LR-N14-0185, License Amendment Request to Isolate Unborated Water Sources and Use Gamma-Metrics Post-Accident Neutron Monitors During Mode 6 (Refueling)

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License Amendment Request to Isolate Unborated Water Sources and Use Gamma-Metrics Post-Accident Neutron Monitors During Mode 6 (Refueling)
ML15068A359
Person / Time
Site: Salem  PSEG icon.png
Issue date: 03/09/2015
From: Jamila Perry
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR S14-03, LR-N14-0185
Download: ML15068A359 (23)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 MAR 09 2015 LR-N14-0185 LAR S14-03 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Salem Nuclear Generating Station Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and 75 NRC Docket Nos. 50-272 and 50-311 I>SEG Nuclttar lLC 10 CFR 50.90

Subject:

License Amendment Request to Isolate Unborated Water Sources and Use Gamma-Metrics Post-Accident Neutron Monitors during Mode 6 (Refueling)

In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) hereby requests an amendment to Renewed Facility Operating License Nos. DPR-70 and 75 for Salem Nuclear Generating Station Units 1 and 2. In accordance with 10 CFR 50.91 (b )(1 ), a copy of this request for amendment has been sent to the State of New Jersey.

The proposed changes include creating new Technical Specification (TS) Limiting Condition for Operation (LCO) 3.9.2.1 to isolate unborated water sources in Mode 6 and revising the existing TS LCO 3.9.2, "Refueling Operations/Instrumentation," to support using the Gamma-Metrics Post Accident Neutron Monitors (PANM) for neutron flux indication during Mode 6 (Refueling).

TS LCO 3.9.2 is renumbered as TS LCO 3.9.2.2.

There are no regulatory commitments contained in this letter. to this letter provides an evaluation supporting the proposed changes. contains marked-up TS pages to indicate the proposed changes. provides the proposed changes to the TS Bases for information only.

PSEG requests NRC approval of the proposed License Amendment by March 9, 2016.

These proposed changes have been reviewed by the Plant Operations Review Committee.

If you have any questions or require additional information, please contact Brian Thomas at (856) 339-2022.

Document Control Desk LR-N 14-0185 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on MAR 0 9 2015 (Date)

Respectfully, c(Lr.

John F. Perry U

Site Vice President Salem Generating Station Attachments:

1.

License Amendment Request to Isolate Unborated Water Sources and Use Gamma-Metrics Post-Accident Neutron Monitors during Mode 6 (Refueling)

2.

Technical Specification Proposed Changes (mark-up pages)

3.

Technical Specification Bases Proposed Changes (for information only) cc:

Mr. D. Dorman, Administrator, Region I, NRC Ms. C. Sanders-Parker, Project Manager, NRC NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Manager IV, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. Cachaza, Salem Commitment Tracking Coordinator

LR-N 14-0185 SALEM GENERATING STATION LAR S14-03 RENEWED FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NO. 50-272 AND 50-311 License Amendment Request to Isolate Unborated Water Sources and Use Gamma Metrics Post-Accident Neutron Monitors During Mode 6 (Refueling)

Table of Contents

1. DESCRIPTION.......................................................................................................... 2
2.

PROPOSED CHANGE.............................................................................................. 2

3.

BACKGROUND........................................................................................................ 3

4. TECHNICAL ANALYSIS............................................................................................ 4
5. REGULATORY ANALYSIS....................................................................................... 8 5.1 No Significant Hazards Consideration............................................................ 8 5.2 Applicable Regulatory Requirements/Criteria............................................... 10 5.3 Precedents.................................................................................... 1 0
6. ENVIRONMENTAL CONSIDERATION................................................................... 11
7. REFERENCES........................................................................................ 11 Page 1 of 11
  • LRN 140 185 1.0 DESCRIPTION LAR S1403 This license amendment request creates a new Technical Specification (TS) Limiting Condition for Operation (LCO) 3.9.2.1 for Unborated Water Source Isolation Valves in Mode 6. TS LCO 3.9.2.1 isolates unborated water sources in Mode 6, which precludes a boron dilution event.

This supports removing the existing requirement for one source range neutron flux monitor with audible indication in the containment and control room during Mode 6. By isolating unborated water sources, a safety analysis for an uncontrolled boron dilution event is not required for Mode 6.

