LR-N16-0134, Response to Request for Additional Information Regarding Chilled Water System Modifications

Response to Request for Additional Information Regarding Chilled Water System Modifications

ML16225A436
Person / Time
Site:	Salem
Issue date:	08/12/2016
From:	Carr E Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF6724, CAC MF6725, LAR S14-04, LR-N16-0134
Download: ML16225A436 (22)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 PSE<i Nur/mr Ll,C AUG "1"2 2016 10 CFR 50.90 LR-N16-0134 LAR S14-04 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Salem Nuclear Generating Station Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

Response to Request for Additional Information Regarding Chilled Water System Modifications (CAC Nos. MF6724 and MF6725)

References 1. PSEG letter to NRC, "License Amendment Request Modifying Chilled Water System Requirements," dated September 11, 2015 (ADAMS Accession No. ML15254A387)

2. NRC letter to PSEG, "Salem Nuclear Generating Station, Unit Nos. 1 and 2 Request for Additional Information Regarding Chilled Water System Modifications," dated July 14, 2016 (ADAMS Accession No. ML16195A449)

In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request for Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. The proposed amendment would revise Technical Specification (TS) 3/4. 7.1 0, "Chilled Water System- Auxiliary Building Subsystem," to allow (1) a reduction in the number of required components (two vs. three required chillers) and (2) use of the cross-tie capability between Unit 1 and Unit 2. A supporting change would also be made to the Control Room Emergency Air Conditioning System TS

3. 7.6.1 (Unit 1) and TS 3. 7.6 (Unit 2).

In the Reference 2 letter, the U.S. Nuclear Regulatory Commission staff provided PSEG a Request for Additional Information (RAI) to support the NRC staff's detailed technical review of Reference 1. The requested information is provided in Attachment 1. Attachment 2 provides revised TS-markups based on the responses in Attachment 1.

PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

LR-N 16-0134 10 CFR 50.90 Page 2 There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please contact Brian Thomas at (856) 339-2022.

I declare under penalty of perjury that the foregoing is true and correct.

-Executed on . JJ/D-/1£'.

(Date)

Respectfully, C#--

Eric Carr Acting Site Vice President Salem Generating Station Attachment 1 Response to Request for Additional Information Regarding Chilled Water System Modifications (CAC Nos MF6724 and MF6725)

Attachment 2 Revised Mark-up of Proposed Technical Specification Pages cc: Mr. D. Dorman, Administrator, Region I, NRC Ms. C. Parker, Project Manager, NRC NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. Cachaza, Salem Commitment Tracking Coordinator

LR-N16-0134 Response to Request for Additional Information Regarding Chilled Water System Modifications (CAC Nos. MF6724 and MF6725) 1 of 17

LR-N16-0134 RAI SBPB-17 Follow up to RAI SBPB-12 BACKGROUND:

The existing TS 3/4.7.10 ACTION allows 14 days completion time with one inoperable chiller and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time with two inoperable chillers for MODES 1, 2, 3 and 4. PSEG stated in their LAR, under proposed TS 3/4.7.10, that Configuration b is proposed to allow chiller replacement.

Standard Technical Specifications - Westinghouse Plants: Specifications (NUREG 1431, Revision 4), Volume 2, Bases, Limiting Condition for operation (LCO) 3.0.2 states, in part:

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered.

ISSUE:

Over a period of time, all three safety-related chillers on Salem, Unit No. 1, will be replaced, and all three safety-related chillers on Salem, Unit No. 2, will be replaced. PSEGs RAI response to SBPB-12 on March 31, 2016 states, in part:

The new proposed configurations (LCO 3.7.10b and LCO 3.7.10c) have significant restrictions that must be met, as outlined in the proposed applicability sections of the LCOs. Because of these restrictions, the new LCO 3.7.10b and 3.7.10c configurations will be used judiciously. From an operational standpoint, it is preferred to remain in the original LCO 3.7.10 a configuration whenever possible and practical (i.e., less likelihood that a Unit, or both Units, would need to make an unplanned transition out of the LCO, or even shutdown).

Originally, PSEG only explored the proposed Cross-Tied LCO (LCO 3.7.10c configuration) for the chiller replacement project (as well as the maintenance on common line components). Due to the Cross-Tie configuration restrictions required by the analysis (particularly the prohibited use of the CREACS single filtration alignment in the Cross-Tie configuration), the additional Two Chiller LCO 3.7.10b configuration was subsequently evaluated and included in the proposed TS change to allow for the necessary time, flexibility and realistic operating conditions to perform the required work. The LCO 3.7.10b 2 of 17

LR-N16-0134 configuration will initially be used to support the chiller replacements; however, use for other operating reasons is not restricted by the analysis supporting the LCO configuration.

In accordance with Standard TSs Bases 3.0.2, which focuses on plant safety, proposed Configuration b and c should only be entered for the performance of TS Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering into Configuration b and c must be done in a manner that does not compromise safety, and intentional entry into Configuration b and c should not be made for operational convenience.

An example of operational convenience includes, but is not limited to, securing equipment without a need to perform maintenance.

