LR-N17-0118, Response to Request for Additional Information (Rai), Accident Monitoring Instrumentation Technical Specifications

Response to Request for Additional Information (Rai), Accident Monitoring Instrumentation Technical Specifications

ML17219A160
Person / Time
Site:	Salem
Issue date:	08/07/2017
From:	Mcfeaters C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF8859, CAC MF8860, LR-N17-0118
Download: ML17219A160 (10)

Text

PSEG 1\Tt!olear LLC P.O. Box 236, Hancocks Br!d1e. 1\Tew .1!1rsey 08038-0236 PStG AUG 07 2017 NuclearLLC 10 CFR 50.90 LR-N17-0118 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem 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 (RAI), Re: Accident Monitoring Instrumentation Technical Specifications (CACs MF8859 and MF8860)

References:

1. NRC email to PSEG, "Request for Additional Information- Salem Units 1 and 2-Accident Monitoring Instrumentation License Amendment Request (CAC No.

M F8859 & 60)," dated July 18, 2017 (ADAMS Accession No. ML17199A112)

2. PSEG letter to NRC, "License Amendment Request to Amend the Accident Monitoring Instrumentation Technical Specifications," dated November 17, 2016 (ADAMS Accession No. ML16323A279)

In Reference 1, the Nuclear Regulatory Commission (NRC) requested PSEG Nuclear LLC (PSEG) to provide additional information in order to complete the review of the license amendment request (LAR) to revise Technical Specification (TS) requirements regarding accident monitoring instrumentation. Attachment 1 provides a response to the request for additional information.

Revisions to four TS markup pages are provided in Attachment 2. The revisions consist of typographical changes, and formatting changes consistent with NUREG-1431, Revision 4, "Standard Technical Specifications, Westinghouse Plants."

+

I 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.

In addition, PSEG requested, in Reference 2, that once approved, the amendment will be implemented within 60 days from the date of issuance. We are requesting to extend the implementation to 90 days from the date of issuance.

There are no regulatory commitments contained in this letter.

Page 2 LR-N17-0118 Should you have any questions regarding this submittal, please contact Ms. Tanya Timberman at 856-339-1426.

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

Executed on f'/7 117 (Date)

Sincerely, . .

Charles V. McFeaters Site Vice President Salem Generating Station Attachments:

1. Response to Request for Additional Information

2. Supplemental Information Needed for Review of the License Amendment Request to Amend the Accident Monitoring Instrumentation Technical Specifications cc: Mr. D. Dorman, Administrator, Region I, NRC Mr. R. Ennis, Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Hope Creek Commitment Tracking Coordinator Corporate Commitment Tracking Coordinator

LR-N17-0118 Attachment 1 Response to Request for Additional Information

LR-N17-0118 Attachment 1 Request for Additional Information (RAI)

Regarding Proposed License Amendment Accident Monitoring Instrumentation Technical Specifications Salem Nuclear Generating Station, Unit Nos. 1 and 2 Docket Nos. 50-272 and 50-311 By letter dated November 17, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16323A279), PSEG Nuclear LLC (PSEG, the licensee) submitted a license amendment request (LAR) for Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. The amendments would revise Technical Specification (TS) requirements regarding accident monitoring instrumentation. Specifically, the amendments would modify the list of instruments required to be operable based on implementation of Regulatory Guide 1.97, Revision 2, dated December 1980, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident" (ADAMS Accession No. ML06075052). In addition, allowed outage times (AOTs) and required actions for inoperable accident monitoring instrumentation channels would be revised to be consistent with NUREG-143 1, Revision 4, "Standard Technical Specifications- Westinghouse Plants" (ADAMS Accession Nos. ML 121OOA222 and ML 121OOA228).

The NRC staff is reviewing your submittal and has determined that additional information is needed to complete its review. The specific information requested is addressed below.

Division of Operating Reactor Licensing (DORL)

Reviewer: Rick Ennis RAI-DORL-1 On July 22, 1993 (58 FR 39 132), the Commission published a "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" ( Final Policy Statement) which discussed the criteria to determine which items are required to be included in the TSs as Limiting Conditions for Operation (LCOs). The criteria were subsequently incorporated into the regulations by an amendment to 10 CFR 50.36 (60 FR 36953, July 19, 1995). Specifically, 10 CFR 50.36(c)(2)(ii) requires that a TS LCO be established for each item meeting one or more of the following criteria: - -- -- --

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

1

LR-N17-0118 Attachment 1 Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

As discussed in the Federal Register notice for the final rule dated July 19, 1995 (60 FR 36955):

LCOs that do not meet any of the criteria, and their associated actions and surveillance requirements, may be proposed for relocation from the technical specifications to licensee-controlled documents, such as the FSAR [Final Safety Analysis Report]. The criteria may be applied to either standard or custom technical specifications.

As discussed in the Final Policy Statement (58 FR 39 138):

When licensees submit amendment requests based on this Policy Statement, they should identify the location of and controls for the technical and administrative requirements of the relocated requirements. The NRC staff will carefully review these submittals to ensure the accountability and the acceptability of controls for each relocated requirement. Many of the requirements will be relocated to the FSAR and will be enforceable through 10 CFR 50.59. Other requirements will be relocated to more appropriate documents (e.g., Security Plan, QA Plan) and controlled by the applicable regulatory requirements. The adequacy of controls for relocated requirements which do not fit in the above categories will be reviewed and approved by the NRC staff on a case-by-case basis to determine, among other things, whether an enforceable control method will need to be established.