This license amendment request proposes to permit using the Nuclear Instrumentation System (NIS) source range neutron flux monitors and/or Gamma Metrics Post Accident Neutron Monitors (PANM) to provide neutron flux indication during Mode 6. The change revises existing TS LCO 3.9.2,"Refueling Operations/Instrumentation," by renumbering the TS LCO as 3.9.2.2 to accommodate the new TS LCO 3.9.2.1; removes the requirement for one audible indication of neutron flux in the containment and control room; rewords the TS LCO and Action Statements, so they are similar for Unit 1 and Unit 2 and consistent with the NUREG1431, Revision 4, "Standard Technical Specifications Westinghouse Plants" language; and replaces the existing Channel Functional Test with a Channel Calibration. The two NIS source range neutron flux monitors and the two GammaMetrics PANM are functionally equivalent and are both Safety Related (Class 1 E) systems. By taking credit for the Gamma-Metrics PANM as source range neutron flux monitors, two additional channels of redundant and independent source range neutron flux monitoring are available during Mode 6.

2.0 PROPOSED CHANGE

The proposed changes are described below and are indicated on the marked-up TS pages provided in Attachment 2 of this submittal. Proposed changes to the TS Bases are provided in for information only. Changes to the affected TS Bases pages will be incorporated per TS 6.17 (Unit 1) and TS 6.16 (Unit 2), "Technical Specifications (TS) Bases Control Program."

1. New TS LCO 3.9.2.1 "Refueling Operations/Unborated Water Source Isolation Valves."

Each valve used to isolate unborated water sources shall be secured in the closed position in Mode 6. With one or more valves not secured in the closed position, immediate action is required to suspend core alterations and initiate actions to secure the valve in the closed position. Surveillance Requirement 4.9.1 (verify boron concentration) must be performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

2. TS LCO 3.9.2 is revised as follows:

Renumber as TS LCO 3.9.2.2.

Revise the LCO to read: Two source range neutron flux monitors shall be OPERABLE.

Page 2 of 11

LR-N14-0185 LAR S14-03 Revise the Action Statements so that Unit 1 and Unit 2 both read:

a. With one of the above required monitors inoperable, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity additions.
b. With both of the required monitors inoperable, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity additions, and initiate action to restore one source range monitor to OPERABLE status; and perform Surveillance Requirement 4.9.1 once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
c.

The provisions of Specification 3.0.3 are not applicable.

Replace the existing Channel Functional Test with a Channel Calibration, and add a note that the neutron detectors are excluded from the Channel Calibration.

3. Revise the Index page to reflect the LCO numbering change and page number change.

3.0 BACKGROUND

Boron Dilution Event Response (Mode 6)

Salem UFSAR Section 15.2.4 "Uncontrolled Boron Dilution" concludes in the discussion on dilution during refueling that there is ample time available for the operators to recognize a high count rate signal, and isolate the reactor makeup water source by closing valves and stopping the primary water supply pumps. The audible count rate instrumentation provides the operator with prompt and definite indication of a boron dilution event. High count rate is alarmed in the containment and control room. Operability of the audible count rate is required by TS LCO 3.9.2.

As an alternative, PSEG proposes to isolate unborated water source in Mode 6. This action precludes a boron dilution event in Mode 6, and eliminates the need for operator action in response to audible count rate instrumentation. Salem UFSAR Section 15.2.4 will be revised to indicate that Salem is isolating unborated water sources during Mode 6, and not taking credit for operator action in response to an audible count rate indication to address the boron dilution event.

Instrumentation (Mode 6)

Existing TS LCO 3.9.2 requires that two source range neutron flux monitors be operable in Mode 6, each with continuous visual indication and one with audible indication in the containment and control room.

1. NIS Source Range Monitors TS LCO 3.9.2 is currently met using the NIS source range neutron flux monitors (original plant installed equipment). These monitors are classified as Safety Related (Class 1 E).

NIS source range neutron flux monitors are boron trifluoride detectors. The detectors monitor the neutron flux in counts per second (cps) over a range that covers six decades Page 3 of 11

LR-N 14-0185 LAR S14-03 (1 0° to 106 cps). They provide continuous visual indication in the control room and audible count rate in the containment and control room. The audible count rate alerts operators to any unexpected changes in core reactivity during refueling operations.

2. Gamma-Metrics Post Accident Neutron Monitors The Gamma-Metrics PANMs are a safety related, Class 1 E, Salem Equipment Qualification (EQ) Program qualified Excore Flux Monitoring System installed to satisfy post-accident monitoring requirements specified in NRC Regulatory Guide (RG) 1.97, Revision 2 (Reference 1 ). The Gamma-Metrics PANMs are also required to support post fire safe shutdown capability per 10 CFR 50, Appendix R. They are designed to provide continuous neutron flux monitoring from shutdown to 200 percent of full power. There are no EQ or Appendix R requirements in Mode 6.

