ML19275D694

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Issuance of Amendment Nos. 330 and 311 Revise Technical Specifications to Adopt TSFT-547, Clarification of Rod Position Requirements
ML19275D694
Person / Time
Site: Salem  PSEG icon.png
Issue date: 11/18/2019
From: James Kim
Plant Licensing Branch 1
To: Carr E
Public Service Enterprise Group
Kim J
References
EPID L 2019 LLA 0018, TSTF-547
Download: ML19275D694 (46)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 18, 2019 Mr. Eric Carr 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 - ISSUANCE OF AMENDMENT NOS. 330 AND 311 RE: REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-547, "CLARIFICATION OF ROD POSITION REQUIREMENTS" (EPID L-2019-LLA-0018)

Dear Mr. Carr:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 330 and 311 to Renewed Facility Operating License Nos. DPR-70 and DPR-75 for the Salem Nuclear Generating Station, Unit Nos. 1 and 2 (Salem), respectively.

These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated February 4, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19035A620), as supplemented by letter dated June 11, 2019 (ADAMS Accession No. ML19162A122).

The amendments revise the Salem Technical Specification requirements on control and shutdown rods and rod and bank position indication, consistent with NRG-approved Technical Specifications Task Force (TSTF) Traveler TSTF-547, Revision 1, "Clarification of Rod Position Requirements," dated March 4, 2016.

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

Docket Nos. 50-272 and 50-311

Enclosures:

1. Amendment No. 330 to DPR-70
2. Amendment No. 311 to DPR-75
3. Safety Evaluation cc: Listserv

+;,

James S. Kim, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

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 I

AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 330 Renewed License No. DPR-70

1.

The U.S. 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 licensees), dated February 4, 2019, as supplemented by letter dated June 11, 2019, 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 10 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; 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:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 330, 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 of the date of issuance.

Attachment:

Changes to Renewed Facility Operating License and Technical Specifications Date of Issuance: November 1 8, 2 O 1 9 FOR THE NUCLEAR REGULATORY COMMISSION Jj~~

Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT NO. 330 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 3

Insert 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 3/4 1-18 3/4 1-18a 3/4 1-19 3/4 1-19a 3/4 1-20 3/4 1-22 3/4 1-23 Insert 3/41-18 3/4 1-18a 3/4 1-19 3/4 1-19a 3/4 1-20 3/4 1-22 3/4 1-23 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 1 O 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. 330, 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. 330

REACTIVITY CONTROL SYSTEMS 3/4.1.3 MOVABLE CONTROL ASSEMBLIES GROUP HEIGHT LIMITING CONDITION FOR OPERATION 3.1.3.1 All full length (shutdown and control) rods, shall be OPERABLE and positioned within+/- 18 steps (indicated position) when reactor power is s 85%, RATED THERMAL POWER, or+/- 12 steps (indicated position) when reactor power is> 85% RATED THERMAL POWER, of their group step counter demand position within one hour after rod motion.

APPLICABILITY: MODES 1* and 2*

ACTION:

a.

With one or more full length rods inoperable due to being immovable as a result of excessive friction or mechanical interference or known to be untrippable, determine that the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With more than one full length rod inoperable or mis-aligned from the group step counter demand position by more than+/- 18 steps(indicated position) at s 85 % RATED THERMAL POWER or+/- 12 steps (indicated position) at> 85% RATED THERMAL POWER, be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c.

With one full length rod inoperable due to causes other than addressed by ACTION a, above, or mis-aligned from its group step counter demand position by more than+/- 18 steps (indicated position) at s 85 % RATED THERMAL POWER or+/- 12 steps (indicated position) at> 85% RATED THERMAL POWER, POWER OPERATION may continue provided that within one hour either:

1.

Deleted

2.

The remainder of the rods in the bank with the inoperable rod are aligned to within+/- 18 steps(indicated position) at s 85 % RATED THERMAL POWER or+/- 12 steps (indicated position) at> 85% RATED THERMAL POWER of the inoperable rod while maintaining the rod sequence and insertion limits in the COLR per specification 3.1.3.5. The THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.5 during subsequent operation, or

3.

The rod is declared inoperable and the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:

See Special Test Exceptions 3.10.2 and 3.10.3.

SALEM - UNIT 1 3/4 1-18 Amendment No. 330

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION (Continued}

a)

A reevaluation of each accident analysis of table 3.1-1 is performed within 5 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions.

b)

The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

c)

A core power distribution measurement is obtained and Fa(Z) and FNaH are verified to be within their limits within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

d)

The THERMAL POWER level is reduced to less than or equal to 75% of RA TED THERMAL POWER within one hour and within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> the high neutron flux trip setpoint is reduced to less than or equal to 85%

of RATED THERMAL POWER THERMAL POWER shall be maintained less than or equal to 75% of RATED THERMAL POWER until compliance with ACTIONS 3.1.3.1.c.3.a and 3.1.3.1.c.3.c above are demonstrated.

SURVEILLANCE REQUIREMENTS 4.1.3.1.1 The position of each full length rod* shall be determined to be within the limits established in the limiting condition for operation in accordance with the Surveillance Frequency Control Program (allowing for one hour thermal soak after rod motion) except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

4.1.3.1.2 Each full length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 10 steps in any one direction in accordance with the Surveillance Frequency Control Program.

Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.

SALEM - UNIT 1 3/4 1-18a Amendment No. 330

REACTIVITY CONTROL SYSTEMS POSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITION FOR OPERATION 3.1.3.2.1 The shutdown and control rod position indication (RPI) systems shall be OPERABLE and capable of determining the actual and demanded rod positions as follows:

a. Analog rod position indicators; All Shutdown Banks: +/- 18 steps at s 85% reactor power or if reactor power is > 85%

RA TED THERMAL POWER +/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 200-230 steps.

Control Bank A: +/- 18 steps at s 85% reactor power or if reactor power is > 85%

RA TED THERMAL POWER +/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 200-230 steps.

Control Bank B: +/- 18 steps at s 85% reactor power or if reactor power is > 85%

RA TED THERMAL POWER +/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 160-230 steps.

Control Bank C and D: +/- 18 steps at s 85% reactor power or if reactor power is

> 85% RA TED THERMAL POWER +/- 12 steps of the group demand counters for withdrawal ranges of 0-230 steps.


Note--------------------------------------------*------------------

Individual RPls are not required to be OPERABLE for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following movement of the associated rods.

b. Group demand counters; +/- 2 steps of the pulsed output of the Slave Cycler Circuit over the withdrawal range of 0-230 steps.

APPLICABILITY:

MODES 1 and 2.

ACTION:

a. With a maximum of one analog rod position indicator per group inoperable either:
1. Determine the position of the non-indicating rod(s) indirectly using the power distribution monitoring system (if power is above 25% RTP} or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or
2. Verify the position of the non-indicating rod(s) indirectly using the power distribution monitoring system (if power is above 25% RTP} or using the movable incore detectors (if power is less than 25% or the power distribution monitoring system is inoperable) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and once per 31 EFPD thereafter, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after discovery of each unintended rod movement, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after each movement of the non-indicating rod( s) greater than 12 steps, and prior to THERMAL POWER exceeding 50% RTP, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after reaching RTP, or SALEM - UNIT 1 3/4 1-19 Amendment No. 330

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION (Continued}

3. Reduce THERMAL POWER to less than 50% of RA TED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
b. With two or more analog rod position indicators per group inoperable:
1. Immediately place the control rods in manual control, and
2. Deleted
3. Verify the position of the rods with inoperable position indicators indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and
4. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the inoperable rod position indicators to OPERABLE status such that a maximum of one rod position indicator per group is inoperable, or
5. Be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
c. When one or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction since the last determination of the rod's position:
1. Determine the position of the non-indicating rod(s) indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or
2. Reduce THERMAL POWER to less than 50% of RA TED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
d. With a maximum of one group demand position indicator per bank inoperable either:
1. Verify that all analog rod position indicators for the affected bank are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the bank are within a maximum of 18 steps when reactor power is :s; 85% RA TED THERMAL POWER or if reactor power is> 85% RATED THERMAL POWER, 12 steps of each other at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or
2. Reduce THERMAL POWER to less than 50% of RA TED POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

SALEM - UNIT 1 3/4 1-19a Amendment No. 330

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS 4.1.3.2.1.1 Each analog rod position indicator* shall be determined to be OPERABLE by verifying that the demand position indication system and the rod position indication system agree within 18 steps when reactor power is s 85% RA TED THERMAL POWER or if reactor power is> 85% RATED THERMAL POWER, 12 steps (allowing for one hour thermal soak after rod motion) in accordance with the Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the demand position indication system and the rod position indication system at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

4.1.3.2.1.2 Each of the above required rod position indicator(s) shall be determined to be OPERABLE by performance of a CHANNEL CALIBRATION in accordance with the Surveillance Frequency Control Program.

