LR-N19-0066, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Adopt TSTF-547, Clarification of Rod Position Requirements.

Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Adopt TSTF-547, Clarification of Rod Position Requirements.

ML19162A122
Person / Time
Site:	Salem
Issue date:	06/11/2019
From:	Mcfeaters C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR S18-06, LR-N19-0066, TSTF-547
Download: ML19162A122 (7)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 0PSEG Nuclear LLC JUN 1120fl 10 CFR 50.90 LR-N19-0066 LAR S18-06 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 Regarding License Amendment Request to Revise Technical Specifications to Adopt TSTF-547, "Clarification of Rod Position Requirements" References 1. PSEG letter to NRC, "License Amendment Request to Revise Technical Specifications to Adopt TSTF-547, "Clarification of Rod Position Requirements," dated February 4, 2019 (ADAMS Accession No. ML19035A620)

2. NRC e-mail to PSEG, "Salem 1 and 2 - Final RAI RE: Adoption of TSTF-547," dated May 21, 2019 (ADAMS Accession No. ML19148A768)

In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request for Salem Generating Station (Salem) Units 1 and 2. The proposed amendment revises the requirements on control and shutdown rods, and rod and bank position indication to adopt Technical Specification Task Force (TSTF) traveler TSTF-547.

In Reference 2, the U.S. Nuclear Regulatory Commission staff provided PSEG a Request for Additional Information (RAI) to support the NRC staff's technical review of Reference 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.

No new regulatory commitments are established by this submittal. If you have any questions or require additional information, please do not hesitate to contact Mr. Brian Thomas at (856) 339-2022.

LR-N19-0066 10 CFR 50. 90 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

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Respectfully, Charles V. McFeaters Site Vice President Salem Generating Station Response to Request for Additional Information Regarding Adoption of TSTF-547 cc: Mr. D. Lew, Administrator, Region I, NRC Mr. J. Kim, Project Manager, NRC NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Chief, NJBNE PSEG Corporate Commitment Tracking Coordinator Salem Commitment Tracking Coordinator

LR-N19-0066 LAR 818-06 Response to Request for Additional Information Regarding Adoption of TSTF-547 1

LR-N19-0066 LAR 818-06 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF LICENSE AMENDMENT REQUEST TO ADOPT TSTF-547 SALEM GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By application, dated February 04, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19035A620), PSEG Nuclear LLC (PSEG) submitted a License Amendment Request (LAR) for Salem Generating Station, Units 1 and 2 (Salem). The proposed LAR would adopt TSTF-547.

RAI - 1: SR 4.1.3.4 For Salem, AEC Criterion 12 (equivalent to GDC 13 - Instrument and Control), AEC Criteria 27 to 31 (equivalent to GDC 26- Reactivity Control System Redundancy and Capability) and AEC Criterion 32 (equivalent to GDC 28 - Reactivity Limits) require LCO 3.1.3.4 for all shutdown rods to be determined fully withdrawn and capable of reliably providing the amount and rate of reactivity to mitigate any reactivity accidents when rods are inserted. The 10 CFR 50.36(c) (3) requires surveillance requirement[s] to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions will be met.

The LAR proposed to change the SR 4.1.3.4 to adopt TSTF-547 by replacing the current note "For power levels below 50% one hour thermal [soak] time is permitted. During this [soak] time, the absolute value of rod motion is limited to six steps," with "Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion."

The proposed deletion of the current note lacks justification. [TSTF]-547 adds a note to the verification of the rod positions one hour after rod motion only. There is no justification in the TSTF or the LAR for changing limits on rod movement. Please provide justification for the proposed changes.

RAI - 2: SR 4.1.3.5 For Salem, AEC Criterion 12 (equivalent to GDC 13 - Instrument and Control), AEC Criteria 27 to 31 (equivalent to GDC 26- Reactivity Control System Redundancy and Capability) and AEC Criterion 32 (equivalent to GDC 28- Reactivity Limits) require LCO 3.1.3.5 for all control banks to be limited in physical insertion as specified in the Core Operating Limits Report and capable of reliably providing the required amount of reactivity to control the reactivity changes resulting from planned, normal power and power distribution changes to assure acceptable fuel design limits are not exceeded. The 10 CFR 50.36( c)(3) requires surveillance requirement[s] to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions will be met.

The LAR proposed to change the SR 4.1.3.5 to adopt TSTF-547 by replacing the current note "For power levels below 50% one hour thermal [soak] time is permitted. During this [soak] time, 2

LR-N19-0066 LAR 818-06 the absolute value of rod motion is limited to six steps," with "Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion."

The proposed deletion of the current note lacks justification. [TSTF]-547 adds a note to the verification of the rod positions one hour after rod motion only. There is no justification in the TSTF or the LAR for changing limits on rod movement. Please provide justification for the proposed changes.

PSEG Response to RAI - 1: SR 4.1.3.4 and RAI - 2: SR 4.1.3.5:

In the "Description of Proposed Change & Technical Evaluation," section of TSTF-547, Item 3, "Allow Time for Thermal Equilibrium of Analog RPI," proposed changes to surveillance requirements (SR) 3.1.5. 1 and 3.1.6.2 of NUREG-1431. The proposed change adds a new note to these surveillance requirements that did not exist prior to TSTF-547. The notes added to SRs 3. 1.5. 1 and 3.1.6.2 state, "Not required to be performed unitil 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion." NUREG-1431 SR 3.1.5.1 is equivalent to Salem SR 4.1.3.4 and NUREG-1431 SR 3.1.6.2 is equivalent to Salem SR 4.1.3.5.

