ML18095A381

Application for Amend to License DPR-75,revising Emergency Diesel Generator Tech Specs,Per Generic Ltr 84-15, Proposed Staff Actions to Improve & Maintain Diesel Generator Reliability.

ML18095A381
Person / Time
Site:	Salem
Issue date:	07/27/1990
From:	LABRUNA S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18095A382	List: ML18095A381 ML18095A383
References
GL-84-15, NLR-N90156, NUDOCS 9008030267
Download: ML18095A381 (6)

Text

Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800 Vice President

-Nuclear Operations ( *-z 7 1990 NLR-N90156 LCR 87-07 United States Regulatory Commission Document Control Desk '. Washington DC 20555 Gentlemen:

EXIGENT REQUEST FOR LICENSE AMENDMENT EMERGENCY DIESEL GENERATOR TESTING FREQUENCY SALEM GENERATING STATION UNIT NO. 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 By letter dated November 20, 1987 (NLR-N87127), PSE&G submitted a request for amendment to revise the Salem Generating Station Emergency Diesel Generator (EDG) Technical Specifications.

The amendment request was based on Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability." PSE&G is presently finalizing a revision to the November 20, 1987 submittal, in order to resolve NRC comments.

The existing EDG Surveillance Requirements for Salem Unit No. 2 specify a test frequency according to diesel failure rate on a per nuclear unit basis. The present testing frequency is once per three days for each of the three diesel generators, or one diesel start per day. Testing on this frequency is inconsistent with Generic Letter 84-15, which recommends a maximum test frequency of once per 7 days, based on the failure rate per diesel generator.

In order to avoid the excessive number of diesel starts required by the present Technical Specifications and diesel failure history, PSE&G is hereby requesting exigent approval of the changes to Salem Unit No. 2 Technical Specification Table 4.8-1, as proposed by the November 20, 1987 submittal.

The revised response to-Generic Letter 84-15 will be sent under separate cover. PSE&G's conclusions regarding No Significant Hazards Analysis, contained in the November 20, 1987 amendment request, remain valid. Attachment 1 provides the description and justification for the change, including a reiteration of the applicable portions of the original Determination of No Significant Hazards Consideration.

It also contains justification for processing this request on an exigent basis. Attachment 2 contains the affected Technical Specification page 9()()*::.(-1"*":*(")""":*(-

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.. Document Control Desk NLR-N90156 revised with pen and ink changes. .dUL 2 7 1990 Because approval of this request would allow an immediate reduction in the frequency of diesel starts for Salem Unit No. 2 consistent with the recommendations of Generic Letter 84-15, please issue an NRC approved License amendment as soon as possible.

Should you have any questions regarding this submittal, please do not hesitate to contact us. Affidavit Attachments (2) c Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Sincerely, Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 REF: NLR-N90156 LCR 87-07 STATE OF NEW JERSEY COUNTY OF SALEM SS. Stanley LaBruna, 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 our letter dated, , concerning the Salem Generating Station, Unit No. 2, are true to the best of my knowledge, information and belief. My Commission expires lARAINE Y. Bi:ARD Notary *public of New Jersey My Commission Expires May 1, 1991 NLR-N90156 ATTACHMENT 1 BACKGROUND PSE&G's amendment request of November 20, 1987 was based on Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability." There are substantial differences between the Technical Specifications proposed in the Generic Letter and the present Salem Technical Specifications.

These differences are attributable to the fact that Salem Unit 1 Technical Specifications were approved prior to issuance of Standard Technical Specifications.

In addition, certain aspects of Salem's design result in differences from the more generic (e.g., as described in Regulatory Guide 1.108 and in Standard Technical Specifications)

EDG testing programs.

Therefore, while the November 20, 1987 submittal proposed to incorporate many of the changes proposed in Generic Letter 84-15, there were several exceptions.

The NRC requested clarifications and revisions to the original submittal, primarily based on differences from Generic

• Letter 84-15. PSE&G is in the process of finalizing a revised amendment request. However, since present circumstances at Salem Unit No. 2 require accelerated EDG testing, PSE&G is requesting an exigent review of a portion of the original submittal.