  • Not required to be met for RP/s associated with rods that do not meet LCO 3. 1. 3. 1 SALEM - UNIT 1 3/4 1-20 Amendment No. 330

REACTIVITY CONTROL SYSTEMS SHUTDOWN ROD INSERTION LIMIT LIMITING CONDITION FOR OPERATION 3.1.3.4 All shutdown rods shall be FULLY WITHDRAWN.

, -----------------------------------------------Note---------------------------------------------

Not applicable to shutdown banks inserted while performing SR 4.1.3.1.2 APPLICABILITY: MODES 1 *, and 2*#@

ACTION:

1.

With one shutdown bank inserted s 10 steps beyond FULLY WITHDRAWN; within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> verify all control banks are within the insertion limits specified in the COLR and determine the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied; and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the shutdown bank to FULLY WITHDRAWN or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2.

With a maximum of one shutdown rod not FULLY WITHDRAWN, for reasons other than Action 1, within one hour either:

a.

FULLY WITHDRAW the rod, or,

b.

Declare the rod to be inoperable and apply Specification 3.1.3.1.

SURVEILLANCE REQUIREMENTS 4.1.3.4 Each shutdown rod shall be determined to be FULLY WITHDRAWN by use of the group demand counters, and verified by the analog rod position indicators**:

a.

Within 15 minutes prior to withdrawal of any rods in control banks A, B, C, or D during an approach to reactor criticality, and

b.

In accordance with the Surveillance Frequency Control Program thereafter.

See Special Test Exceptions 3.10.2 and 3.10.3 Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion.

With Keff greater than or equal to 1.0 Surveillance 4.1.3.4.a is applicable prior to withdrawing control banks in preparation for startup (Mode 2).

SALEM - UNIT 1 3/4 1-22 Amendment No. 330

REACTIVITY CONTROL SYSTEMS CONTROL ROD INSERTION LIMITS LIMITING CONDITION FOR OPERATION 3.1.3.5 The control banks shall be limited in physical insertion as specified in the CORE OPERATING LIMITS REPORT (COLR).


Note-------------------------------------------

Not applicable to control banks inserted while performing SR 4.1.3.1.2 APPLICABILITY: MODES 1*, and 2*#

ACTION:

1.

With control bank A, 8, or C inserted ~ 10 steps beyond the insertion limits specified in the COLR; within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> verify all shutdown banks are FULLY WITHDRAWN and determine the SHUTDOWN MARGIN requirement of 3.1.1.1 is satisfied; and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the control bank to within the insertion limits specified in the COLR or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2.

With the control banks inserted beyond the above insertion limits, for reasons other than Action 1, either:

a.

Restore the control banks to within the limits within two hours, or

b.

Reduce THERMAL POWER within two hours to less than or equal to that fraction of RATED THERMAL POWER which is allowed by the bank position using the insertion limits specified in the COLR, or

c.

Be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS


Note-------------------------------------------

Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion.

4.1.3.5 The position of each control bank shall be determined to be within the insertion limits in accordance with the Surveillance Frequency Control Program by use of the group demand counters and verified by the analog rod position indicators except during time intervals when the Rod Insertion Limit Monitor is inoperable, then verify the individual rod positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

See Special Test Exceptions 3.10.2 and 3.10.3 With Keff greater than or equal to 1.0 SALEM - UNIT 1 3/4 1-23 Amendment No. 330

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. 311 Renewed License No. DPR-75

1.

The U.S. 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 licensees), dated February 4, 2019, as supplemented by letter dated June 11, 2019, 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 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; 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:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 311, 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 of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION 3e~~:;---

Attachment:

Changes to Renewed Facility Operating License and Technical Specifications Date of Issuance: November 1 8, 2 O 1 9 Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATIACHMENT TO LICENSE AMENDMENT NO. 311 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 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 contains marginal lines indicating the areas of change.

Remove 3/4 1-13 3/4 1-14 3/4 1-16 3/4 1-16a 3/4 1-17 3/4 1-19 3/4 1-20 Insert 3/4 1-13 3/4 1-14 3/4 1-16 3/4 1-16a 3/4 1-17 3/4 1-19 3/4 1-20 (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 1 O 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. 311, 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. 311

REACTIVITY CONTROL SYSTEMS 3/4.1.3 MOVABLE CONTROL ASSEMBLIES GROUP HEIGHT LIMITING CONDITION FOR OPERATION 3.1.3.1 All full length (shutdown and control) rods, shall be OPERABLE and positioned within+/- 18 steps (indicated position) when reactor power is s 85% RATED THERMAL POWER, or+/- 12 steps (indicated position) when reactor power is> 85% RATED THERMAL POWER, of their group step counter demand position within one hour after rod motion.

APPLICABILITY: MODES 1* and 2*

ACTION:

a.

With one or more full length rods inoperable due to being immovable as a result of excessive friction or mechanical interference or known to be untrippable, determine that the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With more than one full length rod inoperable or mis-aligned from the group step counter demand position by more than +/- 18 steps (indicated position) at s 85%

RATED THERMAL POWER or+/- 12 steps (indicated position) at> 85% RATED THERMAL POWER, be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c.

With one full length rod inoperable due to causes other than addressed by ACTION a, above, or mis-aligned from its group step counter demand position by more than+/- 18 steps (indicated position) at s 85% RATED THERMAL POWER or+/- 12 steps (indicated position) at> 85% RATED THERMAL POWER, POWER OPERATION may continue provided that within one hour either:

1.

Deleted

2.

The remainder of the rods in the bank with the inoperable rod are aligned to within+/- 18 steps (indicated position) at s 85% RATED THERMAL POWER or+/- 12 steps (indicated position) at> 85% RATED THERMAL POWER, of the inoperable rod while maintaining the rod sequence and insertion limits in the COLR per Specification 3.1.3.5. The THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.5 during subsequent operation, or

3.

The rod is declared inoperable and the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:

See Special Test Exceptions 3.10.2 and 3.10.3.

SALEM - UNIT 2 3/4 1-13 Amendment No. 311

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION <Continued}

a)

A reevaluation of each accident analysis of Table 3.1-1 is performed within 5 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions.

b)

The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

c)

A core power distribution measurement is obtained and Fa(Z) and FNaH are verified to be within their limits within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

d)

The THERMAL POWER level is reduced to less than or equal to 75% of RATED THERMAL POWER within one hour and within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> the high neutron flux trip setpoint is reduced to less than or equal to 85% of RA TED THERMAL POWER THERMAL POWER shall be maintained less than or equal to 75% of RA TED THERMAL POWER until compliance with ACTIONS 3.1.3.1.c.3.a and 3.1.3.1.c.3.c above are demonstrated.

SURVEILLANCE REQUIREMENTS 4.1.3.1.1 The position of each full length rod* shall be determined to be within the limits established in the limiting condition for operation in accordance with the Surveillance Frequency Control Program (allowing for one hour thermal soak after rod motion) except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

4.1.3.1.2 Each full length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 10 steps in any one direction in accordance with the Surveillance Frequency Control Program.

Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.

SALEM - UNIT 2 3/4 1-14 Amendment No. 311

REACTIVITY CONTROL SYSTEMS POSITION INDICATION SYSTEMS-OPERATING LIMITING CONDITION FOR OPERATION 3.1.3.2.1 The shutdown and control rod position indication (RPI) systems shall be OPERABLE and capable of determining the actual and demanded rod positions as follows:

a. Analog rod position indicators; All Shutdown Banks: +/- 18 steps at s 85% reactor power or if reactor power is > 85%

RATED THERMAL POWER+/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 200-230 steps.

Control Bank A: +/- 18 steps at s 85% reactor power or if reactor power is > 85% RATED THERMAL POWER +/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 200-230 steps.

Control Bank B: +/- 18 steps at s 85% reactor power or if reactor power is > 85% RATED THERMAL POWER +/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 160-230 steps.

Control Banks C and D: +/- 18 steps at s 85% reactor power or if reactor power is > 85%

RATED THERMAL POWER +/- 12 steps of the group demand counters for withdrawal range of 0-230 steps.


Note---------------------------------------------------------------

lndividual RP/s are not required to be OPERABLE for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following movement of the associated rods.

b. Group demand counters; +/- 2 steps of the pulsed output of the Slave Cycler Circuit over the withdrawal range of 0-230 steps.

APPLICABILITY:

MODES 1 and 2.