RAI:

Since the stated purpose of TS 3/4.7.10, Configuration b, is three per unit chiller replacements justify keeping configuration b for future chiller maintenance following chiller replacement, beyond the existing 14-day completion time and address the following:

a. Establish a bounding time frame for those maintenance activities/repairs (post-chiller replacements) and addresses anticipated chiller repair completion times.

b. Based on the above, what is a reasonable allowed outage time for those maintenance activities/repairs (post-chiller replacements). If less than 180 days, justify why the additional time is appropriate.

c. Describe how TS operational restrictions will be imposed since the proposed TS 3/4.7.10 has an open maintenance window of approximately 180 days (November 1 to April 30).

d. Since chiller replacement will be performed in Configuration b, provide justification for the 180 day window created by Configuration c, or propose an applicability window aligned with the expected need time. Note that the NRC staff has accepted TS completion times for other chiller designs for one train out of service as follows:

i. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (Comanche Peak, Palo Verde, Shearon Harris, Vogtle, and Waterford) ii. 7 days (Crystal River, South Texas, and Surry - less than three of five chillers for two units) iii. 14 days (San Onofre and Salem) iv. 30 days (Catawba, Duane Arnold, McGuire, North Anna, Oconee, and Praire Island) 3 of 17

LR-N16-0134 PSEG Response LCO Configuration b Although the LAR states that the development of the LCO 3.7.10b configuration is to support the replacement of the Salem chillers, PSEG is clarifying that the this new LCO configuration is also intended, and analyzed, to be used for unplanned operational issues and planned maintenance evolutions.

While the more urgent need for the LCO 3.7.10b configuration is to support the replacement of the chillers (one at a time), the justification for the LCO 3.7.10b configuration was not based on a limited use analysis using probabilistic assumptions. The analysis/justification is deterministic based, and demonstrates that with the cooler temperature calendar window and the removal of heat loads from the chilled water system, the number of required chillers can be reduced from three to two for the period of November 1 to April 30. The analysis conservatively assumes both Units in the LCO 3.7.10b configuration with a chiller removed from service on the non-accident unit and an active single failure for the unit that experiences the design basis accident (one chiller on each Unit operating following the design basis accident).

Maintaining the LCO 3.7.10b configuration in the Salem Unit 1 and 2 Technical Specifications following the planned chiller replacements would allow for planned maintenance on the chillers to be scheduled during the cooler months when chiller capacity requirements are reduced, allowing for chiller maintenance without having reduced system availability by being in an ACTION statement if all three chillers are always required. This would allow operations, maintenance and engineering to schedule the chiller work windows based on the work necessary to ensure long term reliability of the chillers in the future without the work window restrictions of an action statement. By current work management practices, scheduled work windows involving a TS component are targeted not to exceed 50% of the TS allowed outage time. Allowing for an expanded work window will allow for the necessary preventative maintenance work to be performed potentially in one work window instead of taking the chiller out of service for multiple windows during the operating cycle to complete the work.

In addition to improvements in the planning of work for scheduled maintenance, the LCO 3.7.10b configuration would improve the overall plant risk in response to emergent chiller issues in the future. In the event that emergent chiller maintenance challenges the LCO 3.7.10a 14-day allowed outage time (AOT) following the chiller replacement, it would be a prudent action to retain LCO 3.7.10b in lieu of putting a plant through an unnecessary shutdown transient. Since the deterministic analysis discussed above has demonstrated that during the period of November 1 through April 30, the chilled water system can function in response to a design basis accident and withstand an active single failure, there is no additional nuclear safety risk to being in the LCO 3.7.10b configuration. If the LCO 3.7.10b configuration was removed from the Salem TS following the planned chiller replacements and an emergent equipment issue occurred that would challenge the 14-day AOT during the November 1 to April 30 period, PSEG would most likely request a Notice of Enforcement Discretion (NOED) to continue the repairs to restore the chilled water system to operable status in lieu of commencing an unnecessary plant shutdown since there is no additional nuclear safety risk. Retaining the LCO 3.7.10b configuration would allow the organization to focus on the task of repairing the inoperable equipment and minimize the time the equipment remains out of service.

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LR-N16-0134 As discussed during the NRC on-site audit, PSEG recognizes that the currently proposed LCO 3.7.10b configuration would allow entry starting on November 1 and exit on April 30 (i.e., 180 days) with no restriction on how long the plant can stay in this configuration. However, as discussed in the response to RAI-SBPB-121, there are significant operational restrictions that come with LCO 3.7.10b configuration (limitations on CREACS single train alignment) which would limit the time duration based on the operational risk. To further clarify the judicious use of the LCO 3.7.10b configuration, PSEG is proposing to further restrict the use of LCO 3.7.10b to a 60-day contiguous period. It is important to note that the time period for Salem is not an ACTION Statement AOT like the 30 days for Catawba (et al, cited in the RAI) when Catawba is operating with less than the equipment required to meet the LCO. In LCO Configuration b, Salem still has the required operable equipment to meet the LCO and consequently remains in the LCO versus an ACTION statement. The 60-day period does not reflect a time in which equipment needs to be restored to ensure the ability to respond to a DBA and an active single failure, but instead provides an operational limitation.

