ML13102A275

Request for Additional Information Change to PSEG Emergency Plan to Remove the Backup R45 Plant Vent Radiation Monitor Indications

ML13102A275
Person / Time
Site:	Salem
Issue date:	04/25/2013
From:	John Hughey Plant Licensing Branch 1
To:	Joyce T Public Service Enterprise Group
Hughey J
References
TAC MF0337, TAC MF0338
Download: ML13102A275 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 25, 2013 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236, N09 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM GENERATING STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: CHANGE TO PSEG EMERGENCY PLAN (TAC NOS. MF0337 AND MF0338)

Dear Mr. Joyce:

By letter dated November 30, 2012, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML123380450), PSEG Nuclear LLC (PSEG) requested an amendment to the facility operating licenses for the Salem Generating Station (Salem) Units 1 and 2. The proposed Emergency Plan change requests the removal of the backup plant vent extended range noble gas radiation monitoring (R45) indication, recording, and alarm capability in the emergency response facilities. The licensee's application states that the R45 indicators have become obsolete and unreliable. The R45 monitoring indicator is a backup to the R41 monitoring indicator for plant vent intermediate and high range noble gas radiation. The accident sampling function of the R45 monitoring indicator will be maintained The Nuclear Regulatory Commission staff has reviewed the request submitted by the licensee and has determined that additional information is required, as provided in the enclosure, in order to complete its review.

The draft questions were sent to Mr. Brian Thomas of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On April 5, 2013, Mr. Thomas indicated that the licensee will submit a response by May 31, 2013.

T. Joyce If you have any questions, please contact me at (301) 415-3204 or via e-mail at John.Hughey@nrc.gov.

Sin?f J I /.1 ~

,~./f Vf.;41 L-Jonn D. Hughey, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

Request for Additional Information cc: Distribution via ListServ

REQUEST FOR ADDITIONAL INFORMATION SALEM GENERATING STATION, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGE DOCKET NUMBERS 50-272 AND 50-311 By letter dated November 30,2012, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML123380450), PSEG Nuclear LLC (PSEG) requested an amendment to the facility operating licenses for the Salem Generating Station (Salem) Units 1 and 2. The proposed Emergency Plan change requests the removal of the backup plant vent extended range noble gas radiation monitoring (R45) indication, recording, and alarm capability in the emergency response facilities. The licensee's application states that the R45 indicators have become obsolete and unreliable. The R45 monitoring indicator is a backup to the R41 monitoring indicator for plant vent intermediate and high range noble gas radiation. The accident sampling function of the R45 monitoring indicator will be maintained.

The following requests for additional information (RAls) are provided to facilitate the technical review being conducted by the Division of Preparedness and Response, Operating Reactor Licensing and Outreach Branch staff. The Nuclear Regulatory Commission staff has reviewed the information submitted by the licensee, and based on this review, determined the following information is required to complete the evaluation.

(1) The application appears to refer to NUREG-0578' as the licensing basis for the extended range radiation monitor and the particulate and halogen sampling and analysis capability. However, PSEG subsequently committed to Supplement 1 to NUREG-07372 and Regulatory Guide 1.97, Revision 2,3 in a letter dated April 15, 1983, that was submitted in response to Generic Letter 82-33. 4 The NRC confirmed those commitments in an Order dated June 12, 1984. 5 A table attached to that Order contained Item #3, which addressed Regulatory Guide 1.97 and stated that PSEG had submitted a report that described how the requirements to Supplement 1 to NUREG 0737 have been or will be met. Please explain why PSEG believes that NUREG-0578 is the licensing basis for these monitoring capabilities.

1 NUREG-0578, 'TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations," July 1979.

2 NUREG-0737, "Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capability," February 1989.

3 Regulatory Guide 1.97, Revision 2, "Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants," December 1980.

4 Generic Letter 82-33, "Supplement 1 to NUREG-0737, Requirements for Emergency Response Capability," December 17, 1982 5 ADAMS Accession No. ML011660124 Enclosure

- 2 (2) To enable the NRC staff to evaluate the comparability of the R41 and R45 monitors, please complete the following table with the missing range information, as indicated.

