ML18100A642

Forwards Rev 1,Suppl 3 to 930428 Application for Amends to Licenses DPR-70 & DPR-75,revising TS to Change EDG Voltage Criteria,In Response to NRC Comments on Subj Application

ML18100A642
Person / Time
Site:	Salem
Issue date:	09/30/1993
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18100A643	List: ML18100A642 ML18100A644
References
NLR-N93123, NUDOCS 9310070254
Download: ML18100A642 (9)

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 3 0 1993 NLR-N93123 LCR 87-07, Rev. 1, Supplement 3 United states Nuclear Regulatory Commission Document control Desk Washington, DC 20555 Gentlemen:  ;./"'

SUPPLEMENT TO REQUEST FOR AMENDMENT SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 In accordance with the requirements of 10CFR50.90, Public Service Electric and Gas Company (PSE&G) hereby transmits a request for amendment of Facility Operating Licenses DPR-70 and DPR-75 for Salem Generating Station (SGS) Unit Nos. 1 and 2. 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 attached pages supersede the revised SGS Technical Specification pages transmitted in our request for amendment dated April 28, 1993 (NLR-N93018). The changes from the previously submitted pages are in response to NRC staff_ comments on our April 28, 1993 letter, as discussed with the Salem Licensing Project Manager, Mr. J. c. stone. In addition, the acceptable voltage range for diesel surveillance testing would be revised to be consistent with our recently revised degraded grid voltage calculation.

Attachment 1 provides the NRC staff comments on our April 28, 1993 letter, and PSE&G's proposed resolution of those comments.

The changes described in Attachment 1 do not affect the determination of No Significant Hazards Consideration of our April 28, 1993 letter. Attachment 2 describes the changes relative to the Emergency Diesel Generator (EDG) voltage acceptance criteria. It also includes our determination of No Significant Hazards Consideration from the April 28, 1993 letter, revised to include the proposed changes to the EDG voltage criteria. Attachment 3 contains the proposed Technical Specification pages revised with pen and ink changes, including the changes proposed in our letters of March 6, 1991 and April 28, 1993.

Document Control Desk NLR-N93123 SEP 3 0 1993 PSE&G requests that the implementation date for Unit 1 be no later than within 30 days following restart from the first refueling outage subsequent to issuance of the approved License Amendment. This would allow mid-cycle implementation, to accomodate procedure revision and refueling outage planning required for the changes to the Unit 1 surveillance tests performed on an 18 month cycle. For Unit 2, implementation within 60 days of issuance of the License Amendment is requested.

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. s. Barr (S09)

USNRC Senior Resident Inspector, Acting Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

REF: NLR-N93123 STATE OF NEW JERSEY SS.

COUNTY OF SALEM Joseph 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 our letter, NLR-N93123, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.

1993 SHERRY L. CAGLE My Commission expires on NOTARY _PUBLIC qF NEWJER~~

H CemR11:0~100 ~v,mres.MJ!JJ::h 5, 7

NLR-N93123 ATTACHMENT 1 RESPONSE TO NRC COMMENTS PSE&G previously requested Salem EDG Technical Specification changes via letter dated April 28 ,. 1993 (NLR-N93018). The following is PSE&G's proposed resolution of comments received on our April 28, 1993 letter. *Attachment 3 contains the marked up Technical Specification pages as modified by the proposed comment resolution.

Diesel Testing While ih an Action Statement The April 28, 1993 amendment request proposed to revise Action b.

for LCO 3.8.1.1, to allow a diesel to be declared inoperable for preplanned preventive maintenance or pre-test inspection without having to start the other two diesels. This change would facilitate pre-test inspections for fluid accumulation in the engine cylinders which would avoid diesel engine damage due to hydraulic lockup, as described in NRC Information Notice 91-62.

NRC Comment: Adding "Pre-test inspection" to the Action Statement is not necessary, because the more general "preventive maintenance" would include pre-test inspections. Either "pre-test inspection" should be deleted, or the test requirements of the Improved Standard Technical Specifications should be proposed.