The 60-day contiguous period will be added as a note to the applicability of the LCO 3.7.10b configuration. This note will clarify that the 60-day contiguous period would not apply to the LCO 3.7.10b configuration entries for the replacement of the existing chillers. The revised TS markup is provided in the response to RAI STSB-3, and Attachment 2 of this submittal.

The 60-day period would allow sufficient (bounding) time to perform emergent equipment repairs including the potential replacement of major components of the new chiller. This time period would allow for the procurement of the necessary parts if they are not in stock.

LCO Configuration c Although the LAR states that the development of the LCO 3.7.10c configuration is to support the planned maintenance of common line components, PSEG is clarifying that the new LCO configuration is also intended, and analyzed, to be used for unplanned operational issues.

The justification for the LCO 3.7.10c configuration was not based on a limited use analysis using probabilistic assumptions. The analysis/justification is deterministic based, and demonstrates that with the cooler temperature calendar window and the removal of heat loads from the chilled water system, a single units chillers and pumps can supply the chilled water heat removal requirements for both Units while accommodating an active single failure and a design basis accident on either Unit.

In the event that an operational issue arose that would impact the operability of Units chilled water system (i.e., leakage from an ASME boundary on a common line component), if it is determined that the operational issue could be repaired while using the chilled water cross-tie (i.e., the affected portion of the system can be isolated without impacting the function of the cross-tie), PSEG could transition to LCO 3.7.10c in lieu of putting a plant through an unnecessary shutdown transient without chilled water.

As discussed during the NRC on-site audit, PSEG recognizes that the currently proposed LCO 3.7.10c configuration would allow entry starting on November 1 and exit on April 30 (i.e., 180 days) with no restriction on how long the plant can stay in this configuration. However, as 1

PSEG letter to NRC, "Response to Request for Additional Information Regarding Chilled Water System Modifications (CAC Nos. MF6724 and MF6725)," dated March 31, 2016 (ADAMS Accession No. ML16091A237) 5 of 17

LR-N16-0134 discussed in the response to RAI-SBPB-12, there are significant operational restrictions that come with LCO 3.7.10c configuration (both CREACS trains must be OPERABLE) which would limit the time duration based on the operational risk. To further clarify the judicious use of the LCO 3.7.10c configuration, PSEG is proposing to further restrict the use of LCO 3.7.10c to a 45-day contiguous period (this is similarly not an ACTION Statement AOT as discussed above for LCO 3.7.10b configuration). The 45-day contiguous period would allow for the tagging, maintenance, post maintenance testing, and restoration from the cross-tie configuration. The 45-day contiguous period will be added as a note to the applicability of the LCO 3.7.10c configuration.

The revised TS markup is provided in the response to RAI STSB-3, and Attachment 2 of this submittal.

RAI SBPB-18 Follow up to RAI SBPB-CROSS-TIE 2 BACKGROUND:

PSEG stated by letter dated September 11, 2015, that the reason for the unit cross-tie request was to permit maintenance on common line Auxiliary Building (AB) chilled water (CH) components.

Common line components are components on lines that require the removal of a single unit's chillers/pumps in order to perform maintenance. To reduce demand on the AB CH system when in the reduced equipment and cross-tied configurations, the licensee proposes to perform upgrades and maintenance during cooler portions of the year consistent with the operating restrictions proposed for the TSs.

Proposed Note (5) for TS 3/4.7.10 states that when in the LCO 3.7.10b configuration, implement Action b.2 AND Action b.4 OR transition to the LCO 3.7.10c configuration.

PSEGs RAI SBPB-CROSS-TIE 2 response on March 31, 2016, states:

Currently, maintenance (i.e., internal inspection) or replacement on certain components and piping associated with the chillers cannot be performed without impacting multiple chiller trains (i.e., cannot be performed with existing TS) as identified below:

The CH22/27 isolation valves, which provide chilled water isolation to each chiller. Freeze seals to isolate the CH22/27 valves have been considered in the past: however, this was ultimately deemed impossible without impacting at least two chillers simultaneously.

Many of the CH23-26 drain valves within the boundary of the isolation valves.

The chilled water expansion tank.

Replacement of piping within the boundary of the chillers and chilled water pumps.

Since the cross-tie option was eliminated via Amendments 199 and 182 (ADAMS ML011720149), there has been no available option for performing the above activities.

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LR-N16-0134 PSEGs RAI SBPB-12 response on March 31, 2016, states, in part:

The new proposed configurations (LCO 3.7.10b and LCO 3.7.10c) have significant restrictions that must be met, as outlined in the proposed applicability sections of the LCOs. Because of these restrictions, the new LCO 3.7.10b and 3.7.10c configurations will be used judiciously. From an operational standpoint, it is preferred to remain in the original LCO 3.7.10 a configuration whenever possible and practical (i.e., less likelihood that a Unit, or both Units, would need to make an unplanned transition out of the LCO, or even shutdown).

