LR-N13-0125, Response to Request for Additional Information Dated April 27, 2013 Change to PSEG Emergency Plan
| ML13154A128 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/31/2013 |
| From: | Jamila Perry Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N13-0125, TAC MF0337, TAC MF0338, LAR S12-04 | |
| Download: ML13154A128 (9) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 0PSEG NuclearLLC MAY 312013 10 CFR 50.90 LR-N13-0125 LAR S12-04 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 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 dated April27, 2013, "Salem Generating Station, Units 1 and2 - Request for Additional Information RE: Change to PSEG Emergency Plan (TAC Nos. MF0337 and MF0338)"
References:
(1) LR-N12-0289, "License Amendment Request: Change to PSEG Nuclear LLC Emergency Plan to Remove the Salem Backup R45 Plant Vent Radiation Monitor Indications," dated November 30, 2012, ADAMS Accession No. ML123380450.
(2) NRC Letter, Salem Nuclear Generating Station, Units 1 and 2 - Request for Additional Information RE: Change to PSEG Emergency Plan (TAC Nos. MF0337 and MF0338), dated April 27, 2013, ADAMS Accession No. ML13102A275.
In Reference 1 PSEG Nuclear LLC (PSEG) requested an amendment (S12-04) to Renewed Facility Operating License Nos. DPR-70 and DPR-75 for Salem Nuclear Generating Station Units 1 and 2. The proposed amendment would modify the PSEG Emergency Plan to remove the backup plant vent, recording, and alarm capability in the emergency response facilities.
In Reference 2, the NRC provided PSEG a Request for Additional Information (RAI) related to the Reference 1 request, dated April 27, 2013. Attachment 1 to this submittal provides the response to the RAI.
PSEG has determined that the information provided in this response does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards consideration determination previously submitted.
Document Control Desk Page LR-N13-0125 There are no commitments contained in this letter.
If you have any questions or require additional information, please do not hesitate to contact Mr.
Brian Thomas at (856) 339-2022.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on -------
MAY 3 1 2013 (date)
Sincerely, ClP.
?an F. Perry . .
Site Vice President Salem Generating Station Attachment- Response to Request for Additional Information cc: W. Dean, Regional Administrator - NRC Region I J. Whited, Project Manager - USNRC NRC Senior Resident Inspector- Salem Unit 1 and Unit 2 P. Mulligan, Manager IV, NJBNE Commitment Coordinator- Salem PSEG Commitment Coordinator- Corporate
LR-N13-0125 Page Attachment RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SALEM GENERATING STATION. UNITS 1 AND 2 LICENSE AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGE DOCKET NUMBERS: 50-272 AND 50-311 By letter dated November 30, 2012, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML123380450), PSEG Nuclear LLC (PSEG) requested an amendment to the facility operating licenses for the Salem Generating Station (Salem) Units 1 and 2. The proposed Emergency Plan change requests the removal of the backup plant vent extended range noble gas radiation monitoring (R45) indication, recording, and alarm capability in the emergency response facilities. The licensee's application states that the R45 indicators have become obsolete and unreliable. The R45 monitoring indicator is a backup to the R41 monitoring indicator for plant vent intermediate and high range noble gas radiation. The accident sampling function of the R45 monitoring indicator will be maintained.
The following requests for additional information (RAis) are provided to facilitate the technical review being conducted by the Division of Preparedness and Response, Operating Reactor Licensing and Outreach Branch staff. The Nuclear Regulatory Commission staff has reviewed the information submitted by the licensee, and based on this review, determined that following information is required to complete the evaluation.
