ML22298A054
| ML22298A054 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 10/24/2022 |
| From: | Montgomery R Public Service Enterprise Group |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML22298A053 | List: |
| References | |
| LR-N22-0086, NEI 99-04 | |
| Download: ML22298A054 (1) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 10 CFR 71.106(b) 10 CFR 50.71(e) 10 CFR 54.37(b)
NEI 99-04 LR-N22-0086 October 24, 2022 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Salem Generating Station - Unit 1 and Unit 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354
Subject:
Submittal of Salem Generating Station Updated Final Safety Analysis Report, Revision 33, 10 CFR 71.106 review results and 10 CFR 54.37(b) review results for Salem PSEG Nuclear LLC (PSEG) hereby submits:
Revision No. 33 to the Salem Generating Station Updated Final Safety Analysis Report (UFSAR) in accordance with the requirements of 10 CFR 50.71(e)(4) and 10 CFR 50.4(b)(6)
The results of a review performed as required by 10 CFR 54.37(b) to identify any newly-identified Structure, System or Component (SSC) that would be subjected to an aging management review or evaluation of time-limited aging analyses (TLAAs) in accordance with 10 CFR 54.21 A summary of changed/closed regulatory commitments that were not reported by other means during 2021 and 2022 to date in accordance with NEI 99-04.
10 CFR 71.106 10 CFR 50.71(e) 10 CFR 54.37(b)
October 24, 2022 NEI 99-04 Page 2 LR-N22-0086 The results of a review performed as required by 10 CFR 71.106 to identify changes made to the quality assurance (QA) program related to packaging and transportation of radioactive material that did not required previous NRC approval.
Revision No. 33 to the Salem UFSAR is being submitted in its entirety electronically and contains identified text, table and figure changes required to reflect the plant configuration as of May 18, 2022, within six months prior to this submittal. In addition, there are general editorial changes. In accordance with 10 CFR 50.71(e)(2)(ii), a summary of changes made under the provisions of 10 CFR 50.59 but not previously submitted to the Commission is provided in Attachment 1. The previous revision to the Salem UFSAR was issued on June 17, 2021.
Based on NRC Regulatory Issue Summary (RIS) 2015-17, "Review and Submission of Updates to Final Safety Analysis Reports, Emergency Preparedness Documents, and Fire Protection Documents," PSEG has reviewed Revision 33 of the UFSAR for security-related information (SRI). Consequently, Revision 33 of the UFSAR is being provided in its entirety as two separate submittals. This submittal redacts the information that is SRI and designates it as "Security-Related Information - Withheld Under 10 CFR 2.390." This version is suitable for public disclosure. A separate submittal contains the SRI.
In accordance with the Nuclear Energy Institute (NEI) process for managing Nuclear Regulatory Commission (NRC) commitments and associated NRC notifications, PSEG performed a review of regulatory commitments to determine if there were any Salem changed/closed commitments that were not reported by other means during 2021 and 2022 to date. The review concluded that there were 3 changed or closed commitments during that time period and a summary of that review is provided in.
An evaluation was completed to determine whether any newly-identified Systems, Structures, or Components (SSCs) existed in support of submitting Salem UFSAR Revision 33. This evaluation involved reviewing pertinent documentation for the period subsequent to the last Salem UFSAR revision. The evaluation concluded that there were no newly-identified SSCs and no changes to the Salem current licensing basis that would have caused any newly-identified SSCs for which aging management reviews or time-limited aging analyses would apply.
An evaluation was completed to determine whether any changes were made to the Packaging and Transportation of Radioactive Material QA Program in the last two years that did not require previous NRC approval as required per 10 CFR 71.106.
The evaluation concluded that there were no such changes made.
October 24, 2022 Page 3 LR-N22-0086 10 CFR 71.106 10 CFR 50.71(e) 10 CFR 54.37(b)
NEI 99-04 As required by 1 O CFR 50.71 (e)(2)(i), I certify that to the best of my knowledge, the information contained in the Enclosure and Attachments to this letter, which pertains to the Salem UFSAR Revision 33, accurately reflects information and analyses submitted to the NRC, or prepared pursuant to NRC requirements as described above. There are no regulatory commitments contained in this letter.
If you have any questions or require additional information, please do not hesitate to contact Mr. Lee Marabella, at (856) 339-1208.
Sine~..
~/~L Richard Montgomery Manager, Licensing PSEG Nuclear, LLC
Attachment:
- 1. Summary Report of UFSAR Changes
- 2. Summary Report of Salem Changed/Closed Regulatory Commitments
Enclosures:
- 1. Salem UFSAR Rev. 33 (redacted version suitable for public disclosure)
One file submitted electronically CC (Cover letter, Attachments 1 and 2, Enclosure 1)
Administrator - Region I - USN RC USNRC Project Manager USN RC Senior Resident Inspector - Salem USNRC Senior Resident Inspector-Hope Creek Chief, New Jersey Bureau of Nuclear Engineering
10 CFR 71.106 10 CFR 50.71(e) 10 CFR 54.37(b)
October 24, 2022 NEI 99-04 Page 4 LR-N22-0086 bcc:
(Cover letter, Attachments 1 and 2 only)
Plant Manager - Salem Plant Manager - Hope Creek Sr. Director, Regulatory Operations and Nuclear Oversight Director, Site Regulatory Compliance Manager, Licensing Site Compliance Commitment Coordinator Records Management
LR-N22-0086 Summary Report of UFSAR Changes
LR-N22-0086 Summary Report Of UFSAR Changes 1
CN #
SECTION DESCRIPTION BASIS SCN 16-016 3.9 Revised Section 3.9.1.5 to align with Sections 3.6.1.1 and 5.2.1.7.1. Section 3.9.5 is revised to add references to a 1994 Leak-Before-Break letter and WCAP-13659 The change meets the NEI 98-03 criteria for a non-regulatory change.
