ML18107A463

Application for Amends to Licenses DPR-70 & DPR-75,replacing Surveillance 4.6.1.1a with Appropriate NUREG-1431 Requirements

ML18107A463
Person / Time
Site:	Salem
Issue date:	07/29/1999
From:	Bezilla M Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18107A466	List: ML18107A463 ML18107A467
References
RTR-NUREG-1431 LCR-S99-02, LR-N990330, NUDOCS 9908030068
Download: ML18107A463 (11)

Text

e OPS~G

.. Public ~ervice Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit a.18199Sl LR-N990330 LCR S99-02 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 REVISED INFORMATION FOR LICENSE AMENDMENT CONTAINMENT SYSTEM SALEM GENERATING STATION UNITS 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Gentlemen:

By letter dated June 10, 1999 (Ref: N990252), Public Service Electric and Gas Company (PSE&G) reque~ted a revision to the Technical Specification (TS) for the Salem Generating Station Units No. 1 and 2. This submittal supercedes the June 10, 1999, letter. This amendment request adopts additional benefits that can be*obtained by incorporating the guidance of NUREG 1431, Rev 1 (April 1995) Standard Technical Specifications Westinghouse Plants. Specifically, this submittal proposes to replace surveillance 4.6.1.1 a with the appropriate NU REG 1431 requirements. The Salem Technical Specifications Bases are appropriately clarified in Insert B.

The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1),

using the criteria in 10CFR50.92(c) and PSE&G has concluded that this request involves no significant hazards considerations. PSE&G has also reviewed the proposed TS change against the criteria of 10 CFR 51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the above, PSE&G concludes that the proposed change meets the criteria delineated in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

The marked up TS pages affected by the proposed changes are provided in Attachment 111.

( 9908030068-996729 -- - - --------~.

I PDR ADOCK 05000272

\

P . PDR The power is in your hands.

• 95-2168 REV. 6/94

Document Control Desk t.:.~-N99"0330 Upon NRC approval of the proposed change, PSE&G requests that the amendment be made effective upon issuance, but allow implementation period of sixty (60) 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,

/1(5)({.//

M. B. Be~ill;-r' Vice President - Operations Affidavit Attachments (3)

C Mr. H.J. Miller, Administrator- Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris (X24)

USN RC Senior Resident Inspector - Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625

REF: LR-N990330

• LCR S99-02 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

Mark B. Bezilla, being duly sworn according to law deposes and says:

I am Vice President - 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 Stations are true to the best of my knowledge, information and belief.

Subscribed and Sworn to before me this ,lq-th day of Ju yI , 1999 CINDY L RIJGWAY

• NOTARY POOUC Of ~IL My Commission expires on _ _ _ MY_C_<<l_m_ml_~_*El_~

ATTACHMENT I

• • PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)

T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990330 REQUESTED CHANGE AND PURPOSE The proposed change revises Technical Specification (TS) Section 3/4.6.1. The proposed change eliminates the current surveillance 4.6.1.1 a and replaces it with a new surveillance 4.6.1.1a1 and 4.6.1.1a2. Surveillance 4.6.1.1a1 will have a frequency of 31-days and address valves and blind flanges outside containment. Surveillance 4.6.1.1 a2 will be performed prior to entering Mode 4 from Mode 5 if not performed within the last 92-days and address valves and blind flanges inside containment. Administrative means may be used in the performance of these surveillances to verify valve position. For Salem Unit 1 only the double asterisk (* *) associated with the applicability statement of limiting condition for operation 3.6.1.1 is eliminated. The double asterisk (* *) is defined at the bottom of page 3/4 6-1. This double asterik (* *) is associated with a one time extension during the steam generator replacement and expired with the initial entry into Mode 2 from cycle 13. This deletion is purely administrative since it no longer applies.

The purpose of the proposed change is to eliminate unnecessary radiological exposure associated with field verification of valve position for equipment known to be in the proper position by administrative means. Administrative means that may be used to determine proper valve position include; tagging requests, other TS surveillance procedures and/or previously performed valve alignments. This proposed amendment also brings consistency between both Salem Units TS format.

The proposed change is consistent with the guidance and intent of NUREG 1431, Rev 1 (April 1995) Standard Technical Specifications Westinghouse Plants (NUREG 1431).