DESCRIPTION OF PROPOSED CHANGE Table 4.8-1 of Salem Unit No. 2 Technical Specifications requires EDG testing frequency to be established according to the number of failures in the last 100 tests on a per nuclear unit basis. In accordance with Generic Letter 84-15, the proposed Table 4.8-1 will specify a testing frequency based on the number of failures in the last 20 tests on a per diesel generator basis. JUSTIFICATION FOR THE PROPOSED CHANGE Table 4.8-1 of the present Technical Specifications is inconsistent with Generic Letter 84-15, which recommends determining the test frequency based on the failure rate on a per diesel generator basis. In addition, Table 4.8-1 of the Generic Letter specifies a maximum test frequency of once per.7 days. Therefore, approval of Table 4.8-1 as proposed in the November 20, 1987 letter (which is identical to that of Generic Letter 84-15) would result in an immediate reduction in test frequency and prevent PSE&G from having to perform the excessively high number of tests required in the present situation (i.e., one diesel start per day). The basis for reducing the test frequency in the proposed manner is the adverse impact of excessive diesel starts on overall reliability of the engines. Generic Letter 84-15, Table 4.8-2 provides additional reliability actions based on a matrix of the number of failures in the last 20 and 100 tests per diesel generator.

The actions specified by NLR-N90156 this table could result in an accelerated test frequency beyond that of Table 4.8-1. Although the November 20, 1987 submittal included a new Table 4.8-2, subsequent discussions with the NRC staff indicate that the table is no longer considered necessary to satisfy Generic Letter 84-15. Therefore, PSE&G's revised Generic Letter 84-15 submittal will not contain Table 4.8-2, and the actions specified in the table are not considered applicable to the request contained herein. JUSTIFICATION FOR EXIGENT CIRCUMSTANCES Based on the results of the last 100 valid tests, the present test frequency is once per 3 days for each of the three Unit 2 EDG's. Table 1 provides a summary of test results and shows the number of consecutive successful tests that would be required to reduce the frequency in accordance with the present Technical Specifications.

As shown on Table 1, 30 consecutive successful tests would be required to increase the EDG test interval to 7 days per the present Technical Specifications; 35 tests would be required for a 31 day interval.

In order to prevent excessive diesel starts, consistent with the NRC's recommendations, exigent approval of proposed Table 4.8-1 would result in a 31 day interval for each Unit 2 EDG, and would assure that the interval would not be less than 7 days. If the normal approval process is used, including the thirty day public comment period, then the accelerated testing schedule would result in a significant number of additional diesel starts. These additional starts have been shown to be unnecessary by Generic Letter 84-15. Therefore, approval of this request on an exigent basis will eliminate undue wear and stress on the diesel engines, without resulting in a reduction in safety. JUSTIFICATION FOR CATEGORICAL EXCLUSION 10CFR51.22 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 Hazards Consideration is presented in the following section. 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 reduction in EDG testing frequency will not involve a change in any types of effluents released offsite. Reducing test frequency will not increase the amounts of any effluents released, but will reduce the total amount of diesel engine exhaust emissions.

NLR-N90156 iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed change does not involve any increase in occupational radiation exposure.

Therefore, PSE&G has concluded that the proposed change qualifies for a categorical exclusion pursuant to 10 CFR 51.22. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The request proposed herein does not invalidate the Determination of No Significant Hazards Consideration presented in the November 20, 1987 submittal.

For convenience, the applicable portions of the original determination are provided below. The proposed change to Technical Specifications Table 4.8-1 for Salem Unit No. 2: (1) does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Reducing the test frequency is intended to increase overall diesel reliability by minimizing severe test con.ditions which can lead to premature failures.

The proposed change will continue to assure availability of the diesels and should serve to enhance the reliability and consequently the overall safe operation of the diesel generators.

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

The proposed change affects only EDG testing frequency and has no impact on the accident analysis.

No new operating modes or equipment are introduced which could initiate or affect the progression of an accident.

(3) involve a significant reduction in a margin of safety. The change in the testing frequency does not adversely affect the capability of the diesels to perform their required function.

Rather, the purpose of the proposed change is to increase the overall reliability of the diesels consistent with Generic Letter 84-15.