LR-N15-0224, Response to Request for Additional Information License Amendment Request to Isolate Unborated Water Sources and Use Gamma-Metrics Post-Accident Neutron Monitors During Mode 6 (Refueling)
| ML15329A037 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/25/2015 |
| From: | Jamila Perry Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CAC MF5831, CAC MF5832, LAR S14-03, LR-N15-0224 | |
| Download: ML15329A037 (9) | |
Text
NOV*'* 15 2015 LR-N15-0224 LAR S14-03 PSEG Nucleat' LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 I)Sf:G Nudmr 10 CFR 50.90 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 75 NRC Docket Nos. 50-272 and 50-311
Subject:
Response to 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)
References
- 1.
PSEG letter to NRC, "License Amendment Request to Isolate Unborated Water Sources and Use Gamma-Metrics Post-Accident Neutron Monitors during Mode 6 (Refueling)," dated March 9, 2015 (ADAMS Accession No. ML15068A359)
- 2.
PSEG letter to NRC, "Supplement to License Amendment Request to Isolate Unborated Water Sources and Use Gamma-Metrics Post-Accident Neutron Monitors during Mode 6 (Refueling)," dated April 10, 2015 (ADAMS Accession No. ML 151 OOA406)
- 3.
NRC letter to PSEG, "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. MF 5831 and MF5832)," dated November 2, 2015 (ADAMS Accession No. ML15287A105)
In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request for Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. The proposed amendment would create a new Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.9.2.1 to isolate unborated water sources in Mode 6 and revise the existing TS LCO 3.9.2, "Refueling Ope ratio ns/1 nstru mentation."
In Reference 3, the NRC provided PSEG a Request for Additional Information (RAI) related to the Reference 1 request, dated November 2, 2015. Attachment 1 to this submittal provides the response to the RAI.
Page 2 LR-N15-0224 10 CFR 50.90 PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 1 0 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
There are no regulatory commitments contained in this letter.
If you have any questions or require additional information, please contact Mr. Brian Thomas at 856-339-2022.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on Respectfully, NOV' I 5 2015 (date)
/!Lr--
la F. Perry Site Vice President Salem Nuclear Generating Station -
Response to 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) -
Unit 1 Revised Technical Specification Mark-Up Page 3/4 9-2b cc:
Mr. D. Dorman, Administrator, Region I, NRC Mr. T. Wengert, NRC Project Manager, Salem NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. Cachaza, Salem Commitment Tracking Coordinator
LR-N15-0224 Response to 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)
LR-N15-0224 By letter dated March 9, 2015, as supplemented by letter dated April 10, 2015, 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.
NRC Question Instrumentation and Control Systems Branch (EICB) - Request for Additional Information (RAI)-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?
PSEG Response:
The new surveillance procedure, which will be issued during the implementation of the approved Technical Specifications (TS) amendment, will contain the methods for securing the valves in the closed position. The current population of valves for surveillance requirement (SR) 4.9.2.1 includes a failed closed air operated valve (AOV), a motor operated valve (MOV), and manual valves. The fail closed AOV will be secured by closing the valve and isolating the air supply.
The MOV will be closed and power removed from the operator. Manual valves will be locked in the closed position. The new surveillance procedure will maintain configuration control for the unborated water pathways, verifying that the unborated water sources are isolated. The list of valves that are associated with isolating the unborated flow paths will be contained and controlled in the new surveillance procedure.
NRC Question EICB-RAI-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?
PSEG Response: (existing versus new)
As stated in PSEG letter LR-N15-0124 dated June 2, 2015, the SR and IR LAR is not contingent on approval of the Mode 6 LAR. The replacement SR and IR neutron monitoring channels will LR-N15-0224 have the same design functions and features (i.e. audible count rate, alarm functions, trip functions) as the current channels. The replacement SR neutron monitors are being designed to meet the existing TS 3/4.9.2 requirements.
NRC Question EICB-RAI-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?
PSEG Response:
As stated in the Salem Unit 1 and 2 Technical Specification definition of a CHANNEL CALIBRATION (Definition 1.4), "the CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST." Therefore the channel functional test is a subset of the channel calibration. A simulated signal is injected into the channel during the channel calibration.
The source range channels have an existing channel calibration requirement for Modes 2, 3, 4, and 5. The surveillance testing procedure for the performance of the source range channel calibration will be revised accordingly during the implementation of the approved TS amendment to address the Mode 6 instrumentation surveillance requirements. A comparison of the existing source range calibration procedure to the existing channel functional procedure shows that both procedures verify operability and accuracy of channel analog and trip functions.
The channel calibration procedure includes additional steps for making adjustments when required. With respect to functionality, the procedures verify the same indications and alarms at the drawers (local), control room panels, and overhead annunciators. Both procedures verify and record the setpoints for the same functions.
The existing RG 1.97 post-accident neutron monitors will require the development of a new surveillance procedure to Implement the Mode 6 channel calibration surveillance requirement.
This procedure will be developed during the implementation of the approved TS amendment.
LR-N15-0224 NRC Question Reactor Svstems Branch (SRXB)-RAI-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?
PSEG Response:
During the implementation of the license amendment, a new procedure will be issued to implement new surveillance requirement (SR) 4.9.2.1. This surveillance procedure will provide the direction for securing the valves in the closed position as discussed in the response to question EICB-RAI-1. The list of valves that are associated with isolating the unborated flow paths will be contained and controlled in the new surveillance procedure.
NRC Question Technical Specifications Branch (STSB)- RAI-1 Salem Nuclear Generating Station, Unit No. 1, TS LCO 3.9.2, "Refueling Operations Instrumentation," currently specifies SRs 4.9.2.a and b as 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 ALTERATIONS.
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 needs to be added in renumbered SR 4.9.2.a similar to that specified in Unit 2 TS SRs 4.9.2.a and b. Please provide the corrected TS page.
PSEG Response:
The Unit 1 TS markup for SR 4.9.2.2a and 4.9.2.2.b has been corrected to move the 'and' to the appropriate location. The revised markup page is provided in Attachment 2.
NRC Question STSB-RAI-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.
LR-N15-0224 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 5b, " and justify inclusion of the specified frequency interval in the program.
PSEG Response:
The initial surveillance frequency will be 31-days consistent with NUREG-1431, Standard Technical Specifications for Westinghouse Plants.
The criteria for relocation of a surveillance frequency to a licensee controlled program in accordance with TSTF-425 were reviewed. This surveillance frequency is a periodic surveillance that: 1) does not reference other approved programs for the specified interval, 2) is not event driven, 3) does not have a time component based on event occurrence, and 4) is not related to a specific condition for performance. Therefore the periodic surveillance frequency is within the scope of TSTF-425 for location in the licensee controlled Surveillance Frequency Control Program. As stated in the LAR, Salem has implemented TSTF-425 as approved by the NRC with TS Amendment 299 (Unit 1) and 282 (Unit 2).
LR-N15-0224 Unit 1 Revised Technical Specification Mark-Up Page 3/4 9-2b
REFUELING OPERATIONS INSTRUMENTATION LIMITING CONDITION FOR OPERATION 01>K';A81..E.
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SALEM UNIT I 3/4 9-2.b Amendment No. 299