LR-N20-0027, Supplement to License Amendment Request: Revise Minimum Required Channels, Mode Applicability and Actions for the Source Range and Intermediate Range Neutron Flux Reactor Trip System Instrumentation Technical Specifications

Supplement to License Amendment Request: Revise Minimum Required Channels, Mode Applicability and Actions for the Source Range and Intermediate Range Neutron Flux Reactor Trip System Instrumentation Technical Specifications

ML20133K108
Person / Time
Site:	Salem
Issue date:	05/11/2020
From:	Mcfeaters C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR S19-03, LR-N20-0027
Download: ML20133K108 (12)

Text

PSEG Nuclear LLC P. 0. Box 236, Hancocks Bridge, New Jersey 08038*0236 PSEG 10 CFR 50.90 LR-N20-0027 LAR S19-03 May 11, 2020 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

Supplement to License Amendment Request: Revise Minimum Required Channels, Mode Applicability and Actions for the Source Range and Intermediate Range Neutron Flux Reactor Trip System Instrumentation Technical Specifications

References:

1. PSEG letter to NRC, "License Amendment Request: Revise Minimum Required Channels, Mode Applicability and Actions for the Source Range and Intermediate Range Neutron Flux Reactor Trip System Instrumentation Technical Specifications" dated October 23, 2019 (ADAMS Accession No. ML192968108)

In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) to Renewed Facility Operating License Nos. DPR-70 and DPR-75 for Salem Generating Station Units 1 and 2 respectively. The proposed amendment would revise Technical Specification (TS) 3/4.3.1, "Reactor Trip System Instrumentation"; specifically the Limiting Condition for Operation (LCO) and Actions for TS 3.3.1.1, Table 3.3-1 associated with the Intermediate Range (IR) and Source Range (SR) neutron flux channels, Table 3.3-1 Functional Units 5 and 6 respectively.

The subject LAR proposed to revise the modes of applicability for the SR and IR instrumentation to address conditions of SR and IR inoperability that currently require entry into TS 3.0.3. The proposed changes also better align the TS with NUREG-1431 (Westinghouse Standard Improved Technical Specifications) as well as reflect the overall design basis of the SR and IR instrument systems.

The proposed changes to the modes of applicability in TS Table 3.3-1 require similar changes to TS Table 4.3-1, "Reactor Trip System Instrumentation Surveillance Requirements."

LR-N20-0027 10 CFR 50.90 Page 2 The following additional changes to the TS are proposed to align the surveillance requirements for the SR and IR instruments with the proposed modes of applicability:

TS Table 4.3-1: Reactor Trip System Instrumentation Surveillance Requirements Functional Unit Intermediate Range, Neutron Flux In the MODES IN WHICH SURVEILLANCE REQUIRED column, add note (a) to limit applicability in Mode 1 to below the P-10 (Power Range Neutron Flux) interlocks and add note (b) in Mode 2 to limit applicability to above the P-6 (Intermediate Neutron Flux) interlocks. As described in the referenced submittal, the IR trip function is only applicable for core protection in this range of power.

Add descriptions for the new mode applicability notes to the bottom of the affected page of TS Table 4.3-1.

Remove the asterisk applicability for conditions when the reactor trip system breakers are closed and the control rod drive system is capable of rod withdrawal. As discussed in the referenced submittal, this condition of Applicability is unnecessary, based on the proposed changes to the Applicability for the SR and IR neutron flux channels.

Functional Unit Source Range, Neutron Flux Revise Functional Unit 6 to expand it to the following three separate SR functions that reflect the design basis of the SR instruments and correspond with the changes to the SR Functional Units proposed in Table 3.3-1 of the referenced LAR submittal:

o Functional Unit 6A for SR instruments in Startup Mode. The MODE IN WHICH SURVEILLANCE IS REQUIRED column of TS Table 4.3-1 adds note (7) to Mode 2 that limits the surveillance applicability to below the P-6 (Block of Source Range Reactor Trip) setpoint to align with the range of applicability as described in the LAR. This addition of note (7) to Mode 2 makes the note (7) in the CHANNEL CHECK column of TS Table 4.3-1 unnecessary; therefore the note is removed.

o Functional Unit 6B for SR instruments in Shutdown Modes 3, 4 and 5 with reactor trip breakers open and the control rod drive system incapable of rod withdrawal.

