ML18089A373

Application for Amend to Licenses DPR-70 & DPR-75,changing Tech Specs Re Allowable Time to Depressurize & Vent RCS Through 3.14 Square Inch Vent Path & Method for Ensuring Closed Block Valves

ML18089A373
Person / Time
Site:	Salem
Issue date:	09/19/1983
From:	Liden E Public Service Enterprise Group
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML18089A374	List: ML18089A373 ML18089A375
References
LCR-83-10, LCR-83-11, NUDOCS 8309270293
Download: ML18089A373 (6)

Text

PS~G*

Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department Ref: LCR 83-10 LCR 83-11 September 19, 1983 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Steven Varga, Chief Operations Reactors Branch 1 Division of Licensing Gentlemen:

REQUEST FOR AMENDMENT FACILITY OPERATING LICENSES DPR-70 AND DPR-75 NO. 1 AND 2 UNITS SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 In accordance with the Atomic Energy Act of 1954, as amended and the regulations thereunder, we hereby transmit copies of our request for amendment and our analyses of the changes to Facil-ity Operating License DPR-70 for Salem Generating Station, Unit No. 1 and DPR-75 for Salem Generating Station Unit No. 2.

This request proposes to change the allowable time to depressur-ize and vent the reactor coolant system through a 3.14 square inch vent path in the event of an inoperable Pressurizer Over-pressure Protection System (LCR 83-10) and to change the method for ensuring closed block valves in the event of inoperable power operated relief/block valves (LCR 83-11).

The changes do not involve significant hazards considerations and each change involves consideration of a single safety issue for one unit and is a duplicate for the second unit; therefore, the proposed amendments are deemed to be Class III and Class I Amendments respectively as defined by 10CFR 170.22. A check in the amount of $8,800 will be sent to you under separate cover.

Pursuant to the requirements of 10 CFR50.9l(b)(l), a copy of this request for amendment has been sent to the State of New Jersey as indicated below.

8309270293 830919 PDR ADOCK 05000272 P PDR The Energy People 95-21 68 (80 M) 11-82

Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 9/19/83 1

This submittal includes three (3) signed originals and forty (40) copies.

Very truly yours,

~

E~ Liden Manager - Nuclear Licensing and Regulation Enclosure CC: Mr. Donald C. Fischer Licensing Project Manager Mr. James Linville Senior Resident Inspector Mr. Frank Cosolito, Acting Chief Bureau of Radiation Protection Department of Environmental Protection 380 Scotch Road Trenton, New Jersey 08628

STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

RICHARD A. UDERITZ, being duly sworn according to law deposes and says:

I am a Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our Request for Amendment to Facility Operating Licenses DPR-70 and DPR-75 dated September 19, 1983, concerning Pressurizer Overpressure Protection System (LCR 83-10) and Pressurizer PORV/Block Valves (LCR 83-11), are true to the best of my knowledge, information and belief.

Subscribed and sworn to before me P'Jtnl**L'-"r1* *L. \'On ;=:cf-'1-=""i' *.-*

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i*::y Notary Public of New tc~:,,~

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My Commission expires on iJ * *:iept. I 0, 11'?.'!.'-".

LCR 83-10 PROPOSED LICENSE CHANGE

.SALEM GENERATING STATION NO. 1 ~ND 2 UNITS DOCKET NO. 50-272 AND 50-311 Reactor Coolant System Overpressure Protection System Limiting Condition for Operation Description ~f Ch~nge Change the actio~ statements in paragraph (a) and (h) of the limiting condition for operation in Technical Specification Sections 3.4.9.3 (Unit 1) and 3.4.10.3 (Unit 2) to read as follows:

a * . With one POPS inoperable, either restore the inoperable POPS to OPERABLE status within 7 days or depressurize and vent the RCS through a 3.14 square inch vent(s) within the next 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s~ maintain the RCS in a vented condition until both POPS have been restored to OPERABLE status.

b. With both POPS inoperable, depressurize and vent the RCS through a 3.14 square inch vent(s) within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s~ maintain RCS in a vented condition until both POPS have been restored to OPERABLE status.

