ML18102B657

Application for Amends to Licenses DPR-70 & DPR-75,revising Surveillance Requirement 4.6.2.1.b to Verify That on Recirculation Flow,Containment Spray Pumps Develop Differential Pressure of Greater than or Equal to 204 Psid

ML18102B657
Person / Time
Site:	Salem
Issue date:	11/04/1997
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102B658	List: ML18102B657 ML18102B659
References
LCR-S96-20, LR-N970636, NUDOCS 9711140070
Download: ML18102B657 (11)

Text

Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Clf 5'1y 0 *f19§1236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations LR-N970636 LCR S96-20 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS CONTAINMENT SPRAY PUMP SURVEILLANCE CRITERIA SALEM GENERATING STATION NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Ladies and Gentlemen:

In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company requests a revision to the Technical Specifications (TS) for 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 changes contained herein affect TS 3/4.6.2, "Containment Spray System". Specifically, Salem Unit 2 surveillance requirement 4.6.2.1.b is being revised to verify that on recirculation flow, the containment spray pumps develop a differential pressure of greater than or equal to 204 psid.

Currently the surveillance test acceptance criteria requires that each containment spray pump develop a discharge pressure of greater than or equal to 215 psig. For certain potential test configurations, the current acceptance criteria may not adequately verify the containment spray pumps will develop the required head assumed in the accident analyses. The proposal will revise the Salem Unit 2 surveillance test criteria to ensure the surveillance adequately verifies containment spray pump performance meets accident analysis assumptions.

The Salem Unit 1 Technical Specifications currently do not include this surveillance test acceptance criteria. The proposed change adds this surveillance test acceptance criteria to Salem Unit 1 TS 3/4.6.2 to make these specifications the same for the Salem Uni ts.

• PSE&G informed the NRC of this issue in letter LR-N970298 dated May 14, 1997 and committed to submit a license change request to 97ii14oo7o 971104*

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• Document Control Desk LR-N970636 revise this surveillance within 90 days of Salem Unit 2 entering Mode 2, Startup. This submittal fulfills this commitment. As stated in LR-N970298, the acceptance criteria in surveillance test procedures have been revised to ensure the accident analysis assumptions for CS pump performance are verified.

The proposed changes have been evaluated in accordance with 1-0CFR50.91(a) (1), using the criteria in 10CFR50.92(c), and PSE&G has concluded that this request involves no significant hazards considerations.

The basis for the requested changes is provided in Attachment 1.

The 10CFR50.92 evaluation with a determination of no significant hazards consideration is provided in Attachment 2. The marked up TS pages affected by the proposed changes are provided in Attachment 3. The NRC has previously approved the requested change in the Technical Specifications of other licensees, including the Diablo Canyon, Commanche Peak and South Texas Unit 1 and 2 Technical Specifications.

Upon NRC approval of these proposed changes, PSE&G requests that the amendments for each Salem Unit 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, Affidavit Attachments (3) 95-4933

NOV 041997 Document Control Desk ~R-N970636 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 Ms~ M. Evans (X24)

USNRC Senior Resident Inspector Salem Generating Station Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering PO Box 415 Trenton, NJ 08625 95-4933

REF: LR-N97.6 LCR S96-20 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 the Salem Generating Station, Units 1 and 2, are true to the best of my knowledge, information and belief.

Subscribed and Sworn to before me this l( day of J!lo r.r~-e.v t 1997 BARBARA A. POWELL NOTARY PUBLIC OF NEW JERSEY My Commission Expires Dec. 2. 1998 n

m 21so32J.

My commission expires on ~~~~~~~~~~~~~~~

Document Control LR-N970636 LCR S96-20 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSE DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS CONTAINMENT SPRAY PUMP SURVEILLANCE CRITERIA REQUESTED CHANGE AND PURPOSE The Salem Unit 2 Technical Specification 3/4.6.2, "Containment Spray System" surveillance requirement 4.6.2.1.b requires that each Containment Spray (CS) pump be tested to verify on recirculation flow that the pump develops a discharge pressure of greater than or equal to 215 psig. The requested change revises this surveillance test to require that each CS spray pump develop a differential pressure *of greater than orequal to 204 psid on recirculation flow.

