LR-N10-0037, 2009 Summary of Revised Regulatory Commitment

2009 Summary of Revised Regulatory Commitment

ML101310229
Person / Time
Site:	Salem
Issue date:	04/30/2010
From:	Fricker C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N10-0037
Download: ML101310229 (6)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 APR 3 0 2010 0 PSEG LR-NIO- 0037 Nuclear LLC U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Salem Generating Station, Units 1 and 2 Facility Operating License Nos. DRP-70 and DRP-75 NRC Docket Nos. 50-272 and 50-311

Subject:

2009 Summary of Revised Regulatory Commitment - Salem In accordance with the Nuclear Energy Institute (NEI) process for managing Nuclear Regulatory Commission (NRC) commitments and associated NRC notifications, PSEG Nuclear LLC (PSEG) submits this correspondence to discuss commitments that were changed and not reported by other means during 2009.

The attached commitments were evaluated in accordance with the requirements of the PSEG Regulatory Commitment Change Process, which is consistent with the guidance in NEI 99-04, "Guideline for Managing NRC Commitments."

There are no new commitments in this letter.

If there are any questions, please contact Howard Berrick at 856-339-1862.

Sinckere rl . Fri ker Site Vice President - Salem

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Attachments (1) I: S.. S AcYi 95-2168 REV. 7/99

Document Control Desk /APR 3 0_1 LR-N1O- 0037 2 C S. Collins, Administrator - Region 1 R. Ennis, Project Manager - USNRC D. Schroeder - USNRC Senior Resident Inspector - Salem P. Mulligan, Manager, IV, Bureau of Nuclear Engineering H. Berrick, Salem Commitment Coordinator - X25 L. Marabella, Corporate Commitment Coordinator - N21

Attachment LR-N10-0037 Page 1 of 4 Revised Commitment Description Justification For Change Original Commitment: The thermal performance testing frequency of Enclosure 2 of NRC Generic Letter states that a licensee or applicants

"... After about three (3) tests, the tube and shell type 11, 21 and 22 periodic retest program should determine, after three tests, the best a licensee or applicant should Component Cooling Heat Exchangers frequency for testing to provide assurance that the equipment will perform determine the best frequency (CCHX) is every 4 refueling outages (4R, or the intended safety functions during the intervals between tests.

for testing to provide 6 years).

Testing of the CCHX's has verified that the cleaning methods utilized have assurance that the equipment allowed for increased margin to the fouling limit on the heat exchanger will perform the intended safety tubes. The commitment is being revised to extend the thermal performance functions during the intervals testing frequency on the CCHX's listed in Part 1 from 3R (4.5 years) to 4R (6 between the tests and meet years). The 4R (6 years) performance testing frequency will allow alignment the requirements of GDC 44, of the test with the service water nuclear underground header outage (2R) 45, and 46. The minimum and cleaning of the heat exchanger, which is a six-year (6) PM to open, final testing frequency inspect, clean and eddy current tubes.

should be once every 5 years." The performance testing results since 1R1 3 for Unit 1 and 2R1 0 for Unit 2 for the above heat exchangers were reviewed. Results are well below the Source Document: maximum fouling factor limit. Additionally, Salem also performs biofouling trending every 60 days, recording and trending the important system NRC Generic Letter 89-13, parameters (i.e. flow, temperature and pressure).

Service Water System Problems Affecting Safety-Related Equipment, Enclosure 2, Program for Testing Heat Transfer Capability

Reference:

CM-SC-1 990-591 70095726 0020 Date of Change:

08/20/2009

______________________________ I ____________________________________________ I

Attachment LR-N10-0037 Page 2 of 4 Revised Commitment Description Justification For Change Original Commitment: The commitment to maintain procedures has IE Bulletin 85-01, Steam Binding Of Auxiliary Feedwater Pumps, "1. Maintain procedures to not changed. Salem Unit 1 and Unit 2 have a recommended that procedural controls remain in effect until the completion monitor fluid conditions within periodic inspection procedure S1/2.OP-PT.AF of hardware modifications to 'substantially reduce' the likelihood of steam the AFW system each shift -0002, Auxiliary FeedwaterBackleakage, binding, or until it was superseded by action implemented as a result of during times when the system which identifies conditions that could lead to resolution of Generic Safety Issue 93, Steam Binding of Auxiliary Feedwater is required to be operable. This steam binding by monitoring the Auxiliary Pumps (Generic Letter (GL) 88-03). This issue was resolved (for Salem) by monitoring should ensure that Feedwater (AFW) pump discharge piping requesting confirmation that Salem would: 1. Maintain procedures to monitor fluid temperature at the AFW temperature. fluid conditions within the AFW system each shift during times when the pump discharge is maintained system is required to be operable. This monitoring should ensure that fluid However, the criterion that requires at about ambient levels; and temperature at the AFW pump discharge is maintained at about ambient Engineering notification has changed.