Reason for Change The existing action statements in limiting condtion for operation presently require that the Reactor Coolant System (RCS) be depressurized and vented through a 3.14 square inch vent(s) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if both Pressurizer Overpressure Protection System (POPS) relief valves are inoperable or one POPS is inoperable and can not be restored to OPERABLE status within 7 days.

Depressurization and venting of the RCS require that the steam bubble in the pressurizer be eliminated, reactor coolant be degassed to eliminate hydrogen buildup and hence possibility of explosion, and the pressurizer power operated relief valves (PORVs) be gagged open to establish the required vent path. The current requirement to depressurize and vent the RCS within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not realistic. Given the amount of time _it takes to perform each step, the entire sequence of events required to depressurize and vent the RCS could take up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

LCR 83-10 Page 2 Safety Evaluation The Pressurizer Overpressure Protection System (POPS) relief valves are provided to protect the RCS from pressure transients which could exceed the limits of Appendix G to 10CFR Part 50 when one or more RCS cold leg temperature is at or below 312°F.

-Either POPS has adequate relieving capacity to protect the RCS from overpressurization as a result of the limiting heat input or mass input cases, namely i) the start of an idle Reactor Coolant Pump (RCP) with the secondary water temperature of the steam generator less than or equal to 50°F above RCS cold leg temperature or ii) the start of a safety injection pump and its injection into the water solid RCS.

A number of provisions for prevention of pressure transients below P-.7 (when the RCS temperature is below 312°F) presently exists. Current Specification 3.4.1.3 for stratup (and joggin~)

a RCP requir~s that a steam bubble must be established in the pressurizer prior to pump start or the SG/RCS AT be verified to be less than 50°F. Also Technical Specification 3.5.3 allows a maximum of one safety injection pump to remain operable and power to all inoperable safety injection pumps must be removed by racking out the power supply breakers when the RCS temperature is below 350°F. Also the shutdown procedure requires that a steam bubble be maintained in the pressurizer during plant cooldowns.

The Residual Heat Removal (RHR) System is initiated once the RCS temperature is below 350°F but above 312°F. The RHR system provides relief capacity for which no credit has been taken in the low temperature overpressure analysis.

Upon detection that both of the POPS relief v.alves are inoperable, the RCS will be depressurized and a vent path will be established as soon as realistically achievable which could require a time period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The intent of the existing Technical Specification to depressurize and vent the RCS upon detection of inoperable POPS relief valves is met and the proposed change does not involv~ a substantial safety hazard as the following criteria are fulfilled:

a. Probability of ocurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report will not be significantly increased.

The requested change when approved will. increase the allowable time .period within which the RCS will he depressurized. However, the protective features described above will be available. Depressurization of the RCS will

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LCR 83-10 Page 3 be initiated and a vent path will be established through a 3.14 square inch opening(s) as soon as realistically achievable (but within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) so that the maximum RCS pressure will remain below the Appendix G limits.

b * . The possibility of .an accident or malfunction of a different type than any evaluated previously in the safety analysis report will not be created.

The requested change will only extend the allowable time period required to depressurize and vent the RCS, and does not involve any physical change in design. With the protective procedural and administrative measures, this will not impact the safe operation of any system, component or structure required for safety.*

c. The margin of safety as defined in the basis for any Technical Specification is not significantly reduced.

A vent opening of greater than or equal to 3.14 square inches has adequate relieving capacity as either POPS relief valves so that the RCS pressure temperatue limits as identified in the bases for the Technical Specification is maint~ined within the Appendix.G limits. The margin of safety provided by depressurizing and venting the system within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following the determination that both POPSs are inoperable is not realistically achievahle *. With the protective measures described above, the margin of safety will not be significantly reduced even when the allowable time period to depressurize and vent RCS is increased to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.