Each Gamma-Metrics PANM detector assembly contains two fission chambers, which monitor neutron flux in the source range and power range. Both fission chambers in each assembly are used to monitor neutron flux in the source range, while only one fission chamber in each assembly is used to monitor neutron flux in the power range.

These monitors provide neutron flux measurement from reactor shutdown to reactor full power level in a harsh environment. The instrument source range covers six decades (10-1 to 105 cps). They are designed to measure neutron flux with the detector in a high gamma radiation and electrical noise environment. They are designed to operate under normal conditions and to survive a design basis event (DBE), providing reliable measurement during and after a DBE. The Gamma-Metrics PANMs are currently used for information display in the control room. The monitors perform no protective function. They provide no input to any reactor trip or engineering safeguards actuation; and they are not part of the Reactor Protection System (RPS). The Gamma-Metrics PANMs are not modelled in the Salem UFSAR Chapter 15 Accident Analyses. They are not currently included in the Salem TS, but do meet the existing TS LCO 3.9.2 requirement for continuous visual indication in the control room.

4.0 TECHNICAL ANALYSIS

1.

NewTS LCO 3.9.2.1 TS Task Force (TSTF) Change Traveler TSTF-23 (Reference 2) states that the basic methods used to address boron dilution events for Westinghouse plants, through application of LCO 3.9.2, includes isolating unborated water sources or completing a boron dilution analysis. The first option relies on precluding a boron dilution event by requiring all unborated water source isolation valves be closed. In this case, no analyses are required or performed for the boron dilution event consistent with the Standard Review Plan (NUREG-0800, Section 15.4.6, "Inadvertent Decrease in Boron Concentration in the Reactor Coolant System (PWR))."

TS LCO 3.9.2.1 will require that each valve used to isolate unborated water sources shall be secured in the closed position during Mode 6. With one or more valves not secured in the closed position, immediate action is required to suspend core alterations and to initiate actions to secure the valve in the closed position. Surveillance Requirement 4.9.1 (verify Page 4 of 11

LR-N14-0185 LAR S14-03 boron concentration) must be performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The proposed TS LCO provides a satisfactory method of addressing the boron dilution event in Mode 6 without reliance on a boron dilution analysis consistent with NUREG-0800, Section 15.4.6.

New Surveillance Requirement 4.9.2.1 verifies that each valve that isolates unborated water sources is secured in the closed position. The surveillance frequency is established by the Surveillance Frequency Control Program. Salem has implemented TSTF Change Traveler TSTF-425, Revision 3 (Reference 3) as approved by the NRC with TS Amendments 299 and 282 (Reference 4) for Units 1 and 2 respectively.

2. LCO 3.9.2.2-Audible Indication The TS LCO is revised to read "Two source range neutron flux monitors shall be OPERABLE," which is consistent with the NUREG-1431, Revision 4 language. The existing LCO requirement that one source range neutron flux monitor provides audible indication in the containment and control room is deleted.

The NIS source range neutron flux monitors provide audible count rate in the containment and control room. The Gamma-Metrics PANMs do not provide audible indication in either the containment or control room.

NUREG-1431, Revision 4, Bases Section B 3.9.3 "Background" states that for plants that isolate all boron dilution paths, the source range instrumentation operability includes only a visual monitoring function. One of the proposed changes is to create new TS LCO 3.9.2.1 for Unborated Water Source Isolation Valves. TS LCO 3.9.2.1 will require that each valve used to isolate unborated water sources shall be secured in the closed position during Mode

6. This action supports eliminating the requirement for audible indication in the containment and control room.
3. LCO 3.9.2.2 - Action Statements The existing TS Action Statements for Unit 1 and Unit 2 are different even though the source range monitors (NIS or Gamma-Metrics) are functionally the same for both Units. Unit 1 states that if the requirements are not met (one or two source range neutron flux monitors become inoperable) immediately suspend all core alterations and positive reactivity changes. Unit 2 states that if one required monitor is inoperable, immediately suspend all core alterations and positive reactivity changes. With both required monitors inoperable, in addition to immediately suspending all core alterations and positive reactivity changes, determine the boron concentration of the reactor coolant system at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

As discussed in Section 2.0 above, the Action Statements for both Units will be revised so they are similar and consistent with the NUREG-1431, Revision 4 language.

4.

LCO 3.9. 2.2 - Surveillance Requirements The existing TS Surveillance Requirements consist of a Channel Check and Channel Functional Test at frequencies specified in the Surveillance Frequency Control Program.