2. Maintain procedures for levels; and 2. Maintain procedures for recognizing steam binding and for Previously, this criterion was if the AFW recognizing steam binding and restoring the AFW system to operable status, should steam binding occur.

for restoring the AFW system discharge piping reaches 120OF "or the temperature difference (Delta T) between any Salem Unit 1 and Unit 2 have in place a periodic inspection procedure to operable status, should S1/2.OP-PT.AF-0002, Auxiliary Feedwater Backleakage, which identifies steam binding occur." two discharge lines was greater than 10°F."

conditions that could lead to steam binding by monitoring the AFW pump The new criterion is if the discharge piping discharge piping temperature. This procedure, performed once per shift in Source Document: reaches 120OF "or the temperature difference modes 1, 2 and 3, prevents steam binding conditions from occurring.

NRC IE Bulletin 85-01 (Delta T) between the highest temperature The procedures verify that none of the AFW line temperatures are NRC GL 88-03 line and the average line temperature is significantly higher than the others. The procedure originally required PSEG NLR-N88078 dated greater than 10°F." Engineering notification if the discharge piping reaches 120OF or the 05/27/88 (C0270) temperature difference (Delta T) between any two discharge lines is greater than 100 F.

Reference:

The method for steam leakage detection often caused "false positives" when CM-SC-1 988-592 a single line temperature became lower than the other three lines. The new 70093395 0050 criterion for notifying Engineering is if the discharge piping reaches 120°F "or 70095726 0030 the temperature difference (Delta T) between the highest temperature line and the average line temperature is greater than 10°F." Although this Date of Change: criterion does cause a slight loss of sensitivity to temperature changes, it is sufficiently sensitive to identify inconsistencies early on to eliminate false 09/11/08 positives. Not changed is that should the discharge piping temperature reach 160 0 F, specific guidance is provided to restore the AFW system to an operable status.

Attachment LR-N10-0037 Page 3 of 4 Revised Commitment Description Justification For Change Original Commitment: All reference to sampling the BIT and TS Amendment 78 SER, dated 04/07/1987, approved reducing the Boron maximum concentrations is removed. Injection Tank (BIT) boron concentration from 20,000 - 22,000 ppm boron to "1. The existing lines 2,200 ppm or less. The SER stated that in a conference call on 10/3/1986, connecting the [Boron Injection Salem committed to cutting and capping the existing lines connecting the Tanks] BITs to the [Boric Acid BITs to the BATs prior to implementation of the remainder of the proposed Tanks] BATs will be cut and modifications and the BITs would be sampled for boron concentration on a capped prior to implementation quarterly basis. This was because of the NRC staff's "...concern about the of the remainder of the possibility of introducing concentrated boric acid into the BIT in the event of proposed modifications. emergency boration..."

[NOTE: This commitment is There is no longer a connection between the BATs and the BITs so the not impacted by this change]

concerns that concentrated boric acid would accumulate in the BITs are no longer valid. BIT boron concentrations are no longer a concern because

2. The BITs will be sampled there is no minimal boron, and the maximum boron is the concentration from for boron concentration on a the RWST. Additionally, samples since 1986 demonstrate that there is no quarterly basis." concern for concentrated boric acid. BIT sampling cost chemistry technician dose and entry into a contamination area, and is considered a safety hazard Source Document: by the chemistry technicians due to the potential for bumps, trips and falls.

Salem 1/2 Amendments 78/52 The BIT has become a large "pipe" for the injection of boric acid from the SER, dated 04/07/87 (C0451)

RWST. There are no minimum boron concentrations, and the BIT connections to the BATs are gone; therefore, the concerns for concentrated

Reference:

boric acid injection are removed. Additionally, the current safety analysis CM-SC-1 987-593 does not depend on boron from the BIT.

70095726 0040 From UFSAR, Section 6.3.2.2 Equipment and Component Description of Boron Injection Tank... "The BIT contains between 0 to 2500 ppm boric acid Date of Change: solution and is connected to the discharge of the centrifugal charging 10/05/09 pumps. Upon actuation of the safety injection signal, the flow from the centrifugal charging pumps is routed through the BIT into the RCS. Although the BIT is part of the safety injection pressure boundary, the diluted form of boric acid in the BIT is not credited for accident mitigation.

Attachment LR-N10-0037 Page 4 of 4 Revised Commitment Description Justification For Change The BIT is maintained in a 100-percent full condition. The BIT is kept 100%

full administratively by filling and venting periodically using procedural controls. The parallel motor-operated gate valves at the inlet and outlet of the BIT are kept normally closed. The BIT pressure also can be monitored from the Control Room console.

Chapter 15, Accident Analysis, conservatively assumes that the BIT is filled with unborated water (0-ppm boric acid) when analyzing core response, containment integrity, and equipment environmental qualification.

The normal temperature of the BIT and its associated lines is at ambient temperature. Heaters in the BIT and associated line heat tracing are not required because of the low concentration of boric acid."