PSE&G Response: Because preventive maintenance includes preplanned maintenance activities, and would include pre-test inspections to detect fluid accumulation in the cylinders, "preplanned" and "pre-test inspection" are being withdrawn from the proposal.

Use of the Footnote for Testing per Manufacturer Recommendations The April 28, 1993 amendment request proposed to place an "*"

following each surveillance Requirement calling for a diesel start. The "*" note reads:

• Surveillance testing shall be conducted in accordance with the manufacturer's recommendations regarding engine prelube, warm-up and loading (unless loading times are specified in the individual Surveillance Requirements) .

This change was proposed in response to an NRC staff comment on our March 6, 1991 request, which proposed to use "*" as a general note applying to periodic testing to demonstrate diesel operability. The NRC staff had requested the footnote specifically identify each test where manufacturer's recommendations are followed. Because the footnote would apply to all diesel starts required by Technical Specifications, the

"*" was added to each Surveillance Requirement calling for a diesel start.

,--~

NIB-N93123 2 of 3 Attachment 1 NRC Comment: The "*" should be removed from proposed Surveillance Requirement 4.8.1.1.2.c (six month test), because it is a start from ambient conditions and calls for fast loading.

PSE&G Response: PSE&G proposes to retain the proposed "*" for the six month test. The footnote states that manufacturer's recommendations are followed "unless loading times are specified in the*individual Surveillance Requirements." Because ambient

• conditions specified for the six month test would be defined consistent with normal operation of the diesel auxiliary systems, the proposed six month test follows manufacturer's recommendations with the exception of the fast loading.

Therefore, the note applies to the proposed six month test.

Service Water Pump Motor Load for Load Rejection Test The April 28, 1993 amendment request proposed to revise the load used for the single largest load rejection test of proposed Surveillance Requirement 4.8.l.1.2:d.2, .to "a load greater than or equal to the maximum service water pump motor load.n This would have allowed flexibility in~th.e surveillance test criteria to reflect changes in the actual limiting motor .load (e.g~, as a result of pump impeller changes). The*April 28, 1993 letter also included a commitment to verify the maximum pump load every 18 months.

NRC Comment: The proposed change is unacceptable because it does not include a specific value for the pump motor.

PSE&G Response: ."the maximum service water pump motor load."

would be replaced with 11 820 kw." This proposed test value exceeds the present maximum pump motor load of 809 kw.

Review of Auto-Connected Loads The April 28, 1993 amendment request included a commitment for engineering to review design changes every 18 months to verify the Salem EDG auto-connected loads per the loading calculation do not exceed 2860 kw, per proposed Surveillance Requirement 4.8.1.1.2.d.8.

NRC Comment: How will the 18 month review be tracked as a surveillance requirement? Because Surveillance Requirements are generally tracked and performed by operations, the NRC staff would like assurance that a surveillance performed by engineering will be properly tracked and communicated to operations.

PSE&G Response: The review will be tracked in the Managed Maintenance Information System (MMIS) and will be a requirement in the 18 month surveillance procedures. Surveillance procedures will be revised to prompt operations to verify the engineering review has been completed. Engineering will be assigned a periodic task to perform the review.

_ _J

T NLR-N93123 3 of 3 Deletion of Footnote for Shutdown Technical Specifications The April 28, 1993 amendment request deleted the footnote for diesel starts in MODES 5 and 6, which defined valid and non-valid starts relative to loaded runs. However, the 11

• 11 corresponding to the note was not deleted.

NRC Comment: The "*" should be removed if the note is being removed.

PSE&G Response: The proposed change has been revised to remove the 11

• 11 from Surveillance Requirement 4.8.lo2.