Originally, PSEG only explored the proposed Cross-Tied LCO (LCO 3.7.10c configuration) for the chiller replacement project (as well as the maintenance on common line components). Due to the Cross-Tie configuration restrictions required by the analysis (particularly the prohibited use of the CREACS single filtration alignment in the Cross-Tie configuration), the additional Two Chiller LCO 3.7.10b configuration was subsequently evaluated and included in the proposed TS change to allow for the necessary time, flexibility and realistic operating conditions to perform the required work. The LCO 3.7.10b configuration will initially be used to support the chiller replacements; however, use for other operating reasons is not restricted by the analysis supporting the LCO configuration.

ISSUE:

RAI response to SBPB-CROSS-TIE 2 conflicts with TS 3/4.7.10 Note (5) since this Note allows a transition from Configuration b (used for chiller replacement) to Configuration c (used for maintenance on common components).

RAI:

Clarify if Configuration c will be used for chiller replacement. If so, address the following questions:

a. Describe the testing planned to demonstrate that transitioning from Configuration b to c and from Configuration c to b can be safely accomplished and accomplish chiller design conditions without exceeding design temperatures, while conducting Loss of Unit 1/2 Control Area HVAC in accordance with S1 (S2).OP-AB.CAV-0001(Q).

b. Describe the time duration for this transition from Configuration b to c and if this transition can be safely achieved within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> without exceeding room design temperatures.

c. Describe the time duration plan for being in Configuration c for chiller replacement.

d. Describe the stations probabilistic risk assessment (PRA) risk for being in Configuration c for chiller replacement.

e. Justify the 14-day LCO completion time is reasonable if, in Configuration c while conducting chiller replacement and one of the required chillers becomes inoperable.

Note that the NRC staff has accepted TS completion times for other chiller designs for one train out of service as follows:

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LR-N16-0134

i. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (Comanche Peak, Palo Verde, Shearon Harris, Vogtle, and Waterford) ii. 7 days (Crystal River, South Texas, and Surry - less than three of five chillers for two units) iii. 14 days (San Onofre and Salem) iv. 30 days (Catawba, Duane Arnold, McGuire, North Anna, Oconee, and Prairie Island)

PSEG Response PSEG responded to RAI-SBPB-CROSS-TIE 2 (PSEG Letter LR-N16-0055, March 31, 2016) to specifically address the NRC staff question on what common line component maintenance would be performed utilizing the chilled water cross-tie configuration. This response was not placing a limitation on the use of the cross-tie configuration but was describing the common line component maintenance that can only be performed in the cross-tie configuration.

As discussed in RAI-SBPB-12 (PSEG Letter LR-N16-0055, March 31, 2016), the original replacement strategy for the chillers was to replace an entire units set of chillers (all three chillers) at one time while using the cross-tie configuration. Due to the restrictions required by the analysis (particularly the prohibited use of the CREACS single filtration alignment in the cross-tie configuration), the additional Two Chiller LCO 3.7.10b configuration was subsequently evaluated and included in the proposed TS change to support the replacement of the chillers one at a time. The technical justification for both LCO 3.7.10b and LCO 3.7.10c does not limit either LCO configuration to their primary purpose, i.e., to just chiller replacement or just common line maintenance, respectively.

In regards to the use of the cross-tie during chiller replacement, PSEG intends to perform the chiller replacement starting in the LCO 3.7.10b configuration; however, in the event of unplanned inoperability of the remaining chiller(s), the LCO 3.7.10c configuration could be entered in lieu of shutting down a Unit with no chilled water. Although Salem has developed abnormal procedure guidance (S1(2).OP-AB.CAV-0001) for shutting down a Salem Unit with no chilled water (described in response to RAI-SBPB-CROSS-TIE-1 Item c), the use of the cross-tie would avoid the risk incurred of shutting down a unit without normal cooling to the Control Area Relay Room (CARR) and Electrical Equipment Room (EER). Use of the cross-tie would restore chilled water flow to the impacted units CAACS coiling coil and therefore allow cooling of the CARR and EER.

As described in new Note (5) of the proposed technical specification changes, inoperability of the 2 required chillers while in the LCO 3.7.10b configuration requires entry into Action b.2 AND b.4 OR transition to the LCO 3.7.10c configuration. Action b.2 requires the alignment of CREACS to single train operation and Action b.4 requires the Unit to be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN with the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Specifically addressing items a - e of the RAI:

a. Heat up when transitioning from one LCO configuration to another LCO configuration is only a concern when the evolution is performed in response to emergent equipment issues.

Transitioning from LCO Configuration 3.7.10c to LCO Configuration 3.7.10a or 3.7.10b would be a pre-planned evolution that would be performed when the chillers on the Unit with no operable/operating chillers are restored to operability.

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LR-N16-0134 Transition from the LCO 3.7.10a or 3.7.10b configurations to the LCO 3.7.10c configuration can be performed for either pre-planned evolutions or in response to emergent chiller failures on a unit. Therefore, heatup of the of the Control Area Ventilation (CAV) rooms when emergently transitioning to the LCO 3.7.10c configuration needs to assessed.