The Salem Unit 1 Technical Specifications do not currently include this surveillance test acceptance requirement. It is being added to Salem Unit 1 Technical Specification 3/4.. 6.2 to provide consistency between Salem Unit.1 and 2 TS 3/4.6.2. The Containment Spray system design is the.sa~e: for both Salem Units.

The purpose of this change is to revise the surveillance test acceptance criteria such .that .the CS pump performance assumptions in the accident analysis are satisfied for all potential surveillance test configurations. Verification of accident analy.ses assumptions requires that each CS pump develop a differential pressure ~f:204 psid when tested on recirculation flow. The current survei-llance acceptance* criteria requires the CS pump develop a discharge pressure of 215 psig. CS pump discharge pressure is a function of pump suction pressure, which varies with the Reactor Water Storage Tank (RWST) level. Salem Unit 1 and 2 Technical. Specifications 3 .1. 2. 6 and 3. 5. 5 require a minimum volume be maintained in the RWST. During Modes 1 through 4 the minimum required RWST volume results in a CS suction pressure of approximately 26 psig. If it is postulated that a CS pump degrades such that it only provides a. differential pressure of 189 psid while on recirculation flow; the acceptance c~iteria of 215 psig discharge pressure could be met while the accident analysis requirement for a CS pump to deve*lop a minimum of 204 psid would not be verified.

The requested change will revise the surveillance acceptance criteria to prevent this* occurrence. The change does not revise the CS pump or system performance assumed in accident analyses.

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Document Control LR-N970636 LCR S96-20 The change does not revise the CS pump or system performance as described in the UFSAR. PSE&G reviewed ten years of historical CS pump surveillance results. These test results indicate that the current CS pump surveillance acceptance criteria were met and the accident analysis assumptions for CS pump developed head were also verified.

As indicated in PSE&G letter LR-N970298 dated May 14, 1997 (item

1. 5), CS pump inservice test procedures for Salem Unit 1 and 2 have been revised to include the 204 psid pump differential pressure acceptance criteria in addition to the technical specification surveillance requirement of 215 psig pump discharge pressure. PSE&G committed to provide this license change request within 90 days of Salem Unit 2 entering Mode 2, "Startup." This submittal fulfills this commitment.

This submittal also corrects a typographical error in the Salem Unit 2 surveillance TS 4.6.2.1.c.2 where the word "each" is repeated. The second word "each" is removed.

JUSTIFICATION OF REQUESTED CHANGE The CS System is designed to actuate on a high - high containment pressure signal during design basis Loss of Coolant Accidents (LOCA) and Main Steam Line Break Accidents (MSLB) in containment.

The CS System sprays cool water into containment to restore and maintain containment conditions at near atmospheric pressure.

The CS System also provides a mechanism to remove iodine from the containment atmosphere.

The requested change will revise Salem Unit 2 TS surveillance 4.6.2.1.b. The CS pump inservice test acceptance criteria will be revised from 215 psig pump discharge pressure to 204 psid pump differential pressure. Revising the surveillance test acceptance from pump discharge pressure to pump differential pressure will account for the effect of RWST level on the test results. The acceptance criteria will continue to verify each CS pump performs as assumed in the accident analyses.

The Salem Unit 1 Technical Specifications do not currently include this surveillance test acceptance requirement. The Containment Spray system design is the same for both Salem Units.

This surveillance test acceptance criteria is being added to Salem Unit 1 TS 3/4.6.2 to provide consistency between the Salem Unit 1 and 2 Containment Spray Technical Specifications.

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Document Control .LR-N970636 LCR S96-20 The revised acceptance criteria do not represent a change in the CS pump flow performance assumed in accident analyses. A CS pump differential pressure of 204 psid corresponds to the operating point for a nominal pump recirculation flow of 300 gpm. This provides a test point for performance trending on the pump flow curve assumed in accident analyses for LOCA and MSLB accidents.

PSE&G previously submitted license change request S94-41 to implement the Fuel Upgrade/Margin Recovery Program. The accident analyses submitted with LCR S94-41 did not revise the CS system or pump performance requirements. Therefore the proposed change in this submittal is consistent with LCR S94-41.