The CHANNEL CHECK and CHANNEL CALIBRATION are required to be performed at the frequencies specified in the Surveillance Frequency Control Program. When in this condition, the SR instruments perform a monitoring function only, as discussed in the referenced submittal. Therefore the CHANNEL FUNCTIONAL TEST is not applicable and is marked N.A.. In addition, there are no instrument channel setpoints associated with Operability for Functional Unit 6B. Therefore, the TS Table 4.3-1 # and ## notes for as-found channel setpoints are not applied to the CHANNEL CALIBRATION.

o Functional Unit 6C for SR instruments in Shutdown Modes 3, 4 and 5 with reactor trip breakers closed and the control rod drive system capable of rod withdrawal. The CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST are required to be performed at the frequencies specified in the Surveillance Frequency Control Program. Note (16), At the frequency

LR-N20-0027 10 CFR 50.90 Page 3 specified in the Surveillance Frequency Control Program is not required for the CHANNEL FUNCTIONAL TEST since Functional Unit 6C only has a single periodic frequency that is already addressed by Note (15), Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the Table.

Salem has implemented TSTF-425, Rev. 3, Relocate Surveillance Frequencies to Licensee Control as approved by the NRC through TS Amendments 299 (Unit 1) and 282 (Unit 2)

(ADAMS Accession No. ML110410691). The periodic surveillance frequencies for the SR and IR functions will continue to be contained in Salems Surveillance Frequency Control Program to this letter provides the proposed supplemental TS mark-up pages and provides the revised camera-ready TS pages. The TS markups provided in the Reference 1 LAR submittal remain unaffected by this supplement.

PSEG has determined that the information provided 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.

There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please contact Mr. Michael Wiwel at 856-339-7907.

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

Executed on 5/11/2020 (Date)

Respectfully, Charles V. McFeaters Site Vice President Salem Generating Station : Mark-up of Proposed Technical Specification Pages : Revised Camera-ready Technical Specification Pages cc: 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-N20-0027 10 CFR 50.90 Attachment 1 Mark-up of Proposed Technical Specification Pages The following Technical Specification page for Renewed Facility Operating License DPR-70 is affected by this change request:

Technical Specification Page Table 4.3-1 3/4 3-11 The following Technical Specification page for Renewed Facility Operating License DPR-75 is affected by this change request:

Technical Specification Page Table 4.3-1 3/4 3-11

TABLE 4.3-1.

REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS MODES IN CHANNEL WHICH CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE FUNCTIONAL UNIT CHECKPSl CALIBRAT10N(15l TESTt15> REQUIRED

1. Manual Reactor Trip Switch N.A. N.A. ( 9) 1, 2, and*

2. Power Range, Neutron Flux (2), (3) (6) (17) (18) 1, 2, and 3*

3. Power Range, Neutron N.A. (6) (18) 1, 2 Flux, High Positive Rate

4. Deleted

5. Intermediate Range, (6) #, tF# S/UC1>#, tF# 1, 2 a.m:i-!

Neutron Flux

6. Source Range, Neutron Fl (6) #, tF# ( 6) aAel Sll:J(+t . a. 4, e aAel*

Flux

! Replace with Insert #-,##

7. Overtemperature .D.T 1, 2

8. Overpower .D.T 1, 2

9. Pressurizer Pressure--Low 1, 2

10. Pressurizer Pressure--High 1, 2 11 . Pressurizer Water Level- 1, 2 High

12. Loss of Flow - Single Loop

1. If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

1. 1. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the nominal Trip Setpoint at the completion of the surveillance; otherwise the channel shall be declared inoperable. Setpoints more conservative than the nominal Trip Setpoint are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in the Technical Specification Bases.

(a) Below the P-10 (Power Range Neutron Flux) interlocks (b) Above the P-6 (Intermediate Range Neutron Flux) interlocks SALEM - UNIT 1 3/4 3-11 Amendment No. 313

NO CHANGE TABLE 4.3-1 (Continued) PAGE INCLUDED FOR INFO RMATION ONLY NOTATION With the reactor trip system breakers closed and the control rod drive system capable of rod withdrawal.

(1) - If not performed in previous 31 days.

(2) - Heat balance only, above 15% of RATED THERMAL POWER.

(3) - Compare incore to excore axial offset above 15% of RATED THERMAL POWER.

Recalibrate if absolute difference ;:: 3 percent.

(4) - Manual SSPS functional input check in accordance with the Surveillance Frequency Control Program.