The current TS surveillance reads:

"4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a. At least once per 31 days by verifying that:

1. All penetrations* not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except for valves that are opened under administrative control as permitted by Specification 3.6.3.1., and .. "

With the word penetration modified by the

• at the bottom of the page as follows:

1

ATTACHMENT I PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)

T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990330

• Except vents, drains, test connections, etc. which are (1) one inch nominal pipe diameter or less, (2) located inside the containment, and (3) locked, sealed, or otherwise secured in the closed position. These penetrations shall be verified closed at least once per 92 days.

The proposed amendment modifies the surveillance to read as follows:

"4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a1 .At least once per 31 days by verifying that each containment manual valve or blind flange that is located outside containment and required to be closed during accident condition is closed, except for containment isolation valves that are open under administrative controls. Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

a2.Prior to entering Mode 4 from Mode 5 if not performed within the last 92 days by verifying that each containment manual valve or blind flange that is located inside containment and required to be closed during accident condition is closed, except for containment isolation valves that are open under administrative controls. Valves and blind flanges in high radiation areas may be verified by use of administrative controls. "

JUSTIFICATION OF REQUESTED CHANGES As stated in the Salem TS Bases, assuring Primary Containment Integrity ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses.

Assuring Primary Containment Integrity assures the 10 CFR Part 100 dose limits will not be exceeded at the site boundary during accident conditions.

The current Salem Technical Specification 3.6.1.1 allows the use of administrative means to satisfy the requirements of surveillance 4.6.1.1 a only for containment isolation valves that are open under administrative means. The Salem TS and Bases do not provide any additional guidance or clarification as the purpose of the surveillance requirement.

However, NU REG 1431 explicitly states the purpose of this surveillance. As stated in NU REG 1431, the purpose of this surveillance requirement is not to perform any testing or valve manipulations, but to verify that containment isolation valves capable of being mispositioned are in their proper safety position. Physical verification (hands on verification) that these penetrations (containment isolation valves) are in the proper position is performed prior to entering Mode 4 from Mode 5 and documented in the appropriate valve line-up. Allowing the use of administrative means to verify compliance 2

ATTACHMENT I PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)

T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990330 with the surveillance requirement for these valves is acceptable based on the limited access to these areas in Modes 1, 2, 3, and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified in the proper position, is small.

The proposed change is consistent with the guidance and intent of NUREG 1431, Rev 1 (April 1995) Standard Technical Specifications Westinghouse Plants (NUREG 1431), and brings consistency between both Salem Units TS format.

The deletion of the double asterisk (* *) associated with the applicability statement of limiting condition for operation 3.6.1.1 and its definition at the bottom of page 3/4 6-1 is purely administrative since it no longer applies.

CONCLUSIONS The proposed change is consistent with the ALARA principle and the guidance and intent of NUREG 1431, Rev 1 (April 1995) Standard Technical Specifications Westinghouse Plants (NUREG 1431), and brings consistency between both Salem Units TS format.

The use of administrative means is accepted because of the small probability of misalignment of these valves due to the restricted access to these areas in Modes 1, 2, 3, and 4.

3

ATTACHMENT II PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)

T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990330 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 TS do not involve a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below.

REQUESTED CHANGE The proposed change revises Technical Specification (TS) Section 3/4.6.1. The proposed change eliminates the current surveillance 4.6.1.1 a and replaces it with a new surveillance 4.6.1.1a1 and 4.6.1.1 a2. Surveillance 4.6.1.1a1 will have a frequency of 31-days and address valves and blind flanges outside containment. Surveillance 4.6.1.1 a2 will be performed prior to entering Mode 4 from Mode 5 if not performed within the last 92-days and address valves and blind flanges inside containment.

Administrative means may be used in the performance of these surveillances to verify valve position.

The proposed amendment modifies the surveillance to read as follows:

"4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a1 .At least once per 31 days by verifying that each containment manual valve or blind flange that is located outside containment and required to be closed during accident condition is closed, except for containment isolation valves that are open under administrative controls. Valves and blind flanges in high radiation areas may be verified by use of administrative controls a2.Prior to entering Mode 4 from Mode 5 if not performed within the last 92 days by verifying that each containment manual valve or blind flange that is located inside containment and required to be closed during accident condition is closed, except for containment isolation valves that are open under administrative controls. These valves and blind flanges may be verified by use of administrative controls."

For Salem Unit 1 only the double asterisk(**) associated with the applicability statement of limiting condition for operation 3.6.1.1 is eliminated. The double asterisk (* *) is defined at the bottom of page 3/4 6-1. This double asterik (* *) is associated with a one time extension during the steam generator replacement and expired with the initial entry into Mode 2 from cycle 13. This deletion is purely administrative since it no longer applies.

