Text

Issuance of Amendments Correct Non-Conservative Technical Specifications and Other Discrepancies
	ML16229A519
Person / Time
Site:	Salem
Issue date:	09/29/2016
From:	Carleen Parker; Plant Licensing Branch 1
To:	Sena P; Public Service Enterprise Group
	Parker C, NRR/DORL/LPL1-2
References
	CAC MF6987, CAC MF6988
	Download: ML16229A519 (25)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 29, 2016 Mr. Peter P. Sena, Ill President PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1AND2- ISSUANCE OF AMENDMENTS RE: CORRECT NON-CONSERVATIVE TECHNICAL SPECIFICATIONS AND OTHER DISCREPANCIES (CAC NOS. MF6987 AND MF6988)

Dear Mr. Sena:

The Commission has issued the enclosed Amendment Nos. 315 and 296 to Renewed Facility Operating License Nos. DPR-70 and DPR-75 for the Salem Nuclear Generating Station (Salem),

Unit Nos. 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated October 12, 2015.

The amendments revise Salem, Unit Nos. 1 and 2, TSs by adding MODE 4 to the applicability of TS 3.6.2.3, "Containment Cooling System." The amendments also correct a discrepancy between the applicable modes and the action statements of TS 3.7.1.1, "Safety Valves."

A copy of the related safety evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Carleen J. rker, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosures:

1. Amendment No. 315 to Renewed DPR-70

2. Amendment No. 296 to Renewed DPR-75

3. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PSEG NUCLEAR LLC EXELON GENERATION COMPANY. LLC DOCKET NO. 50-272 SALEM NUCLEAR GENERATING STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 315 Renewed License No. DPR-70

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by PSEG Nuclear LLC, acting on behalf of itself and Exelon Generation Company, LLC {the licensee) dated October 12, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR), Chapter I;

8. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-70 is hereby amended to read as follows:

Enclosure 1

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 315, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. PSEG Nuclear LLC shall operate the facility in accordance with the Technical Specifications, and the Environmental .Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULA TORY COMMISSION Douglas A. Broaddus, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License and Technical Specifications Date of Issuance: September 2 9, 2O1 6

ATTACHMENT TO LICENSE AMENDMENT NO. 315 SALEM NUCLEAR GENERATING STATION. UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-272 Replace the following page of Renewed Facility Operating License No. DPR-70 with the attached revised page as indicated. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Insert Page 3 Page 3 Replace the following pages of the Appendix A, Technical Specifications, with the attached revised pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3/46-11 3/4 6-11 3/4 7-1 3/4 7-1

instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) PSEG Nuclear LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) PSEG Nuclear LLC, pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level PSEG Nuclear LLC is authorized to operate the facility at a steady state reactor core power level not in excess of 3459 megawatts (one hundred percent of rated core power).

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 315, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. PSEG Nuclear LLC shall operate the facility in accordance with the Technical Specifications, and the Environmental Protection Plan.

(3) Deleted Per Amendment 22, 11-20-79 (4) Less than Four Loop Operation PSEG Nuclear LLC shall not operate the reactor at power levels above P-7 (as defined in Table 3.3-1 of Specification 3.3.1.1 of Appendix A to this renewed license) with less than four (4) reactor coolant loops in operation until safety analyses for less than four loop operation have been submitted by the licensees and approval for less than four loop operation at power levels above P-7 has been granted by the Commission by Amendment of this renewed license.

(5) PSEG Nuclear LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Renewed License No. DPR-70 Amendment No. 315

CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.3 Five containment cooling fans shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one or two of the above required containment cooling fans inoperable, restore the inoperable cooling fan(s) to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With three or more of the above required containment cooling fans inoperable, restore at least three cooling fans to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY WITHIN the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restore the remaining inoperable cooling fans to OPERABLE status within 7 days of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.2.3 Each containment cooling fan shall be demonstrated OPERABLE:

SALEM - UNIT 1 3/4 6-11 Amendment No. 315

3/4. 7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE SAFETY VALVES LIMITING CONDITION FOR OPERATION 3.7.1.1 All main steam line code safety valves (MSSVs) associated with each steam generator shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

a. With one or two main steam line code safety valves inoperable in one or more steam generators, operation in Modes 1, 2 and 3 may proceed provided, that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either the inoperable valve is restored to OPERABLE status or reduce power to less than or equal to the applicable percent of RATED THERMAL POWER per Table 3.7-1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With three main steam line code safety valves inoperable in one or more steam generators, operation in Modes 1, 2 and 3 may proceed provided, that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either the inoperable valves are restored to OPERABLE status or reduce power to less than or equal to the applicable percent of RA TED THERMAL POWER per Table 3.7-1 and within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , reduce the Power Range Neutron Flux High trip setpoint to less than or equal to the RATED THERMAL POWER per Table 3.7-1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

SURVEILLANCE REQUIREMENTS 4.7.1.1 Verify each required MSSV lift setpoint per Table 4.7-1. No additional Surveillance Requirements other than those required by the lnservice Testing Program.

SALEM - UNIT 1 3/4 7-1 Amendment No. 315

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PSEG NUCLEAR LLC . **

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-311 SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 296 Renewed License No. DPR-75

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by PSEG Nuclear LLC, acting on behalf of itself and Exelon Generation Company, LLC {the licensee) dated October 12, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 1O of the Code of Federal Regulations (1 O CFR), Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-75 is hereby amended to read as follows:

Enclosure 2

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 296, and the environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. PSEG Nuclear LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULA TORY COMMISSION Douglas A. Broaddus, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License and Technical Specifications Date of Issuance: September 2 9 , 2o1 6

ATTACHMENT TO LICENSE AMENDMENT NO. 296 SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 Replace the following page of Renewed Facility Operating License No. DPR-75 with the attached revised page as indicated. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Insert Page 3 Page 3 Replace the following pages of the Appendix A, Technical Specifications, with the attached revised pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3/4 6-12 3/4 6-12 3/4 7-1 3/4 7-1

(4) PSEG Nuclear LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use at any time any byproduct, source or special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required; (5) PSEG Nuclear LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) PSEG Nuclear LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: *

(1) Maximum Power Level PSEG Nuclear LLC is authorized to operate the facility at steady state reactor core power levels not in excess of 3459 megawatts (thermal).

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 296, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. PSEG Nuclear LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. DPR-75 Amendment No. 296

CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.3 Five containment cooling fans shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one or two of the above required containment cooling fans inoperable, restore the inoperable cooling fan(s) to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With three or more of the above required containment cooling fans inoperable, restore at least three cooling fans to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY WITHIN the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restore the remaining inoperable cooling fans to OPERABLE status within 7 days of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.2.3 Each containment cooling fan shall be demonstrated OPERABLE:

SALEM - UNIT 2 3/4 6-12 Amendment No. 296

3/4. 7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE SAFETY VALVES LIMITING CONDITION FOR OPERATION 3.7.1.1 All main steam line code safety valves (MSSVs) associated with each steam generator shall be OPERABLE with lift settings as specified in Table 3.7-4.

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

a. With one or two main steam line code safety valves inoperable in one or more steam generators, operation in Modes 1, 2 and 3 may proceed provided, that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either the inoperable valve is restored to OPERABLE status or reduce power to less than or equal to the applicable percent of RATED THERMAL POWER per Table 3.7-1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With three main steam line code safety valves inoperable in one or more steam generators, operation in Modes 1, 2 and 3 may proceed provided, that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either the inoperable valves are restored to OPERABLE status or reduce power to less than or equal to the applicable percent of RATED THERMAL POWER per Table 3.7-1 and within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , reduce the Power Range Neutron Flux High trip setpoint to less than or equal to the RATED THERMAL POWER per Table 3.7-1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

SURVEILLANCE REQUIREMENTS

4. 7 .1.1 Verify each required MSSV lift setpoint per Table 3. 7-4. No additional Surveillance Requirements other than those required by the lnservice Testing Program.