ACTION:

a. With a maximum of one analog rod position indicator per group inoperable either:
1. Determine the position of the non-indicating rod(s) indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or
2. Verify the position of the non-indicating rod(s) indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% or the power distribution monitoring system is inoperable) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and once per 31 EFPD thereafter, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after discovery of each unintended rod movement, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after each movement of the non-indicating rod(s) greater than 12 steps, and prior to THERMAL POWER exceeding 50% RTP, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after reaching RTP, or SALEM - UNIT 2 3/4 1-16 Amendment No. 311

REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION <Continued}

3. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
b. With two or more analog rod position indicators per group inoperable:
1. Immediately place the control rods in manual control, and
2. Deleted
3. Verify the position of the rods with inoperable position indicators indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and
4. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the inoperable rod position indicators to OPERABLE status such that a maximum of one rod position indicator per group is inoperable, or
5. Be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
c. When one or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction since the last determination of the rod's position:
1. Determine the position of the non-indicating rod(s) indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or
2. Reduce THERMAL POWER to less than 50% of RA TED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
d. With a maximum of one group demand position indicator per bank inoperable either:
1. Verify that all analog rod position indicators for the affected bank are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the bank are within a maximum of 18 steps when reactor power is s 85% RA TED THERMAL POWER or if reactor power is > 85% RA TED THERMAL POWER, 12 steps of each other at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or
2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

SALEM - UNIT 2 3/4 1-16a Amendment No. 311

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS 4.1.3.2.1.1 Each analog rod position indicator* shall be determined to be OPERABLE by verifying that the demand position indication system and the rod position indication system agree within 18 steps when reactor power is :S 85% RA TED THERMAL POWER or if reactor power is> 85% RATED THERMAL POWER, 12 steps (allowing for one hour thermal soak after rod motion) in accordance with the Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the demand position indication system and the rod position indication system at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

4.1.3.2.1.2 Each of the above required rod position indicator(s) shall be determined to be OPERABLE by performance of a CHANNEL CALIBRATION in accordance with the Surveillance Frequency Control Program.

  • Not required to be met for RP/s associated with rods that do not meet LCO 3.1.3.1 SALEM - UNIT 2 3/4 1-17 Amendment No. 311

REACTIVITY CONTROL SYSTEMS SHUTDOWN ROD INSERTION LIMIT LIMITING CONDITION FOR OPERATION 3.1.3.4 All shutdown rods shall be FULLY WITHDRAWN.


Note---------------------------------------------

Not applicable to shutdown banks inserted while performing SR 4.1.3.1.2 APPLICABILITY: MODES 1 *, and 2*#@.

ACTION:

1.

With one shutdown bank inserted s 10 steps beyond FULLY WITHDRAWN; within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> verify all control banks are within the insertion limits specified in the COLR and determine the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied; and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the shutdown bank to FULLY WITHDRAWN or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2.

With a maximum of one shutdown rod not FULLY WITHDRAWN, for reasons other than Action 1, within one hour either:

a.

FULLY WITHDRAW the rod, or,

b.

Declare the rod to be inoperable and apply Specification 3.1.3.1.

SURVEILLANCE REQUIREMENTS 4.1.3.4 Each shutdown rod shall be determined to be FULLY WITHDRAWN by use of the group demand counters, and verified by the analog rod position indicators**:

a.

Within 15 minutes prior to withdrawal of any rods in control banks A, B, C, and D during an approach to reactor critically, and

b.

In accordance with the Surveillance Frequency Control Program thereafter.

See Special Test Exceptions 3.10.2 and 3.10.3.

Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after rod motion.

Surveillance 4.1.3.4.a is applicable prior to withdrawing any control banks in preparation for startup (Mode 2).

With Keff greater than or equal to 1.0.

Note: This page effective prior to startup from fifth refueling outage scheduled to begin March 1990. Letter dated Jan. 11, 1990.

SALEM - UNIT 2 3/4 1-19 Amendment No. 311

REACTIVITY CONTROL SYSTEMS CONTROL ROD INSERTION LIMIT LIMITING CONDITION FOR OPERATION 3.1.3.5 The control banks shall be limited in physical insertion as specified in the CORE OPERATING LIMITS REPORT (COLR).


Note-------------------------------------------

Not applicable to control banks inserted while performing SR 4.1.3.1.2 APPLICABILITY: MODES 1*, and 2*#

ACTION:

1.

With control bank A, B, or C inserted :s; 10 steps beyond the insertion limits specified in the COLR; within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> verify all shutdown banks are FULLY WITHDRAWN and determine the SHUTDOWN MARGIN requirement of 3.1.1.1 is satisfied; and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the control bank to within the insertion limits specified in the COLR or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2.

With the control banks inserted beyond the above insertion limits, for reasons other than Action 1, either:

a.

Restore the control banks to within the limits within two hours, or

b.

Reduce THERMAL POWER within two hours to less than or equal to that fraction of RATED THERMAL POWER which is allowed by the bank position using the insertion limits specified in the CLOR, or

c.

Be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS


Note-------------------------------------------

Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion.

4.1.3.5 The position of each control bank shall be determined to be within the insertion limits in accordance with the Surveillance Frequency Control Program by use of the group demand counters and verified by the analog rod position indicators except during time intervals when the Rod Insertion Limit Monitor is inoperable, then verify the individual rod positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

See Special Test Exceptions 3.10.2 and 3.10.3 With Keff greater than or equal to 1.0 SALEM - UNIT 2 3/4 1-20 Amendment No. 311

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 330 AND 311 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 February 4, 2019 (Agencywide Documents Access and Management System Accession No. ML19035A620), as supplemented by letter dated June 11, 2019 (ADAMS Accession No. ML19162A122), PSEG Nuclear LLC (the licensee) submitted a license amendment request for the Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. The proposed amendments request changes consistent with NRG-approved Technical Specifications Task Force (TSTF} Change Traveler TSTF-547, Revision 1, "Clarification of Rod Position Requirements." By letter dated December 31, 2015 (ADAMS Accession No. ML15365A610), the TSTF submitted to the NRC, Revision 1 to Change Traveler TSTF-547.

Change Traveler TSTF-547 proposes changes to Volumes 1 and 2 of NUREG-1431, Revision 4, "Standard Technical Specifications, Westinghouse Plants" (STS), dated April 30, 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively). TSTF-547, Revision 1, was approved by the NRC staff by letters dated March 4, 2016 (ADAMS Accession Nos. ML16012A130 and ML15328A350).

The supplement dated June 11, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on March 26, 2019 (84 FR 11339).

2.0

2.1 REGULATORY EVALUATION

Description of Rod Cluster Control Assemblies The rod cluster control assemblies (RCCA), or rods, are moved by their control rod drive mechanisms. There are 53 RCCAs in each unit, designated by function as the control groups and shutdown groups. The terms "group" and "bank" are used synonymously throughout this evaluation to describe a particular grouping of RCCAs. For shutdown bank SA and SB, each bank contains eight RCCAs. Each shutdown bank SC and SD contains four RCCAs. For control bank A and C, each contains eight RCCAs. Control banks B and D contain four and nine RCCAs, respectively.

The shutdown banks are maintained either in the fully inserted or fully withdrawn position. The control banks are driven by the same variable speed rod drive control unit which moves the subgroups sequentially one step at a time. The sequence of motion is reversible, that is, a withdrawal sequence is the reverse of the insertion sequence. The variable speed sequential rod control affords the ability to insert a small amount of reactivity at low speed to accomplish fine control of Tavg within the range of a small temperature deadband. The operator is able to select either automatic or manual control. In either case, significant motion of the control banks can only be accomplished in their normal sequence of motion, but with some overlap as one bank approaches its fully withdrawn position and the next bank begins to withdraw.

The overlap between successive control banks is provided to compensate for low differential rod worth near the top and bottom of the core. The control group rod insertion limits ensure that the control rods are withdrawn far enough to provide the necessary shutdown margin (SOM) to achieve hot shutdown following a reactor trip at any time, assuming that the highest worth control rod remains fully withdrawn.

The terms "Shutdown Rod Position Indicator," "Analog Rod Position Indicator," "Control Rod Position Indicator," and "Rod Position Indicator" are all used in the technical specifications (TSs), and all refer to indications driven by the output of the Analog Rod Position Indication (ARPI) system.

One method for determining rod position is by using the indicators on the control console. An alternate method of determining rod position is the plant computer. Use of either the control console indicator or plant computer is sufficient to comply with the TS. The plant computer receives the same input from the ARPI as the control console indicators and provides a resolution equivalent to or better than the control console indicators.

As required by the Salem TS 3.3.3.14, the Power Distribution Monitoring System (PDMS) shall be operable; the control bank position is one of the inputs required for the PDMS to be operable.

The licensee submitted and obtained the NRC's approval of TS Amendment Nos. 237 and 218 for Salem, Unit Nos. 1 and 2, respectively, which allow the licensee to use the PDMS as an alternative to the movable incore detectors for indirectly verifying the control bank position.

The SOM is defined in the TS for Salem, Unit Nos. 1 and 2, as the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full length RCCAs (shutdown and control) are fully inserted except for the single RCCA of highest reactivity worth which is assumed to be fully withdrawn.

The Core Operating Limits Report (COLR) is defined in the TS for Salem, Unit Nos. 1 and 2, as the unit specific document that provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits must be determined for each reload cycle in accordance with TS 6.9.1.9. Plant operation within these limits is addressed in individual Specifications.

