LR-N17-0140, Response to Request for Additional Information (Rai), Accident Monitoring Instrumentation Technical Specifications (CACs MF8859 and MF8860)

Response to Request for Additional Information (Rai), Accident Monitoring Instrumentation Technical Specifications (CACs MF8859 and MF8860)

ML17291A766
Person / Time
Site:	Salem
Issue date:	10/18/2017
From:	Mcfeaters C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF8859, CAC MF8860, LR-N17-0140
Download: ML17291A766 (11)

Text

PSEG Nu<:lear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 PSEG OCT 1 *s 2017 NuclearLLC 10 CFR 50. 90 LR-N17-0140 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

Response to Request for Additional Information (RAI), Re: Accident Monitoring Instrumentation Technical Specifications (CACs MF8859 and MF8860)

References:

1. NRC email to PSEG, "Request for Additional Information- Salem Units 1 and 2-Accident Monitoring Instrumentation License Amendment Request (CAC No.

MF8859 & 60)," dated September 11, 2017 (ADAMS Accession No. ML17254A738)

2. PSEG letter to NRC, "License Amendment Request to Amend the Accident Monitoring Instrumentation Technical Specifications," dated November 17, 2016 (ADAMS Accession No. ML16323A279)

In Reference 1, the Nuclear Regulatory Commission (NRC) requested PSEG Nuclear LLC (PSEG) to provide additional information in order to complete the review of the license amendment request (LAR) to revise Technical Specification (TS) requirements regarding accident monitoring instrumentation. Attachment 1 provides a response to the request for additional information.

Revisions to TS markup pages are provided in Attachment 2. The revisions consist of adding the containment isolation valve position indication function to the Salem Unit 1 and Unit 2 TS Tables 3. 3-11 and 4. 3-11.

PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this s ubmittal 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.

Should you have any questions regarding this submittal, please contact Ms. Tanya Timberman at 856-339-1426.

Page 2 LR-N17-0140 I declare under penalty of perjury that the foregoing is true and correct.

Executed on I o 11<6117 (Date)

Charles V. McFeaters Site Vice President Salem Generating Station Attachments:

1. Response to Request for Additional Information

2. Supplemental Information Needed for Review of the License Amendment Request to Amend the Accident Monitoring Instrumentation Technical Specifications cc: Mr. D. Dorman, Administrator, Region I, NRC Mr. R. Ennis, Project Manager, NRC NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Chief, NJBNE Salem Commitment Tracking Coordinator Corporate Commitment Tracking Coordinator

LR-N17-0140 Attachment 1 Response to Request for Additional Information

LR-N17-0140 Request for Additional Information (RAI)

Regarding Proposed License Amendment Accident Monitoring Instrumentation Technical Specifications Salem Nuclear Generating Station, Unit Nos. 1 and 2 Docket Nos. 50-272 and 50-311 By letter dated November 17, 2016, as supplemented by letter dated August 7, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML16323A279 and ML17219A160, respectively), PSEG Nuclear LLC (PSEG, the licensee) submitted a license amendment request (LAR) for Salem Nuclear Generating Station (Salem),

Unit Nos. 1 and 2. The amendments would revise Technical Specification (TS) requirements regarding accident monitoring instrumentation. Specifically, the amendments would modify the list of instruments required to be operable based on implementation of Regulatory Guide 1.97, Revision 2, dated December 1980, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident" (ADAMS Accession No. ML06075052). In addition, allowed outage times (AOTs) and required actions for inoperable accident monitoring instrumentation channels would be revised to be consistent with NUREG-1431, Revision 4, "Standard Technical Specifications- Westinghouse Plants" (ADAMS Accession Nos. ML12100A222 and ML12100A228).

The NRC staff is reviewing your submittal and has determined that additional information is needed to complete its review. The specific information requested is addressed below.

Technical Specifications Branch (STSB}

Reviewer: Margaret Chernoff RAI*STSB-1 On July 22, 1993 (58 FR 39132), the Commission published a "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (Final Policy Statement) which discussed the criteria to determine which items are required to be included in the TSs as Limiting Conditions for Operation (LCOs). The criteria were subsequently incorporated into the regulations by an amendment to 10 CFR 50. 36 (60 FR 36953, July 19, 1995). Specifically, 10 CFR 50. 36(c)(2)(ii) requires that a TS LCO be established for each item meeting one or more of the following criteria:

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

1

LR-N17-0140 Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The Bases for the Standard Technical Specifications (STS)- Westinghouse Plants (NUREG 1431, Volume 2, Revision 4; ADAMS Accession No. ML121 OOA228) provides an explanation of why the instrumentation listed in LCO 3.3.3, Accident Monitoring Instrumentation, satisfies the criteria of 10 CFR 50.36 as follows:

PAM [Post Accident Monitoring] instrumentation that meets the definition of Type A in Regulatory Guide 1.97 satisfies Criterion 3 of 10 CFR 50. 36(c)(2)(ii).

Category I, non-Type A, instrumentation must be retained in TS because it is intended to assist operators in minimizing the consequences of accidents.

