan in low speed.

The proposed changes are made to ensure that the flow rate and fan speed being verified by the Surveillance Requirement 4.6.2.3 are representative of the CFCU post-accident mode of operation.

Bases section 3/4.6.2.3 is being revised to delete the reference that this surveillance ensures that the containment air temperature will be maintained within limits during normal operation. The purpose of technical specification 3/4.6.2.3 is to verify adequate post-accident containment cooling ability.

Verification that the containment air temperature is maintained below the initial temperature condition assumed in the accident analysis during normal operation is performed by specification 3/4.6.1.5.

BACKGROUND The Containment Fan Cooling Units satisfy Criterion 3 of the NRC Final Acceptance Criteria (10CFR50.36) in that they are components that are part of the primary success path and which function or actuate to mitigate a Design Basis Accident or Page 1 of 3

Document Control LR-N970149 LCR S95-10 Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The proposed changes are therefore being made to ensure that Surveillance Requirement 4.6.2.3 verifies CFCU operability in the post-accident mode of operation.

During normal operation, the CFCUs operate (as required) to remove heat from the containment to keep the containment average air temperature below 120°F. For normal operation, the CFCU is operated in high speed with service water flow through each CFCU about 700 - 900 gpm.

Following a Loss of Coolant Accident (LOCA) or Main Steam Line Break (MSLB), the CFCUs are automatically placed in accident mode. The Safeguards Equipment Control (SEC) System automatically stops all operating CFCUs and then automatically starts all 5 CFCUs in the low speed mode (post-accident mode) .

In the event of a Loss of Offsite Power coincident with a LOCA or MSLB, a minimum of 3 CFCUs will be automatically started in low speed and powered from the Emergency Diesel Generators. For the accident condition, the service water flow through each CFCU is a minimum of 2550 gpm, including adequate cooling water flow to CFCU motor cooler, and the CFCU is operated in low speed.

JUSTIFICATION OF REQUESTED CHANGES Surveillance Requirements 4.6.2.3.a(l) and 4.6.2.3.a(2) currently do not specify the speed in which each fan must be started and operated. The fans operate in high speed during the normal mode of operation and low speed during the post-accident mode. In order to verify adequate post-accident mode of operation, the two Surveillance Requirements are being modified to stipulate that the fans are to be started and operated in low speed. This requirement is justified by the fact that the high speed (normal) and low speed (post-accident) circuit breakers and control circuits are isolated from each other. The separation is accomplished by using independent breaker control circuits and separate circuit breakers to energize the CFCU in high and low speed operation. Since the high speed and low speed control circuits are independent and there are separate breakers used to energize the CFCU motors in high and low speed, the CFCUs would be capable of starting in the low speed mode following a DBA although the high speed breaker and control circuit may not be available.

Surveillance Requirement 4.6.2.3.a(3) currently verifies cooling water flow at a rate of ~ 700 gpm. This surveillance is required to be performed at least once every 31 days and verifies the flow rate required for normal operation of the CFCUs. However, to Page 2 of 3 Document Control Desk LR-N970149 LCR S95-10 ensure that the CFCUs are capable of performing their accident mitigation function, the flow rate being verified must be the post-accident mode of operation flow rate. Therefore, the requested change revises the cooling water flow rate from ~ 700 gpm to ~ 2550 gpm in Surveillance Requirement 4.6.2.3.a(3).

Verification of the post-accident flow rate during the 31 day surveillance also ensures that the required supporting system, Service Water, is available for normal operation. To ensure that the containment air temperature is maintained below the initial temperature condition assumed in the accident analysis during normal operation, Technical Specification 3/4.6.1.5 requires verification of the average containment temperature once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Modes 1 through 4. The revised flow rate for surveillance 4.6.2.3.a(3) is the flow rate required for post-accident operation and ensures sufficient motor cooling capability exists.

Surveillance Requirement 4.6.2.3.b(2} currently does not include the additional cooling water flow to ensure that sufficient motor cooling capability exists. Therefore, the cooling water flow rate is increased from ~ 2500 gpm to ~ 2550 gpm to include the additional cooling water flow to the CFCU motor cooler.

The proposed revision to the CFCU surveillance requirements and the associated bases are consistent with the intent of the 31 day and 18 month surveillance requirements 3.6.6A.2, 3.6.6A.3, and 3.6.6A.7 specified in NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Revision 1, and its associated bases.

CONCLUSIONS The proposed changes for demonstrating operability of the CFCUs in low speed are consistent with the safety function of the CFCUs following a DBA. In addition, the proposed new flow rate reflects the minimum required SWS flow to the CFCUs in the post-accident operating mode accounting for the additional flow to ensure sufficient CFCU motor cooling. Therefore, the proposed changes will ensure that the CFCUs will be capable of maintaining peak containment pressure and temperature to within design limits.

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Document Control LR-N970149 LCR S95-10 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 CONTAINMENT COOLING SYSTEM 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has Goncluded 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 requested changes to Technical Specification 3.6.2.3, "Containment Cooling System," include specifying that the CFCUs are started and operated in low speed and changing the cooling water flow rate from ~ 700 gpm to ~ 2550 gpm, for the 31 day surveillance, and from ~ 2500 gpm to ~ 2550 gpm, for the 18 month surveillance. The proposed changes ensure that the fan speed and cooling water flow rate being verified are representative of the CFCU operation in the post-accident mode and accounts for the cooling water flow used to ensure sufficient motor cooling capability exists.

BASIS

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes ensure that the fan speed and cooling water flow rate being verified is representative of the fan speed and cooling water flow rate required for the post-accident mode of operation. The proposed changes affect an accident mitigation system and are being made to assure that the system is being tested in its accident mitigation mode.

There are no new accident initiators created by the proposed changes. Therefore, the proposed changes do not involve a significant increase in the probability of an accident previously evaluated.

The proposed changes provide assurance that the CFCUs will be capable of maintaining peak containment pressure and temperature within design limits by verifying the proper Page 1 of 3

Document Control LR-N970149 LCR S95-10 post-accident cooling water flow to the CFCUs. No physical changes to the plant result from the proposed changes to the surveillance requirements. Therefore, the proposed changes do not involve a significant increase in the consequences 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 for demonstrating operability of the CFCUs in the low speed mode, with the required post-accident cooling water flow rate, are consistent with the existing safety function of the CFCUs following a Design Basis Accident (DBA) . The proposed changes to the surveillance requirements do not involve any physical changes to plant components, systems or structures, or the operation of the CFCUs in the post-accident mode. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety.

The proposed changes to the surveillance requirements provide assurance that the CFCUs will perform their intended design function of maintaining peak containment pressure and temperature consistent with the current design basis following a DBA by verifying the proper post-accident cooling water flow to the CFCUs. Since the high speed and low speed control circuits are independent and there are separate breakers used to energize the CFCU motors in high and low speed, the CFCUs would be capable of starting in the low speed mode following a DBA although the high speed breaker and control circuit may not be available.

Verification of the post-accident flow rate during the 31 day surveillance also ensures that the required supporting system, Service Water, is available for normal operation.

To ensure that the containment air temperature is maintained below the initial temperature condition assumed in the accident analysis during normal operation, Technical Specification 3/4.6.1.5 requires verification of the average containment temperature once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Modes 1 through 4.

The proposed changes to the CFCU surveillance requirements do not affect the ability of the CFCUs to perform their Page 2 of 3

Document Control LR-N970149 LCR 895-10 normal and post-accident functions. These proposed changes ensure the verification of the proper post-accident service water flow rate to the CFCUs. Therefore, the proposed changes do 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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