The proposed change replaces the Channel Functional Test with a Channel Calibration, and adds a note stating that the neutron detectors are excluded from the Channel Calibration. A Channel Functional Test injects a simulated signal into the channel as close to the primary Page 5 of 11

LR-N14-0185 LAR S14-03 sensor as practical to verify operability including alarm and/or trip functions. There are no credited alarm or trip functions in Mode 6. A Channel Calibration is a more comprehensive test that adjusts, as necessary, the channel output such that it responds with the necessary range and accuracy to known values of the parameter that the channel monitors. A Channel Calibration includes a Channel Functional Test. This change is consistent with NUREG-1431, Revision 4, which requires a Channel Check and Channel Calibration.

5. Comparison of NIS and Gamma-Metric Neutron Flux Monitors The NIS consists of three instrumentation ranges: source range, intermediate range and power range. In Mode 6, the NIS source range neutron flux monitors are used to determine the neutron flux level. These neutron flux monitors are located in a detector well outside of the reactor vessel. The NIS source range neutron flux monitors provide visual and audible indications of neutron count rate. The audible output provides a warning in the containment and control room.

NIS source range neutron flux monitors use a Safety Related Category I (Class 1 E) detector (two per unit) filled with boron trifluoride (BF3) to detect neutrons in the source range. A voltage potential is applied between the electrode and detector wall and the resultant signal is directly proportional to thermal neutron flux. The number of neutrons is represented as low-level current pulses.

The output signal from the NIS source range detector is input to a preamplifier assembly.

The signal is amplified and attenuated at the preamplifier before being sent to the source range drawer. The source range drawer conditions and processes the signal before it goes to indication meters, audio count rate drawer, comparator and rate drawer, and the plant computer.

NIS source range neutron flux monitors have two channels; each is independently input to the RPS. These trains are physically and electrically separated in accordance with the Salem criteria and licensing basis. In Mode 6, the source range neutron flux monitors do not have any RPS trip functions.

NIS Source Range Neutron Flux Monitors Number of detectors 2 (per unit)

Location One detector is located at 0 degree orientation about the reactor vessel, while the second detector is located at 180 degree orientation about the reactor vessel Detector Type Boron Trifluoride (BF3) Proportional Counter Detector Sensitivity 13 cps/neutron-volt (nv) (thermal)

Range 1 0° to 10° cps Accuracy 3% of full scale Designed Range of Detector Operating Up to 300°F Temperatures A separate Gamma-Metrics PANM System was installed in Salem Units 1 and 2 to satisfy the requirements of RG 1.97, Revision 2. The PANMs are capable of detecting neutron flux from the source range through 200% Rated Thermal Power (RTP) during all modes of plant Page 6 of 11

LR-N14-0185 LAR S14-03 operation. The PANMs utilize two separate and independent Safety Related (Class 1 E) fission chamber neutron detectors for all ranges of neutron flux indication. A voltage potential is applied to the detector electrode and outside wall. The signal from the detector is composed of a series of charged pulses that are input to an amplifier assembly containing signal conditioning circuitry, DC power supplies, and the detector high voltage power supply.

The amplifier assembly output goes to a signal processing assembly. The detector signal is displayed in the control room as source range count rate and wide range log power.

Gamma-Metric PANMs provide no protective or control functions. These channels are physically and electrically separated in accordance with the Salem criteria and licensing basis as identified in Salem Technical Standards.

The Gamma-Metrics PANM System includes a Shutdown Monitor (SM). This instrument monitors the count rate from the PANMs for any statistically significant increase that would indicate a loss of reactor shutdown margin. The SM generates an alarm when the count rate increases by an amount equal to the alarm ratio set into the SM. The SM follows the progress of reactor shutdown, continuously reducing the alarm setpoint as the count rate decreases. When the count rate begins to increase, the alarm setpoint remains at its lowest value. A control room alarm (one annunciator for each channel) will occur when the count rate reaches a value equal to the alarm setpoint. If counts are elevated on both channels of the PANMs, the Salem alarm response procedure directs the operator to perform several actions, including notifying personnel in containment of the increase in counts and performing a shutdown margin calculation.

The detector for each NIS source range neutron flux monitor and Gamma-Metrics PANM instrumentation channel is installed in the same type of detector well, equidistant to the reactor vessel. For each Gamma-Metrics PANM, its neutron detector is 90 degrees apart from a NIS source range neutron flux monitor channel and 180 degrees from the second PANM detector with respect to the detector's orientation about the reactor vessel. This orientation is similar to that used for the original NIS detectors.