1

ATTACHMENT II PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)

T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990330 The proposed change is consistent with the guidance and intent of NUREG 1431, Rev 1 (April 1995) Standard Technical Specifications Westinghouse Plants (NUREG 1431).

BASIS

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

The proposed change, as described above, eliminates the current surveillance 4.6.1.1 a and replaces it with surveillances 4.6.1.1 a1 and 4.6.1.1 a2. Incorporating the requirements of NUREG 1431 eliminates unnecessary radiological exposure associated with field verification of valve position for equipment known to be in the proper position

• by administrative means. Administrative means that may be used to determine proper valve position include; tagging requests, other TS surveillance procedures and/or previously performed valve alignments.

Primary Containment Integrity ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses. Assuring Primary Containment Integrity assures the 10 CFR Part 100 dose limits will not be exceeded at the site boundary during accident conditions.

The current Salem Technical Specifications allows the use of administrative means to verify valve position; however limits its application only to valves that are open under administrative controls. The proposed amendment, as described above, does not affect any assumptions made in evaluating the radiological consequences of accidents described in the Safety Analysis Report (SAR). The proposed change to use administrative means continues to ensure that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analysis. Allowing the use of administrative means to verify compliance with the surveillance requirement for these valves is acceptable based on the limited access to these areas in Modes 1, 2, 3, and 4 for ALARA reasons.

Therefore, the probability of misalignment of these containment isolation valves, once they have been verified in the proper position is small. The probability of occurrence of any previously evaluated accident is independent of valve position verification.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated in the SAR.

2

ATTACHMENT II PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)

T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990330

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment, as described above, does not physically alter the facility or the operation of the facility. The proposed change to use administrative means in lieu of field verification continues to ensure that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analysis. The proposed amendment does not affect the response of any systems, structures or components assumed to function in the accident analysis, or creates a new or different accident scenario.

Therefore, the proposed change does not increase the consequences of a malfunction of equipment important to safety previously evaluated in the SAR or creates 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 Technical Specifications margin of safety as defined in the Bases depends upon proper identification of equipment and performance of the proper surveillance requirements to demonstrate equipment operability. The proposed amendment will continue to ensure that the proper valves are identified and tested in accordance with the Technical Specification requirements. The proposed amendment, as described above, does not introduce any new equipment or modifies how the equipment is operated or tested.

The proposed changes do not involve a significant reduction in a margin of safety.

CONCLUSION Based on the above, PSE&G has determined that the proposed change does not involve a significant hazards consideration.

3

ATTACHMENT Ill PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)

T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990330 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following TS for Facility Operating License No. DPR 70 are affected by this change request:

Technical Specification 3.6.1.1 3/4 6-1 3/4.6.1 83/4 6-1 The following TS for Facility Operating License No. DPR 75 are affected by this change request:

Technical Specification 3.6.1.1 3/4 6-1 3/4.6.1 83/4 6-1 1

ATTACHMENT Ill

.. PROPOSED AMENDMENT TO SALEM UNITS 1 AND 2 TECHNICAL SPECIFICATIONS (T.S.)

T.S. 3/4.6.1 PRIMARY CONTAINMENT LR-N990330 INSERT A "4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a1 .At least once per 31 days by verifying that each containment manual valve or blind flange that is located outside containment and required to be closed during accident condition is closed, except for containment isolation valves that are open under administrative controls. Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

a2.Prior to entering Mode 4 from Mode 5 if not performed within the last 92 days by verifying that each containment manual valve or blind flange that is located inside containment and required to be closed during accident condition is closed, except for containment isolation valves that are open under administrative controls. Valves and blind flanges in high radiation areas may be verified by use of administrative controls."

INSERT B (To the TS Basis)

The purpose of this surveillance requirement (4.6.1.1a) is not to perform any testing or valve manipulations, but to verify that containment isolation valves capable of being mispositioned are in their proper safety position (closed).

Physical verification (hands on verification) that these penetrations (containment isolation valves) are in the proper position is performed prior to entering Mode 4 from Mode 5 and documented in the appropriate valve line-up. Allowing the use of administrative means to verify compliance with the surveillance requirement for these valves is acceptable based on the limited access to these areas in Modes 1, 2, 3, and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified in the proper position, is small.

2