SCN 19-014 2.2, T2.2-2, T2.2-4, 6.4 Reflects the installation of the Purate (chlorine dioxide) biocide water treatment system design by NALCO to treat the Circulating Water System at Hope Creek.
10 CFR 50.59 screening performed for DCP 80124128.
SCN 20-002 8.1 Reflects the deletion of the words "and Nuclear Oversight performs independent assessment (as defined in Chapter 18 of the QATR) of randomly selected safety-related cable installations, to ensure proper installation. As an unnecessary requirement.
The change meets the NEI 98-03 criteria for a non-regulatory change.
SCN 20-012 7.10, 8.3 Reflects upgrades to the Salem 1 Plant Computer and combines the Plant Computer and SPDS.
10 CFR 50.59 screening performed for DCP 80112043 SCN 21-004 9.5 Reflects an update to non-PSEG engineer requirements in fire drills and removal of a reference to a superseded document.
Fire Protection Change Regulatory Review performed by Engineering Services SCN 21-006 2.3, T2.3-16, F2.3-7, F2.3-8 Reflects UFSAR update for MET Tower equipment replacement.
10 CFR 50.59 screening performed for DCP 80128616 SCN 21-007 5.2 Reflects deletion of the description of automatic rod withdrawal which was inadvertently omitted under a previously approved change notice.
The change meets the NEI 98-03 criteria for a non-regulatory change.
SCN 21-008 6.2 Reflects implementation of a plant change to add permanent scaffolding inside the containment is Salem Units 1 and 2.
10 CFR 50.59 screening performed for DCP 80128286.
LR-N22-0086 Summary Report Of UFSAR Changes 2
CN #
SECTION DESCRIPTION BASIS SCN 21-009 3.6, T3.6-1, F3.6-1, T4.1-1, 4.4, T4.4-1, 5.2, 15TOC, 15.1, 15.4, T15.4-1, -6, -
12, -13, -14, -24, -15C, -
15D, -16A, -17A, -18A, -
19A, -22A, -23A, -24, -25A,
-28A, -29A, -30A, -31A, -
32A, -33A, -35, F15.4-68, -
69, -70, -76, -77, -78A, -
78B, -112, thru -117, Appdx. B Reflects changes related to the Salem Unit 2 Upflow Conversion Project and the implementation of extended Leak-Before-Break (eLBB).
NRC Safety Evaluation for TS Amendments 336
& 317.
SCN 21-010 4.3 Reflects fuel burnup update to specify the maximum lead rod burnup limit of 62,000 MWD/MTU.
10 CFR 50.59 evaluation performed by Nuclear Fuels and approved by FRC.
SCN 21-013 9.1 Removes the reference to S-C-SF-MDC-2383 (a bounding calculation) and allow for either a bounding calculation or an outage-specific calculation to determine the minimum requirement for reactor subcriticality necessary to meet the SFP water temperature requirements.
10 CFR 50.59 screen performed by Nuclear Fuels SCN 21-014 8.3 Add description of Open Phase Protection to Section 8.3.1.2, Electric Circuit Protection System for permanent monitoring and alarm only function based on risk assessment of manual operator action to respond to an open phase condition.
10 CFR 50.59 screening performed for DCP 80119205 SCN 21-015 4.3 Testing Section was revised to include PWROG-20039, Rod Worth Measurement Elimination.
10 CFR 50.59 screening performed for SCN 21-015.
SCN 22-004 9.4, T10.4 Modifies the reliance of the turbine driven Aux Feed pump design basis function on availability of its associated area room cooler.
10 CFR 50.59 screening performed for SCN 22-004.
SCN 22-009 9 TOC, 9.2 Provides clarification that the Traveling Water Screens do not need to be in Automatic operation/rotation to maintain functionality for the purposes of establishing Service Water Pump operability.
10 CFR 50.59 evaluation performed for SCN 22-009 and approved by FRC.
LR-N22-0086 1
Summary Report of Salem Changed/Closed Regulatory Commitments
LR-N22-0086 1
Original Commitment Revised Commitment Description Justification for Change Original Commitment:
Salem Generating Station will Include the SFP external makeup strategy and Spent Fuel Pool external spray strategy as described In the general description in In plant procedures (Tables A.2 A.2-6).