GAMMA-METRICS PANM Number of detectors 2 (per unit)

Location One detector is located at 90 degree orientation about the reactor vessel, while the second detector is located at 270 degree orientation about the reactor vessel Detector Type Fission Chamber Detector Sensitivity 4 cps/nv(thermal) and 2 cps/nv(fast)

Range 10-*1 to 10° cps (source range)"1 10-8% to 200% RTP (wide range)

Accuracy 2% of full scale Designed Range of Detector Operating 32-302°F, 10%- 90% RH (Service Conditions)

Temperatures Up to 428°F, 90% RH (Design Basis Event) 1 The fact that the Gamma-Metrics PANM does not cover the range of 105 to 106 cps is insignificant in Mode 6. The NIS Source Range Monitors have the one higher decade for the reactor trip function. The reactor trip function is not required in Mode 6 when the Gamma-Metrics will be credited.

Page 7 of 11

LR-N14-0185 Conclusion LAR S14-03 The NIS and Gamma-Metrics PANM source range neutron flux monitors are functionally equivalent and capable of detecting and indicating neutron flux levels over the shutdown range required during Mode 6. Both systems are classified as Safety Related (Class 1 E),

have similar accuracies, and provide indication in the control room. By taking credit for the Gamma-Metrics PANM as source range neutron flux monitors, two additional channels of redundant and independent source range neutron flux monitoring are available during Mode

6.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) hereby requests an amendment to Renewed Facility Operating License Nos. DPR-70 and 75 for Salem Nuclear Generating Station Units 1 and 2.

This license amendment request creates a new Technical Specification (TS) Limiting Condition for Operation (LCO) 3.9.2.1 for Unborated Water Source Isolation Valves in Mode 6. This new TS LCO supports removing the existing requirement for one source range neutron flux monitor with audible indication in the containment and control room during Mode 6. By isolating unborated water sources, a safety analysis for an uncontrolled boron dilution event is not required for Mode 6.

This license amendment request proposes to permit using the Gamma-Metrics Post Accident Neutron Monitors (PANM) to provide neutron flux indication during Mode 6 (Refueling). The change revises TS LCO 3.9.2 " Refueling Operations/Instrumentation" by adopting the NUREG-1431, Revision 4, "Standard Technical Specifications Westinghouse Plants," language for the LCO, Action Statements, and Surveillance Requirements. The TS LCO may be met with any combination of NIS and/or Gamma-Metrics PANM as source range neutron flux monitors. The two NIS source range neutron flux monitor channels and the two Gamma-Metrics PANM channels are functionally equivalent and both are Safety Related Category I (Class 1 E) systems. By taking credit for the Gamma-Metrics PANM as source range neutron flux monitors, two additional channels of independent and redundant source range neutron flux monitoring are available during Mode 6.

PSEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

Page 8 of 11

LR-N14-0185 LAR S14-03

1.

Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

A boron dilution event during Mode 6 has been precluded through the proposed Technical Specification (TS) Limiting Condition for Operation 3.9.2.1, which requires isolating unborated water sources by securing valves in the closed position.

The primary function of the source range neutron flux monitors in Mode 6 is to inform the operators of unexpected changes in core reactivity. The proposed change to allow using the Gamma-Metric PANM for neutron flux monitoring during Mode 6 does not increase the probability of an accident previously evaluated, because the source range neutron flux monitors are not accident initiators or precursors.

The use of Gamma-Metrics PANM, does not significantly increase the consequences of a boron dilution event. Boron dilution during Mode 6 has been precluded by isolating unborated water sources by securing valves in the closed position. The use of Gamma Metrics PANM, does not affect the integrity of the fission product barriers utilized for the mitigation of radiological dose consequences as a result of an accident.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The Gamma-Metrics PANMs are used for monitoring neutron flux and criticality assessment in Mode 6. The *proposed changes will not adversely affect this monitoring capability. The proposed changes do not involve any physical modification of plant systems, structures, or components, or changes in parameters governing plant operation. No new accident scenarios, failure mechanisms, or single failures are introduced as a result of any of the proposed changes. Source range neutron flux monitors are not accident initiators.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Do the proposed changes involve a significant reduction in a margin of safety?

esponse: No.

Margin of safety is related to the confidence in the ability of the fission product barriers to perform their intended functions. These barriers include the fuel cladding, the reactor coolant system pressure boundary, and the containment. The proposed TS changes do not affect any of these barriers. No accident mitigating equipment will be adversely impacted by the proposed changes. Boron dilution during Mode 6 has been precluded by isolating unborated water Page 9 of 11

LR-N 14-0185 LAR S14-03 sources by securing valves in the closed position. The Gamma-Metrics PANM are not explicitly credited in any accident analysis for Mode 6. The existing safety margins are preserved.

Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Based upon the above, PSEG Nuclear LLC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, and, accordingly, a finding of no significant hazards consideration is justified.