Range Salem TIS Channel R45B,C 1 RG 1.97 R41A,B,C 1 3/4.3.32 10- 1 to "

Low range IJ,Ci/cc 10-4 to to 103 Medium range 10-6 to 103 ).lCilcc 10-3 to 10 1 ).lCilcc IJ,Cilcc IJ,Cilcc 10-1 to to 105 High range 10-1 to 105 IJ,Cilcc IJ,Cilcc IJ,Cilcc

", I':'" "

Licensee Capability "";,'"

Particulate and halogen 10-3 to 10 2 ).lCilcc sampling and to ).lCilcc

& Footnote 13 "

analysis '

capability

1. From FSAR Tables 11.4-1 and 11.4-2

2. From T/S Table 3.3-6 Amendments 299 and 272 (3) The licensee's application states that the R45 indication, recording, and alarm capability in the emergency response facilities will be removed and reliance will be placed on the R41 channels. However, the application did not state that the three capabilities exist for the R41 channels. Please confirm that the indication, recording, and alarm capabilities will be available in the control room, technical support center, and emergency operations facility after the retirement of the R45 monitoring indication, or provide an explanation why those capabilities are no longer deemed necessary for effective implementation of the emergency plan.

(4) The licensee's application states that PSEG will be replacing the R45 sampling skid to maintain the ability to take accident samples from the plant vent. Please confirm that the retained sampling and analysis capability will continue to meet the range requirement and the conditions identified in Footnote 13 on Page 1.97-23 of RG 1.97, Revision 2 (5) The Technical Specification 3/4.3.3, Table 3.3-6 for both units identifies an action statement 23 (Unit 1) and action statement 26 (Unit 2) for the monitoring channels served by R41 B,C and R45B,C. Both of these action statements require the licensee, in part, to initiate the preplanned alternate method of monitoring the appropriate parameters within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. From the discussion in the application, it would appear that R45A,B may have been the preplanned alternate. However, this application removes that alternative. Please describe PSEG's preplanned alternative and explain how it maintains an effective classification and/or dose assessment capability for the duration of the inoperability. Please address the following topics in your response:

a. If the alternative is not implemented on a fixed periodicity of sampling, what non periodic indication (e.g., alarm) would initiate the sampling and analysis?

- 3

b. Does this sampling and analysis method assess the noble gas concentration?

c. What are the provisions for restoring the operability of this equipment that are important to emergency preparedness (e.g., prioritization, tracking, etc.)?

(6) The licensee's application states that the reduction in effectiveness was determined as the delay that would exist in obtaining accident grab samples if the R41 channel was out of service and not able to provide noble gas effluent indication. The application also states that accident sampling and analysis of the plant vent effluent is estimated to take approximately 90 minutes from directing the sample to be taken until the results are provided to the emergency response facility.

As the NRC did not require a backup capability for this particular monitoring requirement, there is no explicit timeliness criterion or expectation. Also, it is not clear to the NRC staff what sampling and analyses might be readily performed for noble gas effluent. The NRC staff does note that PSEG did commit in April 1983 to have a capability for extended range halogen and particulate sampling and analysis, but there was no explicit timeliness criterion or expectation for this capability. Please explain why PSEG believes that retiring R45 would constitute a reduction in effectiveness due to sample and analysis delays.

' " ML13102A275 *via email OFFICE LPL 1-2/PM LPL 1-2/LA* NSIR/ORLT/BC* LPL 1-2/BC LPL 1-2/PM JAnderson JHughey NAME JWhited ABaxter MKhanna (MNorris for) (JWhited for)

DATE 04/22/2013 04/18/13 03/19/2013 04/25/2013 04/24/2013