LR-N19-0006, Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program

Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program

ML19098B529
Person / Time
Site:	Salem
Issue date:	04/08/2019
From:	Mcfeaters C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR S19-01, LR-N19-0006
Download: ML19098B529 (15)

Text

PSEG Nuclear LLC P. 0. Box 236, Hancocks Bridge, New Jersey 08038-0236 PSEG 10 CFR 50.90 LR-N19-0006 LAR S19-01 APR 0 8 2019 U.S. Nuclear R egu lato ry Commission ATTN: Document Control Desk Washi n gton, DC 20555-0001 Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

Application to Revise Technical Specifications to Adopt TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program" In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is su bm i tting a request for an amendment to the Te chnical Specifications (TS) for Salem Generati ng Station (Salem) Units 1 and 2.

PSEG requests ad option of TSTF-563, " Revis e Instrument Testing Definitions to I ncorporate the Surveillance Frequency Control P rogram. " TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test. The definition of Channel Calibration currently permit s performa n c e by means of any series of sequential, overlapping, or total channel steps . The definition of Channel Functional Test is revised to explicitly p ermit performance by means of any series of sequential, overlapping, or total cha nnel ste p s . Both definitions are revised to allow the required frequency for test i ng the co mponents or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Progr am.

The enclosure provides a descriptio n and assessment of the proposed changes. p rovides the exis ti ng TS pages marked to show t h e p roposed cha n ges . p rovides revised (clean) TS pages.

Approval of the proposed amendment is requested within one year of submittal acceptance. Once app roved , the amendment shall be implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application is being provid ed to the designated State of New Jersey Official .

There are no regulatory commitments contained in this letter .

LR-N 18-0006 10 CFR 50.90 Page 2 APR 0 8 2019 If you have any questions or require additional information, please contact Mr. Lee Marabella at 856-339-1208.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on cl__f_,_/;_'/_9-

/fk (Date)

Respe Charles V. McFeaters Site Vice President Salem Generating Station

Enclosure:

Description and Assessment : Proposed Technical Specification Changes (Mark-Up) : Revised Technical Specification Pages cc: Administrator, Region I, NRC NRC Project Manager, Salem NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Chief, NJBNE PSEG Corporate Commitment Tracking Coordinator Salem Commitment Tracking Coordinator

LR-N19-0006 LAR 519-01 Enclosure Enclosure Description and Assessment Page 1

LR-N19-0006 LAR 519-01 Enclosure

1.0 DESCRIPTION

PSEG Nuclear LLC (PSEG) requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program." TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test. The definition of Channel Calibration currently permits performance by means of any series of sequential, overlapping, or total channel steps. The definition of Channel Functional Test is revised to explicitly permit performance by means of any series of sequential, overlapping, or total channel steps. Both definitions are revised to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation PSEG has reviewed the safety evaluation for TSTF-563 provided to the Technical Specifications Task Force in a letter dated December 4, 2018. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-563.

As described herein, PSEG has concluded that the justifications presented in TSTF-563 and the safety evaluation prepared by the NRC staff are applicable to Salem Units 1 and 2 and justify this amendment for the incorporation of the changes to the Salem Units 1 and 2 TS.

A Surveillance Frequency Control Program was incorporated into the Salem Units 1 and 2 TS in a license amendment dated March 21, 2011 (NRC Agency Documents Access and Management System (ADAMS) Accession No. ML110410691).

2.2 Optional Changes and Variations PSEG is proposing the following variations from the TS changes described in the TSTF-563 or the applicable parts of the NRC staff's safety evaluation.

a) The Salem TS utilize different numbering than the Standard Technical Specifications (STS) on which TSTF-563 was based. Specifically, definitions in the Salem TS are in Section 1 vice Section 1.1 and the definitions are numbered. These differences are administrative and do not affect the applicability of TSTF-563 to the Salem TS.

b) The Salem Units 1 and 2 TS are different from Revision 4 of the Westinghouse STS (NUREG-1431) on which TSTF-563 is based. The definition of Channel Calibration has wording differences from the STS definition that do not change the intent. The Salem TS Channel Calibration definition states, "The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated." The STS states, "The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps." Elimination of the phrase "so that the entire channel is calibrated" in the proposed change has no effect because the definition previously states that the Channel Calibration must encompass the entire channel.

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LR-N19-0006 LAR 519-01 Enclosure c) The Salem Units 1 and 2 definition of Channel Functional Test is similar to the Babcock & Wilcox (B&W) and Boiling Water Reactor (BWR) STS (NUREG-1430, -

1433, and -1434) definitions. The Salem TS require performance of a Channel Function Test which encompasses the Westinghouse STS Channel Operational Test and Trip Actuating Device Operational Test. Therefore, the proposed change incorporates the Channel Functional Test definition changes in TSTF-563 for B&W and BWR plants.

d) The Salem Units 1 and 2 TS definition of Channel Functional Test does not include a provision to perform the test by means of any series of sequential, overlapping, or total channel steps. However, the existing Channel Calibration definition explicitly includes the Channel Functional Test and permits performance of the Channel Calibration by means of any series of sequential, overlapping, or total channel steps.