SALEM - UNIT 2 3/4 7-1 Amendment No. 296

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 315 AND 296 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 PSEG NUCLEAR LLC EXELON GENERATION COMPANY. LLC SALEM NUCLEAR GENERATING STATION. UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311

1.0 INTRODUCTION

By letter dated October 12, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15285A014), PSEG Nuclear LLC (the licensee) submitted a request for changes to the Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2, Technical Specifications (TSs). The requested changes would add MODE 4 to the applicability of TS 3.6.2.3, "Containment Cooling System, and correct a discrepancy between the applicable modes and the action statements of TS 3.7.1.1, "Safety Valves."

2.0 REGULATORY EVALUATION

The U.S. Nuclear Regulatory Commission (NRC or the Commission) staff reviewed the proposed TS changes against the regulatory requirements and guidance listed below to ensure that there is reasonable assurance that the systems and components affected by the proposed TS changes will perform their safety functions.

2.1 Regulatory Requirements The NRC staff identified the following regulatory requirements as applicable to the proposed amendment.

2.1 .1 General Design Criteria Salem was designed in accordance with the Atomic Industrial Forum General Design Criteria and the licensee's understanding of the intent of the Atomic Energy Commission (AEC)-proposed General Design Criteria published in 1967. The licensee performed a comparison of the Salem, Unit Nos. 1 and 2, plant design and Title 10 of the Code of Federal Regulations (1 O CFR) Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants" (GDC), dated July 7, 1971. This comparison was documented in the Salem Updated Final Enclosure 3

Safety Analysis Report (UFSAR) Section 3.1.3, which concludes, in part, that, "The Salem Plant design conforms with the intent of the 'General Design Criteria for Nuclear Power Plants,' dated July 7, 1971."

The licensee's understanding of Criteria 52 of the 1967 AEC-proposed GDC is stated below:

Criterion 52 - Containment Heat Removal Systems Where active Heat Removal Systems are needed under accident conditions to prevent exceeding containment design pressure, at least two systems, preferably of different principles, each with full capacity, shall be provided.

Discussion The containment heat removal system consists of two subsystems, containment spray (two trains) and containment fan cooling units (five cooing coils). The two subsystems are separate, are operated independently, and are of different design principles, but perform a similar containment heat removal function. The containment heat removal system provides adequate margin for maintaining an acceptable post-accident containment atmospheric pressure and thereby meets the intent of the above criterion.

In addition, the containment heat removal system meets the requirements of General Design Criteria 38. The design and performance of containment spray and the containment fan cooling units are discussed in sections 6.2.2.1, 6.2.2.2, and 15.4.

The containment heat removal requirements of 10 CFR, Part 50, Appendix A, Criterion 38 are:

A system to remove heat from the reactor containment shall be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.

Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

The proposed changes do not alter conformance with either the 10 CFR 50, Appendix A, GDC, or the Atomic Industrial Forum GDC as listed in the Salem UFSAR Section 3.1.2.

2.1.2 Applicable TS Regulations The Commission's regulatory requirements related to the content of the TSs are set forth in 10 CFR Section 50.36, "Technical specifications." This regulation requires that the TSs include items in the following five specific categories: (1) safety limits, limiting safety system settings,

and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. The regulation does not specify the particular requirements to be included in plant TSs.

As discussed in 10 CFR 50.36(c)(2), LCOs are the lowest functional capability or performance level of equipment required for safe operation of the facility. When LCOs are not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCOs can be met.

The proposed changes correct errors in the current Salem, Unit Nos. 1 and 2, TSs, and do not affect the intent of any TS requirements.

2.2 Regulatorv Guidance The NRC staff identified the following regulatory guidance as being applicable to the proposed amendment.

NUREG-1431, Revision 4.0, "Standard Technical Specifications, Westinghouse Plants," Volume 1, "Specifications," and Volume 2, "Bases" (ADAMS Accession Nos. ML 121 OOA222 and ML 121 OOA228, respectively);

NUREG-0452, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors," Revisions O through 4 (ADAMS Accession No. ML102590431 (Revision 4)); and

NRC Administrative Letter 98-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," dated December 29, 1998 (ADAMS Accession No. ML031110108).