The below excerpt is from the Technical Evaluation of Item 3 of TSTF-547:

The analog RPI system derives the rod position signal from measurements using a linear variable differential transmitter (LVDT). An analog signal is produced for each rod by the associated LVDT. The rod drive shaft varies the amount of magnetic coupling between the primary and secondary windings of the coils and generates an analog signal proportional to the rod position. As a rod is raised by its magnetic jacks, the magnetic permeability of the rod drive shaft causes an increase in magnetic coupling.

Thus, an analog signal that is proportional to the rod position is derived.

Rod temperature affects the accuracy of the analog RPI System. Due to changes in the magnetic permeability of the drive shaft as a function of its temperature, the indicated position is expected to change with time as the drive shaft temperature changes. As a result, RPI indications may not be accurate following movement of the associated rod.

This occurs most often when the rod movement is associated with a reactor thermal power change. The proposed change provides a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period for the drive shaft to reach thermal equilibrium following rod movement to ensure accuracy of the indication prior to the RPI being used to verify TS limits. During this period (commonly referred to as a "thermal soak"), the demand rod position is available using the Demand Position Indictor system.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allowance is based on the time necessary to allow the rod drive shaft to reach thermal equilibrium. In the vast majority of cases, the rods are not actually misaligned (only the indication is incorrect) and the risk of an accident occurring during this 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period is small. During the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period, the Demand Position Indication system is available to indicate the demand position of the rods. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allowance has been approved by the NRC for several plants with Westinghouse analog rod position indication systems. For example Salem Units 1 and 2 (Amendment No. 73/48 dated March 19, 1986) and Point Beach Units 1 and 2 (Amendment No. 200/205 dated May 8, 2001.) As stated previously in the discussion of proposed changes, this allowance does not apply to plants with digital RPI systems.

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LR-N19-0066 LAR 818-06 The notes added to SR 3.1.5.1 and 3.1.6.2 of N UREG-1431 are added with no restriction to Reactor Power level and no restriction on the absolute value of rod motion during the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period.

As documented in TSTF-547, the NRC approved the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period for the rod shafts to reach thermal equilibrium for several plants with Westinghouse analog rod position indication systems, including Salem Units 1 and 2 in Amendment No. 73/48 dated March 19, 1986 (ADAMS Accession No. 8604040514). A review of Amendment 73/48 for Salem identified that there were no reactor power or absolute rod motion restrictions documented in the bases for approval of the allowance for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> thermal soak time for the analog rod position indication (ARPI).

Subsequent to Amendment 73/48, PSEG requested additional changes to correct an error in the incorporation of the thermal soak time period for Salem SRs 4.1.3.4 and 4.1.3.5 which inadvertently required the surveillances to be performed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following rod motion. Amendment 103/80 was issued to correct these errors and included the **footnote in Salem SRs 4.1.3.4 and 4.1.3.5. The footnotes were added based on a supplement dated May 22, 1989 at the request of the NRC Project Manager. The SER for Amendment 103/80 states in part:

The original request was submitted to alleviate difficulties encountered in calibration of the Analog Rod Position Indication (ARPI) system. This change shifted rod position determination from the ARPI to the group demand counters with subsequent verification of the ARPis. Comparison of group demand counters to the ARPis (allowing for one hour thermal soak after rod motion) was sufficient verification of the rod position. . . .

The allowance for a one hour thermal soak following rod motion at power levels below 50% is acceptable and desirable. Above 50% power, rod motions are expected to be small and are not expected to induce significant thermal transients in the analog rod position channels. By letter dated May 22, 1989 the licensee proposed adding a footnote to section 4.1.3.4 and 4.1.3.5 to allow the one hour thermal soak time.

Although the **note for SR 4.1.3.4 and 4.1.3.5 proposed in the May 22, 1989 letter included a 50% power level restriction and six step absolute rod motion restriction, a review of Salem TS Amendments 73/48 and 103/80 shows that the basis for the allowance of the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> thermal soak period (reach thermal equilibrium) was not reactor power dependent but to provide a sufficient time for the ARPI to come into alignment with the group demand counters and that the group demand counters provide the operators with the indication of rod position during this period of time. The 50% power level is an unnecessary restriction based on the expectation that the plant would see less thermal impacts to the ARPI above 50% power. The limitation on absolute rod motion during the soak time of six steps is also an unnecessary restriction placed in the Salem TS since the confirmation of the rod positon using the ARPI is based on a set SR periodicity with the allowance to delay performance until one hour following rod motion.

In reviewing the proposed SR changes in TSTF-547, which include addition of a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period to allow rod temperature to stabilize following rod movement (with no limitations on reactor power level or absolute rod motion during the soak time), the NRC staff concluded 4

LR-N19-0066 LAR 518-06 the SRs would continue to ensure the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and the limiting conditions for operation will be met.

Therefore removal of the 50% power level and limitation of rod movement in the ** notes of Salem SR 4.1.3.4 and 4.1.3. 5 is encompassed by the TSTF-547 justification for adding the note to NUREG-1431 SR 3.1.5.1 and 3.1.6.2 for a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> soak time without any power level or rod movement restrictions.

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