ML18093A915

Application for Amends to Licenses DPR-70 & DPR-75, Correcting Typos in Tech Spec Sections 3.1.3.4. & 3.1.3.5, Including Changes to Clarify Applicability of Surveillance Requirement for Rod Position Verification.Fee Paid

ML18093A915
Person / Time
Site:	Salem
Issue date:	06/23/1988
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18093A916	List: ML18093A915 ML18093A918
References
NLR-N88083, NUDOCS 8807010591
Download: ML18093A915 (6)

Text

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• Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer June 23, 1988 NLR-N88083 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR AMENDMENT FACILITY OPERATING LICENSES DPR-70 AND DPR-75 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272, 50-311 Public Service Electric and Gas Company (PSE&G) hereby transmits a request for amendment for Facility Operating Licenses DPR-70 and DPR-75 for Salem Generating Station (SGS), Unit Nos. 1 and

2. In accordance with the requirements of 10CFR170.21, a check in the amount of $150.00 is enclosed. Pursuant to the requirements of 10CFR50.9l(b) (1), a copy of this request has been sent to the State of New Jersey as indicated below.

The enclosed License Change Request (LCR 88-01) is intended to correct typographical errors incorporated by a previously approved amendment. Additional changes are included to clarify the applicability of a surveillance requirement for rod position verification. The proposed changes affect Technical Specification sections 3.1.3.4 and 3.1.3.5 for both Salem units.

The proposed changes are administrative in nature in that they either correct typographical errors or clarify existing requirements without changing either the intent of, or basis for, the existing specification. Since the proposed changes are administrative, no significant amount of specialized technical review should be required for approval of this request.

Therefore, PSE&G believes that the proposed change can be classified as a Category 2 change.

Document Control Desk 2

• 06-23-88 contains further discussion and justification for the proposed revisions. This submittal includes one (1) signed original, including affidavit, and thirty-seven (37) copies pursuant to 10CFRS0.4(b) (2) (ii).

Should you have any questions on the subject transmittal, please do not hesitate to contact us.

Sincerely, Enclosures C Mr. D. C. Fischer USNRC Licensing Project Manager Mr. R. w. Borchardt USNRC Senior Resident Inspector Mr. w. T. Russell, Administrator USNRC Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628

Ref: LCR 88-01 STATE OF NEW JERSEY SS.

COUNTY OF SALEM Steven E. Miltenberger, being duly sworn according to law deposes and says:

I am Vice President and Chief Nuclear Officer of Public Service I.

Electric and Gas Company, and as such, I find the matters set

!

forth in our letter dated June 23, 1988 , concerning Facility Operating Licenses DPR-70 and DPR-75 for Salem Generating Station, are true to the best of my knowledge, information and belief.

- No~Slry,._Public of New Jersey \ffl'\NITA M. Mffe.!1Smi..u NOTARY PUBUC CF ~~aoJ .~~msn My Commission expires on Mv Commissian [;;q:ilrns r~av 6. iQ!JJS

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LCR 88-01 Page 1 of 3 PROPOSED LICENSE CHANGE TECHNICAL SPECIFICATIONS SALEM GENERATING STATION UNIT NOS. 1 AND 2 Description of Change Delete the words "within one hour after rod motion" from Technical Specification Surveillance 4.1.3.4 and 4.1.3.5.

Addition of a footnote to clarify the applicability of Surveillance 4.1.3.4.a. A copy of the proposed specification is attached. Also attached for your convenience is a markup of the existing specification showing the proposed change.

Reason for Change Technical Specification Surveillance 4.1.3.4 is intended to provide a means of performing the surveillance on the shutdown rods within 15 minutes prior to withdrawal of any rods in the control bank and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

Technical Specification Surveillance 4.1.3.5 is intended to provide a means of performing the surveillance on the control rods to be within the insertion limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if the Rod Insertion Limit Monitor*

is inoperable.

It is PSE&G's position that the words "within one hour after rod motion" were a result of a wording error introduced by previous License Change Request 85-12. The error was overlooked in our review, prior to submittal to the NRC. This prior LCR resulted in Amendment No. 73 for Unit 1 and Amendment 48 for Unit 2.