5.2 Applicable Regulatory Requirements and Criteria 10 CFR 50, Appendix A, General Design Criteria (GDC)

Salem Nuclear Generating Station, Units 1 and 2 were designed and constructed in accordance with Atomic Energy Commission (AEC) proposed General Design Criteria published in July 1967. As documented in Salem UFSAR Section 3.1, the applicable AEC proposed criterion is Criterion 12.

Criterion 12 - Instrumentation and Control Systems. Instrumentation shall be provided to monitor variables and systems and controls shall be provided to maintain variables within prescribed operating ranges.

Following implementation of the proposed changes, Salem Nuclear Generating Station, Units 1 and 2 will remain in compliance with AEC proposed Criterion 12.

New TS LCO 3.9.2.2 is being added in accordance with Criterion 2 of 10 CFR 50.36(c)(2)(ii).

In conclusion, based on the considerations discussed above, (1) there is a reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the NRC's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.3 Precedents The NRC has approved similar license amendment changes as indicated below:

1.

Byron Station, Units 1 and 2, Amendments 109 and 109 dated June 2, 1999 (TAC Nos.

MA5020 AND MA5021) (ADAMS Accession No. ML020860637)

2.

Braidwood Station, Units 1 and 2, Amendments 102 and 102 dated June 2, 1999 (TAC Nos. MA5022, and MA5023) (ADAMS Accession No. ML020860637).

Page 10 of 11

LR-N14-0185

6.0 ENVIRONMENTAL CONSIDERATION

LAR S14-03 A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1.

NRC Regulatory Guide 1.97, Revision 2, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," December 1980

2.

Technical Specification Task Force (TSTF) Change Traveler TSTF-23, "Bracket NUREG-1431 LCO 3.9.2, Unborated Water Source Isolation Valves," NRC approved April 17, 1998

3.

Technical Specification Task Force (TSTF) Change Traveler TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," NRC approved July 6, 2009

4.

Letter Richard B. Ennis (NRC) to Thomas Joyce (PSEG), "Salem Nuclear Generating Station, Unit Nos. 1 and 2, Issuance of Amendments RE: Relocation of Specific Surveillance Frequencies to a Licensee-Controlled Program Based on Technical Specification Task Force (TSTF) Change TSTF-425 (TAG Nos. ME3574 and ME3575),"

March 21, 2011.

Page 11 of 11

LR-N14-0185 TECHNICAL SPECIFICATION PROPOSED CHANGES LAR S14-03 The following Technical Specifications for Renewed Facility Operating License DPR-70 are affected by this change request:

Technical Specification Index IX TS LCO 3.9.2 3/4 9-2 The following Technical Specifications for Renewed Facility Operating License DPR-75 are affected by this change request:

Technical Specification Index IX TS LCO 3.9.2 3/4 9-2

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS

===============================================c============

SECTION 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION

!jjt./.C). 2, I VN/Y.:),eAI'fiD WAIE_.e SovA.c:£ ISOl.A'nr:>A.J V4L V£3 3/4.9.2.'2 INSTRUMENTATION

. 3 / 4. 9. 3 DECAY TIME 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS 3/4.9.5 DELETED 3/4.9.6 DELETED 3/4.9.7 DELETED 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION 3/4.9.9 All Water Levels Low Water Level DELETED 3/4.9.10 WATER LEVEL REACTOR VESSEL 3/4.9.11 STORAGE POOL WATER LEVEL 3/4.9.12 FUEL HANDLING AREA VENTILATION SYSTEM 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN 3/4.10.2 GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS 3/4.10.3 PHYSICS TESTS 3/4.10.4 NO FLOW TESTS SALEM UNIT 1 IX t"AGE 3/4 9-1 g Jq '1-l (.t, 3/4 9-2 b 3/4 9-3 3/4 9-4 3/4 9-5 3/4 9-6 3/4 9-7 3/4 9-8 3/4 9-Ba 3/4 9-10 3/4 9-11 3/4 9-12 3/4 10-1 3/4 10-2 3/4 10-3 3/4 10-4 Amendment No.293

REFUELING OPERATIONS UNBORATED WATER SOURCE ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.9.2.1 Each valve used to isolate unborated water sources shall be secured in the closed position.

APPLICABILITY: MODE 6 ACTION:

NOTE----------------------------------------------------------

Separate entry is allowed for each unborated water source isolation valve.

With one or more valves not secured in closed position:

a.

Immediately suspend CORE ALTERATIONS, and initiate actions to secure valve in closed position.

b.

Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> perform Surveillance Requirement 4.9.1 SURVEILLANCE REQUIREMENTS 4.9.2.1 Verify each valve that isolates unborated water sources is secured in the closed position in accordance with the Surveillance Frequency Control Program.

SALEM UNIT 1 3/4 9-2a Amendment No.

REFUELING OPERATIONS INSTRUMENTATION LIMITING CONDITION FOR OPERATION OPER.Af!:.Lf:.,

3.q,zz *3.0.2: As a Fflinirnuffi; 1wo source range neutron flux monitors shall be eperetiM\\L eeeh with continuous visual indication in the control room ana one with aueHble indioat+en in tf1e oontainment and control room.

APPLICABILITY: MODE 6.

ACTION:

With the requirefflents ef tf=le aeete speeifie:;:tieFt-Aet setisHeEl, iFflffledistely suspeAd slf

[ati9r.:1Z invglving COr;?E,A,I..TERJI,TIOJe...gr pesiiYe reeeti¥iqe-:-"Ff1e-pre*tisions of peolfication 6.0.6 are not appHeablo.

SURVEILLANCE REQUIREMENTS*

4.9.2 Each source range neutron flux monitor shall be demonstrated OPERABLE by performance of:

/NS121 Z.

CAt..ll!::l<A'TIOAJ

b. -a-:

A CHANNEL FUWTI8NALTEGT in accordance with the Surveillance Frequency Control Program, and A CHANNEL CHECK in accordance with the Surveillance Frequency Control Program during CORE ALTERATIONS.

SALEM-UNIT i 3/4 9-2 b Amendment No. 299

,INSERT 1.

a.

With one of the above requtred monitors Inoperable, Immediately suspend all operations Involving CORE ALTERATIONS or positive reactivity additions.

b.

With both of the required monitors Inoperable: Immediately suspend all operations involving CORE ALTERATIONS, positive reactivity additions, and initiate action to restore one source range monitor to OPERABLE status; and perform Surveillance Requirement 4.9.1 once per 1 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

c.

The provisions of Specification 3.0.3 are not applicable.

.INSERT 2

--------------------N 0 T E Neutron detectors are excluded from CHANNEL CALIBRATION

'IJ

'I !

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS

===%====%===$%&=='===================(===((========:===$===)===*==========+

SECTION PAGE 314.9 REFUELING OPERATIONS 314.9.1 BORON CONCENTRATION...

.,. 314 9-1

'3/l/

.. q.1.1 I)N/3ol!A:r£D t;JA*rE(( So.JI!. CE. I SOLA77c;yo.J VAl-\\/o :J

'3/t! 'lulcl-3 I 4. 9, 2, '2. INSTRUMENTATION...

..,............................ 314 9-2 b 314.9.3 DECAY TIME.....

... 3/4 9-3 314.9.4 CONTAINMENT BUILDING PENETRATIONS..............

. 314 9-4 3 I 4. 9. 5 DELETED...

..... 3/4 9-5 3 I 4. 9. 6 DELETED

.. 3 I 4 9-6 3 I 4. 9. 7 DELETED

.. 3 I 4 9 -7 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION All Water Levels

.... 314 9-8 Low Water Level....................................... 314 9-9 3/4.9.9 DELETED 314.9.10 WATER LEVEL REACTOR VESSEL

.. 314 9-11 3/4.9.11 STORAGE POOL WATER LEVEL.............................. 314 9-12 3/4.9.12 FUEL HANDLING AREA VENTILATION SYSTEM..,.............. 3/4 9-13 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN.

3/4 10-1 3/4.10.2 GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS.

..,............,. 3/4 10-2 3/4.10.3 PHYSICS TESTS......

.... 3/4 10-4 3/4.10.4 NO FLOW TESTS.

.........,.....,............ 314 10-5 SALEM -

UNIT 2 IX Amendment No.277

REFUELING OPERATIONS UNBORATED WATER SOURCE ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.9.2.1 Each valve used to isolate unborated water sources shall be secured in the closed position.

APPLICABILITY: MODE 6 ACTION:

NOTE----------------------------------------------------------

Separate entry is allowed for each unborated water source isolation valve.

With one or more valves not secured in closed position:

a.

Immediately suspend CORE ALTERATIONS, and initiate actions to secure valve in closed position.

b.

Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> perform Surveillance Requirement 4.9.1 SURVEILLANCE REQUIREMENTS 4.9.2.1 Verify each valve that isolates unborated water sources is secured in the closed position in accordance with the Surveillance Frequency Control Program.

SALEM UNIT 2 3/4 9-2a Amendment No.

