ML18102B258

Application for Amend to License DPR-75,revising TS Section 3/4.7.7 to Reflect Extended Allowed Outage Times & Creating New TS Section 3/4.7.11 to Address Importance of Switchgear & Penetration Area Ventilation Sys

ML18102B258
Person / Time
Site:	Salem
Issue date:	05/01/1997
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102B259	List: ML18102B258 ML18102B260
References
LR-N97231, NUDOCS 9705070252
Download: ML18102B258 (8)

Text

• Public Service Electric and Gas Company Louis F. Storz Public SeNice Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations

• ~AY 011&

LR-N97231 LCR S97-06 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 CHANGE TO TECHNICAL SPECIFICATIONS HVAC SYSTEM TECHNICAL SPECIFICATION CHANGES SALEM GENERATING STATION NO. 2 FACILITY OPERATING LICENSES DPR-75 DOCKET NO. 50-311 Gentlemen:

In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company requests a revision to the Technical Specifications (TS) for the Salem Generating Station Unit 2. In accordance with 10CFR50.9l(b) (1), a copy of this submittal has been sent to the State of New Jersey.

The proposed changes contained herein represent changes to TS section 3/4.7.7, "Auxiliary Building Exhaust Air Filtration System". Specifically, certain Allowed Outage Times (AOT) are extended based on a Probabilistic Safety Assessment (PSA) calculation. Further, a new TS section 3/4.7.11, "Switchgear and Penetration Area Ventilation System" was created to address the important features protected by that system.

The proposed changes have been evaluated in accordance with 10CFR50.9l(a) (1), using the criteria in 10CFR50.92(c), and it has been determined that this request involves no significant hazards considerations.

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

The revised 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.

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• *M~Y 011997 Document Control Desk LR-N97231 Upon NRC approval of this proposed change, PSE&G requests that the amendment 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)

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 Mr. C. Marschall (X24)

USNRC. Senior Resident Inspector - Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933

• REF: LR-N97.1 LCR S97-06 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, Unit 2, are true to the best of my knowledge, information and belief.

Subscribed and Sworn to before me this /n& day o'f-trtcw.p , 1997

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• N? trry Pub

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KIMBERLY JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission Expires April 21, 1998 My commission expires on

Document Control

• LR-N97231 LCR S97-06 SALEM GENERATING STATION UNIT NO. 2 FACILITY OPERATING LICENSE DPR-75 DOCKET NOS. 50-311 CHANGE TO TECHNICAL SPECIFICATIONS HVAC SYSTEM TECHNICAL SPECIFICATION CHANGES BASIS FOR REQUESTED CHANGE The basis for the proposed change is to align the current HVAC related Technical Specification (TS) section 3/4.7.7 Allowed Outage Times (AOT) with Actions that conform with a Salem specific Probabilistic Safety Assessment (PSA) analysis.

Further, a new TS section to address the Switchgear and Penetration Area Ventilation system is being proposed to address the support function this system provides to other necessary systems.

REQUESTED CHANGE AND PURPOSE This proposed amendment modifies the TS section 3/4~7.7 to reflect extended Allowed Outage Times (AOT) based on specific Salem PSA calculations. Further, the proposed changes create a new TS section 3/4.7.11 to address the importance of the Switchgear and Penetration Area Ventilation system. These changes apply only to Salem Unit 2.

BACKGROUND The Auxiliary Building Ventilation System is designed for long term continuous operation to provide consistent levels of temperature, cleanliness, and negative pressure within the building. The Auxiliary Building Ventilation System is a once-through heating and ventilation system and is comprised of supply and exhaust air systems and a network of individual room coolers. The system's essential components consist of two 100-percent capacity supply fan units, three 50-percent capacity exhaust fan units, a charcoal adsorber bank, and three HEPA filters, two of which can be associated with the carbon filter train arrangement. The design capability of the filtration trains ensures that all exhausted emissions from the Auxiliary Building and the containment are within the requirelitents of 10 CFR 20.

The Switchgear and Penetration Area Ventilation (SPAV) system is required to provide sufficient air flow through the elevation 64' and 84' Switchgear Rooms, the 78' Electrical Penetration Area and the 100' Ventilation Equipment Room to maintain area temperatures Page 1 of 3

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• LR-N97231 LCR S97-06 within a suitable range. The system's essential components consist of three 50-percent capacity supply fans, two 100-percent capacity exhaust fans for the switchgear area, and two 50-percent capacity exhaust fans for the penetration area. In addition to maintaining design temperatures, the system supports operability of essential onsite distribution equipment which is governed by Technical Specification section 3/4.8.

JUSTIFICATION OF REQUESTED CHANGES Auxiliary Building Exhaust Air Filtration System Technical Specification section 3.7.7 requires certain LCO Action times based on Auxiliary Building Exhaust Air Filtration System component inoperability. Based on an evaluation performed in accordance with EPRI TR-105396, "PSA Applications Guide", August 1995, an AOT of 30 days is allowable for two inoperable exhaust fans. The proposed change conservatively, with respect to the evaluation performed under the EPRI standard, increases the AOT restoration time of TS 3.7.7.c for only one operable exhaust fan from 7 days to 14 days. The duration's assigned to the AOT result in the equipment unavailability being considered non-risk significant and is less than the acceptance criteria of 1.0 X lOE-6. Requirements for monitoring the effectiveness of maintenance for this system have been established and include goals to provide reasonable assurance that the system is capable of fulfilling its intended function and maintenance repair activities are controlled under administrative guidance. No other changes to the Technical Specification Actions or Surveillance Requirements are proposed by this change.

