LR-N15-0189, Supplemental Information Needed for Review of Emergency License Amendment Request to Remove Pressurizer Power Operated Relief Valve Position Indication Instrumentation from Accident Monitoring Instrumentation Technical Specifications

Supplemental Information Needed for Review of Emergency License Amendment Request to Remove Pressurizer Power Operated Relief Valve Position Indication Instrumentation from Accident Monitoring Instrumentation Technical Specifications

ML15245A754
Person / Time
Site:	Salem
Issue date:	09/02/2015
From:	Jamila Perry Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N15-0189
Download: ML15245A754 (11)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 PSF:92 the PORVs, verifies TIS 3.4.3 days since last control room TIS 3.4.9.3 performance. indication S1407865 Each Refueling Functionally strokes TIS 6.8.4.j the PORVs, verifies TIS 3.4.3 control room TIS 3.4.9.3 indication.

S1100299 Each Refueling Functionally strokes TIS 6.8.4.j, the PORVs, verifies TIS 3.4.3 Remote Position TIS 3.4.9.3 Indication: physical PORV position matches control room indication.

5. On the bottom of page 4 of Section 4.0, Technical Analysis there is a statement regarding the Emergency Operating Procedures (EOPs) which in part states, " Individual EOPs using PORV position can be accomplished using alternate means regardless of whether PORV position instrumentation is available." Please explain what is meant by this statement, and identify the specific alternate means to which this refers

Response

EOPs include steps to verify if the PORVs are closed and determine if they are operating properly (e.g., 1-EOP-TRIP-1). If the PORVs should be closed and are not, they are directed to be closed, and if unsuccessful, the associated block valve(s) are closed. The operator will use not only the limit switch indication to make this determination, but will also verify by alternate means (tailpipe temperatures, PRT temperature and PRT level) as necessary if the validity of LR-N15-0189 the position indication is in doubt. Diagnostic guidance is contained in plant abnormal and emergency operating procedures.

References:

1. PS EG letter to NRC, " Emergency License Amendment Request to Remove Pressurizer Power Operated Relief Valve (PORV) Position Indication Instrumentation from the Accident Monitoring Instrumentation Technical Specifications," dated August 31, 2015 (ADAMS Accession No. ML15243A491)

LR-N15-0189 Attachment 2 Revision of 10 CFR 50.92 No Significant Hazards Consideration LR-N15-0189

5.0 REGULATORY ANALYSIS

10 CFR 50.36 (a)(1) requires that each applicant for a license authorizing operation of a production or utilization facility shall include in its application proposed TS in accordance with the requirements of section 50.36. The TS are part of the facility operating license and any changes to the operating license and TS must be in accordance with 10 CFR 50.90. The changes proposed by this license amendment request conform to these regulations.

No Significant Hazards Consideration PSEG requests an amendment to the Salem Unit 1 Operating License. The proposed change would remove the Pressurizer Power Operated Relief Valve (PORV) position indication from the Accident Monitoring Instrumentation Technical Specifications (TS) 3/4.3.3. 7 Tables 3.3-11 and 4.3-11 for the Salem Generating Station (Salem) Unit 1.

PSEG has evaluated the proposed changes to the TS, using the criteria in 10 CFR 50.92, and determined that the proposed changes do not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

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

Response: No The proposed change to the TS would remove the PORV position indication from the Accident Monitoring Instrumentation TS for Salem Unit 1. The failure of this instrumentation is not assumed to be an initiator of any analyzed event in the UFSAR. Therefore the probability of an accident previously evaluated is not significantly increased.

The proposed changes do not alter the design of the PORVs or any other system , structure, or component (SSC). The proposed changes conform to NRC regulatory guidance regarding the content of plant TS, as identified in 10 CFR 50.36, NUREG-1431, and the NRC Final Policy Statement in 58 FR 39132. TS Operability requirements are retained for Type A and Category 1 variables. Operability of these instruments ensures sufficient information is available to monitor and assess plant status during and following an accident.

Alternate m eans for diagnosing and responding to PORV malfunctions (Pressurizer Relief Tank level and tem perature, and PORV tailpipe temperature) are unaffected by the proposed change. Therefore, the consequences of an accident previously evaluated are not significantly increased.

Therefore, these proposed changes do not represent 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 proposed changes to the TS would remove the PORV position indication from the Accident Monitoring Instrumentation TS for Salem Unit 1. The proposed change does not LR-N15-0189 involve a modification to the physical configuration of the plant or change in the methods governing normal plant operation. The proposed changes will not impose any new or different requirement or introduce a new accident initiator, accident precursor, or malfunction mechanism.

Additionally, there is no change in the types or increases in the amounts of any effluent that may be released off-site and there is no increase in individual or cumulative occupational exposure. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No The proposed changes to the TS would remove the PORV position indication from the Accident Monitoring Instrumentation TS for Salem Unit 1. This instrumentation is not needed for manual operator action necessary for safety systems to accomplish their safety function for the design basis events. The PORV position instrumentation does not provide an input to any automatic trip function or impact the response of the PORVs to a design basis accident.

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

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

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.