As discussed in the TSTF-563 justification, applying the allowance to determine the appropriate Frequency for each step based on the components tested in each Channel Functional Test step avoids potential conflicts between the definitions.

Further, it is consistent with the STS which permits performance of the Channel Functional Test by means of any series of sequential, overlapping, or total channel steps.

The provision to perform the Channel Functional Test by means of any series of sequential, overlapping, or total channel steps was added to the STS definitions of Channel Functional Test by TSTF-205, Revision 3, "Revision of Channel Calibration, Channel Functional Test, and Related Definitions, " which was approved by the NRC on January 13, 1999 and incorporated into Revision 2 of NUREG-1431. TSTF-205 described the change:

Other changes are made for consistency of the definitions between the ISTS NUREGs. The NUREG-1430 Channel Functional Test and NUREG-1431 Channel Operational Test definitions are modified to include the sentence, "The CHANNEL FUNCTIONAL (OPERATIONAL for NUREG-1431) TEST may be performed by means of any series of sequential, overlapping, or total channel steps." This allowance currently exists in the CEOG, BWR/4 and BWR/6 definitions of Channel Functional Test and is understood to apply to the BWOG and WOG definitions, although not stated. The changes proposed increase the consistency of the five NUREGs and are not intended to change the meaning or intent of the affected definitions.

The addition of this sentence to the Channel Functional Test definition is necessary to adopt TSTF-563 and, as stated in TSTF-205, is understood to apply to the existing definition, although not explicitly stated. Therefore, adding the sentence does not change the intent of the existing definition and permits adoption of TSTF-563.

e) The traveler and Safety Evaluation discuss the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GDC).

Salem was designed in accordance with PSEG's understanding of the intent of the Page 3

LR-N19-0006 LAR 519-01 Enclosure Atomic Energy Commission (AEC) proposed General Design Criteria published in July 1967. The applicable AEC proposed criteria, as documented in the Salem Updated Final Safety Analysis Report (UFSAR), Section 3.1, were compared to 10 CFR 50 Appendix A General Design Criteria (GDC) as discussed below.

TSTF-563 references 10 CFR-50, Appendix A, GDC 13, "Instrumentation and Control, " which states:

Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

GDC Criterion 13 is similar to AEC Criterion 12, "Instrumentation and Control Systems, " and Criterion 15, "Engineered Safety Features Protection Systems."

TSTF-563 references 10 CFR-50, Appendix A, GDC 21, "Protection System Reliability and Testability, " which states:

The protection system shall be designed for high functional reliability and inservice testability commensurate with the safety functions to be performed.

Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated.

The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.

GDC Criterion 21 is similar to AEC Criterion 19, "Protection Systems Reliability, "

Criterion 20, "Protection Systems Redundancy and Independence, " Criterion 25, "Demonstration of Functional Operability of Protection Systems, " and Criterion 38, "Reliability and Testability of Engineered Safety Features."

Following implementation of the proposed change, Salem Units 1 and 2 will remain in compliance with AEC Criteria 12, 15, 19, 20, 25 and 38. Therefore, this difference does not alter the conclusion that the proposed change is applicable to Salem.

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LR-N19-0006 LAR 519-01 Enclosure

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis PSEG Nuclear LLC (PSEG) requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program. " TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test. The definition of Channel Calibration currently permits performance by means of any series of sequential, overlapping, or total channel steps. The definition of Channel Functional Test is revised to explicitly permit performance by means of any series of sequential, overlapping, or total channel steps. Both definitions are revised to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.

PSEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment, " as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. The proposed change also explicitly permits the Channel Functional Test to be performed by any series of sequential, overlapping, or total channel steps. All components in the channel continue to be calibrated and tested. The frequency at which a channel is tested or calibrated is not an initiator of any accident previously evaluated, so the probability of an accident is not affected by the proposed change. The channels surveilled in accordance with the affected definitions continue to be required to be operable and the acceptance criteria of the surveillances are unchanged. As a result, any mitigating functions assumed in the accident analysis will continue to be performed.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance PageS

LR-N19-0006 LAR 519-01 Enclosure Frequency Control Program. The proposed change also explicitly permits the Channel Functional Test to be performed by any series of sequential, overlapping, or total channel steps. All components in the channel continue to be calibrated and tested. The design function or operation of the components involved are not affected and there is no physical alteration of the plant (i. e., no new or different type of equipment will be installed). No credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases are introduced. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. The proposed change also explicitly permits the Channel Functional Test to be performed by any series of sequential, overlapping, or total channel steps. All components in the channel continue to be calibrated and tested. The Surveillance Frequency Control Program assures sufficient safety margins are maintained, and that that design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing basis. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by method of determining surveillance test intervals under an NRC-approved licensee-controlled program.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, PSEG concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in Page 6

LR-N19-0006 LAR 519-01 Enclosure the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c) (9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

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LR-N19-0006 LAR 519-01 Attachment 1 Proposed Technical Specification Changes (Mark-Up}

1.0 DEFINITIONS DEFINED TERMS.

l.l The DEFINED TERMS of this section appear in capitalized type and are applicable throughout these Technical Specifications.