REFUELING OPERATIONS 3/4.9.2 INSTRUMENTATION LIMITING CONDITION FOR QPERATIOI'J OPtEI!..A/!:.LE*

3.9.2 As e rniAiffiUFI"lo source range neutron flux monitors shall be Of3eFeting, eeeh wiM9 eeffiinuoP:s visual inelioati-e-A-in tl=!e oentfol roeFA ane:J one witi=l al::le:Jible inel+ea#&A in-tl9e

  • G9R*tai-FH1=1*9-R-t-ar::IQ control FOOFA.

APPLICABILITY: MODE 6.

ACTION:

a.

With one of the above required monitors inoperable, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes. At>Dmovs.

/IV'SEn'T I

b.

With both of tl9e required monitors inoperalele, deterFAine tho bore-n-oo*A-GeO Gt tho roaoter oeelant system at least once p©A-ot:IH3.

c.

The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.2 Each source range neutron flux monitor shall be demonstrated OPERABLE by performance of:

a.

A CHANNEL CHECK in accordance with the Surveillance Frequency Control Program, and 1/JSER:T Z.

CALl &eA:noAJ

b.

A CHANNEI::-R:INCFIBML TEST in accordance with the Surveillance Frequency Control Program.

SALEM-UNIT 2 3/4 9-2 b Amendment No. 282

. INSERT 1.

b.

With both of the required monitors inoperable¿ immediately suspend all operations involving CORE ALTERATIONS, positive reactivity additions, and initiate action to restore one source range monitor to OPERABLE status; and perform Surveillance Requlrement4.9.1 once per 1 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

,INSERT 2

*------**-N 0 T E*-----------------------------------***

Neutron detectors are excluded from CHANNEL CALIBRATION.

...................... \\oi'-'"""""""""".............. _.,..,.,_........................ HM1"1""-,.;........ ~...,...............................................,.. p... w...... y?ol"f... }....... -"'...... -..... l!"'..........,_,......

i i

I I

i

LR-N14-0185 LAR 814-03 TECHNICAL SPECIFICATION BASES PROPOSED CHANGES (FOR INFORMATION ONLY) 3/4.9.2.1 UNBORATED WATER SOURCE ISOLATION VALVES During MODE 6 operations, all isolation valves for reactor makeup water sources containing unborated water that are connected to the Reactor Coolant System (RCS) must be closed to prevent unplanned boron dilution of the reactor coolant. The isolation valves must be secured in the closed position.

Securing the required valves in the closed position during refueling operations ensures that the valves cannot be inadvertently opened, and prevents the flow of unborated water to the filled portion of the RCS. This action precludes the possibility of an inadvertent boron dilution event occurring during MODE 6 refueling operations. By isolating unborated water sources, a safety analysis for an uncontrolled boron dilution event in accordance with the Standard Review Plan (NUREG-0800, Section 15.4.6) is not required for MODE 6.

If any required valve is found not secured in the closed position, there is a potential of having a diluted boron concentration in the RCS. Immediately suspend CORE ALTERATIONS, and initiate actions to secure the valve in the closed position. Surveillance Requirement 4.9.1 must be performed to demonstrate that the required boron concentration exists. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> completion time is sufficient to obtain and analyze a reactor coolant sample for boron concentration.

Surveillance Requirement 4.9.2.1 demonstrates through a system walkdown that the required valves are closed. The surveillance frequency is controlled under the Surveillance Frequency Control Program.

3/4.9.2.2 INSTRUMENTATION The source range neutron flux monitors are used during refueling operations to determine the core reactivity condition. Two OPERABLE source range neutron flux monitors are required to alert the operator to unexpected changes in core reactivity, such as a boron dilution event. This ensures that redundant monitoring capability is available to detect changes in core reactivity. Based on isolating all boron dilution paths per LCO 3.9.2.1, only the source range neutron flux monitor visual indication in the control room is required for OPERABILITY.

Any combination of NIS source range neutron flux monitors and/or Gamma-Metrics post-accident neutron flux monitors may be used to satisfy the LCO. Two of the four total source range neutron flux monitors are required to be OPERABLE.

With only one required source range neutron flux monitor OPERABLE, redundancy has been lost.

Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation.

With no required source range neutron flux monitor OPERABLE, action to restore a monitor to OPERABLE status shall be initiated immediately. With no source range neutron flux monitor OPERABLE, there is no direct means of detecting changes in core reactivity. However, since positive reactivity additions are not to be made, the core reactivity condition is stabilized until the source range neutron flux monitors are OPERABLE. This stabilized condition is confirmed by performing Surveillance Requirement 4.9.1 to ensure that the required boron concentration exists and adequate shutdown margin is maintained.

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