3.0 TECHNICAL EVALUATION

3.1 Background The licensee identified that Salem, Unit Nos. 1 and 2, TS LCO 3.6.2.3, "Containment Cooling System," contained a non-conservatism. Specifically, the licensee identified that the applicability modes did not include MODE 4, Hot Shutdown. The licensee took actions in accordance with NRC Administrative Letter 98-10, including implementing administrative controls to ensure TS 3.6.2.3 was applied in MODE 4; reviewing the other Salem, Unit Nos. 1 and 2, TSs to identify additional discrepancies; and submitting this license amendment request (LAA) to remove the non-conservatism from the applicability statement.

As a result of the licensee's review for other discrepancies, a discrepancy between TS mode applicability and action statements related to shutdown modes in TS 3.7.1 was discovered. This LAA also proposes changes to fix this discrepancy.

3.2 System Descriptions 3.2.1 Containment Heat Removal Systems The Salem UFSAR Section 6.2.2, "Containment Heat Removal Systems," comprehensively describes the containment spray system (CSS) and the containment fan cooling system (CFCS).

What follows is a brief synopsis of the system details relevant to the licensee's proposed change to TS 3.6.2.3.

Adequate post-accident heat removal capability for the containment is provided by two separate Engineered Safety Features. These are the CSS and the CFCS. These systems are of different engineering principles and serve as independent sources of containment cooling to assure that post-accident containment atmospheric temperature and pressure do not rise beyond their design-basis values.

In addition to its ability to remove elemental iodine from the containment atmosphere, the heat removal function of the CSS is similar to that of the containment fan coil units. Salem UFSAR Section 15.4.8, "Containment Pressure Analysis," states that a minimum of three containment fan coil units in operation with a single containment spray train is capable of maintaining post-accident containment temperature and pressure below their design-basis values, assuming a worst-case single active failure. Thus, design margin exists for the containment heat removal system (CHAS).

The CFCS is designed to recirculate and cool the containment atmosphere in the event of a loss-of-coolant accident (LOCA) and thereby ensure that the containment pressure will not exceed its design value. Although the water in the core after a LOCA is quickly subcooled by the safety injection system, the CFCS is designed on the conservative assumption that the core residual heat is released to the containment as steam.

The containment ventilation system, which includes the CFCS, is designed to remove the normal heat loss from equipment and piping in the reactor containment during plant operation and to remove sufficient heat from the reactor containment, following the initial LOCA containment pressure transient, to keep the containment pressure from exceeding the design pressure. The fan cooler units continue to remove heat after the LOCA and reduce the containment pressure close to atmospheric within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The CFCS consists of five air handling units, each including motor, fan, motor heat exchanger, cooling coils, roughing filters, dampers, duct distribution system, instrumentation, and controls.

The units are located on the operating floor between the containment wall and the polar crane wall.

3.2.2 Main Steam System Description The main steam system is described in the Salem UFSAR, Section 10.3, "Main Steam System."

The main steam system for each unit conveys saturated steam from four steam generators to the high pressure (HP) turbine with less than 40 pounds per square inch (psi) pressure drop.

The steam conditions of approximately 3,900,000 pounds per hour, and a density based on 750 pounds per square inch gauge (psig) (nominal) 513 °F steam, were used for the system

design of both units. Reheat is provided, external to the steam generators, between the HP and Low Pressure turbines. For Unit 1, the steam pressure is 814 psig, and the temperature is 522 degrees Fahrenheit (°F) at the steam generator exit nozzle. For Unit 2, the steam pressure is 885 psig, and the temperature is 532 °F at the steam generator exit nozzle.

Steam flow is metered and limited in each line by a dual purpose flow restrictor located inside the containment. Outside the containment, a power operated relief valve (PORV), five safety valves, and a quick acting self-actuating main steam isolation valve are provided in each of the four lines to the mixing bottle. The main steam safety valves, set at 1070, 1100, 1110, 1120, and 1125 psig, respectively, have a total relief capacity of 100 percent of full load flow, while the PO RVs can pass a total of 10 percent of full load flow to atmosphere. Hot reheat stop and intercept valves are provided in each of the six hot reheat lines (as are bypass stop and control valves in each turbine bypass line).

In the unlikely event of a loss of offsite power, decay heat removal would continue to be assured by the availability of one steam-driven and two motor driven auxiliary feed pumps and steam discharge to atmosphere by the power relief valves and/or the steam generator safety valves. In this case, feedwater is available from the auxiliary feedwater storage tank by gravity feed to the auxiliary feed pumps.

