ML18101A260

Application for Amends to Licenses DPR-70 & DPR-75,revising Containment Spray Sys Surveillance Frequency

ML18101A260
Person / Time
Site:	Salem
Issue date:	09/29/1994
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18101A262	List: ML18101A260 ML18101A264
References
LCR-94-29, NLR-N94159, NUDOCS 9410070147
Download: ML18101A260 (6)

Text

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 Vice President

-Nuclear Operations SEP 2 9 1994 NLR-N94159 LCR 94-29 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

LICENSE AMENDMENT APPLICATION REVISION OF CONTAINMENT SPRAY SYSTEM SURVEILLANCE FREQUENCY SALEM GENERATING STATION UNIT NOS. 1 and 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 This letter submits an application for amendment to Appendix A of Facility Operating Licenses DPR-70 and DPR-75 for the Salem Generating Station Unit Nos. 1 and 2, respectively, and is being filed in accordance with 10CFR50.90.

Pursuant to the requirements of 10CFR50.91(b)

(1), a copy of this request for amendment has been sent to the State of New Jersey. The proposed Technical Specification change contained herein represents a change to Section 4. 6. 2. 1 and implements a recommended line item improvement from Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation." The proposed change revises the surveillance interval for performing an air or smoke flow test through each containment spray header from once every five years to once every ten years. It should be noted that similar changes were approved by the NRC Staff for.Surry Power Station Unit Nos. 1 and 2 in an SER dated May 20, 1994. The proposed change has 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.

A description of the requested amendment, supporting information and analyses for the change, and the basis for a no significant hazards consideration determination are provided in Attachment

1. The Technical Specification pages affected by the proposed change are provided in Attachment 2 and 3, with pen and ink changes, for Salem Units 1 and 2, respectively.

Upon NRC approval of this proposed change, PSE&G requests that the

• SEP 2 9 1994 Docume'nt Control Desk NLR-N94159 amendment be made effective on the date of issuance, but implemented within sixty days to provide sufficient time for associated administrative activities.

Should you have any questions regarding this request, please contact us. Affidavit Attachments (3) Sincerely, C Mr. T. T. Martin, Administrator

-Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. J. C. Stone, Licensing Project Manager -Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. C. S. Marschall (S09) USNRC Senior Resident Inspector 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 STATE OF NEW JERSEY ) )SS. COUNTY OF SALEM ) REF: NLR-N94159 LCR 94-29 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 !),9thday 1994 My Commission expires on KIMBERLY JO BROWN NOTARY PUBLIC OF NEW JERSEY My Cnmmjssioo Expin1s 21, 1998 ATTACHMENT 1 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS LICENSE AMENDMENT APPLICATION REVISION OF CONTAINMENT SPRAY SYSTEM SURVEILLANCE FREQUENCY SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 NLR-N94159 DOCKET NOS. 50-272 and 50-311 LCR 94-29 I. DESCRIPTION OF THE PROPOSED CHANGE This amendment revises Surveillance Requirement

4. 6. 2. 1 by requiring a Containment Spray System header flow test every ten (10) years instead of every five (5) years to confirm that the spray nozzles are unobstructed.

II. REASONS FOR THE CHANGE Through this submittal, PSE&G is requesting implementation of the NRC's recommendation regarding the extension of the surveillance interval for performing flow tests through each spray header and verifying that each spray nozzle is unobstructed.

The proposed change to the Technical Specifications is consistent with the guidance of Generic Letter (GL) 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation" and incorporates the recommendation of NUREG 1366, "Improvements to Technical Specifications surveillance Requirements." The proposed change is further supported by the associated reduction in radiation exposure to plant personnel and the elimination of an unnecessary burden on plant staff. III. JUSTIFICATION FOR CHANGE Technical Specification

4. 6. 2. 1 requires the Containment Spray System to be demonstrated operable at least once every five years by performing an air or smoke flow test through each spray header and verifying that each spray nozzle is unobstructed.

The test only verifies that there is flow and does not provide quantitative data on flow rates through the nozzles. Page 1 of 3 ATTACHMENT 1 NLR-N94159 LCR 94-29 As noted by the NRC in NUREG-1366 and GL 93-05 I the NRC reviewed industry data for problems involving the containment spray system uncovered by means of this testing. The problems found in other facilities occurred during construction or were the result of coatings applied to the carbon steel piping. The Salem Unit 1 and Unit 2 Containment Spray Systems utilizes stainless steel piping and does not use coating materials such as sodium silicate, the cause of problems in containment spray systems using carbon steel, as noted in GL 93-05, Item 8.1. A review of the previous two (2) Containment Spray nozzle surveillance tests performed on either Salem Unit 1 or Unit 2, indicates there were no problems which would have resulted in nozzle blockage.

The proposed change is therefore compatible with Salem Unit 1 and Unit 2 plant operating experience.

IV. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION PSE&G has, pursuant to lOCFR50. 92, reviewed the proposed amendment to determine whether our request involves a significant hazards consideration.

We have determined that operation of Salem Generating Station Unit 1 and Unit 2, in accordance with the proposed changes: 1. Does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change does not affect the assumptions, design parameters or results of UFSAR accidents analyzed.

The proposed change does not involve a hardware change, a change to the operation of any system or component, or a change to an existing structure.

The proposed change leads to a reduction in radiation exposure to plant personnel and the reduction of an unnecessary burden on plant staff.

• The Containment Spray System header and nozzles are fabricated from corrosion resistant stainless steel and are maintained dry. Operating experience demonstrates that the proposed increase in the Containment Spray surveillance test interval would not affect operability of the system. Testing the Containment Spray System header and nozzles at the proposed increased surveillance interval does not increase the probability or consequences of an accident previously evaluated.

Page 2 of 3 ATTACHMENT 1 NLR-N94159 LCR 94-29 2. Does not create the possibility of a new or different kind of accident from any previously evaluated.

The proposed change does not modify equipment, affect the system design basis or operability.

This change does not alter parameters utilized in the analyzed accident scenarios.

The Containment Spray System piping and nozzles are fabricated from corrosion resistant stainless steel. The proposed change in surveillance frequency is consistent with the guidance provided in GL 93-05. Testing the Containment Spray System header and nozzles at the proposed increased surveillance interval does not create the possibility of a new or different kind of accident from those previously evaluated.

3. Does not involve a significant reduction in a margin of safety. The proposed change only involves a decrease in surveillance frequency and does not alter the performance of the surveillance itself. System equipment and operation remains unchanged.

Operability and reliability is still maintained by periodic testing. Testing the Containment Spray System header and nozzles at the proposed increased surveillance interval does not involve a significant reduction in the margins of safety. V. CONCLUSIONS Based on the above, PSE&G has determined that the proposed change does not involve a significant hazards consideration.

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