(5) - Each train or logic channel shall be tested in accordance with the Surveillance Frequency Control Program.

(6) - Neutron detectors may be excluded from CHANNEL CALIBRATION.

(7) -

Below P-6 (Block of Source Range Reactor Trip) setpoint.

(8) - Deleted (9) - The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the Undervoltage and Shunt Trip mechanism for the Manual Reactor Trip Function.

The Test shall also verify OPERABILITY of the Bypass Breaker Trip circuits.

(10) - DELETED (11) - The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the Reactor Trip Breaker Undervoltage and Shunt Trip mechanisms.

(12) - DELETED (13) - Verify operation of Bypass Breakers Shunt Trip function from local pushbutton while breaker is in the test position prior to placing breaker in service.

(14) - Perform a functional test of the Bypass Breakers U. V. Attachment via the SSPS.

(15) - Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.

(16) - At the frequency specified in the Surveillance Frequency Control Program.

(17) - In MODES 1, and 2, the SSPS input relays are excluded from this Surveillance when the installed bypass test capability is used to perform this Surveillance.

(18) - The SSPS input relays are excluded from this Surveillance when the installed bypass test capability is used to perform this Surveillance.

SALEM - UNIT 1 3/4 3-13 Amendment No. 312

TABLE 4.3-1 REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS MODES IN CHANNEL WHICH CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE FUNCTIONAL UNIT CHECK(1Sl CALIBRAT10N(15l TESrc1si REQUIRED

1. Manual Reactor Trip Switch N.A. N.A. (9) 1, 2, and*

2. Power Range, Neutron Flux (2), (3) (6) (17) (18) 1, 2, and 3*

3. Power Range, Neutron Flux, N.A. (6) (18) 1, 2 High Positive Rate

4. Deleted

5. Intermediate Range, (6) #, ## S/U(1l#, ##

Neutron Flux

6. Source Range, Neutron (.+) (467 eAd S/LJC4+

Flux Replace with Insert I #,##

7. Overtemperature !::.T 1, 2

8. Overpower!::.T 1. 2

9. Pressurizer Pressure--Low 1, 2

10. Pressurizer Pressure--High 1, 2

11. Pressurizer Water Level- 1, 2 High

12. Loss of Flow - Single Loop

1. If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

1. 1. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the nominal Trip Setpoint at the completion of the surveillance; otherwise the channel shall be declared inoperable . Setpoints more conservative than the nominal Trip Setpoint are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in the Technical Specification Bases.

(a) Below the P-10 (Power Range Neutron Flux) interlocks (b) Above the P-6 (Intermediate Range Neutron Flux) interlocks SALEM - UNIT 2 314 3-11 Amendment No. 294

NO CHANGE TABlE 4.:.H (Conliooed} PAGE INCLUDED FOR INFORMATION ONLY NOTATION With thtli rf¥!C!Ol' mp system break1.m;i closed and the oontrol rod drive syi;;tem capable of roo withdrawal.

(!)' II not performed in pre\llous 31 days.

(2). Hoat ba!anco only, above 15% of RATED THERMAL POWER (3). Compare lncora lo excore axial offset above 15% of RATED THERMAL POWER.

Re<'.allbtate If absotute difference a: 3 percent.

(4). Manual SSPS functional input check in accordance with the Surveillance Frequency Control Program.

(5). Each train or !ogle c h an ne l shall be tested in accordance with !he Surveillance Frequency Control Program.

(tl)* NoulrOti dele<:lots may be excluded from CHANNEL CALIBRATION.

(7)' Below P-6 (Block ol Source Range Reactor Trip} setpolnt (9). Deleted (9). The CHANNEL FUNCTIONAL TEST shall nUy veofy the OPERABILITY of the Undorvottage and Shunt fop mechanism fnrtOO Manual Reactor Trip Function.

The Tost shall also verify OPERABILITY of the Bypass areaker Trip circuits.

(10)

• DELETED (11)

• The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of Iha Reactor Trip Breaker Ur.deMlltage and Shunt Trip mechanisms.

(12)

• DELETED (1 Jl

• Vefify opera\ion QI 6'(P<l55 6realler.s Shunt Trip !unction from local pushbutton while b1eakcr Is ro IM hMI pooitlon prior to placi119breaker1n service.

(14)

• Perform a luncUonal test ot Ille Bypass Breakers U.V. Attachment via the SSPS.

(1 S) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the labkl.