3.2.3 NUREG-1431. "Standard Technical Specifications. Westinghouse Plants" NUREG-1431, Revision 4.0, "Standard Technical Specifications (STSs), Westinghouse Plants,"

Volume 1, "Specifications," and Volume 2, "Bases," describe the following related systems.

Containment Systems The containment spray and cooling systems (atmospheric and dual) (with credit taken for iodine removal by the CSS) are described under STSs TS 3.6.6A. The containment spray and cooling systems are applicable in MODES 1, 2, 3, and 4 and are not required to be OPERABLE in MODES 5 and 6. Containment cooling trains are addressed under this TS.

Specifically, the STSs TS 3.6.6A Bases states:

In MODES 1, 2, 3, and 4, a OBA [design-basis accident] could cause a release of radioactive material to containment and an increase in containment pressure and temperature requiring the operation of the containment spray trains and containment cooling trains.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Thus, the Containment Spray System and the Containment Cooling System are not required to be OPERABLE in MODES 5 and 6.

Main Steam Line Code Safety Valves As described under STSs TS 3.7.1, "Main Steam Safety Valves (MSSVs)," the LCO is applicable in MODES 1, 2, and 3, and if a condition is not met, the required action is to be in MODE 3 in

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and be in MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The STSs TS 3.7.1 Bases states:

In MODES 1, 2, and 3, [five] MSSVs per steam generator are required to be OPERABLE to prevent Main Steam System overpressurization.

In MODES 4 and 5, there are no credible transients requiring the MSSVs. The steam generators are not normally used for heat removal in MODES 5 and 6, and thus cannot be overpressurized; there is no requirement for the MSSVs to be OPERABLE in these MODES.

3.3 Proposed TS Changes Current TS LCO 3.6.2.3:

3.6.2.3 Five containment cooling fans shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

Proposed TS LCO 3.6.2.3:

3.6.2.3 Five containment cooling fans shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

Current TS LCO 3.7.1.1:

3.7.1.1 All main steam line code safety valves (MSSVs) associated with each steam generator shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

a. With one or two main steam line code safety valves inoperable in one or more steam generators, operation in Modes 1, 2 and 3 may proceed provided, that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either the inoperable valve is restored to OPERABLE status or reduce power to less than or equal to the applicable percent of RATED THERMAL POWER per Table 3.7-1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With three main steam line code safety valves inoperable in one or more steam generators, operation in Modes 1, 2 and 3 may proceed provided, that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either the inoperable valves are restored to OPERABLE status or reduce power to less than or equal to the applicable percent of RATED THERMAL POWER per Table 3.7-1 and within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , reduce the Power Range Neutron Flux High trip setpoint to less than or equal to the RATED THERMAL POWER

per Table 3.7-1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Proposed TS LCO 3.7.1.1:

3.7.1.1 All main steam line code safety valves (MSSVs) associated with each steam generator shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

a. With one or two main steam line code safety valves inoperable in one or more steam generators, operation in Modes 1, 2 and 3 may proceed provided, that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either the inoperable valve is restored to OPERABLE status or reduce power to less than or equal to the applicable percent of RATED THERMAL POWER per Table 3.7-1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With three main steam line code safety valves inoperable in one or more steam generators, operation in Modes 1, 2 and 3 may proceed provided, that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either the inoperable valves are restored to OPERABLE status or reduce power to less than or equal to the applicable percent of RATED THERMAL POWER per Table 3.7-1 and within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , reduce the Power Range Neutron Flux High trip setpoint to less than or equal to the RATED THERMAL POWER per Table 3.7-1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

3.4 NRC Staff Evaluation 3.4.1 TS 3.6.2.3, "Containment Cooling System" As described in Salem UFSAR Sections 6.2.2 and 15.4, the containment spray and fan cooler systems are capable of removing sufficient energy to maintain the pressure below the containment design pressure, even in the event of a single failure. Each of these systems consists of independent equipment and components supplied from separate power sources. In accordance with the UFSAR, the LOCA and main steam line break accident analyses determined a minimum of three containment fan coil units in operation, along with other containment heat sinks (i.e., with a single containment spray train), are capable of maintaining containment integrity (i.e., post-accident containment temperature and pressure below their design-basis values), assuming a worst-case single active failure.