NLR-N93123 ATTACHMENT 2 EDG VOLTAGE CRITERIA CHANGE I. DESCRIPTION OF PROPOSED CHANGE TO EDG VOLTAGE CRITERIA Revise the acceptable Emergency Diesel Generator (EDG) voltage, from 4160 +/- 420 volts to ~ 3950 and 5 4580 volts, for the following Salem Unit 1 and Unit 2 Surveillance Requirements:

4.8.1.1.2.a.2 4.8.1.1.2.c 4.8.1.1.2.d.2 4.8.1.1.2.d.3.b 4.8.1.1.2.d.4 4.8.1.1.2.d.6.b 4.8.1.1.2.d.7 II. REASON AND JUSTIFICATION FOR THE PROPOSED CHANGE The affected Surveillance Requirements include an acceptable EDG voltage range in response to various loading conditions~ The present range of 4160 +/- 420 volts is based on the Standard Technical Specification range of plus/minus 10% of the nominal voltage, consistent with a minimum operating voltage of 90%. A recent review of the Salem degraded grid calculations was performed as part of a self-assessment program. During this review, the minimum vital bus recovery voltage was calculated to be 93.2%. This recovery voltage ensures that the vital bus loads would remain operable under degraded voltage conditions.

The proposed minimum allowable EDG voltage is being increased to 3950 volts, which is 95% of nominal. This value would require EDG surveillance testing to demonstrate the voltage is above the minimum needed to ensure operability of the vital bus loads (i.e.

93.2%), within the time specified by the surveillance requirement. The proppsed val.ue is more. restrictive than that allowed by the present- Techrtical Specifications.

III. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The following is applicable to the changes proposed in our letters dated March 6~ 1991, September 20, 1991 and April 28, 1993, as well as the changes proposed in this *document.

The proposed changes to Technical Specifications 3/4.8.1.1 and 3/4.8.1.2 for Salem Unit Nos. 1 and 2:

(1) do not involve a significant increase in the probability or consequences of an accident previously evaluated. Reducing the test frequency while in an action statement and modifying Emergency Diesel Generator (EDG) starting and loading requirements is intended to enhance diesel reliability by minimizing repetitive testing and

I NLR-N93123 Attachment 2 facilitating testing in accordance with the manufacturer's recommendations. The proposal to eliminate Action Statement operability testing for a diesel inoperable because of preventive maintenance or pre-test inspection will facilitate the performance of activities to enhance overall EDG reliability.

The proposed changes to EDG test loads will continue to demonstrate the ability of the EDG's to respond to loading conditions, consistent with the manufacturer's ratings.

Using the proposed basis for determining test frequency according to individual diesel generator performance will prevent overtesting of the diesels because it would increase the test frequency of only those diesels which have an increase in failure rate.

The changes proposed to make the Unit 1 EDG surveillance requirements identical to that of Unit 2 is a conservative change; it will provide Unit 1 with a more comprehensive testing program. The proposed changes will continue to assure availability of the diesels and should serve to enhance EDG reliability and consequently the overall safe operation of the Salem Generating station.

The proposed minimum voltage limit for surveillance testing is more restrictive than.the present Technical Specification limit. It would require EDG voltage to be above the minimum value needed to ensure operability of the vital bus loads, within the time specified by the surveillance test criteria.

(2) do not create the p6ssibility?of a new or different kind of accident from any accident previously evaluated. The proposed changes affect testing .f.requency, starting and loading practices only and hav~* no impact on the accident analysis. No new operating modes or. equipment are introduced which could initiate or aff-ect the progression of

• an accident.

(3) do not involve a significant reduction in a margin of safety. The changes in the testing requirements do not adversely affect the capability of the diesels to perform their required function. The purpose of the proposed changes is to increase the overall reliability of the diesels. In adopting many of the suggestions identified in GL 84-15, the requested change would implement actions which have been determined by the NRC to reduce the risk of core damage from station blackout events.

Therefore, PSE&G has concluded that the changes proposed herein do not involve a Significant Hazards Consideration.

NLR-N93123 ATTACHMENT 3