2.2 Description of Changes Prior to submitting the license amendment request to adopt the Technical Specifications Task Force {TSTF) Traveler TSTF-547, the licensee reviewed the safety evaluation (SE) for TSTF-547 provided to the traveler in letters dated March 4, 2016 (ADAMS Accession Nos. ML16012A130 and ML15328A350). The licensee concluded that the justifications presented in the TSTF-547 proposal and the SE prepared by the NRC staff were applicable to Salem, Unit Nos. 1 and 2, and justified its amendment for the incorporation of the changes to the Salem TSs.

Salem. Unit Nos. 1 and 2, utilize a different TS format than the Improved Standard Technical Specifications (STS) in NUREG-1431, Revision 4 (ADAMS Accession No. ML12100A222) on which TSTF-547 was based.

The following table provides a comparison of the Salem, Unit Nos. 1 and 2, TSs to the TSTF-547 changes to NUREG-1431:

TSTF-547 Change to NUREG-1431 (STS)

Equivalent Salem, Unit Nos. 1 and 2, TSs 3.1.4 Required Action B.1 3.1.3.1 Action c. 1 3.1.4 Required Actions B.2.4 and B.2.5 3.1.3.1 Action c.3.c SR 3.1.4.1 SR 4.1.3.1.1 SR 3.1.4.2 SR 4.1.3.1.2 3.1.5 Actions 3.1.3.4 Actions SR 3.1.5.1 SR 4.1.3.4 3.1.6 Actions 3.1.3.5 Actions SR 3.1.6.2 SR4.1.3.5 SR 3.1.6.3 Not in Salem TS 3.1. 7 Condition A 3.1.3.2.1 Action a 3.1. 7 Condition B 3.1.3.2.1 Action b 3.1. 7 Condition C 3.1.3.2.1 Action c 3.1. 7 Condition D 3.1.3.2.1 Action d SR 3.1.7.1 SR 4.1.3.2.1.1 LCO 3.1.4 LCO 3.1.3.1 LCO 3.1.5 LCO 3.1.3.4 LCO 3.1.6 LCO 3.1.3.5 LCO 3.1.7 LCO 3.1.3.2.1 The NRC staff reviewed the licensee's proposed TS changes to assure that the changes are consistent with and equivalent to the changes proposed in TSTF-547. The specific changes are described in the following subsections.

2.2.1 Provide Time to Correct Rod Movement Failures that Do Not Affect Operability Below is the current Salem TS and proposed TS changes equivalent to the STS and associated TSTF-547 changes. The TSTF-547 proposed changes to the STS for this subsection can be found in the TSTF-547, Revision 1 (ADAMS Accession No. ML15365A610), Section 2.1.

Current Salem TS 3.1.3.4 (corresponding to STS 3.1.5):

ACTION:

With a maximum of one shutdown rod not FULLY WITHDRAWN, except for surveillance testing pursuant to Specification 4.1.3.1.2, within one hour either:

a.

FULLY WITHDRAW the rod, or,

b.

Declare the rod to be inoperable and apply Specification 3.1.3.1.

Proposed Salem TS 3.1.3.4 after change:

ACTION:

1.

With one shutdown bank inserted s 10 steps from FULLY WITHDRAWN; within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> verify all control banks are within the insertion limits specified in the COLR and determine the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied; and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the shutdown bank to FULLY WITHDRAWN or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2.

With a maximum of one shutdown rod not FULLY WITHDRAWN, for reasons other than Action 1, within one hour either:

a.

FULLY WITHDRAW the rod, or,

b.

Declare the rod to be inoperable and apply Specification 3.1.3.1.

Current Salem TS 3.1.3.5 (corresponding to STS 3.1.6):

ACTION:

With the control banks inserted beyond the above insertion limits, except for surveillance testing pursuant to Specification 4.1.3.1.2, either:

a.

Restore the control banks to within the limits within two hours, or

b.

Reduce THERMAL POWER within two hours to less than or equal to that fraction of RATED THERMAL POWER which is allowed by the bank position using the insertion limits specified in the COLR, or

c.

Be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Proposed Salem TS 3.1.3.5 after change:

ACTION:

1.

With control bank A, B, or C inserted s 10 steps beyond the insertion limits specified in the COLR; within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> verify all shutdown banks are FULLY WITHDRAWN and determine the SHUTDOWN MARGIN requirement of 3.1.1.1 is satisfied; and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the control bank to within the insertion limits specified in the COLR or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2.

With the control banks inserted beyond the above insertion limits, for reasons other than Action 1, either:

a.

Restore the control banks to within the limits within two hours, or

b.

Reduce THERMAL POWER within two hours to less than or equal to that fraction of RA TED THERMAL POWER which is allowed by the bank position using the insertion limits specified in the COLR, or

c.

Be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2.2.2 Provide an Alternative to Frequent Verification of Rod Position Using the Power Distribution Monitoring System or the Movable lncore Detectors Below is the current Salem TS and proposed TS changes equivalent to the STS and associated TSTF-547 changes. The TSTF-547 proposed changes to the STS can be found in the TSTF-547 Revision 1, Subsections 2.2 and 2.5 of Section 2.

Current Salem TS Action for Limiting Condition for Operation (LCO) 3.1.3.2.1 (corresponding to STS LCO 3.1. 7):

ACTION:

a.

With a maximum of one analog rod position indicator per group inoperable either:

1.

Determine the position of the non-indicating rod(s) indirectly using the power distribution monitoring system (if power is above 25%

RTP) or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or

2.

Reduce THERMAL POWER to less than 50% of RA TED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

b.

With two or more analog rod position indicators per group inoperable:

1.

Immediately place the control rods in manual control, and

2.

Monitor and record Reactor Coolant System Tavg once every hour, and

3.

Verify the position of the rods with inoperable position indicators indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and

4.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the inoperable rod position indicators to OPERABLE status such that a maximum of one rod position indicator per group is inoperable, or

5.

Be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Proposed Salem TS Action for LCO 3.1.3.2.1 after change:

ACTION:

a.

With a maximum of one analog rod position indicator per group inoperable either:

1.

Determine the position of the non-indicating rod(s) indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or

2.

Verify the position of the non-indicating rod{s) indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% or the power distribution monitoring system is inoperable) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and once per 31 EFPD thereafter, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after discovery of each unintended rod movement, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after each movement of the non-indicating rod( s) greater than 12 steps, and prior to THERMAL POWER exceeding 50% RTP, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after reaching RTP, or

3.

Reduce THERMAL POWER to less than 50% of RA TED THERMAL POWER within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

b.

With two or more analog rod position indicators per group inoperable:

1.

Immediately place the control rods in manual control, and

2.

(Deleted)

3.

Verify the position of the rods with inoperable position indicators indirectly using the power distribution monitoring system (if power is above 25% RTP) or using the movable incore detectors (if power is less than 25% RTP or the power distribution monitoring system is inoperable) at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and

4.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> restore the inoperable rod position indicators to OPERABLE status such that a maximum of one rod position indicator per group is inoperable, or

5.

Be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Note that the licensee did not propose to include the new Required Action A 2.2 to STS LCO 3.1.7. The NRC staff evaluated this variation in Section 3.2 in this SE.

Current Salem Surveillance Requirement (SR) 4.1.3.1.1 (corresponding to STS SR 3.1.4.1 ):

4.1.3.1.1 The position of each full length rod shall be determined to be within the limits established in the limiting condition for operation in accordance with the Surveillance Frequency Control Program (allowing for one hour thermal soak after rod motion) except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Proposed Salem SR 4.1.3.1.1 after change:

4.1.3.1.1 The position of each full length rod

  • shall be determined to be within the limits established in the limiting condition for operation in accordance with the Surveillance Frequency Control Program (allowing for one hour thermal soak after rod motion) except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
  • Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.

2.2.3 Allow Time for Thermal Equilibrium of ARPI The accuracy of the ARPI system is affected by rod temperatures. With this effect, movement of associated rods may make the indications of the ARPI system inaccurate. The proposed revision would allow a 1-hour period for the drive shaft to reach thermal equilibrium following rod movement to ensure the accuracy of the ARPI indications, prior to requiring verification of compliance with TS limits.

Regarding the TSTF-547 proposed change to STS SR 3.1.4.1 by adding a Note to the SR as "Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion," (see TSTF-547, Revision 1, Subsection 2.3 of Section 2), the licensee did not propose to add this Note because current Salem SR 4.1.3.1.1 already contains a similar note and will remain unchanged.

Regarding the TSTF-547 proposed change to STS SR 3.1.5.1 by adding a Note to the SR as "Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion," (see TSTF-547 Revision 1, Subsection 2.3 of Section 2), Salem SR 4.1.3.4 currently has a footnote, "For power levels below 50% one hour thermal [soak] time is permitted. During this [soak] time, the absolute value of rod motion is limited to six steps." The licensee proposed to replace the current footnote with the new Note.