Therefore, Category I, non-Type A, variables are important for reducing public risk.

The PAM instrumentation is listed in Table 3.3. 3-1 of the STS. The function of Penetration Flow Path Containment Isolation Valve Position is included in this Table. However, because the specific instruments may vary from plant to plant, the STS contains a note stating that Table 3.3. 3-1 shall be amended for each unit as necessary to list:

1. All Regulatory Guide 1.97, Type A instruments and

2. All Regulatory Guide 1.97, Category I, non-Type A instruments in accordance with the unit's Regulatory Guide 1.97, Safety Evaluation Report.

As discussed in the LAR, all instruments identified as Type A variables, or non-Type A but Category 1, were evaluated by the licensee and are proposed to be added into the Salem, Unit Nos. 1 and 2, TS Tables 3.3-11 and 4.3-11, with the following two exceptions: (1) containment isolation valve position; and (2) containment hydrogen concentration. The LAR indicates that the containment isolation valve position function is a Type B, Category 1 variable. The LAR states that this is not required to ensure adequate information is available to operators to verify containment operability and the accomplishment of containment isolation when required.

NRC approved Topical Report (TR) WCAP-15981-NP-A (ADAMS Accession No. ML103560687) provides technical justification for identifying PAM instrumentation that should be included in the TSs for Westinghouse plants. The TR also provides a methodology that could be used by licensees to reassess the PAM instrumentation that should be included in plant-specific TSs. The TR states that the containment isolation valve position indication function satisfies Criterion 4 of 10 CFR 50. 36(c)(2)(ii) and, accordingly, should be included in TS

3. 3. 3 in NUREG-1431. Section 3.2.12 of the NRC staff's safety evaluation for the TR agrees with the TR report conclusion that this function should be included in the PAM TSs.

2

LR*N17*0140 The STS are a generic set of TSs that satisfy the regulations in 10 CFR 50.36. However, the provisions of the STS may not be applicable to any given facility because of that facility's unique design or licensing basis. Please describe the unique characteristics of Salem that were used to conclude that an exception to the STS are appropriate for the containment isolation valve position indication function. Please also address:

1) How the existing Salem TSs provide assurance that the operators can confirm containment isolation during an accident and during the post-accident monitoring phase?

2) Why the containment isolation valve position indication function is listed as a Type B, Category 1 variable if it is not necessary to ensure adequate information is available to operators to verify containment isolation has occurred?

3) Why the containment isolation valve position indication function doesn't satisfy Criterion 4 of 10 CFR 50.36(c)(2)(ii) with respect to the Salem licensing and design basis.

PSEG Response to RAI*STSB-1 PSEG is responding to this RAI by adding the containment isolation valve position indication function to the Salem Unit 1 and Unit 2 TS Tables 3. 3-11 and 4.3-11. PSEG is adopting the STS actions and the associated notes. An additional note (c) is added to Table 3. 3-11 to modify the Action for having the number of OPERABLE accident monitoring channels less than the minimum number of channels shown in Table 3. 3-11 for penetration flow paths with only one installed control room indication channel consistent with NUREG-1431.

i Revisions to TS markup pages are provided in Attachment 2. T 3

LR*N17-0140 Attachment 2 Supplemental Information Needed for Review of the License Amendment Request to Amend the Accident Monitoring Instrumentation Technical Specifications Revised Mark-up of Proposed Technical Specification Pages The following are revised Technical Specifications pages for Renewed Facility Operating License DPR-70:

Technical Specification Table 3. 3-11, Accident Monitoring Instrumentation 3/4 3-55 Table 4. 3-11, Surveillance Requirements for Accident Monitoring Instrumentation 3/4 3-57a The following are revised Technical Specifications pages for Renewed Facility Operating License DPR-75:

Technical Specification Table 3. 3-11, Accident Monitoring Instrumentation 3/4 3-51a Table 4. 3-11, Surveillance Requirements for Accident Monitoring Instrumentation 3/4 3-52a

TABLE 3.3-11 (CONTINUED)

ACCIDENT MONITORING INSTRUMENTATION REQUIRED MINIMUM NO. OF NO. OF INSTRUMENT CHANNELS CHANNELS ACTION

13. PGR¥ Block Valve Position Indicator 2/valve**

14. P.resS'dFiz-er-Safety-Valve-P-esition 2/valve**

!fld{catoF Deleted

15. 2-

16. Containment Pressure- Wide Ra n 2 7, 2 17, Containment Water Level - 2 7, 2 Wide Range

18. Core Exit T hermocouples 4/core quadrant 2/core quadrant 1' 2

19. Reactor Vessel L evel Instrumentation 2 1 8, 9 System (RVLIS)

20. Containment High Range Accident 2 2 10 Radiation Monitor

21. Main Steamline Discharge (Safety 1/MS Line 1/MS Line 10 Valves and Atmospheric Steam

- Dumps) Monitor

22. Wide Range Neutron Flux Monitors 2 1 1, 2 Auxiliary Feed Water Storage Tank 2 1 1, 2 (Condensate Storage Tank) Water Level

24. Containment Isolation Valve 2 per penetration 1/valve 1, 2 Position Indication flow path (a)(b) (c)

M Total number of channels is oensidered to be hvo (2) with ene (1) of the-e-hannels beh'19 any one (1) of the following alternate means of determining PORV Block, or Safety-¥alve posiHerr. :r...ailpipe-TeFAper..atwres-fsr--tfle-valves,P-ressufizer-ReHe*f-Taf\k.-=FempeFattlre P.resS;trerRelief-Takevei-GPERABb:

(a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with INSERT only one installed control room indication channel.