Salem TS Limiting Condition for Operation (LCO) 3.3.3. 7 requires that the accident monitoring instrumentation channels shown in TS Table 3.3- 1 1 be operable in Modes 1, 2 and 3. The proposed amendments would delete several of the accident monitoring instrumentation channels listed in the Table. However, the LAR does not identify the location of and controls for the technical and administrative requirements of the relocated requirements. Consistent with

. __the exf2ectations stated in the Final Policy Statement,_pleaseJdentify the specificJie.ensee- __

controlled document for the proposed relocated requirements (e.g., FSAR, Technical Requirements Manual). In addition, specify the regulatory controls that will pertain to the relocated requirements (e.g., 10 CFR 50.59).

PSEG Response to RAI-DORL-1 The specific licensee-controlled document for the proposed relocated requirements is the Salem Updated Final Safety Analysis Report (UFSAR). The regulatory control that will pertain to the relocated requirements is the 10 CFR 50.59 process.

2

LR-N17-0118 Attachment 2 Supplemental Information Needed for Review of the License Amendment Request to Amend the Accident Monitoring Instrumentation Technical Specifications Revised Mark-up of Proposed Technical Specification Pages The following are revised Technical Specifications pages for Renewed Facility Operating License DPR-70:

Technical Specification 3.3.3. 7, Accident Monitoring Instrumentation 3/4 3-53 Table 3.3- 1 1, Accident Monitoring Instrumentation 3/4 3-56 The following are revised Technical Specifications pages for Renewed Facility Operating License DPR-75:

Technical Specification 3.3.3.7, Accident Monitoring Instrumentation 3/4 3-50 Table 3.3- 1 1, Accident Monitoring Instrumentation 3/4 3-51 b

INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION L IMITING CONDITION FOR OPERATION 3.3.3.7 The accident monitoring instrumentation channels shown in Table 3.311 shall be operable.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

/

a. As shown in Table 3.311.

SURY'EILLANCE REQUIESEMENTS 4.3.3.7 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations at the frequencies specified in the Surveillance Frequency Control Program unless other.Nise noted in Table 4.3-11.

N OTE Separate Condition entry is allowed for each Function.

SALEM - UNIT 1 Amendment No. 299

TABLE 3.3-ll (continued)

HOT STANDBY within the next 6 pecial report TABLE NOTATION rdance with S ecification 6.9 With the number of OPBRABLE accident monitoring channels 1 than the Required Number of Channels shown in Table 3.311, res the inoperable channel(s) to OPERABLE status within days, or HaT SHWDOWN wd:thi ne;at 12 hOU.l:!'Lh With the number of OPEnABLE accident monitoring channels less than the MINIMUM Number of Channels shown in Table 3.3-ll, restore the inoperable channel(s) to OPERABLE status within 48 s or be in HOT SHUTDOWN within the hours, ACTION 3 deleted ACTION 4 With the n umber of OPERABLE channels one less than the Required Number of Channels shown in Table 3.3*11, operation may proceed provided that an OPERABLE Ste Generator Wide Range Level channel is available as an alternate means of indication for the Steam Generator with no OPERATABLE Auxilia Peedwater Flow Rate channel ACTION 5 deleted

otherwise, restore the inoperable channel to OPERABLE status within 30 days, or submit a special report in accordance with Specification r-6.9.4.

SALEM - UNIT l 3/4 3*56 Amendment No. 225

INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION liMITING CONDITION FOR OPERATION 3.3.3.7 T he accident monitoring instrumentation channels shown in Table 3.3-11 shall be operable.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a. As shown in Table 3.3-11.

SURVEILLANCE REQUIREMENTS 4.3.3.7 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, CHANNE L CALIBRATION and CHANNEL FUNCTIONAL TEST operations at the frequencies specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.3-11.

t----------**---*----*-----------**---**---*-------- hii O TE---------**---**---*--------*---**---**-----------*---**---**---

Separate Condition entry is allowed for each Function.

SALEM - UNIT 2 3/4 3-50 Amendment No. 282

Y within the next 6 ubmit a special report in ccordance with Specification 6.9.4 TABLE 3.3-11 (continued)

• TABLE NOTATION

.

• I

j

• }'

ACTION 1 er of OPERABLE a c c ide nt monitorin channels less ired Number of Channels shown in able 3. 3-11, noperable channel(s) to OPERABLE atus within +

days, or ithin the next ACTION 2 With the r of OPERASLE accident monitoring channels less than the Mini i.nu Number of Channels shown in Table 3. 3-11, restore the i parable ohannel(s) to OPERABLE status within 48 or be in HOT SHU'l'DOWN within the i-2 hours.

. If\7 d

1-.

• ACTION 3 delated Yfo!lowing 6 I ACTION 4 With the number of OPERABLE channels one*less than the Required Number of Channels shown in Table 3.3-11, operations may proceed provided that an OPERABLE Steam Generat or Wide Range Level channel is available as an alternate means of indication for the

\

Steam Generator with no OPERABLE Auxiliary Feedwater Flow Rate Channel.,

ACUON 5 deleted

otherwise, restore the inoperable channel to OPERABLE status within 30 days, or submit a special report in accordance with Specification

• 6.9.4 .

• 3/4 3*51b Amendment No. 206 SALEM - UNIT 2