Source Document:
Salem Generating Station Unit No. 1 Renewed Facility Operating License DPR-70 I 2.C(16)(b)7, "Spent fuel pool mitigation measures" Salem Generating Station Unit No. 2 Renewed Facility Operating License DPR-75 /.C(32)(b)7, "Spent fuel pool mitigation measures" Salem Generating Station Units 1 and 2 Safety Evaluation for Order EA-02-026 dated August 9, 2007
References:
CM-SC-2007-64 80124591 / 0081 Date of Change:
12/04/2019 Salem Generating Stations Unit No. 1 and Unit No. 2 Implements a two-path mitigation strategy for Spent Fuel Pool (SFP) mitigation measures, The preferred method credits Time Critical Actions for SFP external makeup and SFP external spray implementation within 120 minutes. The alternate method disperses discharged fuel assemblies In an approved pattern until they have been subcritical for more than 295 days.
The current SFP mitigation measures consist of a single-path strategy of dispersing discharged fuel assemblies in an approved pattern until they have been subcritical for more than 295 days.
This strategy results in a significant number of irradiated fuel assembly movements in the SFP every cycle to allow for discharged fuel assemblies to be placed in an approved pattern. Each movement of an irradiated fuel assembly represents risk.
The new SFP mitigation measures designate this path as the alternate path and establishes the preferred path as one that credits the Time Critical Actions for SFP external makeup and external spray implementation. This two-path strategy results in an improvement in nuclear safety by significantly reducing the number of irradiated fuel assembly movements in the SFP.
Original Commitment:
Operations to mitigate fuel damage considering the following: Spent fuel pool mitigation measures [Guidance Document Elements: B.2.m.1, B.2.m.2, B.2.m.3, B.2.m.4, B.2.m.5] SFP thermal mgmt.
Source Document:
Salem Generating Station Unit No. 1 Renewed Facility Operating License DPR-70 I 2.C(16)(b)7, "Spent fuel pool mitigation measures" Salem Generating Station Unit No. 2 Renewed Facility Operating License DPR-75 / 2.C(32)(b)7, "Spent fuel pool mitigation measures" Salem Generating Station Units 1 and 2 Safety Evaluation for Order EA-02-026 dated August 9, 2007
References:
CM-SC-2007-23 80124591 / 0211 Date of Change:
02/19/20 This commitment Is being deleted.
CM-SC-2007-23 addresses Spent Fuel Pool Mitigation Measures. It Is being deleted because CM-SC-2007-64 addresses Spent Fuel Pool Mitigation Measures as required by the Salem Generating Station Unit No. 1 and Unit No. 2 Renewed Facility Operation License 2.C(16) and 2.C(32)1 respectively. CM-SC-2007-23 ls unnecessary and Is being deleted.
LR-N22-0086 2
Original Commitment:
PSEG will submit to the NRC for review and approval a best estimate LBLOCA analysis that applies NRC approved methods that include the effects of fuel Thermal Conductivity Degradation (TCD) for Salem Units 1 & 2. The date for the analysis submittal is contingent on the following milestones which must be completed in order to perform a revised licensing basis Large Break Loss Of Coolant Accident (LBLOCA) analysis with an NRC approved ECCS-EM that explicitly accounts for TCD:
- 1) NRC approval of a fuel performance analysis methodology that includes the effects of TCD.
The new methodology for developing inputs to the LBLOCA-EM would replace the current licensing basis methodology for Salem that is described in WCAP-15063-P-A, Revision 1 with Errata, Westinghouse Improved Performance Analysis and Design Model (PAD 4.0), July 2000 (Ref. 3).
- 2) NRC approval of a best estimate LBLOCA-EM model that includes the effects of TCD and accommodates the rulemaking associated with the proposed 10CFR50.46c.
The new methodology would replace the current licensing basis methodology that is described in WCAP-10266-P-A, Rev.2, The 1981 Version of Westinghouse ECCS Evaluation Model Using the Bash Code, March 1987 (Ref. 4).
Commitment Date: December 15, 2017.
Source Document:
LR-N12-0328 Salem Loss of Coolant Accident Peak Cladding Temperature Margin Tracking - 30 Day Report, October 19, 2012.
References:
CM-U1-2012-860 and CM-U2-2012-861 80107550 / 0081 Date of Change:
7/28/2020 PSEG will submit to the NRC for review and approval a best estimate LOCA analysis using FSLOCA (Westinghouse Full Spectrum LOCA) for Salem Units 1 & 2 consistent with the implementation requirements of 10CFR50.46(c). FSLOCA requires PAD 5 (Westinghouse fuel performance analysis methodology) which explicitly includes the effects of fuel Thermal Conductivity Degradation (TCD).
Earlier submittal may occur based on plant modifications affecting the current LOCA analysis or the decision to recover Peak Clad Temperature (PCT) margin by implementing FSLOCA. Implementation of FSLOCA would remove limitations and conservatisms associated with our current LOCA analysis, including those which address fuel TCD.
Commitment Date: December 15, 2022.
The justification for changing the commitment is based on the uncertainty related to the NRC's approval of 10CFR50.46(c). With the current commitment due at the end of 2020, it is prudent to extend the commitment to 2022 to provide sufficient time between NRC approval and PSEG submitting a schedule for compliance to the NRC.