(1) The application appears to refer to NUREG-05781 as the licensing basis for the extended range radiation monitor and the particulate and halogen sampling and analysis capability. However, PSEG subsequently committed to Supplement 1 to NUREG-07372 and Regulatory Guide 1.97 Revision 2, 3 in a letter dated April 15, 1983 that was submitted in response to Generic Letter 82-33.4 The NRC confirmed those commitments in an Order dated June 12, 1984.5 A table attached to that Order contained Item #3, which addressed Regulatory Guide 1.97 and stating that PSEG had submitted a report describing how the requirements to Supplement 1 to NUREG-0737 have been or will be met. Please explain why PSEG believes that NUREG-0578 is the licensing basis for these monitoring capabilities.
1 NUREG-0578, "TMI -2 Lessons Learned Task Force Status Report and Short-Term Recommendations," July 1979.
2 NUREG-0737, "Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capability, " February 1989.
3 Regulatory Guide 1.97, Revision 2, "Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants, " December 1980.
4 Generic Letter 82-33, "Supplement 1 to NUREG-0737, Requirements for Emergency Response Capability, " December 17, 1982 5 ADAMS Accession No. ML011660124
LR-N13-0125 Page Attachment
Response
Salem Units 1 and 2 are committed to meet Supplement 1 to NUREG-0737 and Regulatory Guide (RG) 1.97, Revision 2 in addition to NUREG-0578. As discussed in the November 30, 2012, license amendment request, the R41 wide range plant vent radiation monitors are currently credited for meeting the requirements of RG 1.97, Revision 2.
(2) To enable the NRC staff to evaluate the comparability of the R41 and R45 monitors, please. complete the following table with missing range information as indicated.
Response
Channel R45B,C1 RG 1.97 Low range Medium range 1 o-6 to 1 03-tCi/cc Particulate and halogen 1 o-3 to 1 02 -tCilcc sampling and 1 0"11 to 102 -tCi/cc*
& Footnote 13 analysis abil
- 1. From FSAR tables 11.4-1, 11.4-2
- 2. From TIS Table 3.3-6 Amendments 299 and 272
- PSEG recently identified inadequate procedural guidance for onsite particulate and halogen analysis and has documented this issue in the Corrective Action Program. Resolution of this onsite analysis capability discrepancy does not impact the requested changes to the PSEG Emergency Plan. Resolution of the inadequate procedural guidance for particulate and halogen analysis is being tracked in the Corrective Action Program.
t". _ . ..
LR-N13-0125 Page Attachment (3) The licensee's application states that the R45 indication, recording, and alarm capability in the emergency response facilities will be removed and reliance placed on the R41 channels. However, the application did not state that the three capabilities exist for the R41 channels. Please confirm that the indication, recording, and alarm capabilities will be available in the control room, technical support center, and emergency operations facility after the retirement of the R45 monitoring indication, or provide an explanation why those capabilities are no longer deemed necessary for effective implementation of the emergency plan.
Response
The R45 radiation monitor currently provides indication in the control room on the CT-28 display ( RMS Rack 109 for Unit 1 and RMS Rack 2368 for Unit 2) with recording and alarm capability on the RP1 recorder panels. The R41 radiation monitor has indication and recording capability on RMS Rack 136 for Unit 1 and the RP1 panel for Unit 2. The R41 failure and alarm capability is wired to the overhead annunciators ( OHA ) through a common radiation monitor OHA window. The OHA response procedure directs the control room operators to review the indications and alarms on RMS Rack 136 for Unit 1 and the RP1 panel for Unit 2 to determine the specific radiation monitor that has either failed or alarmed. Therefore, the R41 radiation monitor provides similar indication, recording and alarm capabilities in the control room to that of the R45 radiation monitor.
The Technical Support Center ( TSC ) and the Emergency Operations Facility ( EOF )
currently receive the indication, alarm and recorded data from the R45 radiation monitor through the safety parameter display system ( SPDS ) . The R41 radiation monitor also provides indication, alarm and recorded data at the TSC and EOF through SPDS. The difference between the R45 and R41 SPDS alarm capability is that the R458 and C channels are provided with specific alarm values for each channel and the R41 is used to supply a noble gas release rate SPDS point that has an alarm value. The R458 and C radiation monitors alarm values in SPDS do not correlate to any actions to be taken during an emergency. The noble gas release rate alarm alerts personnel that the noble gas activity from the plant vent is approaching the Offsite Dose Calculation Manual
( ODCM ) limits. Therefore, the current R41 radiation monitor indication, alarm, and recorded data capabilities in the TSC and EOF, via SPDS, provide the necessary information to implement the emergency plan.