No testing is required to demonstrate CAV room design temperature limits are maintained when transitioning from the LCO 3.7.10b to LCO 3.7.10c configuration. Instead, this is demonstrated by validating the time for completing the necessary operator actions, and by performing an analysis of CAV room heatup based on this time, as discussed below.

The time to open the crosstie valves was determined to be less than two hours. This was verified by a field walk down by a qualified equipment operator. The time to perform the valve manipulations included the pre-job brief, transit time to the Control Area Ventilation (CAV) Equipment Room (including signing in to the radiologically controlled area ), locating and setting up ladder (acceptable ladder is already stored in the room), and time to climb ladder and open the valves (opening of the valves was simulated). Although the valves are maintained "locked closed", only standard lockwire with lock tabs is used and therefore no special equipment/tools are required to remove the locks to allow repositioning of the valves. This time also included any required communications with the Control Room. In parallel with opening the crosstie valves, operators will isolate Chilled Water flow to the non-essential loads, as is required for the LCO 3.7.10c configuration. This will be done remotely from the Control Room via pushbuttons on the console, and thus can also be performed within two hours.

A Technical Evaluation was performed to determine CAV room heatup rates conservatively assuming a loss of Chilled Water for two hours, using the benchmarked CAV GOTHIC model. The GOTHIC model runs were based on no operator contingency actions as included in Abnormal Operating Procedure S1(2).OP-AB.CAV-0001. Currently, since crosstie operation is not allowed, these contingency actions are the only option for Operations on a loss of chillers on one unit. Crosstie operation provides an alternative to the current abnormal procedure actions.

The results show that while the personal comfort temperature limit is exceeded, room temperatures remain below the equipment design temperature limits as follows:

Temperature After Two Hours (°F)

Room Temperature Limit Loss of Unit 1 Chillers Loss of Unit 2 Chillers

(°F)

Control Room 110 88.2 86.5 Unit 1 Data Logging Room 110 95.9 76.4 Unit 2 Data Logging Room 110 76.5 95.5 Unit 1 Elect. Equipment Room 120 95.3 74.6 Unit 2 Elect. Equipment Room 120 75.8 90.3 Unit 1 Relay Room 122 89.6 75.7 Unit 2 Relay Room 122 75.0 87.3

b. Discussed in the response to (a) above.

c. As discussed above PSEG does not intend to start chiller replacements in the LCO 3.7.10c configuration (it will be used as contingency); 45 days is the maximum allowed time in the LCO 3.7.10c configuration (see RAI SBPB-17 response).

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d. The risk increase when operating chilled water in the LCO 3.7.10c configuration falls within normal station work control limits. Baseline CDF with test and maintenance terms excluded from the PRA is 1.4E-05 per year and the CDF associated with the LCO 3.7.10c configuration is 2.4E-06 per year. Time to YELLOW or ICDP of 1E-06 is 150 days.

Baseline LERF with test and maintenance terms excluded from the PRA is 6.3E-07 per year and the LERF associated with the LCO 3.7.10c configuration is 8.3E-08 per year.

Time to YELLOW or ILERP of 1E-07 exceeds one year.

e. Failure of one chiller while in the LCO 3.7.10c configuration causes a CDF from the zero test and maintenance baseline of approximately 2E-05 per year. Time to YELLOW or ICDP of 1E-06 exceeds 14 days. Intentionally removing a functional chiller from service while in the LCO 3.7.10c configuration is unlikely. Consequently, the 14 day AOT is reasonable and justified.

RAI SBPB-19 BACKGROUND:

PSEG stated by letter dated September 11, 2015, that the supporting calculations for two chiller operation (Configuration b) demonstrate that only one chiller is required to be operating in each unit for normal operation and accident conditions. This supports operating with two chillers available and the potential loss of a chiller during an accident as the single failure or the unexpected loss of a chiller during normal operation resulting in entering a TS ACTION Statement until the chiller is restored.

PSEG stated by letter dated September 11, 2015, that the supporting calculations demonstrate that in Configuration c, only two chillers are required to be operating for normal operation and accident conditions. This supports operating with three chillers available and the potential loss of a chiller during an accident as the single failure or the unexpected loss of a chiller during normal operation resulting in entering a TS ACTION statement until the chiller is restored.

PSEG stated in its supplemental letter dated November 5, 2015, that the following tables are the current heat loads for normal and accident conditions based on design summer ambient conditions.