(c) Action 2 not required for penetration flow paths with only one installed control room indication channel.

SALEM - UNIT 1 3/4 3-55 Amendment No. 310

TABLE 4.3*11 (Continued)

SURVEILLANCE REQU IREMENTS FOR ACCI DENT MONITORING LNSTRUMENTATION CHANNEL CHANNEL CH ANNEL FUNCTIONAL CHECK<1l CALIBRATION<tl INSTRUMENT T E ST< t l

12. Deleted

13. PGRV Sleek Valve PositioA IAdleator

15. Gom..s:tre----Naf

• No-A.

= - .,.

16. Containment Pressure - Wide Ra o eleted N.A.

17. Containment Water Level -Wide Range N.A.

18. Core Exit Thermocouples N.A.

19. Reactor Vessel Level Instrumentation N.A.

System (RVLIS)

20. Containment High Range Accident Radiation Monitor

21. Main Steamline Dischar ge (Safety Valves and Atmospheric Steam Dumps)

Monitor Table Notation (1) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.

22. Wide Range Neutron Flux Monitors N.A.

23. Auxiliary Feed Water Storage Tank

. (Condensate Storage Tank) Water Level N.A

24. Containment Isolation Valve Position Indication N.A.

SALEM - UNIT 1 Amendment No. 310

(a) Not required for isolation valves whose associated penetration is isolated by at !east one closed and deactivated automatic valve, closed manual valve, bHnd flange, or check valve with fiow through the valve secured.

(b) Only one position indication channel is required for penetration fiow paths with only one instaHed control room indication channeL (c) Action 2 not required for penetration flow paths with only one instaUed control room indication channel.

TABLE 3.3-11 (Continued)

ACCIDENT HONITORING INSTRUMENTATION REQUIRED HINIHUH NO. OF NO. OF INSTRUMENT CH..:Z\NNELS CHANNELS ACTION

13. 2/valve** l +/--, 2

14. 2/val*,re++ ;t, +/-r 2

15. 2 +/- +/--, 2

16. Containment Pressure - Wide 2 1 7, 2

17. Containment Water Level - Wide Range 2 1 7, 2

18. Core Exit Thermocouples 4/core quadrant 2/core quadrant 1, 2

19. Reactor Vessel Level Instrumentation 2 1 8, 9 Syst em {RVLIS)

20. Containment High Range Accident 2 2 10 Radiation Monitor

21. Main Steamline 1/ 1/ 10 Discharge (Safety HS Line MS Line Valves and Atmospheric Steam Dumps) Honitor

/ D

\-"<-*-1 Tot-1 nlh'Rber of channel s lS ¥6onsidered to be t;w \-2-) vfi:th one H:-l of the channels being any one H:-l of the f.E:>llO'd'in; alternate means of dete rnnnlnq PGR'J-;' PORV Block, or Safety Valve position: Tailpipe Temperatures for the **al-ves. Pressurizer Relie£ Tank 'Femnerature Pressurizer Relief Tanlc Level OPER'\Bf.E'r.

SALEM - UNIT 2 3/4 3-51a Amendment No. 263

22. Wide Range Neutron Flux Monitors 2 1 1, 2

23. Auxiliary Feed Water Storage Tank 2 1 1, 2 (Condensate Storage Tank) Water level l..---- 124. Containment !solation Valve 2 per penetration 1/va!ve 1, 2 Position Indication flow path (a)(b) (c)

TABLE 4.3-11 (Continued)

SURVEILLANCE REQUIREMENTS FOR ACCIDENT MONITORING INSTRUMENTATION

£ CHANNEL CHANNEL CHANNEL FUNCTIONAL INSTRUME Deleted j CHECKS(1) CALIBRATION(1) TEST(1) 1 2.-P-GFW-FL ili -ffiffi&atGr Deleted I N-;A;

13. flGR.fletcaffif N-;A;  !

A;

15. Containment Pressure Narrow Range N:A r=--:--:---:-...

NA

17. Containment Water Level -Wide Range N.A.

18. Core Exit Thermocouples NA. .

19. Reactor Vessel Level Instrumentation NA. .

System (RVLI S )

20. Containment High Range Accident Radiation monitor

21. Main Steamline Discharge (Safety Valves and Atmospheric Steam Dumps) Monitor

--?> Table Notation (1) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.

Wide Range Neutron Flux Monitors N.A.

Auxiliary Feed Water Storage Tank (Condensate Storage Tank) Water Level N.A.

Containment Isolation Valve Position Indication N.A.

SALEM- UNIT 2 3/4 3-52a Amendment No. 282