The proposed changes will provide better consistency between the surveillance acceptance criteria and TS 4~0.5 ASME XI requirements. The revised surveillance acceptance criteria makes the CS pump surveillance acceptance criteria consistent with ASME XI (1983 Edition and Addenda through Sµmmer 1983), Article IWP-3000 reference values. IWP-3000 identifies pump differential pressure as a reference value to be trended for indication of acceptable operation. Pump discharge pressure is not identified as a reference value to be trended. Therefore this change will provide better consistency between the su~~eillance acceptance criteria and ASME XI requirements.

The proposed changes are consistent with the CS pump surveillance acceptance c;r-iteria in the improved technical specifications (NUREG-1431, Volume 1,.Revision 1, Surveillance 3.6.6A.4). The improved technical specification surveillance test requires verification that each CS pumps developed head at the flow test point be greater than or equal to the required developed head at the test point. Pump differential pressure is proportional to developed head whereas.* pump discharge pressure does not correlate to developed head. The proposed changes will provide surveillance acceptance criteria proportional to developed head at the flow test point, consistent with the improved technical specifications.

Please note that the NRC has previously approved CS differential pump pressure for surveillance testing in other licensee Technical Specifications (e.g., Diablo Canyon, Commanche Peak and South Texas Units 1 and 2 Technical Specifications) .

CONCLUSION The proposed changes will ensure the CS pump surveillance test criteria accounts for RWST level affects and verifies the Page 3 of 4

. Document Control LR-N970636 Attachment 1 LCR 896-20 accident analysis assumptions for CS pump performance. The proposed changes also makes the subject surveillance test criteria consistent with the applicable surveillance test criteria in the improved technical specifications. In addition this license change request fulfills a PSE&G commitment previously made to the NRC staff.

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. Document Control Attachment 2 D. e LR-N970636 LCR S96-20 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 SPRAY PUMP SURVEILLANCE CRITERIA 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded 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 10CFRS0.92 is provided below.

REQUESTED CHANGE The requested change will revise the Salem Unit 2 TS Surveillance Test 4.6.2.1.b acceptance criteria for CS pump performance during recirculation flow from achieving 215 psig pump discharge pressure to achieving 204 psid pump differential pressure. The Salem Unit 1 Technical Specifications do not currently include this surveillance test acceptance requirement. It is being added to Salem Unit 1 Technical Specification 3/4.6.2 to provide consistency between Salem Unit 1 .and. 2 TS. 3/4.6.2. Additionally this submittal corrects a typographical error in Salem Unit 2 TS Surveillance 4.6.2.1.c.2 where the word "each" is repeated. The second word "each" is removed.

BASIS

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

The proposed change revises the CS pump technical specification surveillance test acceptance from pump discharge pressure to pump differential pressure. This will account for the effect of RWST level on test results and provide acceptance criteria that verifies each CS pump performs as assumed .in the accident analyses. This surveillance test is also being added to the Salem Unit 1 TS. The proposed change does not alter the physical plant arrangement or the method of CS pump inservice testing.

Therefore it does not increase the probability of an accident. There is no change to pump performance requirements as assumed in the accident analyses. There is no change to cs system performance in response to an Page 1 of 3

Document Control LR-N970636 LCR S96-20 accident. Therefore, the proposed change does not involve an increase in the consequences of an accident previously evaluated.

The proposed change also corrects a typographical error by removing a repeated word. This change does not involve an 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 change revises the Salem Unit 2 CS pump surveillance test acceptance criteria from pump discharge pressure to pump differential pressure. This will account for the effect of RWST level on test results and provide acceptance criteria that verify the CS pumps perform as assumed in the accident analyses. This surveillance test is also being added to the Salem Unit 1 TS. The proposed change does not alter* the plant configuration. The change does not alter the metho.d of performing inservice testing on the CS pumps. The change does not al_ter the CS pump performance assumed in the accident analyses. Therefore, the change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change also corrects a typographical error by removing a repeated word. This change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

The proposed change ensures the CS pump Salem Unit 2 TS surveillance test acceptance criteria verify CS pump performance as assumed in the accident analyses accounting for RWST level affects. This surveillance test is also being added to the Salem Unit 1 TS. The proposal does not change the CS pump performance requirements assumed in the accident analyses and thus does not reduce the margin of safety.

The proposed change also corrects a typographical error by removing a repeated word. This does not involve a significant reduction in a margin of .safety.

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. Document Control LR-N970636 Attachment 2 LCR 896-20 CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

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