ACTION 1.2 ACTION shall be that part of a specification wpich prescribes remedial measures required, tmd.e F designated conditions *

.1\XIAL FLUX DIFFERENCE*'

1.3 AXIAL FLUX d iFFERENCE shall be the difference in normalized flux signals between the top nd bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION 1.4 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values qf the: parameter that the channel monitors. The CHANNEL CALIBRATION.shali encoass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. CalibratiQn of instrument channels with resistance temperature detector (RTD) o.z; the%tl\OC:ouple se . nsors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever an RTD or thermocouple sensing element is replaqed, the next required CHANNEL CALIBRATION shall include an inplace cross ca l ibration that compares the other sensing elements with the recently install d sensing element. The CHANNEL CALIBRATION may be performed by means of any eries' of sequential, overlapping, or total channel steps-se that the eat!J:e ehaaael is ealibnted, I and each step must be verformed within the Freque cy in the Surveillance Fi"equenq Control Program for the devices included m the s tep .

CHANNEL CHECK 15 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operationiby observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/br status derived from independent instrument channels measuring the same pa ameter.

CHANNEL FUNCTIONAL TEST 1.6 A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel! as close to the primary sensor as practicable to verify OPEAABILIT incl U ding alarm and/or trip functions. The CHANNEL FUNCTIONAL TEST may be performed by means of any series or sequential , overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

SALEM - UNIT 1 1-l Amendment No, +94

1.0 DBFJ:NJ:TIONS DBFINBD TBRHS 1.1 The DBFINBD TBRHS of this section appear in capitalized type and are applicable throughout these Technical Specifications.

ACTION 1.2 ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.

AXIAL FLUX DIFFBRBNCB 1.3 AXIAL FLUX DIFFBRBNCB shall be the difference in normalized flux signals between the top and bottom halves of a two section excore neutron detector.

CHANNBL CALIBRATION 1.4 A CHANNBL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNBL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNBL FUNCTIONAL TBST. Calibration of instrument channels with resistance temperatura detector (RTD) or thermocouple sensors may consist of an inplaca qualitative assessment.

of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever an RTD or ther.mocouple sensing element is replaced, the next required CHANNBL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNBL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps sa that the aati* ahaaaal is aalihated , and each step must he performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CHANNKL CHBClt 1.5 A CHANNBL CHBCX shall be the qualative aaaaaament of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

CHANNliL FUNCTIONAL TBST 1.6 A CHANNBL FUNCTIONAL TBST shall be the injection of a simulated signal into the channe l as close to the primary sensor as practicable to verify OPERABILITY including alarm and/or trip functions. The CHANNEL FUNCTIONAL TEST may he performed by mean s of any series of sequential, overlapping, or total chann el steps, and each step must he performed wi thin the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

SALJDI - UNIT 2 l-l Amendment No. i-'1-4

LR-N19-0006 LAR 519-01 Attachment 2 Revised Technical Specification Pages

1.0 DEFINITIONS DEFINED TERMS 1.1 The DEFINED TERMS of this section appear in capitalized type and are applicable throughout these Technical Specifications.

ACTION 1.2 ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.

AXIAL FLUX DIFFERENCE 1.3 AXIAL FLUX DIFFERENCE shall be the difference in normalized flux signals between the top and bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION 1.4 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever an RTD or thermocouple sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CHANNEL CHECK 1.5 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

CHANNEL FUNCTIONAL TEST 1.6 A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY including alarm and/or trip functions. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

SALEM - UNIT 1 1-1 Amendment No. XXX

1.0 DEFINITIONS DEFINED TERMS 1.1 The DEFINED TERMS of this section appear in capitalized type and are applicable throughout these Technical Specifications.

ACTION 1.2 ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.

AXIAL FLUX DIFFERENCE 1.3 AXIAL FLUX DIFFERENCE shall be the difference in normalized flux signals between the top and bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION 1.4 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever an RTD or thermocouple sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CHANNEL CHECK 1.5 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

CHANNEL FUNCTIONAL TEST 1.6 A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY including alarm and/or trip functions. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

SALEM - UNIT 2 1-1 Amendment No. XXX