Switchgear and Penetration Area System A new Technical Specification section 3/4.7.11 is proposed to address the support function the SPAV system provides to other necessary safety support components. PSE&G has performed heat loading calculations for the areas served by systems that the SPAV system supports. The heat loading calculations form the basis for ensuring that the design basis maximum temperature of 110°F is maintained within the areas the SPAV system serves.

Heat loading calculations have verified that the SPAV system air flow rates are sufficient to maintain the area design maximum temperature with the system in a normal configuration. Special consideration is warranted if less than a full complement of SPAV system support equipment is available. The new TS Actions take in to account the potential for SPAV system component Page 2 of 3

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• LR-N97231 LCR S97-06 unavailability and direct appropriate Actions within a reasonable time period. Based on an evaluation (PSE&G SPE 97-047, Rev. 1) performed in accordance with EPRI TR-105396, "PSA Applications Guide", August 1995, an AOT of 30 days is allowable for one inoperable supply or exhaust fan. The proposed change conservatively, with respect to the evaluation performed under the EPRI standard, provides a 14 day AOT restoration allowance for one SPAV supply or either exhaust fan being inoperable in new Actions in 3.7.11.1. Requirements for monitoring the effectiveness of maintenance for this system have been established and include goals to provide reasonable assurance that the system is capable of fulfilling its intended function and maintenance repair activities are controlled under administrative guidance. This new provision recognizes the important role the SPAV system provides in maintaining temperature and directs reasonable compensatory actions given a loss of key SPAV system components. No Surveillance Requirements are proposed for this new specification, because as discussed above, the SPAV system is included under the maintenance rule requirements that provide reasonable assurance that the system will perform its intended function.

CONCLUSION The proposed change to TS section 3.7.7 is founded on PSA calculations and were calculated to be within the acceptance criteria established and methodology used in adopted industry guidance. The new TS section 3/4.7.11 is based on the recognition of the important function of the SPAV system and the Actions were developed with respect to PSA calculations.

Additional conservatism was added to the proposed changes, in that the 30 day AOT recognized under the EPRI standards were reduced to a 14 day AOT. Further, the proposed changes address consideration for prompt actions that may be necessary to maintain the maximum design temperature limit of 110° F if certain components are inoperable.

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• LR-N97231 LCR S97-06 SALEM GENERATING STATION UNIT NO. 2 FACILITY OPERATING LICENSE DPR-75 DOCKET NOS. 50-311 CHANGE TO TECHNICAL SPECIFICATIONS HVAC SYSTEM TECHNICAL SPECIFICATION CHANGES 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Salem Generating Station Unit No. 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 10CFR50.92 is provided below.

REQUESTED CHANGE The proposed changes represent a change to TS section 3/4.7.7, "Auxiliary Building Exhaust Air Filtration System." These changes propose to increase the Allowed Outage Times (AOT) to 14 days for conditions where one Auxiliary Building Exhaust fan is inoperable. In addition, a new TS section 3/4.7.11, "Switchgear and Penetration Area Ventilation System", is proposed that adds LCO provisions for the SPAV system.

BASIS

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

The proposed changes for TS 3/4.7.7 involve changes to Action time periods. TS section 3/4.7.11 is newly created to address the importance of the SPAV system in ensuring proper temperature control for the areas that it serves.

Actions are prescribed to ensure remedial measures are performed under certain conditions. The proposed AOT's have been evaluated and are commensurate with the safety significance based upon PSA calculations using industry recognized methods. The Auxiliary Building Exhaust Air Filtration and Switchgear and Penetration Area Ventilation systems (herein referred to as "the subject HVAC systems")

are support systems providing cooling to their associated supply areas. The subject HVAC systems are not accident initiators of any accidents evaluated in the Safety Analysis Report. No physical changes to the subject HVAC systems result from the proposed TS changes.

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• LR-N97231 LCR 897-06 Therefore, the proposed changes do not significantly increase the probability or 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 changes do not involve any modification or changes to the mode of operation of the subject HVAC systems. It does not change the basic way in which the subject HVAC systems are operated. By maintaining the equipment or components required in the proposed changes adequate cooling is assured to the areas served by the subject HVAC systems.

Therefore, the 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 subject HVAC systems are support systems which provide area cooling. The proposed changes do not involve any modification to the subject HVAC systems or changes to the mode of operation of the systems. The proposed changes to TS establish controls to better ensure the subject HVAC systems will be able to perform their intended design function and ensures that the safety functions of support equipment are maintained.

The proposed changes establish AOT's for the SPAV system and modify the exhaust fan AOT for the Auxiliary Building Exhaust Filtration system, but do not affect the operation of the subject HVAC systems, and thus do not involve a significant reduction in a margin of safety.

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

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