The original LCR (85-12) was submitted to alleviate difficulties encountered in calibration of the Analog Rod Position Indication (ARPI) system. LCR 85-12 shifted rod position determination from the ARPI to the group step counters with subsequent verification by the ARPis. Comparison of group step counters to the ARPis (allowing one hour for thermal soak after rod motion) was sufficient verification of the rod position. The requirement of Technical Specification 3.1.3.2.1 that the capability exists to determine rod position "within one hour of rod motion (allowance for thermal soak)" was apparently transposed to require verification of rod position within one hour of rod motion in other specifications. A review of the NRC SER issuing this change clearly indicates that an allowance of one hour for rod soak following rod motion is acceptable and desirable. There is no discussion of the requirement to verify position within one hour of rod motion in the NRC SER.

As worded in the surveillance specification now, compliance to this requirement precludes Automatic Rod Control since the operator would have to account for every rod motion. This is not practical nor necessary since the operator uses the appropriate indication during rod manipulations.

e LCR 88-01 Page 2 of 3 There is no bases to support the requirement to document a verification of shutdown or control rod position after each movement of rods. The bases section of both the Salem and Westinghouse Standard Technical Specifications state that: "Rod position and OPERABILITY of the rod position indicators are required to be verified on a nominal basis of once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with more frequent verifications required if an automatic monitoring channel is inoperable. These verification frequencies are adequate for assuring that the applicable LCO's are satisfied." There is no requirement for the verification of rod position changes within one hour of rod motion in the Westinghouse Standard Technical Specifications.

Further indication that the wording in Section 4.1.3.4 and 4.1.3.5 is in error is found in Sections 4.1.3.1.1 and 4.1.3.2.1.1 which both state that comparison of the group demand position indicators and the ARPI should be performed once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (allowing for one hour thermal soak after rod motion).

Additionally, a review of Technical Specifications from 25 Westinghouse plants shows that the requirement to verify rod position within one hour of rod motion is unique to the Salem Technical Specifications.

A footnote was added and other changes were made to clarify that Specification 4.1.3.4.a is applicable only when withdrawing control banks in preparation for Mode 2. Mode 2 is defined as Keff > 0.99. Control banks can be pulled prior to Keff reaching 0.99. Therefore, as currently written, Specification 4.1.3.4.a does not correspond with the applicability statement.

No Significant Hazards Evaluation The proposed changes to Technical Specifications 3/4.1.3.4 and 3/4.1.3.5 for both Salem 1 and 2 do not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated. Verifying rod position and rod position indicators on a nominal basis of once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with more frequent verification required if an automatic monitoring channel is inoperable is acceptable as per the basis of these Technical Specification Surveillance. The bases state that the verification frequencies are adequate for assuring that the applicable LCO's are satisfied.

The change does not alter the use of the rod control system and operation of the plant would remain the same. The operation of the rods will still be consistent with present criteria which has been established and considered in the consequences of the accidents already evaluated.

LCR 88-01 Page 3 of 3 (2) create the possibility of a new or different kind of accident from an accident previously evaluated. The requested change does not alter the surveillances in any way which is outside the scope of the intent indicated in the bases of the Salem and Westinghouse Standard Technical Specification Surveillances. The revised surveillance will continue to assure that the applicable LCO's are satisfied and will be consistent with other Westinghouse designed plants. The operation of the rod control system will not change and therefore, no new or different kinds of accidents can be created.

(3) involve a significant reduction in a margin of safety. The change in the surveillance requirement does not affect the operation of the rod control system in any way. The change only affects the frequency that the position of the rods are documented. Independent of the requirement for verification of rod position once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the operators have continuous display of the rod positions. Since the proposed change does not affect the minimum surveillance frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as supported in the bases, the change does not reduce the margin of safety.

These changes mainly clarify the surveillance requirements necessary to ~nsure the LCO's requirements are satisfied. The proposed amendment corresponds to example II.! of 48 FR 14870 as a purely administrative change to correct an error. Thus, PSE&G has concluded that the proposed change to the Technical Speci-fications do not involve a significant hazards consideration.

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