Salem UFSAR Section 15.4.8.1.4 states, in part, that:

An analysis of the effects of the single failure criteria has been performed on the mass and energy release rates for the double ended pump suction break. An inherent assumption in the generation of mass and energy release is that offsite

power is lost. This results in the actuation of the emergency diesel generators, required to power the safety injection system ....

The loss of an emergency diesel generator results in the loss of one pumped safety injection train (minimizing safety injection flow) and the containment safeguards (one spray pump and two fan coolers will fail to operate) on that diesel ....

The LCO for TS 3.6.2.3 requires five containment cooling fans to be OPERABLE during MODES 1, 2, and 3, to ensure that adequate heat removal capacity is available during LOCA conditions when operated in conjunction with the CSSs. The modes of applicability for Salem, Unit Nos. 1 and 2, TS 3.6.2.3 are inconsistent with the other depressurization and cooling systems LCOs in the Salem TSs. More specifically, both TS LCO 3.6.2.1, "Containment Spray System," and TS LCO 3.6.2.2, "Spray Additive System," have an APPLICABILITY of MODES 1, 2, 3, and 4.

The Salem, Unit Nos. 1 and 2, TSs 3.6.2.3 action statements require restoration of one or two containment cooling fans found to be inoperable within 7 days or be in HOT STANDBY (MODE 3) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN (MODE 5) within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Since TS 3.6.2.3 is currently applicable in MODES 1, 2, and 3, the TS is inconsistent with conventional action statements driving the plant down to the mode below the mode of applicability to place the plant in a mode where the TS is not applicable (i.e., MODE 4 in this case).

The modes (i.e., 1 through 6) for Westinghouse Plants are defined by the parameters of "Reactivity Condition, Kett"; "Thermal Power*"; and "Average Coolant Temperature" in NUREG-1431, Table 1.1-1. The modes and parameters contained in Table 1.1. "Operational Modes" of the Salem, Unit Nos. 1 and 2, TSs are consistent with NUREG-1431.

NUREG-1431 discusses that in MODES 1, 2, 3, and 4, a OBA LOCA could cause a release of radioactive material to containment and an increase in containment pressure and temperature, requiring the operation of the containment cooling trains. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these modes. Therefore, the containment cooling system, including the containment cooling fans, is required to be OPERABLE in MODES 1, 2, 3, and 4 and not required to be OPERABLE in MODES 5 and 6. Salem, Unit Nos. 1 and 2, TS 3.6.2.3 current modes of applicability imply that the LCO requirement of five containment cooling fans OPERABLE does not apply in MODE4.

Salem UFSAR Section 3.1.3 states that the CHRS consists of two subsystems, containment spray and containment fan cooling units, which provide adequate margin for maintaining an acceptable post-accident containment atmospheric pressure. Criterion 38 of 10 CFR Part 50, Appendix A, states that a system to remove heat from the reactor containment shall be provided, which shall rapidly reduce the containment pressure and temperature following any LOCA and maintain them at acceptably low levels. The regulation in 10 CFR 50.36(c)(2)(i) states, "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility."

In MODES 1, 2, 3, and 4, five containment fan coil units are required to be OPERABLE to maintain containment integrity (i.e., post-accident containment temperature and pressure below their design-basis values), assuming a worst-case single active failure. In MODES 5 and 6, there are no credible plant transients requiring the Salem TS 3/4.6.2, "Depressurization and Cooling Systems, to be OPERABLE. Therefore, the staff concludes that the current Salem TS 3.6.2.3 is non-conservative because it allows potential plant operation in MODE 4 with less than the required number of containment cooling fans in an OPERABLE status. Accordingly, the staff finds the proposed change to Salem, Unit Nos. 1 and 2, TS 3.6.2.3 would remove a non-conservatism, and therefore is acceptable.

3.4.2 TS 3.7.1.1. "Turbine Cycle - Safety Valves" The LCO for TS 3.7.1.1 requires all MSSVs associated with each steam generator to be OPERABLE in support of secondary system integrity by limiting pressure to 11 O percent of design value during the most severe anticipated system operational transient while in MODES 1 ,

2, and 3. These applicability modes are consistent with Salem TS 3/4.7.1 Bases and the action statements that specify MODES 1 , 2, and 3.