(4) The licensee's application states that PSEG will be replacing the R45 sampling skid to maintain the ability to take accident samples from the plant vent. Please confirm that the retained sampling and analysis capability will continue the meet the range requirement and the conditions identified in Footnote 13 on Page 1.97-23 of RG 1. 97 Revision 2
Response
The replacement R45 sampling skid will continue to meet the range requirement and conditions identified in Footnote 13 on Page 1.97-23 of RG 1.97 Revision 2. As stated in response to question 2, PSEG recently identified inadequate procedural guidance for
LR-N13-0125 Page Attachment onsite particulate and halogen analysis and has documented this issue in the Corrective Action Program. Resolution of this onsite analysis capability discrepancy does not impact the requested changes to the PSEG Emergency Plan. Resolution of the inadequate procedural guidance for particulate and halogen analysis is being tracked in the Corrective Action Program.
(5) The Technical Specification 3/4.3. 3, Table 3.3-6 for both units identifies an action statement 23 (Unit 1) and action statement 26 (Unit 2) for the monitoring channels served by R41B, C and R45B, C. Both of these action statements require the licensee, in part, to initiate the preplanned alternate method of monitoring the appropriate parameters within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. From the discussion in the application, it would appear that R45A, B may have been the preplanned alternate. However, this application removes that alternative. Please describe PSEG's preplanned alternative and explain how it maintains an effective classification and/or dose assessment capability for the duration of the inoperability. Please address the following topics in your response:
- a. If the alternative is not implemented on a fixed periodicity of sampling, what non periodic indication (e.g., alarm) would initiate the sampling and analysis?
Response
The R41 plant vent failure is alarmed in the control room through the overhead annunicators. The alarm response procedure S1 (2).0P-AR.ZZ-0001, Overhead Annunciators Window A, directs the operators to evaluate the failure of the R41 and enter the applicable Technical Specification {TS) action statement and implement the Offsite Dose Calculation Manual (ODCM) actions.
In addition, procedures S1 (2).0P-DL.ZZ-0003, Control Room Log (Modes 1-4),
requires a once per shift check of the R41 radiation monitor. If the R41 is declared inoperable, the operators enter the applicable TS action statement and implement the ODCM actions.
When the R41 is declared inoperable, Chemistry personnel enter procedure SC.CH-AB.ZZ-1102, Response to Inoperable Technical Specification Monitors and Equipment. This procedure directs the actions required by the TS and ODCM, including the installation of the temporary/auxiliary sample rig per procedure SC.CH-SA.WD-0244, Plant Vent Sampling, as required.
The above sampling is for normal plant effluent sampling and is not provided with shielding. Post accident sampling of the plant vent, when high activity is present, is performed through the R45 sampling skid. This sampling is directed to be performed through the Emergency Plan Implementing Procedures.
LR-N13-0125 Page Attachment
- b. Does this sampling and analysis method assess the noble gas concentration?
Response
The temporary/auxiliary sample rig installed per procedure SC.CH-SA.WD-0244, Plant Vent Sampling, is capable of sampling noble gas as well as tritium, particulate, and iodine. This sampling capability is for normal plant vent effluents.
- c. What are the provisions for restoring the operability of this equipment important to emergency preparedness (e.g., prioritization, tracking, etc.)?
Response
The plant vent radiation monitors are Technical Specification required equipment.