Normal Operation Normal Alignment Maintenance Mode*

Component/Area Unit 1 Unit 2 Unit 1 Unit 2 CAACS (BTU/hr) 926380 887683 1073502 1044456 PACUs (BTU/hr) 491100 485700 491100 485700 Misc.coolers (BTU/hr) --- 469500 --- 469500 Totals Total (BTU/hr) 1417480 1842883 1564602 1999656 Total (tons) 118.12 153.57 130.38 166.64 Load/chiller (tons)** 39.4 51.2 43.5 55.5

• For each unit, the values represent the loads when that unit is in Maintenance Mode

• • Based on three chillers running 10 of 17

LR-N16-0134 Accident Conditions Normal Alignment Maintenance Mode*

Component/Area Unit 1 Unit 2 Unit 1 Unit 2 CAACS (BTU/hr) 516921 501499 516921 501499 CREACS (BTU/hr) 240869 240869 355802 355802 ECAC (BTU/hr) 334000 334000 334000 334000 Totals Total (BTU/hr) 1091790 1076368 1206723 1191301 Total (tons) 90.98 89.70 100.56 99.28 Load/chiller (tons)** 45.5 44.8 50.3 49.6

• For each unit, the values represent the loads when that unit is in Maintenance Mode

• • Based on two chillers running ISSUE:

There are no heat load tables provided that describe the bounding heat loads that would occur from November 1 to April 30 with the bounding service water temperature of 79.9 degrees Fahrenheit (°F).

Based on heat loads provided by PSEG, the NRC staff estimated the following heat loads with emergency control air compressor (ECAC) loads removed and compared this to available chiller tonnage.

ACCIDENT OPERATIONS - Normal Alignment Maintenance Mode SUMMER Component/Area Unit 1 Unit 2 Unit 1 Unit 2 CAACS (BTU/hr) 516921 501499 516921 501499 CREACS (BTU/hr) 240869 240869 355802 355802 ECAC (BTU/hr) 0 0 0 0 Totals Total (BTU/hr) 757790 742368 872723 857301 Total (tons) 63.15 61.86 72.73 71.44 Existing chiller rating 60 60 60 60 (design conditions) 11 of 17

LR-N16-0134 RAI:

During dual unit operations for Configuration b, the analysis assumes that a chiller is operating on both units and for Configuration c, the analysis assumes two operating chillers on one unit.

With a focus on room temperature margins and bounding service water temperature of 79.9 °F,

a. Describe the normal and accident design heat load for the proposed TS 3/4.7.10 Configurations b and c (November 1 to April 30 conditions) and state the available (or adjusted based on existing chiller curves) heat removal capability British thermal unit/hour (BTU/hr) of the existing chillers.

b. Describe the normal and accident heat removal margins that are available assuming chillers are being replaced while in Configuration c, and add a single failure of one chiller (two chillers remaining), normal alignment.

c. Describe the normal and accident temperature margins for Configurations b and c as they relate to the main control room acceptance criteria, for personnel comfort and equipment qualification.

PSEG Response

a. Current PSEG Nuclear calculations determine chiller loading based on bounding heat loads for summer conditions as presented in the tables above. Current heat load calculations do not have heat loads calculated for the time period between November 1st and April 30th.

Operation of the Chilled Water system and the Control Area Ventilation system during this time period is evaluated in PSEG Nuclear Calculation No. S-C-CAV-MDC-2320, Evaluation of the Control Area Ventilation System during Chilled Water System Chiller Replacement, Revision 1. This calculation uses GOTHIC to determine the heat loads on the CAACS and CREACS between November 1st and April 30th using April environmental data. The heat loads for other equipment cooled by the Chilled Water system (e.g. PACUs) remain the same for the evaluation since they are less dependent on environmental conditions. The resulting chiller heat loads are presented in the tables below for Cross-tied Operation and Two Chiller Operation.

Operation of the Chilled Water system in the Cross-tied and Two Chiller configurations result in fewer available chillers and higher heat loads per chiller. Using the previous method of evaluating the Chilled Water System based directly on chiller margin is not sufficient to demonstrate acceptable operation during Cross-tied Operations and Two Chiller Operations since the heat load on the chillers exceeds the design basis chiller capacity of 60 tons (for 44 °F Chilled Water temperature and 93 °F Service Water temperature). As shown in Calculation S-C-CH-MDC-2282, chiller capacity increases with increasing Chilled Water temperature. When the system heat load demand exceeds the chiller capacity at 44°F, the Chilled Water temperature will increase until the heat load demand equals the chiller capacity. Calculation S-C-CAV-MDC-2320 determines the corresponding chiller outlet temperature where the chiller capacity matches the heat load demand on the system. This equilibrium chiller outlet temperature is determined for each case.

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LR-N16-0134 Therefore, evaluating the chiller capacity margin is not a meaningful parameter when assessing chiller performance during Cross-tied Operations and Two Chiller Operations.

Calculation S-C-CAV-MDC-2320 evaluates the associated room temperatures which represents the integrated effect of all the various margins, as discussed as part of the response to question subpart c below.

b. Discussed in (a) above.

c. Calculation S-C-CAV-MDC-2320 evaluates the temperatures in the Control Area for the Cross-tied and Two Chiller configurations. The calculation has room temperature criteria ranging from 76 °F to 85 °F. The lowest margin to the acceptance criteria in Calculation S-C-CAV-MDC-2320 is 0.2 °F. The temperature acceptance criteria are based on personnel comfort. Exceeding these criteria would not result in damage to plant equipment.