(16) M the froqul.i-ncy speciffE!d in the Surveillance Frequency Control Program.

(17)

• in MODES 1 and 2, the SSPS Input relays are excluded from this Surveillance when the ltistalled bypnss test capablll!y Is used to perform this Survemance.

(16)

• The SSPS Input relays oro oxcluded from this Surveillance when the installed bypass test capablllty Is used to perfom1 th ls Survolllance.

SALEM

• UNIT 2 314 3-13 Amendment No. 293

INSERT MODES IN CHANNEL WHICH CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE FUNCTIONAL UNIT CHECK(15) CALIBRATION(15) TEST(15) REQUIRED

6. Source Range, Neutron Flux A. Startup (6), #, ## (16), and S/U(1), #, ## 2(7)

B. Shutdown (6) N.A. 3, 4, 5 C. Shutdown (6), #, ## #, ## 3,4,5

Attachment 2 Revised Camera-ready Technical Specification Page The following Technical Specification page for Renewed Facility Operating License DPR-70 is affected by this change request:

Technical Specification Page Table 4.3-1 3/4 3-11 The following Technical Specification page for Renewed Facility Operating License DPR-75 is affected by this change request:

Technical Specification Page Table 4.3-1 3/4 3-11

TABLE 4.3-1 REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS MODES IN CHANNEL WHICH CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE FUNCTIONAL UNIT CHECK(15) CALIBRATION(15) TEST(15) REQUIRED

1. Manual Reactor Trip Switch N.A. N.A. (9) 1, 2, and *

2. Power Range, Neutron Flux (2), (3) (6) (17) (18) 1, 2, and 3*

3. Power Range, Neutron N.A. (6) (18) 1, 2 Flux, High Positive Rate

4. Deleted

5. Intermediate Range, (6) #, ## S/U(1) #, ## 1(a), 2(b)

Neutron Flux

6. Source Range, Neutron Flux (1)

A. Startup (6) #, ## (16) and S/U #, ## 2(7)

B. Shutdown (6) N.A. 3, 4, 5 C. Shutdown (6) #, ## #, ## * *

• 3,4,5

7. Overtemperature T 1, 2

8. Overpower T 1, 2

9. Pressurizer Pressure--Low 1, 2

10. Pressurizer Pressure--High 1, 2

11. Pressurizer Water Level-- 1, 2 High

12. Loss of Flow - Single Loop 1

1. If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

1. 1. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the nominal Trip Setpoint at the completion of the surveillance; otherwise the channel shall be declared inoperable. Setpoints more conservative than the nominal Trip Setpoint are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in the Technical Specification Bases.

(a) Below the P-10 (Power Range Neutron Flux) interlocks (b) Above the P-6 (Intermediate Range Neutron Flux) interlocks SALEM - UNIT 1 3/4 3-11 Amendment No. XXX

TABLE 4.3-1 REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS MODES IN CHANNEL WHICH CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE FUNCTIONAL UNIT CHECK(15) CALIBRATION(15) TEST(15) REQUIRED

1. Manual Reactor Trip Switch N.A. N.A. (9) 1, 2, and *

2. Power Range, Neutron Flux (2), (3) (6) (17) (18) 1, 2, and 3*

3. Power Range, Neutron Flux, N.A. (6) (18) 1, 2 High Positive Rate

4. Deleted

5. Intermediate Range, (6) #, ## S/U(1) #, ## 1(a), 2(b)

Neutron Flux

6. Source Range, Neutron Flux (1)

A. Startup (6) #, ## (16) and S/U #, ## 2(7)

B. Shutdown (6) N.A. 3, 4, 5 C. Shutdown (6) #, ## #, ## * *

• 3,4,5

7. Overtemperature T 1, 2

8. Overpower T 1, 2

9. Pressurizer Pressure--Low 1, 2

10. Pressurizer Pressure--High 1, 2

11. Pressurizer Water Level-- 1, 2 High

12. Loss of Flow - Single Loop 1

1. If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

1. 1. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the nominal Trip Setpoint at the completion of the surveillance; otherwise the channel shall be declared inoperable. Setpoints more conservative than the nominal Trip Setpoint are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in the Technical Specification Bases.

(a) Below the P-10 (Power Range Neutron Flux) interlocks (b) Above the P-6 (Intermediate Range Neutron Flux) interlocks SALEM - UNIT 2 3/4 3-11 Amendment No. XXX