Salem TS Table 3.3-6 Action 23 (Unit 1) and Action 26 (Unit 2) require the following actions for an inoperable medium range (Item 2.b.1) and high range (Item 2. b.2) auxiliary building exhaust system (Plant Vent) radiation monitor channel:
"With the number of OPERABLE Channels less than required by the Minimum Channels OPERABLE requirements, initiate the preplanned alternate method of monitoring the appropriate parameter (s), within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and:
- 1) either restore the inoperable Channel (s) to OPERABLE status within 7 days of the event, or
- 2) prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 14 days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERAB LE status."
The restoration of the equipment is prioritized in accordance with procedure WC M-1 06, Work Screening and Processing. The priority for restoration takes into account the technical specification requirements for the equipment and the impact on emergency response function.
Since the plant vent radiation monitor is a TS required instrument, the inoperability of this equipment is tracked in accordance with procedure OP-SA-108-115-1001, Operability Assessment and Equipment Control Program. This procedure provides guidance on the entry, tracking and exiting of TS action statements.
(6) The licensee's application states that the reduction in effectiveness was determined as the delay that would exist in obtaining accident grab samples if the R41 channel was out of service and not able to provide noble gas effluent indication. The application also states that accident sampling and analysis of the plant vent effluent is estimated to take
LR-N 13-0125 Page Attachment approximately 90 minutes from directing the sample to be taken until the results are provided to the emergency response facility.
As the NRC did not require a backup capability for this particular monitoring requirement, there is no explicit timeliness criterion or expectation. Also, it is not clear to the NRC staff what sampling and analyses might be readily performed for noble gas effluent. The NRC staff does note that PSEG did commit in April 1983 to have a capability for extended range halogen and particulate sampling and analysis, but there was no explicit timeliness criterion or expectation for this capability either. Please explain why PSEG believes that retiring R45 would constitute a reduction in effectiveness due to sample and analysis delays.
Response
PSEG concluded that the removal of the backup plant vent extended range noble gas radiation monitoring (R45) indication, recording, and alarm capability in the emergency response facilities resulted in a potential reduction in effectiveness of the Emergency Plan based on guidance provided in Regulatory Guide (RG) 1.219, Guidance On Making Changes To Emergency Plans For Nuclear Power Reactors. Our review of RG 1.219 concluded the following:
Emergency Planning Standard #8, 10 CFR 50.47 (b) (8), Emergency Facilities &
Equipment was reviewed and the planning function of, "adequate equipment is maintained to support emergency response" is impacted by the proposed change. In accordance with RG 1.219, section 4.8.c.1.a, a change could require prior NRC approval if it would result in a reduction in the existing reliability or redundancy of data acquisition, display, and analysis equipment provided in the Emergency Response Facilities (ERFs).
Emergency Planning Standard #9, 10 CFR 50.47 (b) (9), Emergency Assessment Capability was reviewed and the planning function of, "Methods, systems, and equipment for assessment of radioactive releases are in use" is impacted by the proposed change. In accordance with RG 1.219, section 4.9.c.1, "a change could require prior NRC approval if it would reduce the capability of the ERO to perform assessments of imminent and ongoing radioactive releases in accordance with the emergency plan."
The proposed change was determined to represent a potential reduction in effectiveness of the Emergency Plan based on the evaluation that the change would eliminate existing equipment considered "Important to EP" by the removal of the R45B & C noble gas monitors. These noble gas monitors currently provide backup methods, credited in the PSEG Emergency Plan, for determining the plant vent release rate and thus backup inputs for Salem dose assessment that could be used by the PSEG Emergency Coordinator to assess radiological release related Emergency Action Levels.
As stated in the November 30, 2012, license amendment request, the removal of the R45 intermediate range and high range noble gas indicators while maintaining the R41 intermediate and high range noble gas indicators and the R45 accident sampling capability
LR-N13-0125 Page Attachment continues to meet the planning standards in 10 CFR 50.47 (b) (8) & (9) and the requirements in Appendix E to 10 CFR Part 50.