The temperature margin to equipment failure during Cross-tied Operation or Two Chiller Operation is based on the design basis temperatures for the equipment in the various rooms in the Control Area. When equipment requirements are taken into consideration, the temperature margin is at least 26.7°F. The temperatures and associated margins are provided in the figure below.

The lower portion of the figure below includes additional conservatisms there were discussed in Section 4.5 of the LAR. These conservatisms are present in Calculation S-C-MDC-CAV-2320 relative to flow and heat load values determined in supporting calculations.

These conservatisms are not directly related to temperature margin but they ensure that the temperature margins discussed above are minimums.

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LR-N16-0134 Calculated Control Area Temperatures Temperature Limits: (S-C-CAV-MDC-2320):

Personnel Comfort: Maximum Calculated Control Room Temperature 76*F- Normal Control Area Temgeratures: Margin:

ss*F- Normal (MM) 7s.s*F- Normal 76*F- Accident (CAACS) ... 81SF- Normal (MM) Personnel Comfort:

ss*F- Accident (CREACS) 75.4°F- Accident (CAACS) 0.2*Fminimum 83.3°F- Accident (CREACS)

I9..Y.iJl.e

.tD nt Design Temgeratures: Equipment:

110*F- Control Room Maximum Calculated 26.rFminimum 120*F- EER Temgeratures b'i Room:

122*F- CARR 83.3°F- Control Room 75.6°F- EER 75.8°F - CARR

)

Heat Loads -

Evaluation of Chiller Capacity -

2.5% conservatism Control Area Auxiliary Building _ Minimum 5.7 ton L-.. for normal, Ventilation Model Chillers excess capacity per 3.4% conservatism (S-C-CAV-MDC-2306)

(S-C-CH-MDC-2282) operating chiller for accident CH Flow to CAACS and CREACS -

no conservatism for one case, minimum 4.0% conservatism for all other cases CH Flow to Chiller -----1 SW Flow minimum 25.9%

minimum 2.5% conservatism conservatism I

Evaluation of Service Evaluation of Chilled Water System Water System (5-C-SW-MDC-1967) (S-C-CH-MDC-2319)

RAI STSB-3 BACKGROUND:

The proposed TS table contains a row titled "CONFIGURATION." Typically a word with all letters capitalized signifies a term with a definition in Section 1.0 of the Salem TSs. The word

'configuration' is also used in the proposed changes to the LCO statement and the proposed footnotes. Throughout the majority of the Salem TSs the term "alignment," rather than

'configuration,' is used to refer to particular equipment states.

RAI:

Please provide justification for deviation from typical Salem TS format and terminology or provide an alternate TS table title and corresponding proposed changes to the LCO and footnotes.

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LR-N16-0134 PSEG Response The term Configuration has been retained (in lower case) and is more appropriate than alignment in this case as the term is describing and defining a LCO; the term alignment is currently used in the existing Salem TS in ACTION statements and Surveillance Requirements.

PSEG is proposing the following changes to the TS mark-up Insert A (equivalent changes will be made to Insert D. The TS mark-up of Insert A and D are provided in Attachment 2 of this submittal):

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LR-N16-0134 Insert A a b c Configuration 1. Three OPERABLE 1. Two OPERABLE chillers and, 1. Three OPERABLE chillers chillers and, and,

2. Two OPERABLE chilled water

2. Two OPERABLE pumps 2. Two OPERABLE chilled water chilled water pumps pumps from either Unit 1 or Unit 2 (Units Cross-tied)(2)

APPLICABILITY 1. ALL MODES and 1. From November 1 through 1. From November 1 through during movement April 30 in ALL MODES and April 30 in ALL MODES and of irradiated fuel during movement of irradiated during movement of assemblies fuel assemblies# irradiated fuel assemblies##

2. The Unit 1 Emergency 2. The Unit 1 and Unit 2 Control Air Compressor ECACs are isolated from the (ECAC) is isolated from the chilled water system chilled water system 3. Non-Essential heat loads are

3. Chilled water flow to the third isolated from the chilled chiller that is not in service is water system on BOTH isolated(1) Units

4. Control Room Emergency Air 4. BOTH CREACS trains are Conditioning System operable per TS 3.7.6.1 (CREACS) alignment (single filtration train

a. BOTH CREACS trains alignment is not permitted)

OPERABLE, no 5. Unit chilled water cross-tie additional chilled water valves are OPEN heat load removal 6. Administrative controls are in required, OR place for the Unit providing

b. Single CREACS train the required components to OPERABLE (TS 3.7.6.1 notify the other Unit if a ACTION a.) the following chiller or pump becomes restrictions apply: inoperable

i. Alignment only permitted to Unit 2 ii. Unit 2 must be in the LCO 3.7.10a configuration iii. Non-essential heat loads are isolated from the chilled water system on BOTH Units

1. The LCO 3.7.10b configuration may only be used for periods of 60 contiguous days. The 60 contiguous days does not apply for LCO 3.7.10b entry to support the replacement of all 6 original chillers (Units 1 and 2)

1. 1. The LCO 3.7.10c configuration may only be used for periods of 45 contiguous days.

