ML043270142

RAI, Amendment Request to Modify TS Definition of Operable (Tac MC3857 and MC3858)

ML043270142
Person / Time
Site:	Salem
Issue date:	11/24/2004
From:	Dan Collins NRC/NRR/DLPM/LPD1
To:	Bakken A Public Service Enterprise Group
Collins D S, NRR/DLPM, 415-1427
References
TAC MC3857, TAC MC3858
Download: ML043270142 (5)

Text

November 24, 2004 Mr. A. Christopher Bakken, III President & Chief Nuclear Officer PSEG Nuclear - X15 P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2, REQUEST FOR ADDITIONAL INFORMATION RE: AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION DEFINITION OF ?OPERABLE (TAC NOS.

MC3857 AND MC3858)

Dear Mr. Bakken:

By letter dated July 23, 2004, PSEG Nuclear, LLC (PSEG) submitted a request for changes to the Salem Nuclear Generating Station, Unit Nos. 1 and 2, Technical Specifications (TSs). The proposed change would modify the TS definition of OPERABLE, with respect to available power sources. Additionally, the proposed change would modify the TS action statements for shutdown AC and DC electrical power requirements.

On October 28, 2004, the Nuclear Regulatory Commission (NRC) staff faxed draft questions to Mr. Courtney Smyth of your staff in order to support a conference call that occurred on November 4, 2004. Subsequent to this interaction, the NRC staff has determined an additional question that needs to be addressed. This question is included in the enclosure as question four. The NRC staff requests that you provide responses to the enclosed questions within 30 days in order for the NRC to complete its review in a timely manner. If circumstances result in the need to revise the target date, please contact me at (301) 415-1427.

Sincerely,

/RA/

Daniel S. Collins, Sr. Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

As stated cc w/encl: See next page

November 24, 2004 Mr. A. Christopher Bakken, III President & Chief Nuclear Officer PSEG Nuclear - X15 P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2, REQUEST FOR ADDITIONAL INFORMATION RE: AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION DEFINITION OF ?OPERABLE (TAC NOS.

MC3857 AND MC3858)

Dear Mr. Bakken:

By letter dated July 23, 2004, PSEG Nuclear, LLC (PSEG) submitted a request for changes to the Salem Nuclear Generating Station, Unit Nos. 1 and 2, Technical Specifications (TSs). The proposed change would modify the TS definition of OPERABLE, with respect to available power sources. Additionally, the proposed change would modify the TS action statements for shutdown AC and DC electrical power requirements.

On October 28, 2004, the Nuclear Regulatory Commission (NRC) staff faxed draft questions to Mr. Courtney Smyth of your staff in order to support a conference call that occurred on November 4, 2004. Subsequent to this interaction, the NRC staff has determined an additional question that needs to be addressed. This question is included in the enclosure as question four. The NRC staff requests that you provide responses to the enclosed questions within 30 days in order for the NRC to complete its review in a timely manner. If circumstances result in the need to revise the target date, please contact me at (301) 415-1427.

Sincerely,

/RA/

Daniel S. Collins, Sr. Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION PUBLIC JClifford GMiller ECoby, RGN-I ACRS DCollins AGill CRaynor OGC PDI-2 Reading RJenkins MConception CSchulten TBoyce ADAMS Accession Number: ML043270142 OFFICE PDI-2/PE PDI-2/PM PDI-2/LA IROB-A/SC PDI-2/SC NAME GMiller DCollins CRaynor TBoyce RLaufer for JClifford DATE 11/24/04 11/24/04 11/24/04 11/22/04 11/24/04 OFFICIAL RECORD COPY

Salem Nuclear Generating Station, Unit Nos. 1 and 2 cc:

Mr. Michael H. Brothers Dr. Jill Lipoti, Asst. Director Vice President - Site Operations Radiation Protection Programs PSEG Nuclear - X15 NJ Department of Environmental P.O. Box 236 Protection and Energy Hancocks Bridge, NJ 08038 CN 415 Trenton, NJ 08625-0415 Mr. John T. Carlin Vice President - Nuclear Assessments Brian Beam PSEG Nuclear - N10 Board of Public Utilities P.O. Box 236 2 Gateway Center, Tenth Floor Hancocks Bridge, NJ 08038 Newark, NJ 07102 Mr. Patrick S. Walsh Regional Administrator, Region I Vice President - Eng/Tech Support U.S. Nuclear Regulatory Commission PSEG Nuclear - N28 475 Allendale Road P.O. Box 236 King of Prussia, PA 19406 Hancocks Bridge, NJ 08038 Senior Resident Inspector Ms. Christina L. Perino Salem Nuclear Generating Station Director - Licensing & Nuclear Safety U.S. Nuclear Regulatory Commission PSEG Nuclear - N21 Drawer 0509 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Carl J. Fricker Jeffrie J. Keenan, Esquire Plant Manager PSEG Nuclear - N21 PSEG Nuclear - N21 P.O. Box 236 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Ms. R. A. Kankus Joint Owner Affairs PECO Energy Company Nuclear Group Headquarters KSA1-E 200 Exelon Way Kennett Square, PA 19348 Lower Alloways Creek Township c/o Mary O. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038

REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION DEFINITION OF OPERABLE SALEM GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By letter dated July 23, 2004, PSEG Nuclear, LLC (PSEG) submitted a request for changes to the Salem Nuclear Generating Station, Unit Nos. 1 and 2 (Salem), Technical Specifications (TSs). The proposed changes would modify the TS definition of OPERABLE, with respect to available power sources. Additionally, the proposed change would modify the TS action statements for shutdown AC and DC electrical power requirements. The NRC has been reviewing your application and has determined that the following information is required to complete our review:

1. In support of the change to the definition of OPERABLE, you state that the proposed change improves clarity, removes any potential confusion, and is consistent with the Improved Standard Technical Specifications (ISTS). Additionally, you state that the intent of your current TS 3.8.1.1 is to allow operation to be governed by the time limits of the limiting condition for operation (LCO) of the normal or emergency power source, rather than the corresponding action statement for each affected system or component (which would be allowed by the proposed change to the definition of OPERABLE). The proposed change to the definition of OPERABLE will affect all TSs, not just TS 3.8.1.1.

Although it is not necessary to address the effect on each TS individually, the global effect this change would cause does need to be addressed.

2. Your submittal states that the LCOs for AC and DC sources and distribution during Modes 5 and 6 and during movement of irradiated fuel assemblies are modified to be consistent with the intent of the ISTS. The proposed required actions for LCO 3.8.1.2,

?Electrical Power - Shutdown, would state ?With less than the above minimum required A.C. electrical power sources OPERABLE, immediately declare the affected required features inoperable, or suspend all operations involving CORE ALTERATIONS or positive reactivity changes until the minimum required A.C. electrical power sources are restored to OPERABLE status.

The ISTSs include an additional requirement of suspending the movement of irradiated fuel. Explain why this requirement has not been included in the action statement for 3.8.1.2.

3. Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.91(a), you provided your analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92.

In support of your negative response to Question 1, you stated that the proposed changes would not modify the manner in which the plant is operated. The NRC staff Enclosure

believes that with less power systems required to be operable per the TSs, the manner in which the plant is operated will indeed be changed. Either provide a revised justification for this response, or explain how the proposed change will not modify the manner in which the plant is operated.

4. Your submittal states that the proposed changes are consistent with the ISTS.

Currently, TS 3.8.1.2 requires two separate and independent emergency diesel generators (EDGs) to be operable while in Modes 5 and 6. This is not consistent with the ISTSs, which require one EDG to be operable in Modes 5 and 6. Provide a discussion of why the Salem TSs require more EDGs to be operable in shutdown Modes. If applicable, identify significant differences in loads supported by the different EDGs.