Regarding the TSTF-547 proposed change to STS SR 3.1.6.2 by adding a Note to the SR as "Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion," (see TSTF-547 Revision 1, Subsection 2.3 of Section 2), Salem SR 4.1.3.5 currently has a footnote, "For power levels below 50% one hour thermal [soak] time is permitted. During this [soak] time, the absolute value of rod motion is limited to six steps." The licensee proposed to replace the current footnote with the new Note.

STS SR 3.1.6.3 requires verification that each control bank that is not fully withdrawn from the core is within the sequence and overlap limits specified in the COLR in accordance with the Surveillance Frequency Control Program. The STS change proposed by TSTF-547 adds the following Note to the SR, "Not required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after associated rod motion." The licensee did not propose any change to this STS requirement. The NRC staff evaluates this variation in Section 3.3 of this SE.

Regarding TSTF-54 7 changes to the current STS LCO 3.1. 7 as described in TSTF-54 7 Revision 1, Subsection 2.3 of Section 2, the licensee proposed the corresponding TS changes set forth below.

Current Salem TS LCO 3.1.3.2.1 ( corresponding to STS LCO 3.1. 7):

3.1.3.2.1 The shutdown and control rod position indication systems shall be OPERABLE and capable of determining the actual and demanded rod positions as follows:

a.

Analog rod position indicators; within one hour after rod motion (allowance for thermal soak)

All Shutdown Banks: +/- 18 steps at s 85% reactor power or if reactor power is> 85% RATED THERMAL POWER+/-

12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 200-230 steps.

Control Bank A: +/- 18 steps at s 85% reactor power or if reactor power is> 85% RATED THERMAL POWER+/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 200-230 steps.

Control Bank B: +/- 18 steps at s 85% reactor power or if reactor power is> 85% RATED THERMAL POWER+/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 160-230 steps.

Control Bank C and D: +/- 18 steps at s 85% reactor power or if reactor power is> 85% RATED THERMAL POWER+/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps.

b.

Group demand counters; +/- 2 steps of the pulsed output of the Slave Cycler Circuit over the withdrawal range of 0-230 steps.

Proposed Salem TS LCO 3.1.3.2.1 after change:

3.1.3.2.1 The shutdown and control rod position indication (RPI) systems shall be OPERABLE and capable of determining the actual and demanded rod positions as follows:

a.

Analog rod position indicators; All Shutdown Banks: +/- 18 steps at s 85% reactor power or if reactor power is > 85% RA TED THERMAL POWER +/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 200-230 steps.

Control Bank A: +/- 18 steps at s 85% reactor power or if reactor power is> 85% RATED THERMAL POWER

+/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 200-230 steps.

Control Bank B: +/- 18 steps at s 85% reactor power or if reactor power is> 85% RATED THERMAL POWER

+/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps and 160-230 steps.

Control Bank C and D: +/- 18 steps at s 85% reactor power or if reactor power is> 85% RATED THERMAL POWER

+/- 12 steps of the group demand counters for withdrawal ranges of 0-30 steps.


1\\Jote-----------------------------------------

lndividual RPls are not required to be OPERABLE for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following movement of the associated rods.

b.

Group demand counters; +/- 2 steps of the pulsed output of the Slave Cycler Circuit over the withdrawal range of 0-230 steps.

2.2.4 Clarify TS SR 4.1.3.2.1.1 The licensee followed the same change to STS SR 3.1.7.1 as described in TSTF-547 Revision 1, Subsection 2.4 of Section 2, as set forth below:

Current Salem TS SR 4.1.3.2.1.1 (corresponding to STS SR 3.1. 7.1 ):

4.1.3.2.1.1 Each analog rod position indicator shall be determined to be OPERABLE by verifying that the demand position indication system and the rod position indication system agree within 18 steps when reactor power is s 85% RA TED THERMAL POWER or if reactor power is> 85% RATED THERMAL POWER, 12 steps (allowing for one hour thermal soak after rod motion) in accordance with the Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the demand position indication system and the rod position indication system at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Proposed Salem TS SR 4.1.3.2.1.1 after change:

4.1.3.2.1.1 Each analog rod position indicator* shall be determined to be OPERABLE by verifying that the demand position indication system and the rod position indication system agree within 18 steps when reactor power is s 85% RA TED THERMAL POWER or if reactor power is> 85% RATED THERMAL POWER, 12 steps (allowing for one hour thermal soak after rod motion) in accordance with the Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the demand position indication system and the rod position indication system at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

  • Not required to be met for RPls associated with rods that do not meet LCO 3.1.3.1 2.2.5 Other Proposed Changes The licensee proposed TS changes based on TSTF-547 Revision 1, Subsection 2.6 of Section 2. Details are shown below.
a.

Regarding Item a of Subsection 2.6 related to the elimination of STS LCO 3.1.4 Required Action 8.1, Salem's equivalent change is to delete the current Salem TS 3.1.3.1 Action c.1, "The rod is restored to OPERABLE status within the above alignment requirements, or.

b.

Regarding Item b of Subsection 2.6 related to the relocation of STS LCO 3.1.5 and LCO 3.1.6 Note to the APPLICABILITY, the licensee proposed the equivalent changes below.

Current Salem TS LCO 3.1.3.4 (corresponding to STS LCO 3.1.5):

3.1.3.4 All shutdown rods shall be FULLY WITHDRAWN.

Proposed Salem TS LCO 3.1.3.4 after change:

3.1.3.4 All shutdown rods shall be FULLY WITHDRAWN.


Note-------------------------------------------

Not applicable to shutdown banks inserted while performing SR 4.1.3.1.2 Current Salem TS LCO 3.1.3.5 (corresponding to STS LCO 3.1.6):

3.1.3.5 The control banks shall be in physical insertion as specified in the CORE OPERATING LIMITS REPORT (COLR).

Proposed Salem TS LCO 3.1.3.5 (corresponding to STS LCO 3.1.6) after change:

3.1.3.5 The control banks shall be in physical insertion as specified in the CORE OPERATING LIMITS REPORT (COLR).


Note-------------------------------------------

Not applicable to control banks inserted while performing SR 4.1.3.1.2

c.

Regarding Item c of Subsection 2.6 related to the consistent usage of the defined abbreviation "RPI" in STS 3.1. 7, the licensee proposed its equivalent changes in Salem TS 3.1.3.2.1. See Sections 2.2.3 and 2.2.4 in this SE for the use of RPI in the changes.

d.

Regarding Item d of Subsection 2.6 related to the use of the more standard phrase of "in one or more groups" in STS 3.1. 7 Condition A, the licensee did not propose any change.

e.

Regarding Item e of Subsection 2.6 related to the deletion of the Required Action B.3 in STS 3.1.7, the licensee did not propose any change.

f.

Regarding Item f of Subsection 2.6 related to the consistent use of the phrase of "one RPI per group inoperable" in STS 3.1. 7 Conditions A, B and C, the licensee did not propose any change.

g.

Regarding Item g of Subsection 2.6 related to the consistent use of the phrase of "one or more demand position indicators" in STS 3.1. 7 Condition D, the licensee did not propose any change.

2.2.6 Variations from TSTF-547 Traveler TSTF-547 and the associated SE of March 4, 2016 (ADAMS Accession No. ML16012A126) discuss that STS LCO 3.1.4, "Rod Group Alignment Limits," requires that individual rod positions must be within 12 steps of their group demand position. However, the Salem TSs specify different alignment limits (+/-12 steps and +/-18 steps of demanded position) depending on the bank demand position and power level.

2.3 Regulatory Review The categories of items required to be in the TSs are provided in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c). As required by 10 CFR 50.36(c)(2)(i), the TSs are to include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Pursuant to 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. The regulations under 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

The regulatory requirements in 1 O CFR Part 50, Appendix A, General Design Criteria (GDC), do not apply to Salem Units 1 and 2, as Salem was not licensed to the 10 CFR Part 50, Appendix A, GDC. Salem was designed and constructed in accordance with Atomic Energy Commission (AEC) proposed GDC published in July 1967. The applicable AEC proposed criteria, as documented in Salem UFSAR, Section 3.1, were AEC Criteria 12, and 27 through 32, which are comparable and equivalent to 10 CFR Part 50, Appendix A, GDC 13, GDC 26, and GDC 28 as identified in TSTF-547. The NRC staff found that the differences in the proposed and final GDC will not affect the evaluation and conclusion being made in the following sections because the differences are only editorial in nature.

' The NRC staff's guidance for review of TSs is provided in Chapter 16, Technical Specifications," of NUREG-0800, Revision 3, Standard Review Plan, dated March 2010 (ADAMS Accession No. ML100351425).

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the changes proposed by the licensee and the technical justification for the equivalent changes provided in Traveler TSTF-547 in accordance with the guidance provided in Chapter 16 of NUREG-0800. in addition, the NRC staff reviewed the proposed changes for continued compliance with the requirements of 10 CFR 50.36 and for consistency with conventional terminology and with the format and usage rules embodied in the Salem TSs.

