ML18100A490

Forwards Revised TS 3.3.3.7, Post-Accident Monitoring Sys, Table 3.3-11 & 4.3-11 from 930223 Application for Amends to Licenses DPR-70 & DPR-75

ML18100A490
Person / Time
Site:	Salem
Issue date:	07/19/1993
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18100A491	List: ML18100A490 ML18100A492
References
LCR-92-12, NLR-N93105, NUDOCS 9307280043
Download: ML18100A490 (5)

Text

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Public Service Elec:tric 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 JUL 19 1993 NLR-N93105 LCR 92-12 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REVISED REQUEST FOR AMENDMENT 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 revises our original submittal dated February 23, 1993, Ref: NLR-N93022. As discussed between members of my staff and Mr. J. Stone, NRC Licensing Project Manager for Salem Station, the revision as described in attachment 1 to this letter is being submitted for your review.

The proposed change deletes line item 9 of Technical Specifications 3.3.3.7, Post Accident Monitoring System, Table 3.3-11 and 4.3-11 with its associated Action 3, for both Salem Units. As discussed in Attachment 1 to this letter, PSE&G's conclusion is that granting this request would not involve a significant hazards consideration. Attachment 2 contains the Technical Specifications marked up pages.

Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, and to be implemented within sixty (60) days to provide sufficient time for associated administrative activities.

Sincerely,

,--:-9301200043 9307 19~;-TI PPDR* ADOCK 05000272 PDR

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Document Control Desk 2

• JUL 19 1993 NLR-N93105 Attachments (2) c Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Manager, VI New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

REF: NLR-N93105 STATE OF NEW JERSEY SS.

COUNTY OF SALEM 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 J"§ tic day o~, Lt; ' ' 1993

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Notary Publicof New Jersey KIMBERL y JO BROWN NOTARY PUBUC OF NE My Commission expires on My Commission Expi' A ~ JERSEY res JlCll 21, 1998

NLR-N93105 ATTACHMENT 1 I. DESCRIPTION OF THE PROPOSED CHANGES Delete line item 9 of Technical Specifications 3.3.3.7, Post Accident Monitoring System, Table 3.3-11 and 4.3-11 with its associated Action 3, for both Salem Units.

II. REASON FOR THE PROPOSED CHANGES

.. NUREG-1431 *(Standard Technical Specifications Westinghouse Plants, September 1992) eliminates the BAST level indication from table 3.3-11 as a line item (one of the required post accident monitoring instrumentation). NUREG-1431 only includes instrumentation that has been defined as a Type A Category 1 variables as intended by the stated purpose of the LCO and explained below.

III. JUSTIFICATION AND EVALUATION OF THE SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES OF THE REQUEST The BAST (with the transfer pumps) are part of the boration subsystem of the Chemical and Volume Control System (CVCS). This subsystem provides a means to meet one of the functional requirements of the eves, which is the control of boron (neutron absorber) in the Reactor Coolant System (RCS). The boration system is not assumed to be operable to mitigate the consequences of a Design Basis Accident (DBA) or transient. In case of a malfunction of the eves, which causes a boron dilution event, the automatic response is for the operator to close the appropriate valves in the reactor make-up system. The boration subsystem (BAST) is not assumed to mitigate this event. The BAST level instrumentation is not instrumentation installed or used to detect and indicate a significant degradation of the RCS in the control room.

The Post-Accident Monitoring Instrumentation Limiting Condition for Operation ensures the operability of appropriate instrumentation so that the control room operating personnel can:

Perform the diagnosis specified in the Emergency Operating Procedures. These variables are restricted to pre-planned actions for DBA such as LOCA, steam Breaks, Feedwater Breaks, and SGTR.

Take the specified pre-planned manual actions for which no automatic action is available, that are required of the safety systems to perform their safety function.

Reach and maintain safe shutdown conditions.

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Reg. Guide 1.97 defines/classifies instrumentation as Type A through E depending on the plant variable they monitor and Category 1 through 3 depending upon the importance of the variable monitored. The instrumentation listed in table 3.3-11 is (intended to be) Reg. Guide 1.97 instrumentation defined as Type A and/or Category 1.

The BAST, as stated earlier, is not part of a system assumed to mitigate the consequences of a DBA; therefore the level instrumentation has been defined as a Type B Category 3 variable.

The restrictiveness of this LCO seems to be limited to the present Salem Technical Specifications. NUREG-1431 eliminates the BAST level indication from table 3.3-11 as a line item.

NUREG-1431 only includes instrumentation that has been defined as a Type A variables or other Reg. Guide 1.97 instruments which have been determined to be of prime importance in limiting risk.

Therefore, PSE&G believes that the proposed change is administrative in nature and does not affect the health and safety of the public.

IV. DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION This proposed Amendment request:

1. Does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The request is only administrative in nature and does not involve a system that was assumed to function in any of the design/licensing basis analysis, therefore the probability or consequences of an accident previously evaluated are not increased.

2. Does not create the possibility of a new or different kind of accident from any accident previously evaluated.

• The proposed change does not introduce any design or physical configuration changes to the facility which could create new accident scenarios.

3. Does not involve a significant reduction in a margin of safety.

As stated in response to question number 1 above, the proposed change does not affect a system that was taken credit for or assumed to function under any of the design/licensing basis analysis. Consequently, there is no reduction in any margin of safety.

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