The TS action statements for TS 3.7.1.1 require restoration of inoperable MSSVs to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or reduction in power less than or equal to the applicable percent of RATED THERMAL POWER per Table 3.7-1, or otherwise be in HOT STANDBY (MODE 3) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN (MODE 5) within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The action statements are inconsistent with the practice of driving the plant down to the mode below the mode of applicability to place the plant in a mode where the TS is not applicable. To be consistent, the TS actions should drive the plant to HOT SHUTDOWN (MODE 4).

The conflict in mode applicability and action statement modes does not impact the ability to comply with the action statement. Once the action is taken to go from HOT STANDBY to COLD SHUTDOWN, the plant is no longer in a mode of applicability and can exit the LCO. The conflict in TS mode applicability and the TS actions has existed since the original issuance of the Salem TSs. The Salem TSs were based on NUREG-0452. A review of NUREG-0452 identified that the conflict in TS mode applicability and TS action existed in the NUREG as well. During the conversion from STSs (NUREG-0452) to the Improved STSs (NUREG-1431 ), the inconsistency in TS 3.7.1 was corrected. The TS actions were revised to stop the mode descension in MODE 4 (HOT SHUTDOWN) instead of MODE 5 (COLD SHUTDOWN).

In MODES 1, 2, and 3, MSSVs for the steam generators are required to be OPERABLE to prevent main steam system overpressurization. In MODES 4 and 5, there are no credible transients requiring the MSSVs. The steam generators are not normally used for heat removal in MODES 5 and 6 and thus cannot be overpressurized. Specifically, there is no requirement at Salem for the MSSVs to be OPERABLE in MODES 4, 5, and 6. Therefore, the staff finds the proposed TS 3.7.1.1 change acceptable The change in completion time from "at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months " to "at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , is also acceptable. The new completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable to reach the required unit conditions, from full power conditions, in an orderly manner and without challenging unit systems. This change is also

consistent with the guidance in NUREG-1431. Therefore, the staff finds the proposed TS

3. 7.1.1 change acceptable.

3.5 NRC Staff Conclusion

Based on the above review, the NRC staff has determined that the proposed changes will remove a non-conservatism from the Salem TSs by adding MODE 4 to the applicability of TS 3.6.2.3 and correct a discrepancy between the applicable modes and the action statements of TS 3.7.1.1. With the change to each unit's TS, TS LCO 3.6.2.3 properly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility in that it requires that five containment cooling fans must be operable during power operation, startup, hot standby, and hot shutdown. Concerning the changes to the actions that must be taken when TS LCO 3.7.1.1 is not met (i.e., when not all MSSVs associated with each steam generator are operable), the remedial action of proceeding to MODE 4, hot shutdown, reasonably assures public health and safety because the MSSVs are not required for safe operation in MODE 4. In addition, the NRC staff finds that the proposed changes to the Salem TSs are consistent with the guidance in NUREG-1431. As such, the NRC staff concludes that the proposed changes to the TSs are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New Jersey State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (81 FR 264; January 5, 2016). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission'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.

Principal Contributors: David Nold Larry Wheeler Date: September 2 9 , 201 6

ML16229A519 *bv memorandum dated OFFICE DORL/LPL 1-2/PM DORL/LPL 1-2/LA DSS/SBPB/BC* DSS/SBPB/BC* DSS/STSB/BC NAME CParker LRonewicz GCasto RDenning AKlein DATE 08/18/16 08/18/16 02/16/16 05/16/16 08/22/16 OFFICE OGC (NLO) DORL/LPL 1-2/BC DORL/LPL 1-2/PM NAME DRoth DBroaddus CParker DATE 09/01/16 09/29/16 09/29/16

v t e Letter Sequence Approval
CAC:MF6987, (Approved, Closed) CAC:MF6988, (Approved, Closed)
Initiation Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2016-09-29 [Table View]

ML16229A519

Text

SUBJECT:

Dear Mr. Sena:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

3.5 NRC Staff Conclusion

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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