3.1 Provide Time to Correct Rod Movement Failures that Do Not Affect Operability Review The proposed changes made in Section 2.2.1 are summarized below for the evaluation.

1.

STS 3.1.5 and STS 3.1.6 new Condition as proposed in TSTF-547 is correspondingly incorporated into Salem TSs 3.1.3.4 and 3.1.3.5 as new Action 1, and the existing action is numbered as 2.

2.

The insertion limits for the Salem shutdown banks in TS 3.1.3.4 are referred to Salem TS definition 1.13a FULLY WITHDRAWN instead of the COLR.

3.

New Required Action A.2.1 for STS 3.1.5 as proposed in TSTF-547 refers to the SDM limits being in the COLR whereas the Salem SOM limits are contained in Salem TS 3.1.1.1. The existing Salem TS actions direct the operators to determine if the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. The language used in new Salem TS Action 1 has been changed to be consistent with the existing Salem TS versus the TSTF-547 wording of "Verify SOM is within the limits..... "

4.

New Required Action A.2.2 for STS 3.1.5 as proposed in TSTF-547 to initiate boration to restore SOM within limits is implemented by applying the action of Salem TS 3.1.1.1. The existing plant shutdown requirement in STS 3.1.5 Condition C is incorporated into new Salem TS 3.1.3.4 Action 1 to align with the current format of the Salem TS.

5.

Salem TS 3.1.3.5 only has requirements for insertion limits in contrast to STS 3.1.6 that has requirements for insertion, sequence, and overlap limits; therefore, the new Salem TS Action 1 for Salem TS 3.1.3.5 does not contain sequence or overlap limits.

6.

New Required Action A.1 for STS 3.1.6 refers to the shutdown bank insertion limits being in the COLR; however, the insertion limits for the Salem shutdown banks in TS 3.1.3.4 are referred to Salem TS definition 1.13a FULLY WITHDRAWN. The new Required Action A.2.1 for STS 3.1.6 refers to SOM limits being in the COLR whereas the Salem SDM limits are contained in Salem TS 3.1.1.1. The existing Salem TS actions direct the operators to determine if the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. The language used in new Salem TS Action 1 has been changed to be consistent with the existing Salem TS versus the TSTF-547 wording of "Verify SDM is within the limits..... "

7.

New Required Action A.2.2 for STS 3.1.6 as proposed in TSTF-547 to initiate boration to restore SDM within limits is implemented by applying the action of Salem TS 3.1.1.1. The existing plant shutdown requirement in STS 3.1.6 Condition C is incorporated into new Salem TS 3.1.3.5 Action 1 to align with the current format of the Salem TS.

As noted in the above summary, the new Action 1 to Salem TSs 3.1.3.4 and 3.1.3.5 will define limits of both duration and insertion if a bank is immovable due to failures external to the control rod drive mechanism. A maximum of one control or shutdown bank may be inserted beyond the limits for a maximum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided all other banks are within the insertion limits and that the reactor could be shut down using control rods or boration. The new Action 1 imposes a limit of s 10 steps beyond the insertion limit. The value of 10 steps corresponds to the minimum number of steps that the rods must be moved to ensure successful performance of Salem SR 4.1.3.1.2.

The NRC staff reviewed the change and justification for the addition of new Action 1 to Salem TSs. The justification in TSTF-547 in terms of the Salem TS language and format states:

1.

All control and shutdown rod assemblies are required to be OPERABLE.

If one or more rod is untrippable (i.e., inoperable), then a plant shall enter into the action statements associated with Salem LCO 3.1.3.1.

2.

Only one control bank and shutdown bank may be inserted beyond insertion limits by no more than +/-12 or +/-18 steps depending on the reactor power. If one or more than one control banks or shutdown banks exceed the insertion limit, a brief time period is permitted to correct the condition. Otherwise, the plant shall be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

3.

If one rod is not within the alignment limits, adequate SDM is verified and a power reduction is required by LCO 3.1.3.1, Action c. If more than one rod is not within the alignment limit as defined in LCO 3.1.3.1, a plant shutdown is required by LCO 3.1.3.1, Action b.

The insertion limits are established to ensure a sufficient amount of negative reactivity can be rapidly inserted to shutdown the reactor. The NRC staff finds that allowing continued full-power operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a rod movement failure is acceptable for the following reasons:

(1)

The SDM continues to be met.

(2)

All control and shutdown rods are trippable i.e., capable of being rapidly inserted into the core.

(3)

Only one bank may exceed insertion limits by no more than a specified number of steps.

(4)

All immovable rod assemblies are aligned.

(5)

The rods must be restored to within the insertion limits within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The change to Salem TSs 3.1.3.4 and 3.1.3.5 to provide time to correct rod movement failures that do not affect operability will allow sufficient time for diagnosis and repairs while maintaining the safety function of the control rods since the affected rods are still trippable. The thermal margins may be affected by power distribution changes due to control rod bank insertion, both during the insertion and during the resulting local xenon transient. However, insertions at or near the typical value of 10 steps from fully withdrawn, as provided in the proposed changes to Salem TSs 3.1.3.4 and 3.1.3.5, would result in a very small negative reactivity impact at the top of active fuel. The resulting effect on the axial power distribution is not expected to be significant. In addition, alignment of all rods with the rod bank position (as per LCO 3.1.3.1) must be maintained and the licensee must verify that the reactor can still be shutdown.

Therefore, the NRC staff has determined that the proposed 24-hour completion time for Action 1 in LCO 3.1.3.4 and 3.1.3.5 specifying shutdown bank and control bank insertion limits is acceptable.

The NRC staff concludes that Salem TSs 3.1.3.4 and 3.1.3.5, as modified by the addition of Action 1, continue to specify the minimum performance level of equipment needed for safe operation of the facility as a LCO; and continue to specify the appropriate remedial measures if the LCO is not met. SRs are not being changed by the addition of Action 1. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO and the appropriate remedial measures are specified if the LCO is not met.

3.2 Provide an Alternative to Frequent Verification of Rod Position Using the Power Distribution Monitoring System or the Movable lncore Detectors Review The NRC staff reviewed Salem's proposed changes (Section 2.2.2) that correspond to the TSTF-547 changes in the STS. The proposed changes made in Section 2.2.2 are summarized below.

1.

STS 3.1. 7 new Required Action A.2 is incorporated into Salem TS 3.1.3.2.1 Action a.2. Existing Salem TS 3.1.3.2.1 Action a.2 is renumbered Action a.3.

2.

New Salem TS 3.1.3.2.1 Action a.2 uses the terminology 'non-indicating rod(s)'

instead of "inoperable [D]RPI" contained in TSTF-547 to remain consistent with the language in existing Salem TS 3.1.3.2.1 Action a.1.

3.

New Salem TS 3.1.3.2.1 Action a.2 is modified to allow use of the movable incore detectors or the PDMS. The proposed change deviates from TSTF-547 in retaining the current allowance in the Salem TS to use the PDMS (TS 3.3.3.14) as an alternative to the movable incore detectors for indirectly verifying rod position. The NRC approved use of the PDMS (BEACON system) to determine the position of non-indicating rods in Salem Unit Nos. 1 and 2 TS Amendments 237 and 218, respectively.

4.

The deletion of STS 3.1.7 Required Action B.3 in TSTF-547 is not made since the format of Salem TS makes the corresponding deletion in Salem TS 3.1.3.2.1 Action b.3 unnecessary.

5.

The editorial changes of STS Condition A, Required Action A.1, Condition B, Required Action B.4, Condition C, Required Action C.1 and Condition D are not incorporated due to the format of the Salem TS.

6.

The note for STS SR 3.1. 7.1 is added as footnote

Salem LCO 3.1.3.2.1 requires that the shutdown and control RPI systems be Operable and capable of determining the actual and demand rod positions during Power Operation and Startup. When one or more RPI are inoperable, current Salem TS 3.1.3.2.1 requires verification of rod position once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> using the movable incore detector system or reduce thermal power to less than or equal to 50 percent rated thermal power (RTP) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Based on TSTF-547 Revision 1, Subsection 2.2 of Section 2, the licensee added an alternative Action, i.e.

new Action a.2 (See Section 2.2.2 in this SE for the proposed new Action a.2).

The implementation of new Action a.2 would allow use of an alternative monitoring scheme until the next shutdown. The NRC staff finds that the new Action a.2 and completion times are appropriate because Action a.2 requires verification of rod position following circumstances in which rod motion could occur. This is appropriate as compared to current TS 3.1.3.2.1 Action a.1, which requires verification of rod position using the PDMS or the moveable incore detection system once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, regardless of whether the rods have moved or not.

