ML15287A105

Request for Additional Information License Amendment Request to Isolate Unborated Water Sources and Use Gamma-Metrics Post-Accident Neutron Monitors During Mode 6 (Refueling) (CAC Nos. MF5831 & MF5832)

ML15287A105
Person / Time
Site:	Salem
Issue date:	11/02/2015
From:	Thomas Wengert Plant Licensing Branch 1
To:	Braun R Public Service Enterprise Group
Wengert T, NRR/DORL/LPLI-2
References
CAC MF5831, CAC MF5832
Download: ML15287A105 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 2, 2015 Mr. Robert Braun President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST TO ISOLATE UNBORATED WATER SOURCES AND USE GAMMA-METRICS POST-ACCIDENT NEUTRON MONITORS DURING MODE 6 (REFUELING)

(CAC NOS. MF5831 AND MF5832)

Dear Mr. Braun:

By letter dated March 9, 2015, 1 as supplemented by letter dated April 10, 2015, 2 PSEG Nuclear LLC (the licensee) submitted a license amendment request to add a new Technical Specification Limiting Condition for Operation 3.9.2.1 to isolate unborated water sources in Mode 6 (refueling mode) to preclude a boron dilution event for Salem Nuclear Generating Station, Unit Nos. 1 and 2. This amendment also supports removing the existing requirement for the audible indication of the source range neutron flux monitor in the containment and in the control room during Mode 6.

The U.S. Nuclear Regulatory Commission staff has determined that additional information is needed to complete its review of the submittals. The specific questions are found in the enclosed request for additional information. The draft questions were sent by electronic transmission on October 6, 2015, to Mr. Paul Duke. The draft questions were sent to ensure that they were understandable, the regulatory basis was clear, and to determine if the information was previously docketed. On October 30, 2015, Mr. Brian Thomas of your staff indicated that the licensee will submit a response to this request by November 30, 2015.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML15068A359.

2 ADAMS Accession No. ML 151 OOA406.

R. Braun If you have any questions, please contact me at 301-415-4037 or Thomas.Wengert@nrc.gov.

Sincerely, Thomas J. Wengert, Senior Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

Request for Additional Information cc w/enclosure: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ISOLATE UNBORATED WATER SOURCES AND USE GAMMA-METRICS POST-ACCIDENT NEUTRON MONITORS DURING MODE 6 (REFUELING)

PSEG NUCLEAR LLC SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By letter dated March 9, 2015, 1 as supplemented by letter dated April 10, 2015, 2 PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) to add a new Technical Specification (TS) Limiting Condition for Operation (LCO) 3.9.2.1 to isolate unborated water sources in Mode 6 (refueling mode) to preclude a boron dilution event for Salem Nuclear Generating Station, Unit Nos. 1 and 2. This amendment also supports removing the existing requirement for the audible indication of the source range neutron flux monitor in the containment and in the control room during Mode 6. The U.S. Nuclear Regulatory Commission staff has determined that additional information is needed, as described below, to complete its review of the submittals.

Instrumentation and Control Systems Branch (EICB)-Request for Additional Information (RAl)-1 Surveillance Requirement 4.9.2.1 states:

Verify each valve that isolates unborated water sources is secured in the closed position in accordance with the Surveillance Frequency Control Program.

Please advise the method that verifies all unborated water sources are isolated. For example, are the valves locked closed, visually verified closed, etc.? Is there a list to verify that the applicable valves are closed/secured?

1 ADAMS Accession No. ML15068A359.

2 ADAMS Accession No. ML 151 OOA406.

Enclosure

EICB-RAl-2 PSEG submitted a separate LAR for replacement of startup range (SR) and intermediate range (IR) neutron monitors on April 3, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15093A291 ). When implemented, this license amendment will replace the existing SR and IR neutron monitors with the new Thermo-Scientific monitors.

Considering the differences in the features (e.g., audible alarms) between the existing and the replacement source range monitors, please state how the two amendments can be implemented independently without affecting the other amendment or violating TS requirements in any way?

EICB-RAl-3 LAR Section 4.0, Item 4, states:

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 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.

Describe how the channel functional test is accomplished as part of the calibration test. Does the Channel Calibration Test include all the steps for the Channel Functional Test that were previously performed in the standalone Channel Functional Test?

Reactor Systems Branch (SRXB)-RAl-1 New LCO 3.9.2.1 states:

Each valve used to isolate unborated water sources shall be secured in the closed position.

Is there an existing procedure that is used to secure all applicable valves in the closed position?

Is there a list of applicable valves to be secured?

Technical Specifications Branch (STSB)-RAl-1 Salem Nuclear Generating Station, Unit No. 1, TS LCO 3.9.2, "Refueling Operations -

Instrumentation," currently specifies SRs 4.9.2.a and bas follows:

a. A CHANNEL FUNCTIONAL TEST in accordance with the Surveillance Frequency Control Program, and

b. A CHANNEL CHECK in accordance with the Surveillance Frequency Control Program during CORE AL TERATIONS.

According to the application, LCO 3.9.2 is renumbered as LCO 3.9.2.2. The proposed change to LCO 3.9.2.2 reverses the numbering of these surveillances. In other words, SR 4.9.2.a is to be renumbered as 4.9.2.b and vice versa. The change, as proposed, needs a correction. The word "and" at the end of the renumbered SR 4.9.2.b should be deleted and then added in renumbered SR 4.9.2.a, similar to that specified in Unit No. 2 TS SRs 4.9.2.a and b. Please provide the corrected marked up TS page.

STSB-RAl-2 Surveillance Requirement 4.9.2.1 states:

Verify each valve that isolates unborated water sources is secured in the closed position in accordance with the Surveillance Frequency Control Program.

Since this is a new surveillance, please identify the initial surveillance frequency, review TS Task Force (TSTF) Change Traveler TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative Sb," and justify inclusion of the specified frequency interval in the program.

ML15287A105 *by memorandum **by e-mail OFFICE LPL 1-2/PM LPL 1-2/LA DE/EICB/BC(A)* DSS/SRXB/BC** DSS/STSB/BC* LPL 1-2/BC LPL 1-2/PM NAME TWengert LRonewicz DRahn CJackson RElliott DBroaddus TWengert (REnnis for)

DATE 10/20/15 10/20/15 8/31/15 9/10/15 10/2/15 11/2/15 11/2/15