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LR-N16-0134 RAI STSB-4 BACKGROUND:

The proposed format and text for Item 4 in the b applicability statement is not clear. It appears to be a list of items that must be met, rather than a list of items that are required only for CREACS single filtration train alignment.

RAI:

Please provide justification for the proposed format and text for Item 4 in the b applicability statement, or provide an alternate format and text that clarifies the items.

PSEG Response See the revised TS mark-up in response to RAI STSB-3; Item 4 applicability wording has been revised to clarify the restrictions when CREACS is in either two train or single filtration train alignment.

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LR-N16-0134 Revised Mark-up of Proposed Technical Specification Pages The following Technical Specifications for Renewed Facility Operating License DPR-70 are affected by this change request:

Technical Specification Page 3/4.7.10, Insert A 3/4 7-33 The following Technical Specifications for Renewed Facility Operating License DPR-75 are affected by this change request:

Technical Specification Page 3/4.7.10, Insert D 3/4 7-28

LR-N16-0134 Attachment 2 Insert A a b c Configuration 1. Three OPERABLE 1. Two OPERABLE chillers and, 1. Three OPERABLE chillers chillers and, and,

2. Two OPERABLE chilled water

2. Two OPERABLE pumps 2. Two OPERABLE chilled water chilled water pumps pumps from either Unit 1 or Unit 2 (Units Cross-tied)(2)

APPLICABILITY 2. ALL MODES and 1. From November 1 through 1. From November 1 through during movement April 30 in ALL MODES and April 30 in ALL MODES and of irradiated fuel during movement of irradiated during movement of assemblies fuel assemblies# irradiated fuel assemblies##

2. The Unit 1 Emergency 2. The Unit 1 and Unit 2 Control Air Compressor ECACs are isolated from the (ECAC) is isolated from the chilled water system chilled water system 3. Non-Essential heat loads are

3. Chilled water flow to the third isolated from the chilled chiller that is not in service is water system on BOTH isolated(1) Units

4. Control Room Emergency Air 4. BOTH CREACS trains are Conditioning System operable per TS 3.7.6.1 (CREACS) alignment (single filtration train

a. BOTH CREACS trains alignment is not permitted)

OPERABLE, no 5. Unit chilled water cross-tie additional chilled water valves are OPEN heat load removal 6. Administrative controls are in required, OR place for the Unit providing

b. Single CREACS train the required components to OPERABLE (TS 3.7.6.1 notify the other Unit if a ACTION a.) the following chiller or pump becomes restrictions apply: inoperable

i. Alignment only permitted to Unit 2 ii. Unit 2 must be in the LCO 3.7.10a configuration iii. Non-essential heat loads are isolated from the chilled water system on BOTH Units

1. The LCO 3.7.10b configuration may only be used for periods of 60 contiguous days. The 60 contiguous days does not apply for LCO 3.7.10b entry to support the replacement of all 6 original chillers (Units 1 and 2)

1. 1. The LCO 3.7.10c configuration may only be used for periods of 45 contiguous days.

LR-N16-0134 Attachment 2 Insert D a b c Configuration 1. Three OPERABLE 1. Two OPERABLE chillers and, 1. Three OPERABLE chillers chillers and, and,

2. Two OPERABLE chilled water

2. Two OPERABLE pumps 2. Two OPERABLE chilled water chilled water pumps pumps from either Unit 1 or Unit 2 (Units Cross-tied)(2)

APPLICABILITY 3. ALL MODES and 1. From November 1 through 1. From November 1 through during movement April 30 in ALL MODES and April 30 in ALL MODES and of irradiated fuel during movement of irradiated during movement of assemblies fuel assemblies# irradiated fuel assemblies##

2. The Unit 2 Emergency 2. The Unit 1 and Unit 2 Control Air Compressor ECACs are isolated from the (ECAC) is isolated from the chilled water system chilled water system 3. Non-Essential heat loads are

3. Chilled water flow to the third isolated from the chilled chiller that is not in service is water system on BOTH isolated(1) Units

4. Control Room Emergency Air 4. BOTH CREACS trains are Conditioning System operable per TS 3.7.6 (CREACS) alignment (single filtration train

a. BOTH CREACS trains alignment is not permitted)

OPERABLE, no 5. Unit chilled water cross-tie additional chilled water valves are OPEN heat load removal 6. Administrative controls are in required, OR place for the Unit providing

b. Single CREACS train the required components to OPERABLE (TS 3.7.6 notify the other Unit if a ACTION a.) the following chiller or pump becomes restrictions apply: inoperable

i. Alignment only permitted to Unit 1 ii. Unit 1 must be in the LCO 3.7.10a configuration iii. Non-essential heat loads are isolated from the chilled water system on BOTH Units

1. The LCO 3.7.10b configuration may only be used for periods of 60 contiguous days. The 60 contiguous days does not apply for LCO 3.7.10b entry to support the replacement of all 6 original chillers (Units 1 and 2)

1. 1. The LCO 3.7.10c configuration may only be used for periods of 45 contiguous days.