For Salem TS 3.1.3.2.1, the licensee proposed to not include the new Required Action (RA) A.2.2 to STS 3.1.7, "Rod Position Indication," as proposed in TSTF-547. The RA A.2.2 states, "Restore inoperable [D]RPI to OPERABLE status," with a Completion Time of "Prior to entering MODE 2 from MODE 3."

The NRC staff found the licensee's exclusion of the new Required Action A.2.2 acceptable because:

1.

An application of STS LCO 3.0.4.a (or Salem LCO 3.0.4.a) permits the plant to enter Mode 2 with an inoperable RPI since, by the Applicability of STS 3.1. 7 ( or equivalently, Salem 3.2.3.2.1 ), the TSTF-547, STS 3.1. 7, RA A.1 or A.3 for continued operation can be followed.

2.

In TSTF-547, STS 3.1.7 Required Actions A.1, A.2 which includes A.2.1 and A.2.2, and A.3 are joined by a logical OR, a licensee may not choose to follow RA A.2 (which includes A.2.1 and A.2.2) after entering Mode 2.

In addition, the similar exclusion had been previously approved by the NRC in Braidwood/Byron Amendment Nos. 196/202 (ADAMS Accession No. ML18065A529) and Watts Bar Amendment Nos. 120/20 (ADAMS Accession No. ML18079A029).

If the RPI is failed for an individual rod, the rod's position is determined indirectly by use of the PDMS or the moveable incore detectors. The NRC staff has determined that verification of the rod position using the PDMS or the movable incore detectors based on the occurrence of events requiring rod motion, rather than determining position on a specified frequency, is acceptable because events requiring rod motion of the shutdown banks and control banks are relatively infrequent during steady state operation. Further, the indirect determination of rod position is required after significant changes in power level or following substantial rod motion.

The NRC staff finds that the addition of Note 1 of TSTF-547, SR 3.1.4.1, to Salem SR 4.1.3.1.1, to state that the SR is not required to be performed for rods associated with an inoperable RPI, is appropriate. This is because the new Action a.2 to Salem TS 3.1.3.2.1 for an inoperable RPI provides the appropriate actions for indirectly determining the position of the affected rods.

The NRC staff concludes that the addition of an alternative monitoring scheme to indirectly determine the position of rods associated with an inoperable RPI is acceptable. Salem TS 3.1.3.2.1, as modified, continues to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO and continues to specify the appropriate remedial measures if the LCO is not met. The revised Salem SR 4.1.3.1.1, which has been clarified to specify when it is required to be performed, continues to be an appropriate means to ensure that the necessary quality of systems is maintained. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO and the appropriate remedial measures are specified if the LCO is not met. The NRC staff finds that the requirements of 10 CFR 50.36(c)(3) continue to be met because the revised SR provides the appropriate testing to ensure the necessary quality of components is maintained and that the LCO will be met.

3.3 Allow Time for Thermal Equilibrium of ARPI Review The NRC staff reviewed Salem's proposed changes (Section 2.2.3) that correspond to the TSTF-547 changes to the STS. The proposed changes made in Section 2.2.3 are reviewed below.

Several changes are proposed to allow a 1-hour period for the drive shaft to reach thermal equilibrium following rod movement to ensure accuracy of the RPI analog indications to verify TS limits. Salem LCO 3.1.3.2.1 would be revised with a note stating that individual RPls are not required to be operable for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following rod motion. Salem SRs, 4.1.3.4 and 4.1.3.5 would be revised to not be required to be performed until 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the associated rod motion. It is noted that the Note required to be added in STS SR 3.1.6.3 is not proposed to be changed by the licensee. The NRC staff finds it acceptable because Salem does not have any SRs comparable to STS SR 3.1.6.3.

The 1-hour period is based on the necessary time to allow the rod drive shaft to reach thermal equilibrium following rod motion. There are thermal effects which cause the analog position indicators to drift following rod motion. During this period prior to establishment of thermal equilibrium, the indicators could be unstable and could indicate an inaccurate rod position. The provision to allow a 1-hour period to reach thermal equilibrium ensures that actions are not taken based on an inaccurate indication of rod position, which could lead to unnecessary transients. During this 1-hour period, the analog rod position indicators would be available to verify the demand position of the rods.

Since the shutdown banks are positioned manually by the control room operator, a verification of shutdown bank position at a frequency established by the Surveillance Frequency Control Program, after the reactor is taken critical, is adequate to ensure that they are FULLY WITHDRAWN. Also, the Surveillance Frequency Control Program considers other information available in the control room for the purpose of monitoring the status of shutdown rods.

When control banks are maintained within their insertion limits as verified by SR 4.1.3.5, it is unlikely that their positions will not be in accordance with requirements provided in the COLR. A SR frequency established by the Surveillance Frequency Control Program is consistent with the insertion limit verification in SR 4.1.3.5.

During its review, the NRC staff was concerned that the licensee's proposal of replacing the footnote associated with both Salem SR 4.1.3.4 and 4.1.3.5 with the TSTF-547 proposed new Note (see Section 2.2.3 in this SE), did not address the impact of a deletion of the original restriction imposed on rod motion on the SR. The NRC staff requested additional information for clarify this issue. On June 11, 2019, the licensee provided its RAI response (ADAMS Accession No. ML19162A122) and confirmed (ADAMS Accession No. ML19169A245) that:

(1)

The footnote proposed in the May 22, 1989, Supplement and added to the Salem TS by Amendment 103-80 was added to address the de-calibration (drift) of the ARPI due to thermal effects following rod motion, and (2)

As discussed in Salem Amendments 78-43 and 103-80, the 1-hour soak period currently in the Salem TS and proposed in TSTF-547 is sufficient time to allow the ARPI indication to reach equilibrium such that the rod position of the ARPI can be compared to the group demand counters and verify that rods are within the insertion limits.

The NRC staff reviewed the licensee's response and determined the information provided was acceptable to resolve this issue, because the 50 percent power and 6 steps of rod motion restrictions originate from the concern that the ARPI would be susceptible to drift due to thermal transients induced by the rod motion. When the 1-hour soak time is implemented as proposed in TSTF-547, the thermal fluctuations that potentially affect the ARPI go away within the 1-hour soak time and have no impact on the SR.

The NRC staff reviewed the technical justification provided in TSTF-547 to ensure that the reasoning is logical, complete, and clearly written as described in Chapter 16 of NUREG-0800.

The NRC staff concludes that Salem TS 3.1.3.2.1, as modified by the addition of a Note, continues to specify the minimum performance level of equipment needed for safe operation of the facility, and continues to specify the appropriate remedial measures if the LCO is not met.

The changes to the SRs ensure the SRs are performed when the position indication system has achieved thermal stability following rod motion. The SRs continue to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCO will be met. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met.

3.4 Clarification of SRs in Salem TSs 3.1.3.1 and 3.1.3.2.1 Review 3.4.1 Clarification of SR 4.1.3.1.1 ( corresponding to STS SR 3.1.4.1)

Salem LCO 3.1.3.1 (corresponding to STS LCO 3.1.4) requires that all shutdown and control rods shall be operable and individual indicated rod positions shall be within limits. SR 4.1.3.1.1 requires verification of the individual rod positions within the alignment limit periodically. With the new addition of Note 1 of TSTF-547, SR 3.1.4.1 (see Section 2.2.2), SR 4.1.3.1.1 is not required to be performed for rods with an inoperable rod position indicator or demand position indicator. However, failure to meet an SR is considered a failure to meet an LCO requirement.

Therefore, if SR 4.1.3.1.1 cannot be performed, entry into LCO 3.1.3.1 Actions a orb is required. The action associated with Action a orb requires, in part, that the reactor be in Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Salem LCO 3.1.3.2.1 requires the RPI to be operable, and that actual and demanded rod positions be determined. LCO 3.1.3.2.1 Action d applies if a maximum of one group demand position indicator(s) per bank is inoperable. Action d requires verification that all RPls for the affected banks are operable and require verification that the most withdrawn rod and the least withdrawn rod of the affected banks are less than or equal to 12 steps apart when reactor thermal power is greater than 85 percent RTP, and less than or equal to 18 steps apart when reactor thermal power is less than or equal to 85 percent RTP, and once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Alternatively, thermal power must be reduced to less than or equal to 50 percent RTP within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

A Note is being added to Salem SR 4.1.3.1.1 stating that this SR is not required to be performed for rods associated with an inoperable rod position indicator or demand position indicator. The alignment limit is based on the demand position indicator. If the bank demand position indicator is inoperable, the SR cannot be performed.

Following modification of Salem SR 4.1.3.1.1, Action d of Salem LCO 3.1.3.2.1 would be the applicable Action to be entered in the event of inoperable demand position indicators. Action d provides the appropriate actions in this situation by requiring that the RPls are operable and that the individual rods in the bank are not misaligned by more than 12 steps when reactor thermal power is greater than 85 percent RTP and less than or equal to 18 steps apart when reactor thermal power is less than or equal to 85 percent RTP.

3.4.2 Clarification of Salem SR 4.1.3.1.1 and SR 4.1.3.2.1.1 Salem LCO 3.1.3.1 requires that all shutdown and control rods shall be operable and individual rod positions shall be within limits.

Salem LCO 3.1.3.2.1 requires the RPI to be operable and be capable of determining the actual and demanded rod positions.

Salem SR 4.1.3.2.1.2 requires that channel calibration of each RPI be performed in accordance with the Surveillance Frequency Control Program. Failure to meet an SR is considered a failure to meet the LCO per Salem SR 4.0.1. The requirements of SRs must be satisfied both during the performance of the surveillance and between performances of the surveillance. If a control or shutdown rod is not within defined limits of its bank demand position indication, then the requirements of both Salem LCO 3.1.3.1 and LCO 3.1.3.2.1 are not met.

A Note is being added to Salem SR 4.1.3.2.1.1 (See Section 2.2.4 for the Salem TS change) stating that this SR is not required to be performed for rods that are known not to meet LCO 3.1.3.1. If a rod is known not to be within limits of the group demand position, LCO 3.1.3.1 provides the appropriate required actions. With one rod not within the alignment limit, Action c requires verification of SDM or initiation of boration until SDM is met; a reduction in reactor power; periodic re-verification of SDM; verification that hot channel factors are within limits; and that the safety analyses be re-evaluated to confirm continued operation is permissible. If more than one rod is misaligned, the SDM must be determined by verifying that the SDM is within limits or by initiating boration to restore required SDM and shutdown of the plant.

The NRC staff reviewed the technical justification for the proposed changes provided in the Traveler TSTF-547 for logical reasoning, completeness and clarity. The purpose of the changes is to prescribe the appropriate Actions to be followed when equipment is inoperable.

Salem TS 3.1.3.1 provides limits on rod alignment to ensure acceptable power peaking factors and local linear heat rates and an acceptable SDM, all of which are initial conditions in the applicable safety analyses. It is appropriate to consolidate requirements associated with rod misalignments in this TS. Salem TS 3.1.3.2.1 provides requirements for instrumentation to monitor rod position. The instrumentation is used to verify that the rod alignment limits in TS 3.1.3.1 are satisfied. Similarly, it is appropriate to consolidate requirements associated with instrumentation operability in this TS.

The NRC staff concludes that the clarifications to Salem SR 4.1.3.1.1 and SR 4.1.3.2.1.1 to specify configurations in which performance of the SRs is not required are appropriate. The TSs, as modified, continue to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO, and continue to specify the appropriate remedial measures if the LCO is not met. The revised SR 4.1.3.1.1 and SR 4.1.3.2.1.1 continue to be appropriate, because they ensure that the necessary quality of systems is maintained. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3) continue to be met.

3.5 Elimination of an Unnecessary Action from Salem TS LCO 3.1.3.2.1 Review The NRC staff reviewed the justification for deletion of LCO 3.1.3.2.1, Action b.2, which requires the licensee to monitor and record reactor coolant average temperature {Tav9) (see the Salem TS proposed change made in Section 2.2.2 in this SE). Action b.2 is one of the Actions associated with LCO 3.1.3.2.1 Action b. Action b applies when more than one RPI per group is inoperable in one or more groups. Action b.1 requires that the control rods be placed in manual control immediately, and existing Action b.4 requires restoring the inoperable position indicators to operable status such that a maximum of one RPI per group is inoperable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The NRC staff has determined that Action b.2 provides no safety benefit for identifying trends in reactor coolant T avg. This Action was intended to help assure that significant changes in power distribution and the ability to shutdown the reactor is avoided. During normal steady state power operation, there is very little rod motion. LCO 3.1.3.2.1 Action b.1 and Action b.4 continue to apply when more than one RPI per group is inoperable. LCO 3.1.3.1 and LCO 3.1.3.2.1, provide the appropriate requirements for monitoring rod position and alignment and provide the appropriate actions, if a rod is misaligned. This provides the necessary verification that SDM is maintained. The nuclear instrumentation monitors neutron flux in the core providing indication of changes in power distribution. Therefore, the NRC staff concludes that Action b.2 of LCO 3.1.3.2.1 is unnecessary and can be deleted.

The NRC staff concludes that the proposed changes to LCO 3.1.3.2.1 are acceptable because the LCO continues to specify the minimum performance level of equipment needed for safe operation of the facility. As described in the preceding paragraph the appropriate remedial measures are prescribed when the LCO is not met. SRs are not being changed by the deletion of Action b.2. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met.

3.6 Other Proposed Changes Review The NRC staff found that the following changes, as summarized from Section 2.2.5 in this SE, are editorial in nature, do not change the TS requirements, and are, therefore, acceptable.

a.

Regarding Item a of Section 2.2.5, STS 3.1.4 Required Action 8.1 is equivalent to Salem TS 3.1.3.1, Action c.1 with the exception that Salem Action c.1 addresses a single inoperable rod or a single mis-aligned rod. STS 3.1.4 Condition A which covers one or more inoperable rods does not have a required action to restore the inoperable rod. Therefore, elimination of the Salem TS 3.1.3.1, Action c.1 to restore the inoperable or mis-aligned rod is consistent with TSTF-547 and STS.

STS 3.1.4 Required Actions 8.2.4 and 8.2.5 are combined into new Required Action 8.4. New Required Action 8.4 is equivalent to the Salem TS 3.1.3.1 Action c.3.c. An editorial change is being made to Salem Unit No. 1 TS 3.1.3.1 Action c.3.c to insert the word 'and' between Fa(Z) and FNc.H to make it consistent with the Salem Unit No. 2 TS 3.1.3.1 Action c.3.c.

b.

Regarding Item b of Section 2.2.5, as discussed in Section 2.2.3, to be consistent with the TSTF-547 traveler, a change is proposed to add a note to Salem SR 4.1.3.4, SR 4.1.3.5, and LCO 3.1.3.2.1 to allow a 1-hour period for the drive shaft to reach thermal equilibrium following rod movement prior to requiring verification of compliance with TS limits.

A note stating, "Not applicable to shutdown banks inserted while performing SR 4.1.3.1.2," is added to reflect the proposed change as made in TSTF-547 for Salem LCO 3.1.3.4 and similarly a note, "Not applicable to control banks inserted while performing SR 4.1.3.1.2," is also added for Salem LCO 3.1.3.5. This change clarifies the note and does not alter its meaning.

c.

Regarding Item c of Section 2.2.5, Salem TS 3.1.3.2.1 is revised to use the defined abbreviation "RPI."

d.

Regarding Item d of Section 2.2.5, related to the use of the more standard phrase of "in one or more groups" in STS 3.1. 7 Condition A, the licensee did not propose any change on this.

e.

Regarding Item e of Section 2.2.5 related to the deletion of the Required Action 8.3 in STS 3.1.7, the licensee did not propose any change on this.

f.

Regarding Item f of Section 2.2.5 related to the consistent use of the phrase of "one RPI per group inoperable" in STS 3.1.7 Conditions A, 8 and C, the licensee did not propose any change on this.

g.

Regarding Item g of Section 2.2.5 related to the consistent use of the phrase of "one or more demand position indicators" in STS 3.1. 7 Condition D, the licensee did not propose any change on this.

3.7 Other Variation from TSTF-547 Traveler TSTF-547 and its SE discuss that LCO 3.1.4, "Rod Group Alignment Limits," requires that individual rod positions must be within 12 steps of their group demand position. However, the Salem TS LCO 3.1.3.1 specifies different alignment limits (+/-18 steps and +/-12 steps of demanded position) depending on the power level. The NRC staff has determined that this difference in alignment limits is appropriate for Salem and does not affect the applicability of TSTF-547 to the Salem TS and is, therefore, acceptable.

3.8 Summary of the NRC Staff's Conclusions The regulations in 10 CFR 50.36, require that TSs will include items in specified categories, including LCOs and SRs. The proposed changes modify the LCOs, Actions, and SRs applicable to control rod and shutdown rod insertion and alignment limits, and the instrumentation utilized to monitor rod position and alignment. The proposed Salem TSs continue to specify the LCOs and remedial measures to be taken if the requirements are not satisfied. The proposed Salem TSs continue to specify appropriate SRs for tests and inspections to ensure that the necessary quality of affected structures, systems and components is maintained. Therefore, the NRC staff finds that the proposed LCOs and SRs meet the requirements of 10 CFR 50.36(c)(2) and 50.36(c)(3), respectively.

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 on June 25, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change SRs.

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, published in the Federal Register on March 26, 2019 (84 FR 11339), and there has been no public comment on such finding. 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: S. Peng Date: November 18, 2019

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2-ISSUANCE OF AMENDMENT NOS. 330 AND 311 RE: REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-547, "CLARIFICATION OF ROD POSITION REQUIREMENTS" (EPID L-2019-LLA-0018) DATED NOVEMBER 18, 2019 DISTRIBUTION:

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